EFRAG ESRS Simplification Consultation: Researchers Unite to Improve Sustainability Reporting Data Quality

The European Financial Reporting Advisory Group (EFRAG) launched a 60-day public consultation on the revised and simplified European Sustainability Reporting Standards (ESRS) in July 2025. The consultation, which concluded on September 29, 2025, represented a critical moment for sustainability reporting in Europe, as it aimed to balance the need to reduce reporting burden with maintaining data quality and research usability.

The consultation followed the European Commission’s Omnibus initiative and its formal request to EFRAG in March 2025 to deliver a critical simplification to the ESRS adopted in 2023. The objective was to make sustainability reporting under the Corporate Sustainability Reporting Directive (CSRD) more manageable while preserving its relevance and alignment with the European Green Deal.

The Simplification Challenge

EFRAG faced a complex challenge: how to significantly reduce the reporting burden on companies while maintaining the quality and comparability of sustainability data that researchers, investors, and civil society need.

The proposed reductions were substantial:

57% reduction in mandatory datapoints (to be reported if material)
68% reduction in total disclosures (mandatory and voluntary combined)
Over 55% shorter standards overall

These reductions were achieved through:

Streamlining the double materiality assessment
Reducing overlaps across standards
Clarifying language and structure
Removing all voluntary disclosures
Introducing new relief mechanisms, such as exemptions where reporting would cause undue cost or effort

The Researcher Perspective: Data Quality Concerns

While companies welcomed the reduction in reporting burden, researchers raised critical concerns about data quality and usability. As Andreas Dimmelmeier highlighted in his call for researcher participation, common frustrations include:

Inconsistent, partial, or cryptic disclosures that make analysis difficult
Missing values and overly broad categories that prevent meaningful comparisons
Dependence on expensive, proprietary datasets from commercial vendors that vary by provider
Limited usability of sustainability reports for research and analysis

These concerns are not trivial. High-quality, comparable sustainability data is essential for:

Academic research on corporate sustainability performance
Investor decision-making and risk assessment
Policy evaluation and impact assessment
Civil society monitoring and advocacy
Benchmarking and industry comparisons

The Copenhagen Declaration and Academic Consensus

The academic community’s concerns were formalized in the Copenhagen Declaration, signed by over 264 scholars. The declaration emphasized that proposed reductions in qualitative and quantitative datapoints, along with exemptions from reporting standards, threaten the usability, accessibility, and reliability of corporate sustainability data.

Key concerns raised:

Lowering reporting standards does not necessarily reduce burdens but shifts them onto users—academics, analysts, and civil society—who must invest resources to create meaningful datasets from low-quality and partial disclosures or purchase expensive, black-box analytics from commercial vendors
Broader implications: Lower standards could hinder interdisciplinary research—from climate science to political economy—and weaken Europe’s sustainability information ecosystem
Data quality is at stake: The proposed changes threaten the usability, accessibility, and reliability of corporate sustainability data that researchers depend on

Researcher Mobilization: Workshops and Coordinated Feedback

Recognizing the importance of researcher input, Andreas Dimmelmeier, Felicitas Sommer, and Thorsten Sellhorn organized a workshop on September 22, 2025 to help researchers identify where and how they could contribute to the consultation.

Dr. Felicitas Sommer, an anthropologist specializing in law and technology at the Technische Universität München (TUM) and key contributor to the GreenDIA project, played a crucial role in mobilizing academic engagement. Together with Andreas Dimmelmeier, she launched an ad-hoc initiative to support academic input into the EFRAG consultation, preparing a policy brief and collecting datapoint-level assessments to guide responses.

GreenDIA (Green Finance and Smart City Data, Indicators and Algorithms) is a transdisciplinary research project investigating how sustainable finance and regional planning influence land use changes. The initiative’s engagement in the EFRAG consultation reflects its commitment to ensuring that sustainability data standards serve both regulatory compliance and research needs.

Following the points raised by the Copenhagen Declaration—signed by over 264 scholars—the academic mobilization emphasized that changes to the standards need to take benefits of standardized and high-quality data into account. The initiative was supported by leading researchers including Prof. Dr. Ali Aslan Gümüsay, Andreas Rasche, Judith Stroehle, Florian Berg, Gaia Melloni, and Dr. Florian Hoos.

The workshop addressed:

Understanding the consultation questions and their implications
Identifying potential impacts on data quality and availability
Developing strategies for effective feedback
Coordinating researcher responses to ensure comprehensive coverage

This mobilization effort was crucial because researchers bring unique perspectives on:

Data usability: How data will be used in practice for analysis and research
Comparability: What level of standardization is needed for meaningful comparisons
Completeness: Which data points are essential for robust analysis
Quality: How to ensure data reliability and accuracy

The Consultation Process

The public consultation ran from July 31 to September 29, 2025, with EFRAG organizing outreach events throughout September and October to gather further feedback. The consultation survey was available both online and in PDF format, making it accessible to diverse stakeholders.

Key documents published for consultation:

12 Amended ESRS Exposure Drafts for simplification
Basis for Conclusions explaining the rationale and methodology
Log of Amendments for each standard
Non-mandatory illustrative guidance
FAQ document
Consolidated feedback summary from prior stakeholder engagement

Outcomes and Next Steps

Following the consultation, EFRAG delivered its technical advice to the European Commission by November 30, 2025. The draft simplified ESRS were published on December 3, 2025, incorporating feedback from the consultation process.

The final standards reflect a careful balance between:

Reducing burden for companies, especially SMEs and those newly in scope
Maintaining quality and comparability of reported data
Preserving alignment with the European Green Deal objectives
Ensuring usability for researchers, investors, and other stakeholders

Lessons for Future Consultations

The EFRAG ESRS simplification consultation offers valuable lessons for how researchers can effectively engage with policy consultations:

Early mobilization matters: Organizing workshops and coordinating feedback early in the consultation period maximizes impact
Specific expertise is valuable: Researchers’ practical experience with data quality issues provides unique insights
Collaboration amplifies voice: Coordinated responses from the research community carry more weight than individual submissions
Data usability perspective is critical: Researchers can identify practical issues that policymakers may not anticipate

The Importance of Researcher Engagement

The active engagement of researchers in this consultation demonstrates the critical role that academic and research communities play in policy development. By bringing their practical experience with data quality, comparability, and usability challenges, researchers help ensure that policy outcomes serve not just compliance needs, but also the broader goals of transparency, accountability, and evidence-based decision-making.

As sustainability reporting continues to evolve, the collaboration between policymakers, companies, and researchers will be essential to ensure that reporting standards deliver both manageable compliance and high-quality, usable data.