All the changes that you should care about in ESRS 2.0

About the Author

Neda is a Senior Project Manager at Willow Sustainability. She specialises in GHG support, science-based targets, and regulatory advice. She has extensive experience in managing projects, running research studies and analysing data, supplemented by her recent year-long post-graduate research role at the University of Surrey.

The original ESRS introduced in 2023, provides a comprehensive framework designed to achieve the aims set out by the CSRD, namely to increase corporate transparency and stakeholder access to high-quality data regarding sustainability. 

The Omnibus vote in December 2025 marked a turning point for sustainability legislation in the EU. It showed a shift from introducing strict regulations towards a politically charged simplification aimed at boosting competitiveness.

The changes to the ESRS as a result of the Omnibus agreement have been published as revised drafts and have focused on prioritising clarity, simplicity and practicality for reporting companies by significantly reducing data points coverage and requirements. 

Key Points

Streamlined Data 

The Omnibus has drastically changed the extent of datapoints (qualitative and quantitative) required to be collected and reported. Mandatory datapoints have been reduced by 61% and voluntary disclosures have been removed. 

A broad principle of ‘undue cost or effort’ has been introduced, and the emphasis on direct data within the value chain has been removed. Both these actions will significantly reduce the pressure surrounding data collection by allowing companies to use: 

• Estimates via a proxy - closely related indicators to approximate missing data; 

• Sample data - alternative data from a representative sample to estimate overall performance; 

• Sector averages - industry-specific benchmark data; 

• Regional data - geographically relevant statistics. 

Simplified Materiality 

Whilst double materiality remains the foundation of ESRS, the process has been simplified and now requires less documentation, including: 

• An option for companies to use a top-down assessment - material topics can be identified based on their strategy and business model, instead of a detailed, bottom-up evaluation of individual impacts, risks and opportunities (IROs). 

• Clearer structure for companies to report on the results of their double materiality assessment (IRO-1 and IRO-2) - section IRO-1 maintains a focus on process description, and section IRO-2 integrates material impacts, risks and opportunities from SBM-3. 

• No reporting triggered for an entire topic, if its sub-topic is material - if a sub-topic is material, the information to be reported is limited to that sub-topic, without triggering reporting on the entire topic. 

Example

A beer producer recognises that beer is fundamentally made of water.

Water use and water impacts are therefore material by definition.

The company does not run a long internal debate or produce extensive documentation to "prove" materiality.

Therefore, they report on water because excluding it would clearly misrepresent the business.

Reclaiming The Narrative 

The Omnibus stresses ‘fair presentation’ – allowing companies to control the narrative of their reporting, giving a more balanced, decision-useful picture of progress. Companies can tell their stories rather than following a strict structure, whilst increasing transparency on how judgements were reached on matters such as borderline topics or limitations. This allows for more purposeful and authentic reporting. 

Breathing Space 

A few additional reliefs have been introduced to add flexibility and reduce specific burdens.  This includes deferred disclosures – datapoints that are identified as material, but companies are permitted to delay reporting on. This applies to Biodiversity and ecosystems (E4), Workers in the value chain (S2), Affected communities (S3), and Consumers and end-users (S4) until FY27. 

No Double Counting 

EFRAG reviewed the ESRS to improve alignment and overall interoperability with the International Sustainability Standards Board (ISSB). Like ISSB, the materiality of information is now a general filter for reported information; the climate change GHG emission boundary has been replaced by the financial consolidation approach. In addition, a new separate disclosure based on operational control has been introduced. 

What Now? 

If you remain in scope, the Omnibus agreement has significantly reduced the time and effort you will need to spend on compliance. Companies are encouraged to use this additional space to familiarise themselves with the ESRS and prepare for data collection to reduce the burden of compliance. If you are suddenly out of scope, this can be used to prepare or get a head start by reporting voluntarily. 

Non-financial reporting remains a cornerstone of transparent and responsible business: your stakeholders - including customers, investors and partners - will expect transparency and action. 

If you wonder what steps you should take first, here is what we suggest: 

• Updating your Double Materiality Assessment (DMA) 

• Identifying the gaps in your data and mapping availability 

• Continuing engagement with management and stakeholders 

• Studying how your existing data may be adapted to ESRS 2.0 

The ESRS 2.0 eases the data burden while maintaining transparency, marking a significant shift toward more understandable and manageable sustainability reporting.

For in‑scope companies, these changes provide valuable space to focus on robust materiality assessments and form better foundations for data. 

For companies now out of scope, this is a chance to prepare, mature internal processes, and demonstrate leadership through voluntary alignment. 

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Willow is here to help! Contact us and explore the hands-on reporting expertise of our friendly team, alongside our bespoke level of service. 

A special thank-you to Gabriella Lovas, an independent sustainability consultant, for her contribution to these materials as part of our ongoing webinar series on the CSRD and ESRS. To access the webinar materials, email us at office@willow-sustainability.com!