The ongoing EU Omnibus simplification process raises serious concerns. There appears to be no clear, science-based strategy guiding decisions on which disclosures to retain or eliminate. Without such a framework, the process risks generating data that lacks credibility in reflecting corporate impacts—thereby undermining its value for assessing risks and opportunities.
While reducing the reporting burden is important, it must not come at the expense of weakening the core purpose of the Corporate Sustainability Reporting Directive.
Below are documents and comments that reflect our researchers’ position on the matter:
Mistra FinBio Consultation response regarding the revised and simplified Exposure Drafts of the ESRS
In late july 2025 EFRAG published the revised and simplified Exposure Drafts of the European Sustainability Reporting Standards (ESRS). The draft was launched to gather feedback from stakeholders across the EU corporate reporting ecosystem.
This follows 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 is tomake sustainability reporting under the Corporate Sustainability Reporting Directive (CSRD) more manageable while preserving its relevance and alignment with the European Green Deal.
This is Mistra FinBio’s feedback to the draft from EFRAG. Please feel free to copy as much as you like from it and use in your response. It is important that we make the voice of science heard in the consultation and urge EFRAG to complement the current ESRS with scientific guidance.
Response to the EFRAG call for public feedback on the simplification of ESRS
May 15, 2025
As environmental scientists engaged in sustainability reporting, we see the ESRS as a crucial step toward integrating sustainability into corporate accountability. Its value lies in making environmental impacts visible and credibly disclosed—critical for tracking progress against climate and nature targets and for robust risk assessment.
We note two critical concerns that we urge the simplification to address:
(i) the excessive volume and complexity of E1-5, and
(ii) the subjectivity introduced as companies self-identify financially material environmental impacts, which risks inconsistency and weak comparability.
BRIEF – Staying Green: Retaining the integrity of environmental disclosures under European corporate sustainability reporting
February 24, 2025
With the forthcoming EU Omnibus Proposal, the push for regulatory streamlining and simplification must not come at the expense of robust and scientifically valid environmental disclosures.
European scientific, legal, and accounting communities play a crucial role in ensuring that corporate sustainability reporting retains its integrity under the current waves of geopolitical upheaval and pressures. Insights from these communities can importantly support legislators and policymakers to streamline extant compliance burdens while successfully retaining the ambitions and intent of the CSRD, ESRS, Taxonomy Regulation, and related instruments.
OPEN LETTER TO THE EUROPEAN COMMISSION
December 23, 2024
Grounding EU Sustainability Reporting in Science: A Call for Action
As Europe and the world await the European Commission’s anticipated February 2025 Omnibus Simplification Package, it is vital that members of the scientific and research communities add their voices to the dialogue on the future of EU corporate sustainability-oriented legislation. Recent statements from Accountancy Europe and over 90 organizations representing financial, corporate, and civil society interests have argued for the need to reduce the reporting burden on market participants while ensuring a smart implementation of legislative and reporting existing frameworks. We agree with these statements but emphasize that science must play a central role in achieving these goals.
Reporting less, knowing more: the case for smarter ESRS reforms
May 29, 2025
Professor Beatrice Crona’s Op-Ed published on Sustainable Views
Watering down sustainability reporting without a science-based strategy risks leaving us with data that is less credible, less useful and less comparable. Simplification of the European Sustainability Reporting Standards must be guided by science to ensure high-impact environmental indicators are retained and data remains decision-useful. Anchoring double-materiality assessments in scientific evidence would improve consistency and prevent companies from omitting critical environmental disclosures. Expanding location-specific reporting requirements is essential for assessing real environmental risks and tracking progress towards climate and nature targets.
