ESRS Exposure Drafts - Changes to Environment
- Julien Pezet
- Aug 25
- 3 min read
The European Sustainability Reporting Standards (ESRS) are currently undergoing a revision aimed at one key goal: fewer data points, reduced redundancies, and greater clarity for companies.
The new exposure drafts show significant simplifications across all environmental standards.
E1 – Climate-Related Disclosures: Clearer, More Concise, More Flexible
Changes in the area of climate action and risks are particularly significant, with data points reduced by 53% and total text length by 65%.
E1-1 Transition Plan
Disclosure requirements regarding transition plans have been simplified and clarified.
Improved structure: starting with the identification of IROs (E1-2), followed by assessment of resilience to climate risks (E1-3).
E1-2 Climate-Related Risks and Scenario Analysis
Disclosure has been significantly simplified, focusing on information relevant for assessment.
Companies should disclose the key elements of their climate risk assessment methodology—however, a scenario analysis is not mandatory for all.
E1-3 Resilience to Climate Change
Wording has been aligned with IFRS S2.22 and redundant sections removed.
E1-4 Climate-Related Concepts
Previously E1-2.
Descriptions of policies on climate impacts, risks & opportunities have been moved to ESRS 2.
Shifts and simplifications aim to avoid redundancies and improve readability.
E1-5 Climate-Related Actions and Resources
Previously E1-3.
No major content changes; primarily reorganization and streamlining.
E1-6 Climate-Related Targets
Previously E1-4.
Focus on absolute GHG reduction targets, alignment with system boundaries and the 1.5 °C goal.
Prohibition of CO₂ removals, credits, and avoided emissions for target achievement remains.
Overall, fewer data points and more flexibility—but reduced comparability and transparency.
E1-7 Energy Consumption and Energy Mix
Previously E1-5.
Disclosure requirements simplified and content streamlined, but core content remains unchanged.
Information on high-impact sectors has been removed.
E1-8 Gross GHG Emissions (Scope 1, 2, 3)
Previously E1-6.
Simplification in defining company boundaries (financial control approach).
GHG intensity per net revenue removed.
Disclosure requirements streamlined, redundant paragraphs removed; core information remains.
E1-9 GHG Removals and Projects to Reduce GHGs via CO₂ Certificates
Previously E1-7.
Content on CO₂ removals in the value chain and CO₂ certificates outside the value chain has been clarified and better structured.
Some complex requirements removed.
E1-10 Internal CO₂ Price
Previously E1-8.
Internal CO₂ price disclosures streamlined, retaining key data points; additional requirements removed for simplification.
E1-11 Expected Financial Effects of Significant Physical and Transition Risks and Potential Climate-Related Opportunities
Previously E1-9.
E2 to E5: Focusing on the essentials
The trend of fewer data points, shorter text length, and simplified requirements continues across the other environmental standards.
E2 – Pollution
Data points reduced by 61% and total text length by 68%.
Previous data point “Disclosure requirement in connection with ESRS 2 IRO-1” removed.
Disclosure requirements simplified, redundant sections removed, content streamlined to align with main content of E2-4 (air, water, and soil pollution).
“Expected financial impacts” (previously E2-6) removed; now addressed centrally in ESRS 2 SBM‑3.
E3 – Water
Data points reduced by 70% and total text length by 82%.
The term “marine resources” removed from the standard and its subtopics.
Disclosure requirements shortened and restructured for clarity and consistency.
Total water withdrawal and discharge, previously optional and in AR, now explicitly mandatory.
“Expected financial impacts” (previously E3-5) removed; addressed centrally in ESRS 2 SBM‑3.
E4 – Biodiversity & Ecosystems
Data points reduced by 78% and total text length by 78%.
LEAP guidance removed due to methodological challenges.
Companies decide which biodiversity metrics (land-use change, invasive species, species/ecosystem condition) are material.
Disclosures on biodiversity-sensitive areas remain despite stakeholder criticism.
“Expected financial impacts” (previously E4-6) removed; addressed centrally in ESRS 2 SBM‑3.
E5 – Resource Use & Circular Economy
Data points reduced by 60% and total text length by 72%.
Disclosure focus on “key” products and services to simplify data collection.
Disclosures reduced and shortened to simplify difficult-to-define points, such as product recyclability.
Two new data points regarding critical and strategic raw materials and wastes of unknown final fate.
“Expected financial impacts” (previously E5-6) removed; addressed centrally in ESRS 2 SBM‑3.
Conclusion
The ESRS Exposure Drafts 2025 make one thing clear: less is more. Companies will benefit from simplified disclosure requirements, clearer structures, and fewer data points, while gaining flexibility in choosing what to report. At the same time, this may reduce comparability and transparency.
The takeaway for companies: focus on material topics, ensure thorough documentation, and start preparing for the new standards early.
