ESRS Exposure Drafts - Changes to Social
- Stefan Graf
- Aug 25, 2025
- 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 social standards.
S1-4 – All social standards
For policies relating to human rights and alignment with the UNGP and the OECD Guidelines for Multinational Enterprises, eight data points from the four social standards were combined into a ‘human rights policy’ in ESRS 2 for the four stakeholder groups concerned.
The indicator relating to serious human rights violations was combined into a single indicator that applies to all four social standards, and the scope of application for serious human rights violations was revised to create a clearer definition (S1-16, S2-3, S3-3, S4-3).
S1 – Own workforce
Reduction of data points by 53 % and a reduction in total word count by 67 %.
Definition of ‘significant employment’ in S1-5 adjusted: A country is now considered significant if it has 50+ employees and is among the top 10 countries in terms of number of employees.
Several items have been removed from S1-6 (S1-5 in the draft), including gender distribution among employees with non-guaranteed hours, number of departures during the reporting period, and voluntary breakdowns (e.g. permanent/fixed-term by region).
Non-EU ‘adequate wages’ redefined in S1-10: priority given to statutory/collective agreement minimum wages according to ILO, otherwise living wage estimates.
The data point ‘proportion of employees taking family-related leave’ has been removed from S1-14.
S2 – Workers in the value chain
Reduction of data points by 60 % and reduction of total word count by 75 %.
In the former S2-3, information on the timing, type and frequency of labour involvement in the value chain has been removed and is now voluntary.
Voluntary information on confidentiality, anonymity, feedback and detailed criteria has been deleted/moved to NMIG; S2-3 now only refers to UNGP* criteria and allows cross-referencing to G1-1.
In S2-4, detailed information on target measurement has been deleted; the new focus is on the involvement of workers, their representatives or credible proxies in effectiveness testing and the derivation of improvements.
S3 – Affected communities
Reduction of data points by 62 % and a reduction in total word count by 73 %.
The previous five main categories of Disclosure Requirements (DRs) have been consolidated into four DRs (policies, stakeholder engagement, measures and targets).
Engagement, grievance mechanisms and remediation (previously S3-2 and S3-3) have been combined into one DR (S3-2) to avoid repetition and make reporting more coherent.
Redundant data points have been removed, simplified in some places or moved to NMIG.
S4 – Consumers and end users
Reduction of data points by 64 % and a reduction in total word count by 79 %.
The previous five main categories of disclosure requirements (DRs) have been consolidated into four DRs (policies, stakeholder engagement, measures and targets).
Engagement, grievance mechanisms and remediation (previously S4-2 and S4-3) have been bundled into one DR (S4-2) to avoid repetition and make reporting more coherent.
Redundant data points have been removed, simplified in some places or moved to NMIG.
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.
