The EFRAG Portal: A Glimpse into Early ESRS Implementation​

The "EFRAG 2025 State of Play" portal stands as a live, interactive platform, meticulously designed to provide crucial insights from EFRAG's market study on the initial adoption of ESRS under the CSRD. Its core functionalities include a "Statistics Dashboard," which allows users to explore overall trends and metrics derived from 656 sustainability statements issued in 2025, and a "Report Repository," offering access to the complete set of analyzed company reports collected between January 1 and April 20, 2025. Complementing these interactive features, an accompanying "State of Play 2025" report is also available in PDF format, summarizing the statistics and offering key observations.

This portal serves as a critical tool for a diverse range of stakeholders. For preparers, it offers an opportunity to benchmark their own reporting practices against peers, identifying areas where improvements can be made. For investors, civil society organizations, and consumers, the portal significantly enhances transparency and comparability, enabling a more informed evaluation of companies' sustainability performance and associated risks. This directly addresses the historical "accountability gap" where reported sustainability information was often insufficient, difficult to compare, and lacked reliability.

Key Findings from the "State of Play 2025" Report​

EFRAG's comprehensive analysis of the first 656 sustainability statements offers crucial insights into the initial phase of ESRS implementation:

Materiality Coverage: A significant finding from the report is the varied application of the double materiality principle. Only 10% of the analyzed companies identified all 10 topical ESRS standards as material. The most frequently disclosed topical standards were Climate Change (E1), Own Workforce (S1), and Business Conduct (G1). The data further reveals that more than half (52%) of preparers disclosed between 4 and 6 material topical standards, while approximately 25% reported 4 or fewer.

Stakeholder Engagement Gaps: The study uncovered a notable disparity in stakeholder engagement during materiality assessments. A vast majority, 97%, of companies involved internal stakeholders, primarily employees. However, engagement with broader societal stakeholders, such as authorities, Non-Governmental Organizations (NGOs), Industry Unions and Academia, remained considerably less common. This contrast between high internal engagement and low broader societal stakeholder involvement in materiality assessments highlights a significant area for improvement in operationalizing the "impact materiality" aspect of double materiality.

Climate Transition Plans: The report indicates that 55% of companies disclosed a climate transition plan, indicating that initial reporting on this topic is ongoing. However, a key observation is the variation in approaches and formats for these plans, highlighting different levels of maturity. Encouragingly, approximately 70% of preparers reported having near-term (2030 or earlier) Scope 1 & 2 targets compatible with the 1.5°C global warming limit. However, the absence of similar data for Scope 3 emissions (often the largest portion of emissions for many companies) suggests a potential reporting challenge or a less mature area of focus. This indicates that while companies are setting targets, the specific methodologies for achieving and reporting on these targets are still developing, posing challenges for stakeholders seeking actionable insights into climate resilience.

Reporting Depth and Length: The sustainability statements analyzed varied widely in length, ranging from 70 to over 200 pages on average. Financial institutions, in particular, tended to produce longer reports.

Underreported Topics: The study identified specific areas with limited disclosures. Topics such as biodiversity (E4) and internal carbon pricing showed restricted reporting. Furthermore, human rights incidents were rarely reported, even when other social data was present. The consistent underreporting of these topics points to inherent complexities in data collection, measurement, and materiality assessment within these areas. Unlike climate change, which has more established methodologies and frameworks, topics like biodiversity and human rights often involve more qualitative data, require specialized expertise, or necessitate deeper engagement across extended value chains.

Recommendations​

Given the dynamic and evolving landscape of ESRS, companies subject to these regulations should adopt a proactive and strategic approach to their sustainability reporting.

Revisit and Refine Materiality Assessments: Companies should embrace the simplified, top-down Double Materiality Assessment (DMA) approach, focusing on identifying truly material impacts, risks, and opportunities relevant to their specific business model, rather than attempting to report on every single data point. A critical area for improvement, as identified in the "State of Play" report, is strengthening engagement with broader societal stakeholders beyond internal teams to ensure a comprehensive understanding of impact materiality. This will lead to more relevant and credible disclosures.

Streamline Report Structure and Content: Preparers should anticipate and prepare to incorporate an executive summary at the beginning of their sustainability statement to highlight key strategy, metrics, and future outlook upfront. To enhance readability and conciseness, consider relocating detailed or highly technical data, such as EU Taxonomy disclosures, to dedicated appendices. The focus should be on presenting core, decision-useful information in the main body of the report, avoiding over-reporting on non-material or voluntary disclosures unless there is a clear strategic benefit.

Optimize Data Collection and Management: Companies should leverage the new flexibility regarding value chain data. Where direct data from smaller suppliers is not feasible or disproportionately costly, preparers should be ready to use robust estimates or industry data, ensuring transparency in their methodology. Investing in comprehensive data management systems is crucial for accurately tracking ESG performance across complex operations and supply chains. Furthermore, it is advisable to prioritize improving data collection and reporting for currently underreported topics like biodiversity and human rights incidents, as these areas are likely to remain subjects of significant regulatory and stakeholder scrutiny.

Stay Engaged with Regulatory Developments: Active participation in public consultations, such as EFRAG's upcoming consultation (expected from late July to early September 2025), offers a valuable opportunity to influence the final standards and voice practical concerns. Continuous monitoring of legislative updates is also essential, particularly concerning the finalization of the simplified ESRS by October 2025 and their anticipated adoption by mid-2026.

Embrace Interoperability: For multinational companies, aligning internal data collection and reporting processes with both ESRS and ISSB standards is a strategic imperative. This approach can significantly reduce duplication of effort and enhance the global comparability of sustainability disclosures, providing a more consistent narrative to a global audience.

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The launch of EFRAG's ESRS Statistics and Report Portal provides great insights into the early implementation of ESRS, revealing both significant progress and areas requiring further refinement.

As the ESRS framework evolves towards a more principles-based and materiality-driven approach, companies are presented with a unique opportunity to move beyond mere compliance. By strategically adapting their reporting processes, focusing on decision-useful information, and embracing the spirit of transparency, businesses can not only meet their regulatory obligations but also unlock new avenues for value creation, enhance stakeholder trust, and contribute meaningfully to a more sustainable economy. The future of sustainability disclosure is one of continuous improvement, informed by real-world data and driven by a shared commitment to accountability and positive impact.

SME Sustainability Reporting​

On July 30, 2025, the European Commission formally adopted a recommendation introducing a Voluntary Sustainability Reporting Standard for non-listed Micro-, Small-, and Medium-sized Enterprises (VSME). Developed by EFRAG, this initiative provides a streamlined, standardized, and accessible framework to help SMEs engage in sustainability reporting.

Non-listed SMEs are not directly required to report under the Corporate Sustainability Reporting Directive (CSRD), yet they face growing pressure to provide ESG data to large business partners and financial institutions. These stakeholders, subject to mandatory disclosure requirements, can cascade data demands down their value chains. As a result, SMEs will be burdened with fragmented, repetitive ESG questionnaires, leading to inefficiencies, duplicated efforts, and rising operational costs.

This voluntary standard aims to replace the multitude of uncoordinated ESG data requests, thereby increasing efficiency and lowering operational costs. Furthermore, the Recommendation is expected to enhance SMEs' access to sustainable finance by providing credible and comparable sustainability data. By encouraging large companies to base their data requests on the VSME, the Commission positions it as a de facto market standard, promoting greater consistency across supply chains.

The VSME reflects a forward-thinking regulatory approach, with the goal of enabling broad participation in sustainability efforts without stifling growth or competitiveness.

The VSME characteristics​

The VSME is specifically designed for companies that are not publicly traded and are not subject to the mandatory Sustainability Reporting. Its primary target audience comprises undertakings with fewer than 250 employees (micro, small, and medium-sized enterprises), while it can apply to bigger companies that are willing to start their reporting journey.

Key features:

• It is voluntary
• Intended for companies with fewer than 250 employees
• Aligned with the European Sustainability Reporting Standards (ESRS)
• Covers complete Environmental, Social & Governance (ESG) topics
• Tailored to the size, capacity, and needs of SMEs

A Modular and Flexible Approach​

The VSME standard is structured around a two-module approach, a design choice to ensure proportionate and adaptable reporting for the diverse sizes and capabilities of SMEs. This modularity allows businesses to choose a level of detail that best matches their needs.

The Basic Module​

This module is intended as the entry-level for all SMEs embarking on their sustainability reporting journey. It is specifically highlighted as the target module for micro undertakings (defined as SMEs with fewer than 10 employees), providing a manageable starting point. It comprises 11 core disclosures that focus on key sustainability indicators most frequently requested by value chain partners. These are the fundamental data points that provide essential transparency.
Key disclosures within this module include Greenhouse Gas (GHG) emissions (Scope 1 and 2), other environmental metrics, own-workforce data, and anti-corruption measures. It provides general information and basic metrics across environmental, social, and governance areas.

The Comprehensive Module​

This module builds upon the Basic Module, offering a more in-depth reporting framework for SMEs that need or wish to provide more detailed sustainability information, it includes 9 additional disclosures. These supplementary disclosures are often sought by banks and investors, as well as value chain partners who require a more understanding of an SME's sustainability performance. Examples of disclosures in this module cover a brief description of ESG practices or future initiatives (disclosure C2), GHG reduction targets and climate transition plans (disclosure C3), confirmed value chain incidents (disclosure C7), and information related to exclusion from EU reference benchmarks (disclosure C8).

A cornerstone of the VSME's design, aimed at reducing complexity, is that it does NOT require a mandatory materiality assessment. This stands in stark contrast to more complex reporting frameworks, which mandate a rigorous double materiality assessment process. Instead, the VSME promotes flexibility and usability through an "if applicable" conditionality. This means that undertakings are only required to apply and report on sustainability topics and disclosures that are genuinely relevant to their specific operations and business activities. If a particular disclosure does not apply to a company, there is no obligation to report on it, significantly simplifying the process. While a formal assessment is not mandated, even a simplified analysis of materiality can be beneficial. This helps companies identify which data points are most pertinent to their business, ensuring the reported information is truly meaningful and impactful.

Digital Tools and Ecosystem Support​

To support the adoption of the Voluntary Sustainability Reporting Standard for SMEs (VSME), EFRAG has introduced a suite of digital tools, including an Excel template, XBRL taxonomy, and an XBRL converter for generating machine-readable disclosures. These resources, available on EFRAG's website, will soon support multiple languages and include additional mappings to tools like GHG calculators. EFRAG is also developing practical guides to help SMEs draft their disclosures on key topics such as sustainable transition practices (C2), climate targets and transition planning (C3), and severe human rights incidents within the value chain (C7).

EXO.G platform builds on this foundation by providing SMEs with an intuitive, AI-powered platform that simplifies ESG data collection and report generation, fully aligned with VSME framework. With features such as guided reporting, modular templates, and collaborative tools for engaging suppliers, EXO.G ensures that even non-experts can confidently create compliant, transparent, and impactful ESG reports.
EXO.G transforms regulatory requirements into strategic opportunities by empowering companies to move beyond compliance and toward performance-driven sustainability. Instead of treating ESG as a reporting obligation, EXO.G helps businesses unlock value through data-driven, actionable insights and strategic roadmaps for improvement.

The platform simplifies frameworks like the VSME standard into guided workflows, enabling institutions to collect and structure data efficiently, even without in-house sustainability teams. Using AI and robust analytics, it transforms that data into clear diagnostics, benchmarking intelligence, and customized action plans to reduce risks, improve efficiency, and elevate ESG performance.

As EFRAG expands its resources, EXO.G integrates them into a seamless user experience, helping SMEs transform regulatory requirements into strategic opportunities.

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The impact of GRI's New Climate and Energy Standards

The Global Reporting Initiative (GRI) has increased the requirements for corporate sustainability disclosure with its new Climate Change (GRI 102) and Energy (GRI 103) Standards. Driven by urgent stakeholder demands and global climate goals, these updates are a call to action for businesses worldwide.

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What's New and Why It Matters​

These updated standards replace the older GRI 302, 305 (Disclosures 305-1 to 305-5) and GRI 201 (Disclosure 201-2), bringing enhanced rigor and scope to climate and energy reporting. Effective January 1, 2027, they shift the focus from mere metrics to strategic, impactful disclosure.

GRI 102: Climate Change​

GRI 102: Climate Change, which integrates and revises content from most of GRI 305: Emissions and the Disclosure 201-2: Financial implications and other risks and opportunities due to climate change, focuses on how organizations influence the climate and how they manage these influences. This standard introduces several critical features and objectives, such as reporting on how climate mitigation and adaptation plans impact workers, communities, and vulnerable groups. This adds a crucial social equity dimension to climate action, ensuring businesses address human impacts alongside environmental ones.

GRI 103: Energy​

GRI 103: Energy, which completely replaces GRI 302: Energy, enables an organization to publicly disclose its most significant energy-related impacts and how it manages them. This standard reflects an enhanced comprehension of how energy use influences climate change and aligns with pressing global commitments to mitigate climate change, consistent with IPCC recommendations and the Paris Agreement goals. This will enable organizations to disclose on energy consumption, reduction, efficiency, and renewable energy sources with a focus on impacts associated with energy consumption and transition to renewables.

Interoperability​

Both standards are designed to work seamlessly with other major frameworks like the ISSB's IFRS S2, the EU's ESRS (under CSRD), and the Science Based Targets initiative (SBTi). This helps reduce reporting duplication for multinational companies.

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Practical Implications: Challenges & Opportunities​

Implementing these new standards includes challenges and advantages.

Challenges:

• Increased Data Demands: Companies will need to collect more data on energy, value chain impacts, and social dimensions.
• Robust Data Systems: Upgrading existing systems or investing in new ESG software is crucial for managing this data accurately and efficiently.
• Cross-Functional Collaboration: Success hinges on coordination between different teams.
• Supply Chain Pressure: Large companies will need to engage with suppliers, including SMEs, to gather necessary value chain data.

Opportunities:

• Enhanced Credibility & Transparency: Detailed reporting builds trust with investors, customers, and regulators.
• Future-Proofing Reporting: Aligning with these leading standards ensures your reporting meets evolving global expectations.
• Improved Decision-Making: Deeper insights into energy use and climate impacts enable better strategic planning and risk management.
• Leadership in Climate Action: Proactive adoption positions companies as leaders in sustainable business practices.

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Your Next Steps​

To prepare effectively, businesses should:

1. Assess Readiness: Evaluate current reporting processes and data systems against the new GRI 102 and 103 requirements.
2. Invest in Systems: Consider ESG software to streamline data collection, ensure accuracy, and support alignment with multiple frameworks.
3. Refine Strategy: Integrate transition principles into climate mitigation and adaptation plans, aligning targets with global scientific consensus.
4. Stay Informed: Keep an eye on updates from GRI and other standard-setters to leverage interoperability and maintain compliance.

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Conclusion​

The new GRI Climate Change and Energy Standards can be powerful tools for driving meaningful climate action and corporate accountability. By adopting these standards, organizations can meet stakeholder demands and assess their impacts and costs, which must be addressed efficiently to ensure greater savings. It's a strategic move that enhances credibility, fosters trust, and accelerates growth.

Feeling the regulatory whiplash from Brussels? You're not alone. The European ESG landscape is in a state of intense flux. A political drive to ease administrative burdens is clashing head-on with the EU Green Deal's core mission, leaving C-suite leaders caught in a storm of uncertainty.

Many are tempted to hit pause on their ESG strategy, waiting for the dust to settle. This is a strategic mistake.

While the rules of the game may be shifting, the fundamental drivers of sustainability—investor demands, market risks, and consumer expectations—are only accelerating. This article cuts through the noise to reveal how to turn your ESG report from a compliance burden into a strategic intelligence tool that unlocks five crucial business insights.

The Great Unraveling? Understanding the Proposed Changes​

The core of the current "whiplash" comes from a significant political push to reduce the regulatory scope of both the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).

• June 2025: The European Council endorses a negotiating mandate proposing drastic scope reductions for both CSRD and CSDDD.
• July 2026: Original transposition deadline for the CSDDD, now likely to be pushed back significantly.
• July 2028: The proposed new transposition deadline for the CSDDD under the Council's mandate, prolonging uncertainty.

Beyond Compliance: 5 Strategic Insights from Your ESG Report​

Viewing ESG reporting as a mere burden is the fastest way to miss its true value. Here's how to reframe the process from a cost center to a value driver.

Insight 1: Identify Hidden Operational Inefficiencies​

Your ESG data on energy, water, and waste is a direct proxy for operational waste and squandered revenue. Analyzing this data reveals hidden cost-saving opportunities.

• Energy & Water Use: Pinpoint inefficient facilities and processes.
• Waste Streams: Quantify the cost of wasted raw materials.

Insight 2: De-risk Your Entire Supply Chain​

Real-world risk—from climate events to labor crises—hides deep in your value chain. Mapping these risks before they escalate into crises is fundamental.

• Climate Risk: Map supplier locations against data on water stress and floods.
• Social Risk: Screen for dependencies in regions with high risks of forced labor or instability.

Insight 3: Win the War for Talent​

In a competitive labor market, culture is an advantage. The social data in your ESG report (DEI metrics, employee turnover, pay equity) is the key to becoming an employer of choice.

• Attract Talent: Use transparent data to build trust.
• Retain Talent: Analyze turnover and well-being data to diagnose cultural issues.

Insight 4: Drive Product and Service Innovation​

Your ESG report is an R&D engine waiting to be ignited. Analyzing data on product life-cycles and customer expectations can spark the next generation of sustainable offerings.

• Circular Economy: Use data on material flows (ESRS E5) to design for remanufacturing and recycling, opening new revenue streams.
• Sustainable Innovation: Identify opportunities to substitute conventional materials with lower-impact alternatives, creating premium products that command higher margins.

Insight 5: Strengthen Brand and Reputation​

In an age of skepticism, trust is your most valuable currency. A transparent, data-backed ESG report is your strongest defense against "greenwashing" accusations and your most powerful tool for building an unbreakable brand.

• Win Over Investors: Investors demand credible data. A robust, auditable report is now a prerequisite for effective capital markets communication.
• Build Trust: Reporting honestly on progress—and challenges—builds a level of authenticity that traditional marketing cannot achieve, solidifying trust with customers, regulators, and NGOs.

Your Strategic Action Plan​

The intelligent response to regulatory uncertainty is not to stop, but to build the right foundations.

From Data Points to Decisions: The Final Word​

The current regulatory chaos in Europe is a test of leadership. Companies that see only a compliance burden will fall behind. But those that recognize this as a strategic moment to build a truly data-driven, resilient, and efficient enterprise will emerge as the leaders of tomorrow.

Reporting is the output. Insight is the outcome.

Don't let your ESG data gather dust in a report. Our platform is designed specifically to transform your raw ESG data from a complex compliance headache into the strategic intelligence that fuels your company's future.

Ready to move beyond compliance? See how our platform turns ESG data into your competitive advantage.