Businesses may now decide for themselves whether to break down their materiality analysis by region or country; carrying out a detailed analysis at that level does not require reporting at the same level. Information may also be omitted where it is commercially sensitive or would seriously compromise the competitive position.

The revised ESRS also introduce structural reliefs:

• an “undue cost and effort” principle: for certain information, companies may weigh whether the cost is proportionate to the added value for the user;
• a more flexible approach to acquisitions and divestments: a newly acquired subsidiary may be deferred to the following financial year;
• the use of estimates is explicitly permitted where reliable data are not yet available, provided the methodology is made transparent.

There are also targeted refinements within the individual topical standards:

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• Greenhouse gas emissions: the reporting boundary now starts from a single basis – the financial control approach from the GHG Protocol – supplemented by the operational control approach where operated assets would otherwise fall outside the scope. This better aligns with what many organisations already do.
• Microplastics and pollutants: the reporting obligation for microplastics is restricted to primary microplastics. Which pollutants are material is now determined on the basis of a management assessment of your activities and sector. The obligation to start from European reference lists (E-PRTR and the EU list of substances of very high concern) is removed.
• Human rights and discrimination incidents: only substantiated cases need to be reported, reducing the risk of reporting on unconfirmed complaints or allegations still under investigation.