The European Commission has now adopted the revised European Sustainability Reporting Standards (ESRS), the penultimate step in the Omnibus simplification process which has been underway since February 2025. Pending any objections from the EU Council or Parliament, this could be in place by the end of this year, meaning less box‑ticking, more materiality, more connectivity and more responsibility for the story you tell.
With the ESRS simplification now nearing completion, we have put together some practical next steps to consider.
Under the revised ESRS, the fair presentation principle is clarified to apply to the whole sustainability statement, with materiality of information now a general expectation for all disclosures. Compliance is no longer about ticking every datapoint; it’s about demonstrating that what you report is genuinely relevant and balanced.
What this means in practice: This is a chance to take a step back and consider your sustainability statement wholistically. Make sure your reporting reflects the expectations of fair presentation and materiality.
Double materiality remains a defining feature of the ESRS, but the revised standards have simplified the process, allowing a more pragmatic top‑down double materiality assessment that starts from the business model and value chain and aims to avoid unnecessary assessment of materiality in relation to each individual impact, risk or opportunity.
What this means in practice: Double materiality assessments are now less rigid, if you have already run one of these processes, the good news is it should be a more straightforward process next time. When revisiting your DMA consider integrating it more closely with your risk and strategy processes rather than running it as a standalone exercise.
With a headline 61% cut of mandatory datapoints, an option of an executive summary and optional adoption of dedicated appendices, now is a great time to be thinking about your sustainability statement structure.
What this means in practice: Consider whether to introduce an executive summary, if you should regroup your policies, actions, targets and metrics, and which content could live in appendices rather than the core narrative.
Extended phase‑ins and new reliefs allow companies to delay some disclosures and rely on reasonable and supportable information without undue cost or effort. This should reduce the immediate burden but market expectations in this area are not yet clear. At the same time the Commission has also published a draft regulation outlining a voluntary version of the ESRS for small and medium sized businesses.
What this means in practice: Make sure you know where your company sits on the disclosure pathway. If you’re not yet in scope, now is the time to be building out, revising and confirming your roadmap towards compliance.
Done thoughtfully, the revised ESRS give businesses the opportunity to move from data‑heavy compliance to a more strategic, investor‑oriented sustainability narrative, without losing sight of robust coverage of impacts, risks and opportunities. After a long period of uncertainty, the finish line for the finalised ESRS is in sight, and now is the time for companies to prepare accordingly.
Black Sun Global supports organisations at every stage of their CSRD journey - helping align regulation, reporting and communication to meet both compliance requirements and stakeholder expectations. Our team advises on reporting structure, sustainability strategy, stakeholder communication and digital delivery, ensuring sustainability statements are robust, navigable and effective beyond regulatory audiences.
If you would like to understand more about how Black Sun can help, please contact:
Bob Crosbie-Dawson, Head of Business Development
bcrosbie-dawson@blacksun-global.com.
About Black Sun
Black Sun Global is a stakeholder advisory and engagement agency that's been driving transformation and positive change for ambitious brands for more than 20 years. With deep expertise in disclosure and reporting, ESG, sustainability, and digital engagement, we reshape how organisations connect with customers, investors, employees, and the wider world.
We are trusted partners to some of the most influential global organisations, sparking innovation and sustainable performance through our strategic insights, partnerships, and proprietary technologies.
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