CSRD after the summer “quick-fix”: what changes, what stays, and how to prepare for 2026

The European Commission’s July 2025 “quick-fix” to the first set of European Sustainability Reporting Standards (ESRS) aimed to trim burden for early reporters (wave one reporting) without abandoning the core architecture of double materiality, value-chain coverage, and assurance. At the same time, EFRAG ran a 60-day consultation on broader simplifications to the ESRS, signalling further adjustments before the 2026 reporting cycle locks in.

What the July “quick-fix” accomplished

The Commission adopted a delegated regulation on 11 July 2025 that targeted the first ESRS set, focused on companies already reporting for the 2024 financial year (wave one). The edits aim to reduce immediate burden and increase certainty for these companies, while avoiding new data additions compared with last year.

For legal counsel, the practical effect is scope stability for wave one entities through the 2025 cycle: fewer surprises in mandatory datapoints, clearer materiality signposting, and limited tactical relief in disclosures where data maturity is weakest. It should be stressed however that the instrument preserves the core framework that boards, auditors, and investors have already integrated and any hope that the quick-fix would also roll back double materiality or value-chain expectations is misguided.

The summer consultation: simplification without hollowing-out

EFRAG’s revised exposure drafts opened a 60-day consultation that closed on 29 September 2025. The stated direction: simplify structure, clarify materiality, streamline datapoints, and align guidance while keeping the core objectives intact. A one-page brief flagged an indicative 57% reduction in datapoints under the proposal. EFRAG’s final technical advice should be expected by 30 November 2025, followed by a Commission adoption process.

Geopolitics: global pressure to scale back, but not to abandon

Since February 2025, the Commission has trailed a competitiveness-driven “omnibus” to ease sustainability red tape, including proposals to raise size thresholds so fewer companies are caught. Parliament rapporteurs have floated further cuts. This political pressure explains the quick-fix and the simplification mandate, but it does not amount to an abandonment of the objectives. The underlying motivation lies in the increasing pressure Europe as a bloc feels in comparison to its geopolitical rivals.

What stays stable through 2026

• Double materiality as the organising principle. The duty to assess both impact materiality and financial materiality remains foundational. The simplification processes in 2025 emphasise better scoping and documentation to improve this objective.
• Value-chain coverage with proportionality. Upstream and downstream data remains in scope, tempered by feasibility and prioritisation. Enforcement will continue to expect credible plans to close gaps over time.
• Limited assurance. Assurance posture remains in place – simplification seeks to make evidence expectations more realistic without diluting assurance as a disciplining mechanism.
• Core climate, governance, and anti-greenwashing anchors. These pillars continue to drive investor and regulator scrutiny regardless of datapoint counts, tying back to the EU’s broader sustainability finance agenda.

What is likely to move

There are three broader factors that the current process aims to reform and/or optimise:

• Datapoint density and granularity. The 57% claim is illustrative of the end-goal. If adopted in 2026, companies should evidence fewer and clearer datapoints with stronger narrative context and better cross-reference to risk management. This means that businesses operating in Europe should plan for reduced lists, instead of reduced responsibilities or expectations.
• Illustrative guidance and structure. Expect more modularity: clearer optional guidance, better grouping of disclosures, and revisions to annexes and glossaries that would reduce ambiguity without shifting outcomes.
• SME interfaces. The Commission adopted a VSME recommendation at the end of July, signalling more proportional pathways for SMEs interacting with large groups. This matters for contractual flow-downs and supplier enablement.

Legal risk: green claims, omissions, and internal controls

Reputational exposure around “greenwashing” has migrated into hard law via consumer-protection and securities-style enforcement. The more CSRD simplifies, the more regulators will focus on the integrity of what remains, and on the coherence between sustainability statements, financial statements, and marketing. The quick-fix does reduce volume but also concentrates liability, as fewer datapoints mean less excuse for inconsistency across the annual report, website, and investor decks.

Outlook for 2026

The CSRD’s core objectives remain intact, with the quick-fix trimming procedural burden to improve business usability and EU competitiveness. Whether the narrowed datapoint set preserves decision-useful information across the bloc will be tested in the next reporting cycle. For now, the signal is clear: authorities are willing to simplify without dismantling the framework, which should aid adoption and comparability.