In July 2025, EFRAG published a draft of amended ESRS (a simplification exercise requested by the European Commission). For ESRS E1 — Climate change, the point is not to change the role of climate in the CSRD in substance, but to restructure the standard to clarify what is mandatory, reduce redundancy, and align the text with how companies actually report.
Why a “second wave” of ESRS?
The ESRS in the 2023 delegated regulation set the baseline. The amendments under consultation aim to ease implementation without dropping climate ambition: separate disclosure requirements more clearly from non-mandatory implementation guidance, and make expectations easier to read for preparers and assurance providers.
What technical commentary highlights for E1
Public analyses of the draft (firms, associations, trade press) typically stress:
- an expected tightening on consistency of transition plans and alignment with recognised decarbonisation pathways when the company claims long-term alignment;
- clearer emissions metrics (Scopes 1, 2, 3) aligned with the GHG Protocol, to improve comparability across reports;
- moving voluntary or illustrative elements into non-normative guidance (often called NMIG — non-mandatory implementation guidance), so the standard focuses on what is actually mandatory.
Consultation and legal status
The draft amended ESRS were subject to a public consultation (check EFRAG’s site for exact dates and responses). Until the European Commission adopts a revised delegated act, the binding text remains the 2023 delegated regulation. Reporting teams should distinguish preparation (understanding the direction of travel) from current obligation (complying with the framework in force for the reporting period).
Implications for activity data (including AI)
Even when E1 paragraph wording changes, the logic stays the same: documented methodology, explicit boundary, consistency over time. For Scope 3 LLM inference loads, that reinforces the value of usage data (tokens, model, test vs production scope) rather than one-off, untraceable estimates.
Sources and caution. Always rely on official texts (EFRAG, EU Official Journal) for obligations. Explainers — including this one — summarise drafts that may change before final adoption.