The Global Network Initiative (GNI) appreciates the opportunity to provide feedback to the European Financial Reporting Advisory Group (EFRAG) on the proposed changes to the simplified Exposure Drafts of the European Sustainability Reporting Standards (ESRS). The simplification of the ESRS is part of the European Commission’s Omnibus initiative to make sustainability reporting under the Corporate Sustainability Reporting Directive (CSRD) more manageable while preserving its relevance and alignment with the European Green Deal.
GNI supports and urges EFRAG to preserve certain key elements of the amended ESRS, as they are central to effective reporting and must not be weakened. In particular, the foundational four-pillar structure of the social standards is essential to maintaining a coherent and comprehensive approach to sustainability reporting. It is also essential to preserve the flexibility for companies to present their most significant sustainability issues in a connected way, which is crucial for ensuring meaningful disclosure and comparability across different contexts.
GNI would also like to highlight several areas of concern in the amended standards. First, while ESRS 2 appropriately references key instruments such as the UN Guiding Principles on Business and Human Rights (UNGPs) and the International Covenant on Civil and Political Rights (ICCPR), ESRS S4 (Users and Consumers) fails to include references to international human rights instruments, unlike ESRS S1-S3. This omission creates inconsistency and weakens alignment with the Recital 49 of the Corporate Sustainability Reporting Directive (CSRD). GNI suggests that for consistency, ESRS S4 should explicitly reference the International Bill of Human Rights (UDHR, ICCPR, ICESCR) and other core UN conventions to ensure companies fully consider the range of relevant rights.
Second, in S3 and S4, paragraph 4, the proposed removal of “for example” is problematic. By removing this language from the lists of economic, social, cultural, civil, and political rights, the standards risk narrowing the scope of issues companies are expected to take into account. Deleting this qualifier risks turning what should be open-ended guidance into a closed list. This change contradicts the principles of human rights-based approaches, which emphasize considering the complete set of potentially relevant rights rather than a restricted subset. This issue is particularly relevant for ESRS 1 Appendix A (List of Topics), ESRS S3 paragraph 4, and ESRS S4 paragraph 4, and should therefore be reconsidered.
GNI has consistently supported proportional, risk-based reporting frameworks that strengthen corporate accountability and improve outcomes for rights-holders. We believe the ESRS have potential to provide a meaningful and internationally aligned foundation for sustainability reporting, provided that their core structures are preserved and gaps are addressed.
About GNI
GNI is a multistakeholder organization that brings together leading companies, civil society organizations, investors, and academics to protect and advance freedom of expression and privacy in the technology sector. Through shared principles and collaborative engagement, GNI promotes responsible business practices that respect human rights and foster transparency and accountability worldwide.