The revision and simplification of the ESRS offers companies the opportunity to make their materiality analysis more efficient – and thus save time and money. The more precise the analysis, the more focus can be placed on the truly material issues. The result: shorter reports, fewer key figures, lower audit costs. As part of several customer projects, iron has already conducted systematic reviews of companies' first double materiality analyses and identified concrete optimization potential. The most important finding: this can significantly reduce the effort and costs involved in CSRD reporting – without compromising compliance.
Starting point: Simplified ESRS as an opportunity for more efficient reporting
Following the EU omnibus proposal of February 2025, the European Commission tasked EFRAG with simplifying the existing ESRS. Feedback from the public consultation has now been consolidated and the current status of the work was published at the end of November 2025. The final version is expected in mid-2026.
For many companies, which have already carried out a double materiality analysis in accordance with the original version of the ESRS, the question arises: Does the materiality analysis that has been carried out meet the emerging requirements of the revised ESRS – and can it be made more efficient in order to reduce future reporting efforts? To clarify this, the iron team was commissioned to carry out systematic reviews. The aim was to identify specific optimization potential in addition to compliance testing.*
Methodology: Structured evaluation creates clarity
The review followed a clear approach: Based on the documentation and process descriptions provided by the companies, iron developed a systematic assessment framework. This made it possible to check the materiality analysis against the foreseeable requirements of the revised ESRS and to identify both areas that comply with the standards and those with potential for improvement. The result: a detailed gap report with specific recommendations for action – tailored to the specific situation of each company.
Where companies can save time and money in the future
The revised ESRS offer several starting points for making materiality analysis more efficient. Here is an overview of the most important areas for optimization:
a) Top-down instead of bottom-up: More efficient topic selection
In future, the selection of key topics will be based on business activities (top-down) and no longer on the AR-16 list of topics, which contained well over 100 topics, sub-topics, and even sub-sub-topics (bottom-up). This significantly reduces the amount of analysis required and focuses on the sustainability issues that are actually relevant to the company.
b) Pragmatic IRO assessment: Don't analyze every detail
The revised ESRS allow for a more pragmatic approach to assessing impacts, risks, and opportunities (IROs). Companies no longer have to assess every possible IRO across all business areas and the entire value chain in order to identify reportable issues. There is also more leeway when assessing time horizons and severity characteristics. In addition, quantitative assessment can be replaced by qualitative information. However, these simplifications should be applied with caution, as they can compromise the objectivity of the IRO assessment.
c) Stricter criteria for positive impacts
The revised ESRS clarify the definition of positive impacts. Activities that merely comply with legal requirements, mitigate their own negative effects, or are purely philanthropic in nature with no connection to the core business are not considered positive. This clarification reduces the number of impacts to be assessed and strengthens the focus on those that actually make a positive contribution to the situation of people and the environment.
Michael Werner, strategic partner at iron and former partner at PwC with over 15 years of experience in sustainability consulting, emphasizes the potential savings in practice:
“Based on the revised ESRS, companies will not only save time when evaluating IROs, but above all when preparing reports later on. If a precise materiality analysis succeeds in reducing the scope of the report by 30%, for example, the total costs for preparation and review will automatically decrease. This quickly makes a critical review of the materiality analysis a profitable business case – and that's without even taking into account the reduced effort involved in collecting key figures.“
Where companies should continue to invest time
Despite all the simplification, there are areas where methodological diligence remains crucial and pays off in the long term – especially when it comes to convincing the auditor of the approach and proactively avoiding complications during the audit. Our experience shows that auditors take a particularly close look during the initial audit.
The definition of clear, objectively comprehensible thresholds is central to this. They determine the severity at which an IRO is considered material. Companies should invest time here to create a methodologically sound basis. In addition to qualitative assessments, it is also advisable to develop quantitative scales for evaluating the financial impact of opportunities and risks. These show, for example, how certain risks could affect EBIT. Such scales create objectivity and illustrate in concrete terms what financial consequences a shortage or increase in the price of raw materials would have on the bottom line.
What the review showed among our customers
The systematic review made it possible to check the materiality analysis carried out against the foreseeable requirements of the revised ESRS with pinpoint accuracy. This identified areas where the previous approach did not (yet) comply with the standards, as well as specific potential for optimization.
Conclusion: Check now, benefit later
The simplification of the ESRS is an opportunity: those who systematically review and methodically optimize their materiality analysis now will save time and money in the future. Shorter reports mean less auditing effort, less data collection, and lower costs – while maintaining the same level of compliance security.
As far as the timing of the review is concerned, the documents published at the end of November 2025 provide a reliable interim status that is likely to be very close to the final version planned for mid-2026. Therefore, clear trends can already be identified that are likely to be implemented as planned – especially with regard to simplifications. In our opinion, the risk of starting the review too early is therefore manageable. On the other hand, those who wait until the final ESRS are available will lose valuable preparation time.
*Important note: The aspects of the revised ESRS cited in this article are subject to change, as the standards are not yet final. The statements are based on the draft version from November 2025.
Would you like to know how your materiality analysis compares to the emerging ESRS requirements – and where there is potential for savings? Feel free to contact us. We can assist you with a structured review and show you how you can systematically reduce your future reporting effort.
