"Position Paper on the Future of Sustainability Reporting Status", 4 July 2025

Reporting obligations under the Green Deal need to undergo targeted, practical revision based on the experience of early adopters. The goal is to reduce the administrative burden on businesses in the European Union and to shift the focus back to the core objective of the regulations: to create additional investment capacity for the sustainable transformation of the economy and to enhance companies’ competitiveness and resilience.

The current policy debate on simplifying sustainability reporting – extending in some cases to calls for far-reaching changes – does not reflect the shared goals of stakeholders and companies. Improving the European Sustainability Reporting Standards (ESRS) requires trust-based and constructive collaboration together with factual and nuanced dialogue with stakeholders.

To this end, Allianz SE, BASF SE, the Accounting Standards Committee of Germany (ASCG), EnBW Energie Baden-Württemberg AG (EnBW), Germanwatch e.V., the Hans Böckler Foundation’s Institute for Codetermination and Corporate Governance and the University of Hamburg as well as capital market participants and assurance providers have formulated seven positions:

1. Even if reporting requirements are postponed, sustainability-related impacts, opportunities and risks remain...
2. European standards should be interoperable with emerging global regulations...
3. Stability in regulation is essential...
4. Sustainability information needs to be decision-useful...
5. A user- and preparer-oriented simplification of the sector-agnostic ESRS is attainable...
6. Focusing on material information increases the meaningfulness and the comparability of companies’ reports. Double materiality and a risk-based approach to analysing value chains are key elements that should be retained...
7. The application of target-oriented ESRS increases the resilience of business models and value chains across companies. Companies of all sizes and their suppliers can better identify and manage the material impacts, risks and opportunities of their business models.