Client Alert: EU Seeks Feedback on Revised ESRS and Voluntary Sustainability Reporting Standards

The European Commission has opened a public feedback period on the draft final versions of the revised European Sustainability Reporting Standards (ESRS). The consultation marks another important step in the EU’s ongoing efforts to simplify and streamline sustainability reporting requirements under the Corporate Sustainability Reporting Directive (CSRD).

The revised ESRS standards are intended to reduce the administrative burden for EU companies subject to mandatory sustainability reporting while maintaining the quality and consistency of sustainability disclosures. According to the European Financial Reporting Advisory Group (EFRAG), the proposed revisions focus on improving usability, reducing the number of datapoints (including a reduction of more than 60% in mandatory datapoints and over 70% overall), simplifying double materiality assessments, and introducing new flexibilities for companies.

In parallel, the Commission is seeking stakeholder input on voluntary sustainability reporting standards intended for small and medium-sized enterprises (SMEs) and organizations outside the scope of mandatory CSRD reporting. The voluntary framework aims to support more proportionate ESG reporting while helping smaller companies respond to increasing sustainability information requests from their reporting business partners that are subject to mandatory sustainability reporting requirements.

Stakeholders are invited to submit feedback through the European Commission’s portal until June 3. Following the close of the consultation period, the Commission is expected to adopt the two delegated acts and subsequently submit them to the European Parliament and the Council for review under the standard no-objection procedure before the standards formally enter into force.

For more information, visit the European Commission announcement:
European Commission Feedback Process on Revised Sustainability Reporting Standards

Livable Cities Update: EPA Releases CPRG Status Report Primer

EPA clarifies CPRG Status Report requirements and expectations for grantees.

The U.S. EPA has released a new Status Report Primer for recipients of Climate Pollution Reduction Grants (CPRG) planning funds, confirming that a Status Report is required at the end of the four-year grant period.

The primer outlines EPA’s expectations for the report and offers recommendations on how jurisdictions can structure it and track implementation progress under their Comprehensive Climate Action Plans (CCAPs).

Key Elements Required in the Status Report

Consistent with earlier CPRG guidance, EPA confirms that Status Reports must include updates on several core CCAP elements, plus one additional requirement, including:

Required

• Implementation status of greenhouse gas (GHG) reduction measures

• Metrics tracking and quantified results for completed measures

• Review of authority to implement measures

• Intersection with other funding opportunities

• Workforce planning progress

• Updated benefits analysis

• Additional Requirement: Identify and outline next steps for CCAP implementation, including near-term projects, timelines, milestones, and associated budget and staffing needs

Encouraged

• GHG inventory updates

• GHG emissions projections and reductions

• Updates to GHG reduction targets

• Implementation narratives providing additional detail on progress

• Updated cost analysis

• Public outreach related to CCAP implementation

These components largely reflect the reporting expectations outlined in the original 2023 CPRG planning grant guidance, which anticipated that the Status Report would provide updates on CCAP implementation and identify next steps.

What’s New in the Primer

While the core requirements remain largely consistent with earlier guidance, the primer provides additional detail on how grantees should approach the report, including:

• Clarification that updates to GHG inventories and emissions projections are encouraged but optional.

• The previously required LIDAC benefits analysis is no longer required for the Status Report.

• Recommended approaches for tracking implementation progress.

• Grantees must report quantified emissions reductions for fully implemented GHG reduction measures using the metrics in their CCAP. Reporting for partially implemented or under-development measures is encouraged but not required. Grantees are also encouraged to update estimated or actual GHG reductions for any measures as needed.

• Guidance on updating benefits analysis and co-pollutant reductions

• Expanded discussion of funding alignment, workforce needs, and implementation barriers

Takeaways and Implications

Implementation tracking will be critical.

The Primer signals that jurisdictions should establish processes to track implementation progress and measurable outcomes throughout the grant period, rather than waiting until the end to compile reporting materials. 

The Status Report is more than a compliance exercise.

EPA emphasizes that the report should be used to communicate progress, adjust priorities, and identify resources needed to sustain climate action beyond the CPRG planning grant period.

Narratives must address progress across all measures. 

Reduction measures will be at varying stages of implementation, making narrative updates essential to clearly communicate progress. All measures must be addressed in the Status Report, including those with limited or no progress, along with explanations and next steps.