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On November 10, 2025, the EU published Delegated Regulation (EU) 2025/1416 in the Official Journal. This so-called ESRS Quick Fix amends the original Regulation (EU) 2023/2772 and introduces important relief measures for Wave 1 companies, which have already been required to report under the Corporate Sustainability Reporting Directive (CSRD) since 2024.
The Quick Fix is an adjustment to ESRS Set 1 designed to ease the burden on companies for the reporting years 2025 and 2026. Its objective is to reduce the considerable effort associated with sustainability reporting and to make the implementation of the European Sustainability Reporting Standards (ESRS) more practical.
1. Amendment to Annex C of ESRS 1 The phase-in provisions have been expanded. Companies may omit disclosures relating to the following standards for 2025 and 2026, even if these have been assessed as material:
Disclosures regarding expected financial impacts may also be temporarily suspended.
2. Relief measures for all Wave 1 Companies The transitional provisions now apply not only to companies with up to 750 employees, but to all Wave 1 companies.
3. New disclosure requirement (ESRS 2.17, as amended) Companies that fully make use of the relief measures must disclose this transparently in their sustainability report. The new disclosure under ESRS 2.17 summarizes the topics that have been omitted.
4. Direct application in all EU Member States As an EU regulation, the Quick Fix applies directly and does not require national implementation. The amendments enter into force three days after publication and apply to financial years starting on or after January 1, 2025.
The Quick Fix provides planning certainty and reduces the effort required for sustainability reporting. Companies can focus on already established disclosures and temporarily exclude more complex topics such as biodiversity or value chains. Important: the use of the relief measures must be clearly documented.
Companies should assess whether they can benefit from the transitional relief and, if necessary, adjust their ESRS strategy for 2025 and 2026. If you have questions regarding transitional provisions or the implementation of your sustainability reporting, our ESG team will be happy to advise you.
The Delegated Regulation (EU) 2025/1416 is available here.
Nils Borcherding
Partner
German CPA, Certified Tax Advisor
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