Simplified ESRS: ANC's Analysis and the InVivo Case Study

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🔎 Key takeaways

The simplification of ESRS aims to significantly reduce the reporting burden, with fewer data points, less narrative, and a refocus on truly material issues.
The goal is to make reporting a management tool rather than a compliance exercise, by relying on a more strategic and "top-down" double materiality analysis.
The ANC confirms a realignment with international standards, particularly on climate, while giving companies more responsibility for their transition pathways.
The InVivo case shows that companies should continue to prepare now, even in the event of a regulatory postponement, to ensure data reliability, test their processes, and scale up gradually.

The simplification of ESRS is entering a decisive phase. At Tennaxia Connect, held on June 2, 2026, the French Accounting Standards Authority (ANC) and the InVivo group shared their interpretation of the ongoing developments and their concrete implications for businesses.

Covering regulatory clarification, reduction of data points, and refocusing reporting on material issues, this conference allowed for a comparison of the ANC's perspective on the European trajectory and InVivo's feedback on the operational implementation of simplified ESRS.

ANC Analysis: Towards an "Omnibus" Simplification

Regulatory news is strongly marked by the spirit of simplification instilled by the European Commission through its "Omnibus" work. The ANC, through its expert Eric Duvaud, Director of Sustainability Standards, provides crucial insight into the trajectory of these standard simplifications.

The spirit of regulatory simplification

Unlike the initial versions perceived as excessively complex, current guidelines aim for a drastic rationalization of the reporting burden for companies:

Significant reduction in volume: The revisions project an approximate 60% decrease in data points, primarily targeting narrative obligations, as well as a 50% reduction in the total number of pages in the frameworks.
From compliance to management: The stated objective is to move away from a purely administrative "checklist" approach towards a "true and fair view" (Fair presentation), making the sustainability report a genuine strategic steering and transition tool.
"Top-Down" Approach to Materiality: The ANC confirms the primacy of the Double Materiality Analysis (DMA) driven by macro issues, rather than a granular, bottom-up approach based on Impacts, Risks, and Opportunities (IRO).

Major Changes and Conceptual Realignments

The negotiations highlight fundamental trade-offs between EFRAG's initial visions and the imperatives of economic simplification:

Return to International Standards: The retention of GHG Protocol methodologies is favored to ensure consistency with other sustainable finance tools.
Accountability for Trajectories: Responsibility for establishing the 1.5°C transition plan is transferred to the company and no longer to the user of the sustainability statements, allowing it the flexibility to define its own terms.
Sectoral and Geographical Exclusions: Assets managed on behalf of third parties are notably excluded from the reporting scope. Furthermore, requirements relating to secondary microplastics have been removed, and the emphasis on local geographical granularity has been reduced with regard to IROs and indicators.

"Double materiality is now firmly established. Finance and CSR functions have integrated to drive the transition." — Éric DUVAUD, Director of Sustainability Standards (ANC)

Implementation Timeline for the Revised CSRD

The institutional timeline is becoming clearer for the coming years:

2025: Finalization of the Omnibus Trilogue and publication of EFRAG's technical opinion.
2026: Formal adoption of the Omnibus text and publication of the revised ESRS (Simplified Set 1).
2027:
- Mandatory application of the revised ESRS for the first wave of subject companies.
- First application for the second wave of companies.
2030: Full stabilization of the framework and integration of the quantification of expected financial effects.

Strategic and operational implementation by InVivo

As a leading player in European agriculture and structured as a Mission-driven company, the InVivo group (15,000 employees) integrates these developments not as a constraint to be endured, but as a business structuring opportunity.

Results of the double materiality analysis

InVivo deployed a robust double materiality approach, surveying a wide panel (21 issues tested via 18 questionnaires with 500 users). This analysis made it possible to filter the ESRS topics strictly applicable to the group's business model:

ESRS Standard	Topic scope	Materiality status at InVivo
ESRS E1 to E5	Environment: Climate, Pollution, Water, Biodiversity, Circular economy	● Material
ESRS S1	Social: Group's own workforce	● Material
ESRS S2	Social: Value chain workers (upstream agriculture)	● Material
ESRS S3	Social: Affected communities	○ Not material
ESRS S4	Social: Consumers and end users	● Material
G1	Governance: Business conduct	● Material

Leveraging the Omnibus opportunity and deadline postponement

The shift in the European timeline offers a major strategic opportunity for InVivo. Initially positioned for a reporting obligation in summer 2026, the group is now legally part of the second wave of CSRD, postponing the official obligation to summer 2028.

InVivo's strategic decision: Despite the legal postponement to 2028, management decided to voluntarily maintain a reporting exercise and a dry run audit immediately. This choice allows them to retain the methodological lead gained, to fine-tune data collection processes, and to avoid a last-minute catch-up effect.

Practical case of simplification: The ESRS S1 standard (Human Resources)

The HR project perfectly illustrates the efficiency gains enabled by the filtering work and the early application of the spirit of "Set 2" of the ESRS:

Initial assessment: The raw framework contained 83 applicable data points.
Simplified target: After applying materiality criteria and removing indicators that were purely voluntary or not relevant to the cooperative model, the scope was reduced to 50 data points.
Benefit: This reduction in workload allows HR teams to focus on high-value business performance indicators rather than on an exhaustive collection of secondary data.

Next Steps for the Group

InVivo's path combines methodological rigor and regulatory agility. The coming months will be dedicated to the following projects:

July 2026: Analysis of the final Omnibus texts resulting from the European trilogues to finalize the data framework.
End of 2026: In-depth analysis and full integration of environmental topics (ESRS E2 Pollution, E4 Biodiversity, and E5 Circular Economy) into the group's information system.
Early 2027: Consideration of the remaining ESRS
By 2028: Publication of the first sustainability report officially certified as compliant with CSRD.

Conclusion

The simplified ESRS are about to be published (mid-July in theory). This will be the right time for companies that were awaiting them to resume preparations and take the time to get ready for their reporting exercise.

Keep in mind: the simplification proposed by EFRAG and adopted by the European Commission in the version submitted for public consultation is primarily aimed at helping companies make this reporting an exercise in strategic management and transformation, not just compliance, as has been too often seen with publications over the past two years.

‍Governance, in particular, has a key role to play in this process with the necessary alignment between CSR and finance departments to ensure connectivity between financial and non-financial information. Finally, addressing the exercise now will allow companies to gradually scale up by involving the different departments step by step.