Simplified ESRS: Analysis by the ANC and Operational Feedback from InVivo

The simplification of ESRS is entering a decisive phase. At Tennaxia Connect, held on June 2, 2026, the Accounting Standards Authority (ANC) and the InVivo Group shared their perspectives on the ongoing changes and their practical implications for businesses.

Covering topics such as regulatory clarification, the reduction of data points, and a refocusing of reporting on material issues, this conference provided an opportunity to compare the ANC’s perspective on the European trajectory with InVivo’s feedback on the operational implementation of the simplified ESRS.

Analysis of the ANC: Toward an "Omnibus" Simplification

Regulatory developments are strongly influenced by the spirit of simplification promoted by the European Commission through its “Omnibus” initiatives. The ANC, through its expert Eric Duvaud, Director of Sustainability Standards, provides crucial insight into the direction of these regulatory streamlining efforts.

The spirit of regulatory simplification

Unlike earlier versions, which were seen as overly complex, the current guidelines aim to drastically streamline the reporting burden on companies:

• Significant reduction in volume: The revisions are expected to result in a reduction of approximately 60% in the number of data points, with a focus on narrative disclosures, as well as a 50% reduction in the total number of pages in the disclosure documents.
• From Compliance to Strategic Management: The stated goal is to move away from a purely administrative “checklist” approach toward “fair presentation,” transforming the sustainability report into a genuine tool for strategic management and transition.
• Top-Down Approach to Materiality: The ANC confirms the primacy of the Double Materiality Analysis (DMA) driven by macro-level issues over 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 proposals and the need for economic simplification:

• Return to international standards: The GHG Protocol’s methodologies are preferred to ensure consistency with other sustainable finance tools.
• Accountability for pathways: Responsibility for developing the 1.5°C transition plan is transferred to the company rather than to the user of the sustainability reports, giving the company the flexibility to define its own approach.
• Sectoral and geographic exclusions: Assets managed on behalf of third parties are notably excluded from the reporting scope. In addition, the requirements regarding secondary microplastics have been removed, and the emphasis on local geographic granularity has been scaled back with regard to IROs and indicators.

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

Timeline for the Implementation of the Revised CSRD

The institutional calendar for the coming years is taking shape:

• 2025: Completion of the Omnibus Trilogue and publication of the EFRAG technical advice.
• 2026: Formal adoption of the Omnibus Act and publication of the revised ESRS (Simplified Set 1).
• 2027 : 
  
  • Mandatory application of the revised ESRS for the first group of companies subject to the requirements.
  • First application for the second group of companies.
• 2030: Full stabilization of the system and incorporation of an assessment of the expected financial impacts.

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) views these changes not as a constraint to be endured, but as an opportunity to reshape its business.

Results of the double materiality analysis

InVivo has implemented a robust dual materiality approach, surveying a broad sample (21 issues assessed through 18 questionnaires administered to 500 users). This analysis made it possible to identify the ESG themes that are directly relevant to the group’s business model:

Taking Advantage of the Omnibus Opportunity and Extending the Deadline

The shift in the European timeline presents a major strategic opportunity for InVivo. Initially subject to a disclosure requirement in the summer of 2026, the group has been reclassified under the regulations to fall under the second wave of the CSRD, postponing the official requirement until the summer of 2028.

InVivo's Strategic Approach: Despite the legal deadline being extended to 2028, management has decided to proceed with a voluntary reporting exercise and mock audit immediately. This decision allows the company to maintain its methodological lead, refine data collection processes, and avoid a last-minute rush to catch up.

Case Study on Simplification: The ESRS S1 Standard (Human Resources)

The HR initiative perfectly illustrates the efficiency gains made possible by the screening process and the proactive implementation of the principles of "Set 2" of the ESRS:

• Initial assessment: The raw dataset contained 83 applicable data points.
• Simplified scope: After applying materiality criteria and removing indicators that were purely voluntary or irrelevant to the cooperative model, the scope was reduced to 50 data points.
• Benefit: This reduction in workload allows HR teams to focus on key performance indicators that drive significant business value rather than on the exhaustive collection of secondary data.

Next Steps for the Group

InVivo’s trajectory combines methodological rigor with regulatory agility. The coming months will be devoted to the following initiatives:

1. July 2026: Analysis of the final Omnibus texts resulting from the European trilogues to finalize the data standards.
2. By the end of 2026: Further development and full integration of environmental topics (ESRS E2 Pollution, E4 Biodiversity, and E5 Circular Economy) into the Group’s information system.
3. Early 2027: Consideration of the remaining ESRS
4. Horizon 2028: Publication of the first sustainability report officially certified as compliant with the CSRD.

Conclusion

The simplified ESRS are set to be published (in mid-July, in theory). This will be the right time for companies that have been waiting for them to resume their work and take the time to prepare for their reporting cycle.

Keep in mind: the simplification proposed by EFRAG and adopted by the European Commission in the version submitted for public consultation is intended, in particular, to help companies treat this reporting as an exercise in management and transformation rather than mere compliance—as has been all too common with the disclosures of the past two years.

‍Governance has a key role to play in this process, particularly by fostering the necessary collaboration between CSR and finance departments to ensure alignment between financial and non-financial information. Finally, starting this process now will allow companies to ramp up their efforts gradually by bringing the various departments on board step by step.

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To learn more, download the recording of our webinar 👇