Building Trust Through Transparency: ESMA's 2025 Sustainability Reporting Priorities

For public interest companies with more than 500 employees ("Wave 1 companies"), 2025 marks the first reporting year under the Corporate Sustainability Reporting Directive ("CSRD"). As a result, these companies are applying the European Sustainability Reporting Standards (ESRS) for the first time. The European Commission has been working on streamlining these requirements through what is known as the Omnibus legislative package. This includes proposed amendments to simplify the CSRD, delay some reporting obligations, and refine the ESRS for future years.

Despite this, the European Securities and Markets Authority ("ESMA"), has made its position clear. Companies reporting for 2025 must use the existing standards that are already in force. Draft revisions or proposed changes cannot be used as a basis for reporting until they are formally adopted. In this period of transition, ESMA's enforcement priorities issued on the 14^th of October 2025, serve as a guide to