This briefing is a result of discussions with EFRAG members who were involved in the writing of the two Implementation Guidance documents for the European Sustainability Reporting Standards (ESRS) published in May 2024. The case of ESRS implementation guidance is distinctive due to the granularity and length of the ESRS legal text (approximately 300 pages), the absence of a user-friendly version of the text, and the lack of previously established guidance frameworks for the topics covered.

Among different critics, the guidance materials were perceived as coming too late, not answering all questions, nor being operational enough to be introduced into companies’ practices. Based on their feedback, we establish below a set of six operational recommendations for the upcoming guidance for the Corporate Sustainability Due Diligence Directive (CSDDD).