2025 Draft Simplified ESRSESRS G1

Disclaimer

  1. This draft version of the Simplified ESRS has been published by EFRAG as a Technical Advice to the European Commission on 30 November 2025 and is not yet adopted as a Delegated Act. A version based on the Delegated Act on Simplified ESRS will be provided on the ESRS Knowledge Hub as soon as available. Access latest adopted 2023 ESRS here.

Objective

  1. 1.

    The sustainability statement shall include information in relation to ESRS G1 Business Conduct if this topic relates to material impacts, risks and opportunities to cover the reporting areas listed in paragraph 5 of ESRS 1 General Requirements. If not all the sub-topics prescribed by this standard are to be reported following the materiality assessment, paragraph 30 of ESRS 1 General Requirements applies.

  2. 2.

    The objective of this Standard is to set out Disclosure Requirements (DRs) providing information in relation to the reporting areas referred above that implement and complement the cross-cutting provisions of ESRS 1 General Requirements and ESRS 2 General Disclosures.

  3. 3.

    In this Standard, each DR is introduced by a disclosure objective, except for policies, actions and targets, for which the provisions in ESRS 2 GDR-P, GDR-A and GDR-T provide the necessary framing for the relevant disclosures.

  4. 4.

    This Standard sets out DRs related to business conduct, particularly with respect to the following sub-topics:

    1. (a)

      corporate culture, including anti-corruption and anti-bribery, the protection of whistleblowers and animal welfare;

    2. (b)

      the management of relationships with suppliers, including payment practices, especially late payment to small and medium-sized undertakings (SMEs); and

    3. (c)

      political influence, including lobbying activities.

Disclosure Requirements

Impact, risk and opportunity management

Disclosure Requirement G1-1 – Policies related to business conduct

  1. 5.

    (7) The undertaking shall disclose its business conduct policies in accordance with the provisions of ESRS 2 GDR-P.

  2. 6.

    In addition to the information required by ESRS 2 GDR-P, the undertaking shall disclose:

    1. (a)

      (10(b)) whether or not it has anti-corruption and anti-bribery policies consistent with the United Nations Convention against Corruption;

    2. (b)

      (10(d)) whether or not it has policies on the protection of whistle-blowers; and

    3. (c)

      (10(h) amended) the functions or roles within the undertaking that are most at risk in respect of corruption or bribery.

APPLICATION REQUIREMENTS – ARs

AR 1 for para. 5

(corruption or bribery – definition)

For purposes of this Standard, the undertaking shall apply the ESRS definition of corruption and bribery (see ESRS Glossary), which is generic, to overcome the differing definitions found in local laws or in laws applicable in the jurisdiction of the parent company and to ensure comparability across reporting undertakings.

AR 2 for para. 6(b)

(whistleblowers)

(11) Undertakings that are subject to legal requirements under national law transposing Directive (EU) 2019/1937, or to equivalent legal requirements with regard to the protection of whistleblowers, can comply with the disclosure specified in paragraph 6(b) by stating that they are subject to those legal requirements.

AR 3 for para. 6(c)

(corruption or bribery)

(AR4) When disclosing information under paragraph 6(c), 'functions or roles most at risk' means those functions or roles deemed to be most at risk of corruption or bribery as a result of their tasks and responsibilities within the undertaking, such as those operating in high-risk countries or interacting with public authorities and governments.

Disclosure Requirement G1-2 – Actions related to business conduct

  1. 7.

    The undertaking shall disclose its actions related to business conduct in accordance with the provisions of ESRS 2 GDR-A.

  2. 8.

    In addition to the information required by ESRS 2 GDR-A, the undertaking shall disclose information about the following actions:

    1. (a)

      (12 amended) the management of relationships with suppliers, including:

      1. i.

        (15(b) amended) if the undertaking takes into account environmental, social, and governance (ESG) performance factors in the selection of its suppliers, how this is done;

      2. ii.

        (10(g) amended) ESG training provided to the procurement team, if any; and

      3. iii.

        (15(a) amended) engagement with suppliers for the improvement of their ESG performance; and

    2. (b)

      (18(a)) the undertaking’s procedures to prevent, detect, investigate and respond to allegations or incidents related to corruption or bribery, including:

      1. i.

        (21 (b) and (c) amended) anti-corruption and anti-bribery training given to functions or roles most at risk within the undertaking, including members of the administrative, management and supervisory bodies; and

      2. ii.

        (24(b)) any actions taken to address breaches in procedures and standards of anti-corruption and anti-bribery.

APPLICATION REQUIREMENTS – ARs

AR 4 for para. 8(a)

(relationships with suppliers)

In presenting the information in accordance with paragraph 8(a), the undertaking may consider cross-referring to the information about the existence of a supplier code of conduct in accordance with ESRS S2 Workers in the Value Chain, paragraph 11.

Metrics and Targets

Disclosure Requirement G1-3 – Targets related to business conduct

  1. 9.

    The undertaking shall disclose its business conduct targets in accordance with the provisions of ESRS 2 GDR-T.

Disclosure Requirement G1-4 – Metrics related to corruption or bribery

  1. 10.

    (23) The objective of this DR is to enable transparency on the convictions and sanctions, including fines, related to corruption or bribery during the reporting period and the related outcomes.

  2. 11.

    (24(a)) The undertaking shall disclose the number of convictions and sanctions, including the total amount of fines, for violation of anti-corruption and anti-bribery laws during the reporting period.

APPLICATION REQUIREMENTS – ARs

AR 5 for para. 11

(corruption or bribery – convictions and sanctions)

Convictions for the violation of anti-corruption and anti-bribery laws refer to final decisionsissued by a criminal court against an individual or undertaking in respect of a criminal offence related to corruption or bribery, where these court decisions are entered in the criminal record of the convicting European Union Member State or, if outside the EU, in the equivalent register or record of the jurisdiction concerned.

Sanctions for the violation of anti-corruption and anti-bribery laws refer to final decisions issued by administrative or regulatory authorities against an individual or undertaking in respect of corruption or bribery.

AR 6 for para. 11

(corruption or bribery – fines)

Fines issued for the violation of anti-corruption and anti-bribery laws refer to mandatory monetary penalties resulting from violations of anti-corruption and anti-bribery laws imposed by a court, administrative or regulatory authority, which are paid to a public treasury, and which are recognised in the undertaking’s financial statements during the reporting period.

Disclosure Requirement G1-5 – Metrics related to political influence, including lobbying activities

  1. 12.

    (28) The objective of this DR is to enable an understanding of the undertaking’s activities and commitments related to exerting its political influence through political contributions and lobbying activities.

  2. 13.

    (29(b)) The undertaking shall disclose the total monetary value of financial and in-kind political contributions made directly and indirectly by the undertaking during the reporting period, aggregated by country or geographical area where relevant, as well as the type of recipient/beneficiary.

  3. 14.

    (29(c)) The undertaking shall disclose the main topics covered by its lobbying activities and the main positions taken, including explanations of how its lobbying activities interact with its material impacts, risks, and opportunities.

  4. 15.

    (30) The undertaking shall disclose information about the appointment of any members of the administrative, management, and supervisory bodies during the current reporting period who held a comparable position in public administration (including regulators) in the two preceding years.

APPLICATION REQUIREMENTS – ARs

  1. AR 7 for para. 13

    (political contributions)

    (AR 9) For purposes of this Standard, ‘political contribution’ means financial or in-kind support provided directly to political parties, their elected representatives or persons seeking political office. Financial contributions can include donations, loans, sponsorships, advance payments for services, or the purchase of tickets for fundraising events, and other similar practices. In-kind contributions can include advertising, use of facilities, design and printing, donation of equipment, provision of board membership, employment or consultancy work for elected politicians or candidates for office.

    AR 8 for para. 13

    (indirect political contribution)

    (AR 10) For purposes of this Standard, ‘indirect political contribution’ refers to those political contributions made through an intermediary organisation such as a lobbyist or charity, or support given to an organisation such as a think tank or trade association linked to or supporting particular political parties or causes.

    AR 9 for para. 15

    (political influence)

    (AR 11) When determining ‘comparable position’ in this Standard, the undertaking shall factor in the level of responsibility and scope of the activities undertaken.

Disclosure Requirement G1-6 – Metrics related to payment practices

  1. 16.

    (32) The objective of this DR is to enable an understanding of standard payment terms and of the undertaking’s performance with regard to payment, especially late payment to SMEs.

  2. 17.

    The undertaking shall disclose:

    1. (a)

      (33(b) amended) a description of the undertaking’s standard payment terms in number of days by main category of suppliers, specifying those that apply to SMEs, only if they are different from those generally applied;

    2. (b)

      (33(b)) the percentage of its payments aligned with these standard terms; and

    3. (c)

      (33(c)) the number of legal proceedings currently outstanding for late payments.

APPLICATION REQUIREMENTS – ARs

AR 10 for para. 17(b)

(payment practices)

If late payment to SMEs is a material topic for the undertaking, paragraph 11 of ESRS 1 General Requirements applies; therefore, the undertaking shall provide an entity-specific metric, if material.