Governance Briefing — November 15, 2025
Boards preparing CSRD sustainability statements must lock in the Commission's ESRS quick-fix relief as the delegated act enters the Official Journal in mid-November 2025 and coordinate QC 1000 evidence with EFRAG's 30 November simplified-ESRS delivery.
Executive briefing: The European Commission’s July 2025 “quick-fix” delegated act that extends wave-one CSRD relief will enter the Official Journal in mid-November, triggering application three days later and fixing what wave-one reporters must attest for financial years 2025 and 2026. Audit committees that already mapped PCAOB QC 1000 controls in October and December briefings now need to align their sustainability reporting evidence packs with the simplified ESRS advice EFRAG must hand the Commission by 30 November 2025.
Board checkpoints before the Official Journal publication
- Reconfirm scope of relief. Validate that the quick-fix maintains the ability to omit anticipated financial effects and certain workforce metrics for FY2025–2026, and document which subsidiaries still need full disclosures so board minutes reflect consistent application.
- Update filing calendars. Build a November compliance window that assumes the delegated act is published around 15 November and becomes binding three days later, so sustainability statements and assurance scoping mirror the new phasing.
- Coordinate with legal and investor teams. Prepare messaging that explains why 2025–2026 reports continue wave-one relief while acknowledging the Commission’s broader ESRS simplification track.
Audit committee integration with QC 1000 programmes
- Fold relief decisions into the quality management system. Tie QC 1000 design memos to the ESRS quick-fix so the firm’s governance response explains which disclosure objectives remain deferred and how monitoring procedures cover the narrowed scope.
- Refresh risk assessments. Reassess sustainability reporting risks so QC 1000 risk responses incorporate reduced metrics while still enforcing data lineage, estimates governance, and evidentiary thresholds for material topics.
- Plan evaluation evidence. Build 2025 year-end evaluation workpapers that demonstrate how the quick-fix was applied, what exceptions were noted, and where remediation is scheduled ahead of the simplified ESRS regime.
Documentation to collect ahead of 30 November
- Board briefings. Capture slide decks and minutes that explain why wave-one relief continues, how it interacts with audit committee oversight, and what triggers exist once the simplified ESRS delegated act is adopted in 2026.
- Disclosure control matrices. Update matrices showing which ESRS datapoints remain deferred, the control owners, and the checkpoints that will reactivate once the Commission completes the broader simplification.
- Stakeholder outreach logs. Track correspondence with investors, lenders, and regulators documenting how the organisation will respond to EFRAG’s 30 November submission and any subsequent Commission consultations.
Zeph Tech integrates the ESRS quick-fix sequencing into QC 1000 roadmaps so audit committees have defensible evidence when the Official Journal publication lands.