An interview with Paul Broekhof on how ESRS learning stays robust despite regulatory change

Intro by Simon Pitsillides:

Today I’m joined by Paul Broekhof, **Director of Education at the Global Reporting Initiative.

GRI is not only the global pioneer of sustainability reporting which is currently used by over 78% of the largest 250 global companies — it is also a co-constructor of the European Sustainability Reporting Standards, the ESRS.

Paul leads GRI’s global education and certification programmes, including the GRI-certified ESRS pathway that leads to the title “GRI Certified ESRS Sustainability Professional.”

Today we’ll talk about how ESRS learning is designed to stay robust despite regulatory change, and what that means for professionals deciding whether now is the right time to start.

Paul, welcome — it’s great to have you with us.

Simon Pitsillides: ESRS is still evolving. How has GRI designed its learning so it stays robust even when the regulation itself continues to change?

Paul Broekhof: Hi Simon, thank you for having me on your podcast.

We designed the certification program for reporting with the ESRS in 2024. Looking at what was ahead, looking at the challenges that so many companies would be facing once they were obligated to start reporting with the ESRS, we asked ourselves: how can we best support the thousands of reporters-to-be. Many of them would be new to sustainability reporting, so what should we focus on first? We decided that the best way to start would be to focus on the reporting process, rather than on the content and disclosures of the standards. By “reporting process”, I mean everything from scoping and stakeholder engagement through materiality analysis, data collection, assurance, and ultimately publishing.  After all, reporters spend some time reading the specific datapoints they need to report on and collecting data., but when producing a report for the first time, it is crucial to also understand all the steps involved in the reporting process — and this is where guidance from us can be especially helpful. Once that foundation was in place, we planned to create courses on specific standards, a bit like we have done for some of the GRI Standards. So the idea was always to make learners familiar with the reporting journey, the process, before diving into the details of the standards. This design choice has proven to be very robust, because, as you well know, in February 2025, the Omnibus proposal was published. It proposed a lot of changes to the CSRD and the ESRS, but these changes hardly touched upon the actual reporting process.

SP: GRI often describes ESRS learning as process-based rather than version-dependent. What does that actually mean in practice for professionals on the ground?

PB: Indeed, the ESRS training courses are based on the reporting process. That means that anyone who is or will be involved in reporting with the ESRS for their own company or for their clients will build a solid and practical foundation by taking our ESRS certification program. To give you two examples, the ESRS course on stakeholder engagement is relevant to the ESRS reporting process, regardless of which elements of the Omnibus proposal are accepted by the EU and its member countries. Even though different reporting standards may use slightly different definitions of stakeholders, the practice and principles of stakeholder engagement apply to all of them, not only to ESRS reporting but also to reporting with the GRI standards. It is a pretty generic skill to have.

A second example is the ESRS course on double materiality. It is one of the core concepts of the ESRS, and it basically means that when looking at sustainability matters, for example climate change, one should not only look at how climate change affects the company and its investors financially, let’s say the financial angle, but also at how the company itself affects climate change and what impacts it has on its stakeholders, which is the impact angle. That concept is still at the core of ESRS reporting and will be long after the dust around the proposed changes to the ESRS is settled, even if some technicalities do end up changing in the amended ESRS

So even if specific datapoints or thresholds change following the Omnibus proposal, having the skills to perform solid stakeholder engagement and materiality assessment doesn’t become obsolete – they’re transferable across reporting instruments and over time.

SP: What are the core skills and ways of thinking that ESRS learning is really trying to build, beyond just understanding the standards themselves?

PB: Well, as you know, GRI has played an important role in the creation of the ESRS. Much of what characterizes the GRI Standards has been adopted in the ESRS. Sustainability reporting is our core business, so to speak, so that is what we cover in our courses. As I mentioned earlier, the ESRS are based on double materiality. Our training course on double materiality will give the learners a solid and much-needed understanding of what double materiality is and how it applies not only to the ESRS but also to regions of the world where the IFRS Sustainability Standards, are being introduced. In today’s world, sustainability reporting is about impact and financial materiality and anyone involved in sustainability reporting should be aware of the different reporting tools for both.

Now, double materiality may be a core aspect of the ESRS, but we cover a lot more in the ESRS certification program. We tried to cover every aspect of the reporting process, and  that is how we came up with a program, of six courses. It starts with a quick introduction to the CSRD and the ESRS, then moving on to stakeholder engagement, double materiality assessment, and data collection. That last one, the data collection course is the one where we really dive into some of the reporting standards themselves, like E1, about climate change, S2, about workers in the value chain and G1 which is about Business Conduct.

But we also included a course on preparing for external assurance. The required level of external assurance was changed through the Omnibus proposal (now organizations need to prepare for limited assurance only), but the fact that external assurance must be done has not changed. Assurance is likely to be something new for first-time sustainability reporters, and this course prepares them for it.

The last course I want to mention is the digital reporting course, which covers another generic concept. Of course, the concept of digital sustainability reporting is not unique to the ESRS, but it is a recent development that many reporters still have to wrap their heads around. Many reporters are still unclear what terms like XBRL, or taxonomy mean. This course explains very clearly what digital reporting is and what it means for the reporting profession, what it looks like today and what we can expect in the future.

I want to emphasize that we have made all ESRS courses as practical as possible by including case studies and taking examples from real reporting practice. We followed the same approach as we do with all our training courses: focusing on the practice of sustainability reporting.

SP: When guidance evolves or updates are issued, how does GRI ensure continuity for learners already in certified ESRS pathways?

(note: we are already informing learners that they will be able to join a free FBRH led half day workshop which will be focused on any updates)

PB: Until December last year, the Omnibus proposal was still very much under discussion and it was still unclear what elements were going to be adopted. Of course, the proposal itself was important enough for course participants to be aware of, so we included a section on the Omnibus proposal in all our ESRS certification courses. We updated that section every time we learned that specific elements of the proposal had been agreed upon by the EU. Behind the scenes, the team that develops these courses is continuously tracking the Omnibus discussions to make sure that what ends up in the courses aligns with the reality of the CSRD and the ESRS as it develops.

By now, January 2026, the discussion of the Omnibus proposal has been completed and it is clear which of the proposed changes to CSRD are adopted. These changes will be reflected in the next update on the training courses, and all our students who bought a seat on the ESRS courses will be given access to the updated versions. But, because most of the proposed changes were about CSRD scope and the reporting timelines, and not about the reporting concepts or process, I am confident that the course updates that we will need to make will be quite limited.

BTW, I know that you run short, free workshops on updates to the ESRS for your own course participants. That is also is great way of keeping learners informed of what is going on.

SP: For professionals wondering whether now is the right time to start ESRS learning, what reassurance would you give them?

PB: That is a very good question. One outcome of the Omnibus proposal is that the reporting obligations for wave 2 and wave 3 companies have been delayed by two years. It would be a mistake to conclude that if your company is part of wave 2 or wave 3, you can sit back and relax for another two years. What we hear consistently from companies that have started to prepare for reporting under the CSRD, is that they underestimated the effort to have their staff trained and the controls in place that are needed for a proper reporting process. Consistently, their advice is to start early with preparations and go through the full reporting process well before the deadline. Use the two years you have been given to prepare, so that when you have to submit your first report, you can be confident that the process will run smoothly.

So, concretely, how should you prepare if you want to start today?

You know that the reporting standards themselves are still under revision, and are expected to be finalized somewhere mid 2026. So I would recommend that professionals start familiarising themselves with the reporting process and not go too deep into the standards yet. The next release of the ESRS will have far fewer datapoints than the initial release, so don’t dive into data-collection details today that may turn out to be irrelevant in the future.

So, focus on the reporting process first. A great way to start is by taking the ESRS certification courses available on the GRI Academy and through some of our certified training partners, like FBRH. That prepares you for the next step, which is to contact one or two peer organizations that have already started their reporting process or have completed the necessary preparations. They can give very practical advice on what your next steps should be. This is a great way to learn from the pitfalls encountered by others. That way, when the revised standards are finalized, you’re not starting from zero, instead, you’re ready to plug them into an established process.

Closing statement by Simon Pitsillides:

The key message here is simple: ESRS isn’t about waiting for certainty — it’s about building capability.
When learning is process-based it stays relevant, even as regulation evolves.

For professionals who want to move forward with confidence rather than hesitation, that’s the difference that matters.

And if you’d like to explore the GRI-certified ESRS pathway offered by FBRH in more detail, you can find more information at www.fbrh.co.uk/esrs.

Paul, thank you — this has been a genuinely valuable conversation.