Stakeholder Positions in the ESRS LSME Consultation: Comparability Versus Proportionality

ABSTRACT This study examines stakeholder perceptions of the ESRS LSME, the Sustainability Reporting (SR) standards issued by EFRAG for listed SMEs under Directive 2022/2464/EU. It analyses the 69 responses to the public consultation closed in May 2024, combining deductive content analysis with an institutional logics framework. Respondents are classified by stakeholder type, geographical area, sector and size to map participation, while open‐ended answers are coded to reconstruct the reasoning behind assessments of each proposed simplification. Positioning proves layered rather than dichotomous: two logics, comparability and proportionality, structure the debate, and respondents commonly accept the rationale of a simplification while contesting its calibration. Only sector‐specificity reconciles the two logics; the remaining simplifications trade one against the other. Administrative burden and implementation costs are weighed against demands for standardised, comparable information. The paper offers a systematic analysis of stakeholder feedback on the ESRS LSME and informs the debate on SR for listed SMEs.