ESRS 2: All Disclosure Requirements and What Has Changed

ESRS 2 specifies the structure of a sustainability report under the CSRD: governance, strategy, business model, materiality process, and the general requirements for approaches, measures, metrics, and targets. The version dated July 3, 2026, reduces the number of disclosure requirements from 16 to 15. Two changes carry more weight than the reduction itself: Three governance codes have been moved down one position, and ESRS 2 is no longer automatically required to be reported separately from the materiality analysis.

What is ESRS 2, and to whom does the standard apply?

ESRS 2 “General Disclosures” is the standard that defines the basic structure of every sustainability report under the CSRD: governance, strategy and business model, the process for identifying material impacts, risks, and opportunities, as well as the general requirements for policies, measures, metrics, and targets. In its version dated July 3, 2026, it includes 15 disclosure requirements.

The standard applies to all companies within the scope of the CSRD. For those subject to it starting with the 2027 fiscal year, Directive (EU) 2026/470 of February 24, 2026, has been revised to include companies with more than 1,000 employees and more than 450 million euros in net revenue. This marks the end of the phased implementation in waves.

ESRS 2 is the standard with the broadest scope within the set. Topic-specific standards such as ESRS E1 or ESRS S1 apply only if the respective topic is material. The disclosures under ESRS 2, on the other hand, apply to every reporting company—although the extent to which this applies has shifted somewhat in 2026. You can find a classification of all twelve standards and their relationships to one another in the overview of all ESRS standards.

What disclosure requirements does ESRS 2 contain?

The revised version contains 15 disclosure requirements organized into five sections: two on the basis for preparation (BP-1, BP-2), four on governance (GOV-1 through GOV-4), three on strategy and business model (SBM-1 through SBM-3), two on addressing impacts, risks, and opportunities (IRO-1, IRO-2), and four general disclosure requirements (GDR-P, GDR-A, GDR-M, GDR-T).

What has changed compared to the 2023 set?

The number of disclosure requirements is reduced from 16 to 15. One governance disclosure is eliminated without replacement, three governance codes move up in the list, two headings are expanded, and the four minimum disclosure requirements—MDR-P, MDR-A, MDR-M, and MDR-T—will henceforth be called GDR-P, GDR-A, GDR-M, and GDR-T. The following table maps each disclosure requirement from the 2023 set to its equivalent in the 2026 version.

Does ESRS 2 still apply regardless of the materiality analysis?

No longer automatically. The 2023 set of standards was clear: According to ESRS 1, Section 29, the company was required to disclose the information mandated by ESRS 2—specifically, all disclosure requirements and data points—regardless of the outcome of its materiality analysis. This wording no longer appears in the 2026 version.

It is replaced by a two-part mechanism. ESRS 1, Section 24 generally prohibits the disclosure of information that is not material and does not exempt ESRS 2 from this rule. Application Requirement AR 12, however, states that the disclosure requirements in ESRS 2 are “fundamental in nature” and therefore are likely to result in material information for all companies. An unconditional obligation thus becomes a very strong presumption.

In practice, this changes little in terms of the scope of most reports. It does, however, shift the burden of proof somewhat. Anyone who omits an ESRS 2 disclosure in the future will no longer be arguing against the wording of the standard, but rather within the materiality framework—and must be able to document this assessment.

Our assessment: We do not expect companies to make significant omissions in ESRS 2. The presumption set forth in AR 12 is clear, and the audit effort required to justify a deviation is likely to be greater than the effort required to provide the disclosure itself. The rule becomes interesting in cases where individual data points are clearly irrelevant to the company—such as disclosures regarding incentive systems in companies without variable compensation.

Governance: Why GOV-3 Means Something Different Today Than It Did in 2023

The number of governance disclosures is reduced from five to four, and three codes are shifted by one position. GOV-2 from the 2023 set—Information to the governing bodies and the sustainability topics they address—is no longer a separate disclosure requirement. The previous GOV-3, GOV-4, and GOV-5 are renumbered as GOV-2, GOV-3, and GOV-4. The content remains the same; only the numbers have changed.

This is where asset documentation still goes wrong. Anyone who created a data point list, a responsibility matrix, or an audit file in 2024 or 2025 will find the incentive systems listed under GOV-3. In the 2026 version, the due diligence statement is listed under GOV-3. Both documents are correct on their own; when placed side by side, however, they result in an error that goes unnoticed when reading because the codes appear plausible.

This primarily affects three types of documents that are virtually always present in CSRD projects: the mapping table between internal data sources and disclosure requirements, the approval matrix listing the responsible parties for each disclosure requirement, and the working papers for the audit. These documents use the codes as keys, often in column headers or file names.

In terms of content, what is actually being eliminated is the separate line in the report detailing which sustainability issues the governing bodies addressed during the reporting period and how they were informed about them. Certain aspects of monitoring are retained in GOV-1: Paragraph 12(d) requires a description of how the governing bodies manage goal-setting and progress monitoring, while paragraph 12(e) requires a description of how material impacts, risks, and opportunities are incorporated into strategy, material transactions, and risk management. The chronology of the governing bodies’ deliberations is thus no longer covered.

From MDR to GDR: The Four General Disclosure Requirements

The four minimum disclosure requirements in the 2023 set are referred to as general disclosure requirements in the 2026 version: GDR-P for strategies (paras. 41–43), GDR-A for actions and resources (paras. 44–46), GDR-M for metrics (paras. 47–49), and GDR-T for targets (paras. 50–52). They apply whenever a sustainability topic has been classified as material—using the same structure for each topic.

The application guidance is set forth in ESRS 1, paragraph 29: For material topics, the company applies ESRS 2 GDR-P, GDR-A, GDR-M, and GDR-T, in addition to the topic-specific disclosure requirements of the respective standard. Therefore, entities reporting under ESRS E1 must report climate protection strategies and measures in accordance with the structure set forth in ESRS 2 and provide climate-specific disclosures in accordance with ESRS E1 Climate Change.

In terms of content, the four disclosure requirements stipulate the same things as their predecessors, but in a more streamlined form:

• GDR-P: Key content and objectives of the policy; scope of application covering the company’s own business activities and value chain; reference to third-party standards; and, with regard to social issues, consideration of the interests of affected stakeholders.
• GDR-A: Key measures taken and planned, including their scope and timeframe, expected results, and the financial resources used and planned for the future, with reference to the annual financial statements.
• GDR-M: Definition, unit, calculation method, data sources, and estimation methods; for indicators from the value chain, use of indirect data and approximate values; classification of significant changes compared to the previous period.
• GDR-T: measurable, time-bound targets with target values, scope, base year, target year, and intermediate steps, along with methodology and assumptions; for environmental targets, an indication of whether they are based on sound scientific evidence.

The name change is more than just a cosmetic change, but less than a substantive reform. Those who have set up the MDR structure properly can continue to use it. Those who never set it up properly will now notice the same issue as before: with GDR-A and the linking of measures to funds that have actually been allocated.

Materiality in the Process: IRO-1, IRO-2, and the Top-Down Approach

IRO-1 describes the process by which the company identifies material impacts, risks, and opportunities—and, in the 2026 version, also the process by which it determines which information is material. IRO-2 consolidates what was previously spread across two sections in 2023: the material impacts, risks, and opportunities, and the list of disclosure requirements that are actually applied in the statement.

The expansion of IRO-1 is the more substantial of the two changes. It shifts the determination of materiality from the realm of implicit editorial judgment to the reporting process itself. Those who were previously able to justify why a topic is material must, in the future, also be able to justify why certain data points within that topic are reported and others are not.

ESRS 1, paragraph 27, provides relief in this regard. The company may derive materiality conclusions from its analysis of strategy and business model—including sectors, regions, and the characteristics of the upstream and downstream value chain—without further assessment. Only if it remains unclear after this analysis whether an issue is material should a specific assessment follow. For companies with a clearly defined business model, this significantly shortens the dual materiality analysis; for conglomerates with a heterogeneous portfolio, it has little effect.

Which set applies to my company, and when?

The revised version is mandatory for fiscal years beginning on or after January 1, 2027. For fiscal years beginning between January 1 and December 31, 2026, Article 2 of the delegated act grants an option. Entities that exercise this option must explicitly state in the sustainability statement which version was applied.

The question of who is required to report is not governed by the delegated act, but rather by Directive (EU) 2026/470 of February 24, 2026, published in the Official Journal on February 26, 2026, and in effect since March 18, 2026. Starting with the 2027 fiscal year, companies with more than 1,000 employees and more than 450 million euros in net revenue are required to report. Both criteria must be met. Details on the scope of application and setting up the reporting process are summarized on our services page regarding CSRD reporting.

What exemptions apply to ESRS 2—and which ones are no longer in effect?

The relief relevant to ESRS 2 is set forth in ESRS 1, paragraph 125. So-called “wave-one” entities—defined in paragraph 123 as those required to report for the first time for the fiscal year 2024—may omit the disclosures regarding expected financial effects under ESRS 2, paragraph 27, in their entirety for fiscal years prior to 2027, and may omit the quantitative disclosures related thereto for fiscal years prior to 2030. Paragraph 27 is part of SBM-3.

Two key conditions are regularly overlooked in this context. First, paragraph 122 ties the exemptions to the first year of the reporting requirement; voluntary early adoption does not trigger the phase-ins. Second, BP-2 requires disclosure of every phase-in option utilized—including an indication of whether the omitted topic was assessed as material. If it is material, the key aspects must still be reported in accordance with paragraph 9: the topic itself, its integration into the business model, objectives and progress, strategies, measures, and the relevant key performance indicators. The relief is therefore not an exemption, but a reduction in the level of detail required.

And then there’s the set of transitional rules that’s still all over the internet but has effectively run its course. The 2023 set tied several exemptions to a maximum annual average of 750 employees—for example, regarding certain greenhouse gas data points. Since Directive (EU) 2026/470 limits the reporting requirement to companies with more than 1,000 employees, no company subject to reporting can fall below this threshold anymore. The rule is still in the text, but its scope of application is empty.

The same applies to the “wave” logic. Transition periods based on Wave 2 or Wave 3 no longer apply, since the phased implementation has been discontinued. Anyone reusing project documents from 2024 should delete these passages rather than update them.

What ESRS-2 Projects Face in Practice

ESRS 2 is considered the easy part of projects because it does not require emissions data or supply chain information. In our experience, however, it is often the standard that remains unresolved the longest—for three reasons, none of which have anything to do with technical expertise.

First, the issue of responsibility. Information on governance and incentive systems is handled by Human Resources, the Legal Department, and the Corporate Secretariat—not by the sustainability team. These departments are often brought into CSRD projects at a late stage, and their contributions require approvals that the Executive Board cannot grant on the side due to time constraints. Anyone who leaves ESRS 2 until last will end up waiting for signatures.

Second, IRO-2. The list of disclosure requirements cannot be finalized until every subject-specific standard is complete. It is therefore structurally the final element of the statement—and at the same time, the first thing auditors examine, because it reflects the completeness of the reporting. Any subsequent changes to a subject-specific standard are reflected here.

Third, GDR-M. The requirement to disclose the calculation method, data sources, and estimation procedures for each key figure applies to data sets in which precisely this metadata is not recorded anywhere. The figure is in the table; its source is in a colleague’s head. This can be fixed, but not in the week before the editorial deadline—and it’s the point where sound ESG data and software management pays off the fastest.

Our assessment: The most sensible first step for the 2026 version is not a technical one, but an editorial one. Update existing mapping tables, approval matrices, and audit working papers to reflect the new governance codes, remove the rows referring to the old GOV-2, and replace the MDR designations with GDR. This will take just a few hours and prevent errors that are difficult to detect later because they appear plausible.

Frequently Asked Questions About ESRS 2

Conclusion: Update the code before making any changes to the content

The revised version of ESRS 2 introduces few new requirements in terms of content. What it does require is careful attention to terminology: one governance disclosure has been removed, three codes have been repositioned, and four disclosure requirements have been renamed. Each of these changes is trivial on its own, but when taken together in existing documentation, they are precisely why this is dangerous—because the old codes still appear to be valid.

The second change will take effect later, but it is more fundamental. With the elimination of the unconditional reporting requirement for ESRS 2, the standard falls under the materiality framework. This will hardly shorten the report, but the rationale behind it becomes relevant to the audit. Those who document now why ESRS 2 is being reported in full will avoid this discussion in the audit report.

Sources and Legal Bases

1. European Commission: Delegated Regulation C(2026) 5010 final of July 3, 2026, amending Delegated Regulation (EU) 2023/2772 (Articles 2 and 3, Recital 3). ec.europa.eu (PDF) (as of August 2026).
2. European Commission: Annex to C(2026) 5010 final — ESRS 1 and ESRS 2. ec.europa.eu (PDF) (as of August 2026).
3. EFRAG: ESRS 2 General Disclosures, version of the delegated act, interactive full text (BP-1 through GDR-T, paras. 3–52, AR 5–8). knowledgehub.efrag.org (as of August 2026).
4. EFRAG: ESRS 1 General Requirements, version of the delegated act, interactive full text (paragraphs 24, 27, 29, AR 12, paragraphs 122–125). knowledgehub.efrag.org (as of August 2026).
5. European Commission: ESRS 2 General Disclosures, Annex I to Delegated Regulation (EU) 2023/2772 (BP-1 through IRO-2, MDR-P through MDR-T). efrag.org (PDF) (as of August 2026).
6. European Commission: ESRS 1 General Requirements, Annex I to Delegated Regulation (EU) 2023/2772 (paras. 29 and 30, Appendix C). efrag.org (PDF) (as of August 2026).
7. EFRAG: [Draft] ESRS 2 General Disclosures, November 2025 (technical recommendation to the European Commission). efrag.org (PDF) (as of August 2026).
8. EFRAG: [Draft] ESRS 1 General Requirements, November 2025 (paras. 122–125). efrag.org (PDF) (as of August 2026).
9. European Commission: Press release on the adoption of the revised standards, July 3, 2026 (reduction of mandatory data points by over 60%, and of total data points by over 70%). finance.ec.europa.eu (as of August 2026).
10. European Commission: Delegated Regulation (EU) 2023/2772 of July 31, 2023, Annex I. eur-lex.europa.eu (as of August 2026).
11. European Parliament and Council: Directive (EU) 2026/470 of February 24, 2026 (application thresholds, elimination of waves 2 and 3). eur-lex.europa.eu (as of August 2026).