DATE
6.7.2026
AUTHORS
TOPICS
Reporting
Governance & regulation
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DATE
6.7.2026
AUTHORS
TOPICS
Reporting
Governance & regulation
SHARE
The ESRS Standards are the set of rules according to which companies within the scope of the CSRD disclose their sustainability information. They comprise twelve standards. On July 3, 2026, the European Commission adopted a revised version as a delegated act, which replaces the standards that have been in effect since July 2023. This overview outlines which standards exist, what has changed, and which version applies when.
The European Sustainability Reporting Standards (ESRS) specify what sustainability information companies within the scope of the Corporate Sustainability Reporting Directive must disclose and in what format. They are not a voluntary framework, but rather EU law that is directly applicable through a delegated act. Their purpose is to standardize sustainability disclosures so that they are comparable across companies and subject to external verification.
Binding EU reporting standards for the sustainability statement in the management report, adopted as a delegated act under the CSRD. First version dated July 31, 2023; revised version dated July 3, 2026.
The standards are developed by the European Financial Reporting Advisory Group (EFRAG), which provides technical input to the Commission. They are adopted by the Commission itself. This division of labor explains why there may be differences in content between an EFRAG draft and the final version—the Commission also made specific changes to the EFRAG recommendations in 2026.
There are twelve ESRS standards. Two of them are cross-standard and address principles and general disclosures; ten are topic-specific and cover the areas of environment (E), social (S), and governance (G). This classification has remained unchanged since 2023—the 2026 revision streamlined the content but did not remove or add any standards.
The revised ESRS significantly reduce the scope of reporting without compromising the CSRD’s substantive focus. According to the Commission, the number of mandatory data points will decrease by more than 60 percent. The second major change concerns the structure: requirements and supporting explanations are more clearly separated, and duplications between the standards have been eliminated.
The most significant changes occur where disclosure requirements have been restructured and renumbered. In ESRS E1, the number of disclosure requirements has increased from nine to eleven because climate risk analysis and resilience have become separate disclosure requirements. As a result, all subsequent numbers have shifted: The greenhouse gas disclosures that were listed under E1-6 in 2023 will be found under E1-8 in 2026. Anyone working with older guidance documents, data catalogs, or internal process documents will therefore be referring to the wrong section.
The revised ESRS are mandatory starting with the 2027 fiscal year, with initial reporting in 2028. This applies to companies with more than 1,000 employees and revenue exceeding 450 million euros. For the 2026 fiscal year, companies already subject to reporting requirements have the option to choose between the 2023 version and the revised standards.
The legislative process has not yet been fully completed. The delegated act is currently before the European Parliament and the Council for review. The initial review period is two months and may be extended by an additional two months. If neither the Parliament nor the Council raises any objections, the standards will enter into force once the review period expires.
For companies not subject to reporting requirements, the Voluntary Standard —which was adopted at the same time—is relevant. The so-called “value chain cap” is linked to this standard: Companies subject to reporting requirements may, in principle, only request sustainability information from companies with fewer than 1,000 employees that is covered by the Voluntary Standard. This significantly limits the scope of ESG data requests along the supply chain.
Initially, only ESRS 2 is mandatory for all companies subject to reporting requirements. Which of the ten topic-specific standards are added is determined by the two-part materiality analysis. In practice, three to eight standards are usually found to be material—depending on the business model, industry, and supply chain structure.
ESRS E1 applies to virtually every company, because practically every economic activity is associated with emissions and energy consumption. If a company determines that climate change is not material, it must provide a detailed justification for that decision. Manufacturing companies often report on E2 and E5 as well; labor-intensive companies report on S1; and companies with complex supply chains report on S2.
The 2026 revision did not change this fundamental principle—but it did change its significance. Since fewer data points are required, the materiality analysis plays an even greater role in determining the scope of a report. It thus evolves from a preliminary step to the actual tool for controlling the scope of the report.
In practice, the 60 percent reduction in mandatory data points is often interpreted as “60 percent less work.” That is not the case. Most of the data points that were eliminated were those that could be extracted from existing systems with reasonable effort. What remains are the most time-consuming components: the greenhouse gas inventory, including Scope 2 and Scope 3; the transition plan; the materiality analysis; and the ability to reconcile the data with the financial statements.
Companies that have already reported in accordance with the 2023 standards will face additional transition costs. Existing materiality analyses must be adapted to the two-tier topic structure, data collection processes must be aligned with the reduced scope of mandatory disclosures, and internal references must be updated to reflect the new numbering system. Companies that do not begin the transition until the 2027 fiscal year will forfeit the option to use 2026 as a trial run.
Our recommendation: Use fiscal year 2026 as a transition year to test the new structure without the pressure of an audit. Experience has shown that this is the best time to identify data gaps—especially in Scope 3 and regarding the expected financial impacts, where the transition relief has been extended through fiscal year 2028 and will no longer apply thereafter.
With the adoption of the standard on July 3, 2026, the rules governing reporting starting with the 2027 fiscal year are now set. The most sensible next step depends on where your company stands: Companies already subject to reporting requirements should consider whether to use the option for 2026 as a trial run and adapt their existing materiality analysis to the two-tier topic structure. Companies that will fall within the scope of the standard for the first time starting in 2027 should begin with the materiality analysis—it will determine the overall scope of the work required going forward. Companies outside the scope of the standard should review the voluntary standard as a response to customer inquiries.
A brief initial consultation will clarify the scope of application, deadlines, and the best first step for your company.

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