EFRAG’s draft datapoint list
Every datapoint the ESRS define; draft as at 11 October 2026.
“It must not be used as a checklist.”CSRD · readiness, check by check
CSRD readiness checklist: every check, and the rule behind it
A CSRD readiness checklist should run in six phases — scope, version, materiality, disclosures, value chain, and controls with assurance — and every line should name its rule.
This one is keyed to Directive 2013/34/EU as amended by Omnibus I and to the revised ESRS in Delegated Regulation (EU) 2026/1563, as at 11 October 2026.
It is not a datapoint list, because the body that writes the datapoint list says its list must not be used as one.
How the checklist runs
Six phases of CSRD readiness, in the order the rules impose
The order matters, because each phase depends on the answer to the one before.
Scope decides whether the rest applies at all, and the version decides which paragraph numbers the rest of the work cites.
Read how to use the checklist
Each table below gives the check, what it means and the provision it comes from.
Treat a check as done only when you can point to the evidence for it, because the assurance opinion covers the process as well as the result.
The checklist describes what the rules require; it sets no timetable, and the readiness plan further down is an illustration.
The rules themselves are summarised on the CSRD explained and the standards on the ESRS page.
- 1
1 · Scope
Are we in, from which year, on whose figures?
- 2
2 · Version
Which ESRS for FY2026, and FY2027 onwards?
- 3
3 · Materiality
Which topics and sub-topics are material?
- 4
4 · Disclosures
ESRS 2 first, then only the material standards, with phase-ins.
- 5
5 · Value chain
What may we ask suppliers for?
- 6
6 · Controls and assurance
Can the process and the numbers be assured?
Phase 1 · scope
Are you in scope? The FY2027 test has two limbs
From financial years beginning on or after 1 January 2027 the CSRD reaches undertakings that exceed both €450 million of net turnover and an average of 1,000 employees.
One limb is not enough, and a figure exactly at the threshold does not exceed it.
Read the scope checks
| Check | What it means | Rule |
|---|---|---|
| Run the FY2027 scope test on the undertaking’s own figures | Exceeds €450m net turnover AND an average of 1,000 employees; both limbs | Accounting Directive Art 19a(1) |
| For a parent, test the group on a consolidated basis | The same two limbs, consolidated | Art 29a(1) |
| Check whether a parent’s consolidated report could exempt the entity | Conditions apply, including publication of the parent’s report and assurance opinion | Arts 19a(9), 29a(8) |
| For a non-EU group, test Article 40a from FY2028 | EU turnover above €450m for each of the last two years, plus an EU subsidiary or branch above €200m | Art 40a(1) |
| Note the two-of-three “large undertaking” test is no longer the CSRD test | €25m / €50m / 250 survives as a size class only | Art 3(4) |
| Record which Member State’s transposing law applies | Transposition by 19 March 2027 | Directive (EU) 2026/470 Art 5(1) |
Wave one reported for financial years 2024 to 2026, and the stop-the-clock directive moved the later waves to 2027 and 2028 before Omnibus I replaced them with the single test.
The figures can be run through the scope checker on CSRD thresholds, and the history of the dates is on the CSRD timeline.
Scope routesExplore
Module 01 / 04
EU undertaking
Exceeds €450m net turnover and an average of 1,000 employees (Art 19a(1)).
Module 03 / 04
Non-EU group
Article 40a from FY2028, on EU turnover in each of the last two years.
Module 04 / 04
Exemption
A qualifying parent’s consolidated report can exempt a subsidiary, on conditions.
Phase 2 · version
Which ESRS, and say which
For a financial year starting in 2026 the undertaking chooses between three versions and must state its choice.
From financial years beginning on or after 1 January 2027 the revised ESRS apply with no choice.
Read the version checks
| Check | What it means | Rule |
|---|---|---|
| Choose the ESRS version for any FY2026 report | 2023 ESRS as amended by DR 2025/1416; those with eight reliefs; or the revised ESRS | DR (EU) 2026/1563 Art 2(1) |
| State the version chosen in the statement | “shall clearly state … which version they apply” | DR (EU) 2026/1563 Art 2(2) |
| Plan FY2027 on the revised ESRS | Applies to financial years beginning on or after 1 January 2027 | DR (EU) 2026/1563 Art 3 |
| Cite paragraph numbers with their version | Annex I was replaced in full, so paragraph numbers do not carry over | DR (EU) 2026/1563 Art 1 |
The eight reliefs are ESRS 1 ¶27 (top-down materiality), ¶¶32–33, ¶¶74–75, ¶90, ¶91, ¶92, ¶106 and ¶110.
Three FY2026 optionsExplore
Module 01 / 04
2023 ESRS
As last amended by Delegated Regulation (EU) 2025/1416.
The dated rules
The dates every CSRD readiness plan has to fit
These are the dates in force or announced as at 11 October 2026; consultation deadlines are EFRAG’s and may move.
- 18 March 202601
Omnibus I in force
The €450m and 1,000-employee test and the value-chain cap enter EU law. - 21 September 202602
Revised ESRS published
Delegated Regulation (EU) 2026/1563; the voluntary standard, 2026/1560, is published the same day. - 23 October 202603
Datapoint list feedback closes
EFRAG’s fatal-flaw survey on its draft list; the final resource is expected by the end of 2026. - 10 November 202604
Revised ESRS enter into force
Entry into force is not application; the XBRL consultation also closes on 11 November. - FY202705
- 19 March 202706
- 1 July 202707
- FY202808
Phase 3 · double materiality
The assessment that decides what you report
The double materiality assessment converts the twelve standards into the handful a given undertaking reports.
Either lens is enough: impacts can be material “irrespective of whether they are financially material” (ESRS 1 ¶35).
Read the assessment checks
| Check | What it means | Rule |
|---|---|---|
| Choose top-down or bottom-up for each topic, and record why | Top-down needs the strategy and business-model analysis on file | ESRS 1 ¶¶27–28, AR 9–10 |
| Assess impacts first, then risks and opportunities | “In general, the starting point is the assessment of impacts” | ESRS 1 ¶36 |
| Treat each of scale, scope and irremediable character as able to make an impact severe | “Any of the three characteristics … can make a negative impact severe” | ESRS 1 ¶40, AR 22 |
| Apply likelihood only to potential impacts; severity first for human rights | Actual impacts on severity alone | ESRS 1 ¶40 |
| Record thresholds; qualitative may suffice | No number is set by the standard | ESRS 1 ¶37, AR 13, AR 19 |
| Draw on engagement carried out within due diligence | A key input to impact materiality; no survey is required | ESRS 1 ¶42, AR 24 |
| Draft IRO-1, IRO-2 and SBM-3 from the working papers | Specific to the process, not boilerplate | ESRS 2 IRO-1 ¶35, AR 24 |
The method in full is on running a double materiality assessment, a working register on the assessment template, and the threshold question on materiality thresholds.
EFRAG’s implementation guidance was written for the 2023 ESRS and is non-authoritative; as at 11 October 2026 none is listed for the revised set.
Assessment checksExplore
Phase 4 · disclosures
ESRS 2 first, the rest only if material
Once the assessment is done, the disclosure checks follow from it: ESRS 2, whose disclosures are likely to be material for every undertaking, then the material topical standards, and only the material sub-topics within them.
Over-reporting is now a defect, because information that is not material shall not be disclosed.
Read the disclosure checks
| Check | What it means | Rule |
|---|---|---|
| Start from ESRS 2 | Its disclosures are “likely to result in material information for all undertakings”; the materiality filter still applies | ESRS 1 AR 12 |
| Report only material topics, and only material sub-topics | Material sub-topic information only | ESRS 1 ¶¶26, 30 |
| Strip out immaterial information | “shall not disclose”, except supplementary information under §8.2 | ESRS 1 ¶24 |
| If climate is material, cover E1-1 to E1-11 | Transition plan or a statement that there is none; Scope 2 location- and market-based | ESRS E1 ¶¶12–13, 30 |
| If own workforce is material, cover S1 with S1-5 in any case | S1-5 applies whenever own workforce is reported | ESRS S1 ¶1 |
| List the phase-ins you take | AFE relief with the E1-11 carve-out; S1 first-year omissions | ESRS 1 ¶¶125–127 |
| Place the statement in the management report | “shall include in their management report” | Accounting Directive Art 19a(1) |
Climate is the standard most undertakings test first: ESRS E1, requirement by requirement, sets out the eleven disclosure requirements, including location- and market-based Scope 2 and significant Scope 3 categories.
Own workforce is the other common candidate, and ESRS S1 in full lists its sixteen requirements and the first-year omissions.
Anticipated financial effects can be omitted in early years, but the relief does not reach ESRS E1-11 paragraphs 39(a)(b) and 40(a)(b).
What gets reportedExplore
Module 02 / 04
Material topics
The topical standards and only their material sub-topics.
The datapoint list
The one document that is not a CSRD checklist
The most common shortcut is to treat EFRAG’s list of datapoints as the checklist.
EFRAG’s own explanatory note says the list “must not be used as a checklist” and should be used “only in conjunction with the exercise of judgement underpinning materiality considerations”.
Read what the list is for
The note also says the revised ESRS “have no mandatory datapoints that are to be reported irrespective of materiality assessment” (¶68).
Its draft count is 292 “shall” datapoints, excluding the policy, action, target and metric datapoints and six technical ones, and every one is subject to materiality.
Read that way, it helps check coverage once the materiality judgements are made, and EFRAG expects the final version by the end of 2026; ESRS datapoints explains the count and what each figure measures.
Two different documents
Your materiality conclusions
Which topics and sub-topics you report.
The list is used alongside that judgement.Phase 5 · value chain
What you may ask suppliers for, and what they may decline
The revised ESRS 1 lets an undertaking assess its value chain using “average regional data, sector data or generally available information” (¶33).
And Omnibus I limits what it may require from suppliers with an average of 1,000 employees or fewer in the preceding financial year.
Read the value-chain checks
| Check | What it means | Rule |
|---|---|---|
| Use reasonable and supportable information without undue cost or effort | Sector and regional averages are allowed | ESRS 1 ¶¶32–33 |
| Keep supplier requests within the cap for protected undertakings | Average of 1,000 employees or fewer in the preceding financial year | Art 19a(3); DR (EU) 2026/1560 Annex II |
| Mark any part of a request that exceeds the cap | The supplier may decline it | Art 19a(3) |
| Separate CSRD requests from other information requests | The cap covers information gathered for CSRD reporting only | Directive (EU) 2026/470 recital (12) |
The Commission’s note says the cap “does not impose or imply any obligation” on companies in the value chain to provide sustainability information.
What a capped questionnaire contains is on the VSME guide.
Value-chain checksExplore
Module 02 / 04
The cap
Protected suppliers may decline information beyond the voluntary standard.
Module 03 / 04
Annex II
The cap is measured against the voluntary standard’s Annex II datapoints.
Phase 6 · controls and assurance
Controls, evidence and limited assurance
The last phase makes the first five provable: controls, an evidence trail and an assurance provider allowed to give the opinion.
The opinion is limited assurance, and it covers the process carried out to identify the information reported as well as the result.
Read the controls and assurance checks
| Check | What it means | Rule |
|---|---|---|
| Document internal controls over sustainability reporting | ESRS 2 gains GOV-4 | ESRS 2 GOV-4 |
| Keep an evidence trail for the process, not only the numbers | The opinion covers the process to identify the information reported | Art 34(1)(aa) |
| Include Taxonomy Article 8 disclosures in the assurance scope | Inside the perimeter | Art 34(1)(aa) |
| Confirm who may assure under national law | Statutory auditor by default; other auditors or independent providers if the Member State allows | Art 34(1), (3), (4) |
| For a PIE, keep preparation and assurance apart | Preparing sustainability reporting is a prohibited non-audit service for the statutory auditor | Regulation (EU) No 537/2014 Art 5(1)(c) |
| Track the XBRL taxonomy, but do not treat tagging as due yet | Not yet mandatory; draft out to 11 November 2026 | EFRAG, 17 September 2026 |
The assurance rules, including who may provide the opinion, are on assurance under the CSRD, and the taxonomy on the ESRS XBRL taxonomy page.
Assurance checksExplore
Module 02 / 04
Scope of opinion
Compliance, the process to identify information, and Taxonomy Art 8.
Module 03 / 04
Limited only
The reasonable-assurance path was deleted; standards due by 1 July 2027.
Module 04 / 04
Independence
A PIE’s statutory auditor may not prepare its sustainability reporting.
UK groups
CSRD readiness for a UK group
No UK law asks a UK company to be CSRD-ready.
A UK group meets the CSRD through an EU subsidiary, an EU listing, Article 40a from FY2028, or as a supplier receiving requests.
Read the UK angle
The routes for UK groups are set out under CSRD reporting for UK groups.
UK SRS applies single (financial) materiality, so a group reporting under both can start its UK work from the financially material subset of its ESRS assessment; how the CSRD and UK SRS compare covers the overlap.
How the scope changed under Omnibus I is on the CSRD after Omnibus I.
Where a UK group meets itExplore
Module 01 / 04
EU subsidiary
In scope on its own figures, unless exempted by a parent report.
An illustrative plan
A CSRD readiness plan for a first FY2027 report
This sequence is an illustration of how the six phases could be ordered for an undertaking whose first report covers FY2027.
The rules set no internal timetable, and the quarters below are not deadlines.
- Q4 2026 · illustrative01
Scope and version
Run the scope test, record the transposing law, and fix the ESRS version. - Q4 2026 · illustrative02
Assessment design
Choose routes, thresholds and evidence sources; set up the register. - H1 2027 · illustrative03
Assessment and conclusions
Assess impacts first, then risks and opportunities; record conclusions. - H1 2027 · illustrative04
- H2 2027 · illustrative05
Controls and dry run
Document GOV-4 controls and test the evidence trail with the assurer. - 202806
First report and opinion
The FY2027 statement in the management report, with limited assurance.
What goes wrong
Eight readiness mistakes the rules rule out
Using the old two-of-three test
From FY2027 the test is €450m AND 1,000 employees (Art 19a(1)).
Starting from the datapoint list
EFRAG says it “must not be used as a checklist”.
Forgetting to state the FY2026 version
Article 2(2) of DR (EU) 2026/1563 requires it.
Reporting everything to be safe
Immaterial information “shall not” be disclosed (ESRS 1 ¶24).
Commissioning a survey because “the ESRS require it”
They do not (ESRS 1 AR 24); engagement carried out within due diligence is a key input (¶42).
Demanding full ESRS data from small suppliers
The cap lets protected suppliers decline (Art 19a(3)).
Planning for reasonable assurance
The path was deleted; the opinion is limited (Directive (EU) 2026/470).
Treating XBRL tagging as due
It is not yet mandatory (EFRAG, 17 September 2026).
Frequently asked
Questions people ask
What should a CSRD readiness checklist cover?
Six things in order: whether the undertaking is in scope and from when; which version of the ESRS it applies; its double materiality assessment; the disclosures that follow, including the phase-ins; its value-chain information; and its data, controls and assurance.
Each check should name the provision it comes from, so that the checklist can be tested rather than trusted.
Who is in scope of the CSRD from FY2027?
Undertakings that exceed both a net turnover of €450 million and an average of 1,000 employees, for financial years beginning on or after 1 January 2027, under Article 19a(1) of the Accounting Directive as amended by Omnibus I; parents test the group on a consolidated basis under Article 29a(1).
Both limbs must be exceeded.
Non-EU groups are reached separately under Article 40a from financial year 2028.
Can I use EFRAG’s datapoint list as a CSRD checklist?
No. EFRAG’s explanatory note to its 2026 Draft List of Datapoints says the list “must not be used as a checklist” and should be used “only in conjunction with the exercise of judgement underpinning materiality considerations”.
It lists every datapoint the ESRS define, and the note says none is reported irrespective of materiality.
Which version of the ESRS applies to my first report?
For a financial year starting in 2026 there are three choices: the 2023 ESRS as amended by Delegated Regulation (EU) 2025/1416; those standards with eight reliefs from the revised set; or the revised ESRS in full.
The undertaking must state which it used.
From financial years beginning on or after 1 January 2027 the revised ESRS apply.
Is a double materiality assessment the first step?
It comes after scope and version.
Once those are settled, the assessment decides which topical standards and sub-topics are reported; ESRS 2’s disclosures are “likely to result in material information for all undertakings” (ESRS 1 AR 12), and information that is not material shall not be disclosed, apart from supplementary information under section 8.2 of ESRS 1.
Do I have to report on climate?
Only if climate change relates to material impacts, risks or opportunities.
ESRS E1 applies on that condition.
If climate is judged not material, ESRS 2 IRO-2 requires the basis for that conclusion.
What does the CSRD assurance check involve?
A limited assurance opinion covers the sustainability reporting, its compliance with the ESRS, the process carried out to identify the information reported, and the Taxonomy Article 8 disclosures.
The reasonable-assurance path was deleted by Omnibus I, and the Commission must adopt limited-assurance standards by 1 July 2027.
Is XBRL tagging part of CSRD readiness?
Not yet as an obligation.
EFRAG says digital tagging of ESRS disclosures is not yet mandatory because the framework is still to be established by ESMA and the Commission.
Its draft taxonomy for the revised ESRS is out for consultation until 11 November 2026.
What phase-ins can a first-time reporter use?
The revised ESRS 1 ¶¶125–127 allow, among others, omission of anticipated financial effects for early years, with a carve-out for parts of ESRS E1-11, and omission of several ESRS S1 datapoints in the first year of reporting for undertakings outside wave one.
ESRS 1 ¶124 removes comparatives in the first year in specified cases.
Does a UK company need to be CSRD-ready?
Only if the CSRD reaches it: through an EU subsidiary or parent above the thresholds, an EU listing, or, from financial year 2028, Article 40a on its EU turnover.
UK law asks for none of this, and UK SRS uses single (financial) materiality.
Can our auditor help us prepare the sustainability statement?
For a public-interest entity, preparing sustainability reporting is a prohibited non-audit service for the statutory auditor under Article 5(1)(c) of Regulation (EU) No 537/2014.
Who may assure, and what other help is allowed, depends on national law and the firm’s independence rules.
Do suppliers have to answer our CSRD questionnaire?
No legal obligation arises from your CSRD reporting.
The value-chain cap protects undertakings with an average of 1,000 employees or fewer in the preceding financial year from requests beyond the voluntary standard’s capped datapoints, and the Commission says the cap imposes no obligation on companies in the value chain.
When must Member States transpose Omnibus I?
By 19 March 2027 for Articles 1 to 3 of Directive (EU) 2026/470.
National law then sets details such as assurance-provider options, so a readiness plan should be checked against the transposing law of the Member State concerned.
Is there official EFRAG guidance for the revised ESRS?
Not as at 11 October 2026.
EFRAG’s implementation guidance IG 1–3 relates to the 2023 ESRS and is non-authoritative; EFRAG’s guidance page lists none for the revised set.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 12 sources fromEUR-LexCouncil of the EUEFRAGEuropean Commission
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026 — Arts 19a(1), 19a(3), 19a(9), 29a(1), 34(1), 40a(1)
The scope test, the management report, the value-chain cap, the exemptions, the assurance opinion and the third-country route.
- EUR-LexDirective (EU) 2026/470 (Omnibus I) — recitals (5) and (12), Arts 1(3) and 5(1)
In force 18 March 2026; transposition by 19 March 2027; limited-assurance standards by 1 July 2027.
- EUR-LexDirective (EU) 2025/794 (“stop the clock”) — Art 1 and recital (3)
Moved the later waves to FY2027 and FY2028 before Omnibus I replaced them.
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — Arts 2–3; ESRS 1 Chapter 3 and ¶¶124–127; ESRS E1; ESRS S1
The revised ESRS: the FY2026 choice, the assessment, the phase-ins and the climate and own-workforce standards.
- EUR-LexCommission Delegated Regulation (EU) 2026/1560 — the voluntary standard, Art 3 and Annex II
The datapoints the value-chain cap is measured against.
- Council of the EUC(2026) 5010 final, Annex I — the revised ESRS as transmitted
ESRS 2 gains GOV-4 on internal controls over sustainability reporting.
- EFRAGESRS Knowledge Hub — ESRS 2 IRO-1, IRO-2 and SBM-3 (delegated-act text)
What the statement discloses about the assessment and its results.
- European CommissionFeedback on sustainability reporting standards: the value chain cap, 6 May 2026
The cap applies to information gathered for CSRD reporting and imposes no obligation on suppliers.
- EFRAG2026 Draft List of Datapoints and Draft XBRL Taxonomy — Explanatory Note, 28 August 2026
“It must not be used as a checklist.” Feedback by 23 October 2026.
- EFRAGDraft ESRS XBRL Taxonomy for the revised ESRS, 17 September 2026
Consultation to 11 November 2026; digital tagging is not yet mandatory.
- EFRAGESRS implementation guidance documents
IG 1–3 relate to the 2023 ESRS; none is listed for the revised ESRS as at 11 October 2026.
- EUR-LexRegulation (EU) No 537/2014, consolidated — Art 5(1)(c)
For a public-interest entity, preparing sustainability reporting is a prohibited non-audit service for the statutory auditor.
Continue reading
Read next
Scope
CSRD thresholds and scope checker
Run your figures against the FY2027 test and Article 40a.
Method
The double materiality assessment
The method behind phase 3, step by step.
Tools
Choosing CSRD software
What software must get right, and the questions to ask.
Assurance
Assurance under the CSRD
Limited assurance, who may provide it, and when.