The revised ESRS
Delegated Regulation (EU) 2026/1563 decides it for financial years from 1 January 2027.
The law.EU reporting · EFRAG’s guidance
EFRAG implementation guidance: what IG 1, IG 2 and IG 3 still tell you
EFRAG implementation guidance means three documents finalised on 31 May 2024: IG 1 on materiality assessment, IG 2 on the value chain and IG 3, a list of datapoints.
All three are non-authoritative and written for the 2023 ESRS, and as at 11 October 2026 EFRAG lists no guidance for the revised ESRS.
So use IG 1 for method, cite the revised ESRS 1 for the rule, and never cite an IG paragraph number against Delegated Regulation (EU) 2026/1563.
The three documents
IG 1, IG 2 and IG 3: what each one covers
EFRAG finalised the three documents on 31 May 2024, after issuing them in draft for public feedback on 22 December 2023.
EFRAG’s announcement says plainly: “These documents are non-authoritative and support implementation.”
Read EFRAG’s own descriptions
IG 1 “provides an illustrative materiality assessment process for undertakings, and it develops the concept of impact and financial materiality with a number of examples, including how these two concepts interplay”.
IG 2 “outlines the reporting requirements for the value chain from materiality assessment to policies and actions to metrics and targets”, and includes “a ‘value chain map’ summarising value chain implications per disclosure requirement across all ESRS”.
IG 3 “translates the complete ESRS Set 1 list of detailed requirements in each Disclosure Requirement and related Application Requirements in Excel format”, and EFRAG suggests it as the basis for a data gap analysis.
Feedback statements accompany each document, and EFRAG’s guidance page lists them with the drafts and the responses received.
EFRAG IG 1–3Explore
Module 01 / 04
IG 1
Materiality assessment: an illustrative process, impact and financial materiality, and FAQs.
Module 02 / 04
IG 2
Value chain: from the materiality assessment to policies, actions, metrics and targets, with a value-chain map.
Module 03 / 04
IG 3
Every detailed 2023 ESRS requirement in an Excel workbook, with its type and transitional status.
Status, as at 11 October 2026
Non-authoritative, and written for the 2023 ESRS
EFRAG’s guidance page says the guidance “relates to the ESRS adopted in 2023 as Commission Delegated Regulation (EU) 2023/2772”.
It adds that EFRAG “will not issue new or updated implementation guidance for the Draft Simplified ESRS released in December 2025 before their adoption by the European Commission”.
Read the status in detail
The Commission adopted the revised ESRS on 3 July 2026, and they were published in the Official Journal on 21 September 2026.
As at 11 October 2026 the guidance page lists no implementation guidance for the revised standards, and EFRAG’s Knowledge Hub said that no implementation guidance was yet available for them.
IG 1’s own disclaimer says it “is non-authoritative … does not form part of” the ESRS, and that if anything in it appears to contradict a requirement, the ESRS take precedence.
The practical rule follows: the guidance can explain an approach, but only the delegated regulation can settle a question.
A question about the ESRS
IG 1–3
May explain an approach; they relate to the 2023 ESRS and give way to the standards.
Non-authoritative.The guidance, by date
From draft guidance in 2023 to a revised ESRS with none yet
The guidance was built for one set of standards, and the standards have since been replaced.
The dates explain why a 2024 document cannot carry 2026 paragraph numbers.
- 31 July 202301
First ESRS adopted
Delegated Regulation (EU) 2023/2772, the text IG 1–3 were written for. - 22 December 202302
- 31 May 202403
- December 202404
- 3 December 202505
Simplified ESRS advice
EFRAG submits draft simplified ESRS; its guidance page says no updated guidance before Commission adoption. - 28 August 202606
Draft List of Datapoints
Support material for the revised ESRS; expressly not implementation guidance. - 21 September 202607
Revised ESRS published
Delegated Regulation (EU) 2026/1563 replaces the 2023 standards in full; applies from FY2027. - 11 October 202608
IG 1, materiality
What EFRAG IG 1 says about the materiality assessment
IG 1 says “the ESRS do not mandate a specific process or sequence of steps”, and offers four illustrative ones.
Its most-quoted point is ¶65: one assessment reflects both perspectives and their interconnections, without “two separate and independent processes”.
Read IG 1’s key points in its own words
¶65 in full: “The undertaking’s materiality assessment shall reflect both the impact and financial materiality perspectives, as well as interconnections between the two, but need not perform two separate and independent processes. The identification of material impacts is generally a starting point”.
Key point 11: “the GRI assessment constitutes a good basis for the assessment of impacts under the ESRS.”
Key point 12: an ESRS reporter “is expected to be able to comply with the identification of sustainability-related information on risks and opportunities under IFRS Sustainability Disclosure Standards”.
Source: EFRAG IG 1 Materiality Assessment Implementation Guidance (May 2024).
The revised standards now say much of this in the law itself, as the next section shows.
- 1
Understand the context
Activities, business relationships and stakeholders.
- 2
Identify
Actual and potential impacts, risks and opportunities.
- 3
Assess and determine
Which impacts, risks and opportunities are material.
- 4
Report
Disclose the process and the results.
Using IG 1 today
IG 1’s ideas, mapped to the revised ESRS 1
Most of what IG 1 explained is now written into Chapter 3 of the revised ESRS 1, and the law is the text to cite.
The table below pairs each IG 1 idea with the revised paragraph that now carries it.
Read the full mapping table
| IG 1 idea (May 2024) | Revised ESRS 1 (DR (EU) 2026/1563) | What changed |
|---|---|---|
| No mandated process; four illustrative steps | ¶25 two stages; ¶¶27–28 top-down or bottom-up; AR 10 combine; AR 20 three impact steps | A top-down route is now written into the standard |
| One assessment, both perspectives (¶65) | ¶35 two dimensions and how they interact; ¶36 impacts first | Same idea, now in the law |
| Severity and likelihood (2023 ESRS 1 ¶45) | ¶40 and ¶41; AR 22 any one factor makes an impact severe | Renumbered |
| Stakeholder engagement | ¶42; AR 23 categories; AR 24 no separate engagement process | Explicit relief from a separate process |
| Thresholds | ¶37; AR 13 qualitative may suffice; AR 19 | No numeric threshold in either |
| Mitigation and remediation | ¶43; AR 27 a policy alone is not considered | Gross and net now set out in the law |
| Value chain (IG 2) | ¶¶32–33: focus where impacts are likely; sector and regional data | Undue cost or effort written in |
| Datapoints (IG 3) | The 2026 Draft List of Datapoints | Support material, not guidance; not a checklist |
The method these paragraphs set out is worked through on the double materiality assessment, and the framework-neutral version on materiality assessment.
Method, not numberingExplore
Module 01 / 04
Process
IG 1: no mandated process. Revised ESRS 1 ¶25: two stages; ¶¶27–28 top-down or bottom-up.
Module 02 / 04
Both lenses
IG 1 ¶65: one assessment. Revised ¶35: consider how the dimensions interact; ¶36 start with impacts.
Module 03 / 04
Severity
Now revised ¶40 and AR 22: scale, scope, irremediable character; likelihood separate.
Module 04 / 04
Stakeholders
Revised ¶42 and AR 24: due-diligence engagement, no separate engagement process.
IG 2, value chain
Value-chain guidance, and the cap that came after it
IG 2 explained how far into the value chain a 2023 ESRS reporter had to look.
The revised ESRS 1 now writes the proportionality into the law: focus where material matters are likely, and use sector or regional data where direct input is unavailable.
Read the value-chain detail
Under ¶32 the undertaking uses reasonable and supportable information available without undue cost or effort and “is not required to assess every possible impact, risk or opportunity”.
Under ¶33 it may assess the value chain “without direct input from value chain actors”.
Smaller suppliers are also protected by the value-chain cap, set out on the voluntary standard for suppliers page.
Value chain then and nowExplore
Module 01 / 04
IG 2 (2024)
Value-chain reporting from materiality to metrics, with a value-chain map.
Module 02 / 04
¶32
Focus where material impacts, risks or opportunities are likely; no need to assess every possibility.
Module 03 / 04
¶33
Average regional data, sector data or generally available information may stand in.
Module 04 / 04
Suppliers
The value-chain cap limits what a reporter may require of smaller undertakings.
IG 3, datapoints
IG 3 and the 2026 draft list: not the same kind of document
IG 3 was implementation guidance; its successor for the revised ESRS is something else.
EFRAG’s explanatory note says the 2026 Draft List of Datapoints “does not constitute implementation guidance” and “must not be used as a checklist”.
Read about the 2026 draft list
The note says the final list will be published as EFRAG Secretariat supporting material “rather than official implementation guidance”.
Its own count, the definition behind it and the feedback deadline are on ESRS datapoints.
The machine-readable version is the draft ESRS XBRL taxonomy.
Two datapoint listsExplore
Module 01 / 04
IG 3 (2024)
Implementation guidance listing every 2023 ESRS requirement.
Module 02 / 04
2026 draft list
Support material for the revised ESRS: “does not constitute implementation guidance”.
Module 04 / 04
Feedback
Fatal-flaw survey closes 23 October 2026, as at 11 October 2026.
ESRS Q&A and the Knowledge Hub
The other EFRAG tools beside the guidance
EFRAG also runs an ESRS Q&A Platform and an ESRS Knowledge Hub, both listed on its sustainability reporting pages.
The Knowledge Hub is the most useful companion to IG 1 today, because it links each revised paragraph to the 2023 paragraph it replaced.
Read how to treat these tools
Like the implementation guidance, the Q&A answers and the Hub explain the standards; the delegated regulation is the text that decides a question.
Check any answer against the version of the ESRS you apply, because a 2024 answer may cite 2023 paragraph numbers.
EFRAG’s support toolsExplore
Module 01 / 04
Q&A Platform
EFRAG’s ESRS Q&A Platform, listed on its sustainability reporting pages.
Module 02 / 04
Knowledge Hub
The revised ESRS interactively, with links to the 2023 paragraphs and amendment logs.
Module 03 / 04
Datapoint list
Draft support material for the revised ESRS, not guidance.
GRI and the ISSB
What the guidance says about GRI and the ISSB
IG 1 points both ways: to GRI for the impact half and to the ISSB for the financial half.
Both relationships are documented elsewhere by EFRAG with its partners, and all of those documents describe the 2023 ESRS.
Read the detail and its limits
The GRI–ESRS Interoperability Index says an ESRS reporter can be considered to report “with reference” to the GRI Standards, and that the index does not imply compliance with the ESRS by reporting in accordance with GRI.
GRI’s own test is in GRI 3, and the comparison is on the GRI Standards page.
The ISSB side is on ESRS and ISSB interoperability.
Two neighboursExplore
Module 01 / 04
GRI
IG 1: a GRI impact assessment is “a good basis” for ESRS impacts.
Module 02 / 04
GRI statement
The ESRS adopted the same definition of impact materiality as GRI.
Module 03 / 04
ISSB
IG 1: an ESRS reporter should be able to meet the ISSB identification of risks and opportunities.
Module 04 / 04
Interoperability
Financial-materiality definitions aligned; the regimes differ.
Doing it
Using EFRAG implementation guidance with the revised ESRS
This sequence is an illustration of one sensible way to use the 2024 guidance now; it is not a procedure EFRAG prescribes.
- 01 / Version01
Confirm which ESRS apply
For FY2026 there is a choice; from FY2027 the revised ESRS apply. - 02 / Rule02
Read the revised ESRS 1 first
Chapter 3 sets the assessment; cite its paragraphs. - 03 / Method03
Borrow IG 1’s approach
Its illustrative steps and examples, where they do not conflict with the law. - 04 / Translate04
Translate any IG reference
Use the Knowledge Hub links from revised to 2023 paragraphs. - 05 / Record05
Record which text you relied on
The assurance opinion covers the process, so the evidence file should name it.
Read the reasons for each step
The FY2026 options are the 2023 ESRS as amended, those standards with eight reliefs, or the revised ESRS in full, and the statement must say which.
IG 1 maps the 2023 numbering, so a reference such as “ESRS 1 ¶45” for severity is now ¶40 in the revised text.
Who runs EFRAG and what else it is consulting on is on EFRAG.
If you remember one thing
IG 1 is a good teacher and a poor citation: use its method, and cite the revised ESRS 1.
For a UK company
When a UK company needs EFRAG’s guidance at all
EFRAG has no authority in the UK, and its guidance matters to a UK company only where the CSRD reaches its group or a customer asks for ESRS data.
A UK listed company reports under UK SRS, whose single (financial) materiality is explained on financial materiality.
Read where to go next
The two lenses are compared on double materiality, and all of the materiality guides are listed on materiality explained.
What the ESRS ask as a whole is on the ESRS page.
UK situationsExplore
Module 01 / 04
EU subsidiary in scope
The subsidiary applies the ESRS and may use IG 1 for method.
Module 02 / 04
Asked by an EU customer
Check the value-chain cap before doing ESRS-style work.
Frequently asked
Questions people ask
What is EFRAG implementation guidance?
It is three documents EFRAG finalised on 31 May 2024: IG 1 on materiality assessment, IG 2 on the value chain and IG 3, a list of ESRS datapoints.
EFRAG describes them as non-authoritative support for implementing the ESRS adopted in 2023.
Is EFRAG IG 1 binding?
No. IG 1 says it is non-authoritative, does not form part of the ESRS, and that where anything in it appears to contradict a requirement the ESRS take precedence.
Does IG 1 apply to the revised ESRS?
It was written for the ESRS adopted on 31 July 2023, and its paragraph references are to that text.
The revised ESRS in Delegated Regulation (EU) 2026/1563 replaced the standards in full, so IG 1 can still help with method but should not be cited for paragraph numbers.
Has EFRAG published implementation guidance for the revised ESRS?
Not as at 11 October 2026.
EFRAG said it would not issue new or updated implementation guidance for the draft simplified ESRS before the Commission adopted them, and its guidance page lists none for the revised standards.
What does EFRAG IG 1 say about the materiality process?
That “the ESRS do not mandate a specific process or sequence of steps”, and it illustrates four: understanding the context, identifying actual and potential impacts, risks and opportunities, assessing and determining the material ones, and reporting.
Does IG 1 require two separate assessments for impact and financial materiality?
No. IG 1 ¶65 says the assessment shall reflect both perspectives and their interconnections “but need not perform two separate and independent processes”, and that identifying material impacts is generally a starting point.
What is EFRAG IG 2?
IG 2 is the value-chain implementation guidance.
EFRAG says it outlines the value-chain reporting requirements from the materiality assessment to policies, actions, metrics and targets, and includes a value-chain map by disclosure requirement. It is written for the 2023 ESRS.
What is EFRAG IG 3?
IG 3 is an Excel list of every detailed requirement in the 2023 ESRS, with information such as the type of requirement and whether it is subject to transitional provisions.
A technical addendum followed in December 2024.
For the revised ESRS EFRAG has published a separate 2026 Draft List of Datapoints, which it says is not implementation guidance.
Can I use the 2026 Draft List of Datapoints as a checklist?
No. EFRAG’s explanatory note says the list “does not constitute implementation guidance” and “must not be used as a checklist”; it should be used only after reaching conclusions on materiality.
What does IG 1 say about GRI?
Its key points say that a GRI impact assessment “constitutes a good basis for the assessment of impacts under the ESRS”.
The EFRAG–GRI joint statement says the ESRS adopted the same definition of impact materiality as GRI.
What does IG 1 say about the ISSB?
Its key points say an ESRS reporter “is expected to be able to comply with the identification of sustainability-related information on risks and opportunities under IFRS Sustainability Disclosure Standards”.
The joint interoperability guidance says the financial-materiality definitions are aligned.
Where do I find the 2023 paragraph a revised ESRS paragraph replaced?
EFRAG’s ESRS Knowledge Hub serves the revised ESRS with links to the corresponding paragraphs in the 2023 ESRS and detailed amendment logs, which is the practical way to translate an IG 1 reference.
What is the ESRS Q&A Platform?
EFRAG runs an ESRS Q&A Platform, listed on its sustainability reporting pages.
As with the implementation guidance, the delegated regulation is the text that decides a question; check any answer against it and against the version of the ESRS you apply.
Does a UK company need EFRAG guidance?
Only if the CSRD reaches its group or a customer asks it for ESRS data.
UK SRS has its own sources of guidance, and EFRAG has no authority in the UK.
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 14 sources fromEFRAGEUR-LexIFRS Foundation / EFRAGGRI / EFRAGGlobal Reporting Initiative
- EFRAGESRS implementation guidance documents — project page
IG 1–3 relate to the 2023 ESRS; no updated guidance for the simplified ESRS before Commission adoption.
- EFRAGNews, 31 May 2024 — finalisation of IG 1 to IG 3
“These documents are non-authoritative and support implementation.”
- EFRAGIG 1 Materiality Assessment Implementation Guidance (May 2024)
Four illustrative steps; ¶65, one assessment covering both perspectives.
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — revised ESRS 1, Chapter 3
The law IG 1 has to be read against from FY2027.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 — the 2023 ESRS
The standards IG 1–3 were written for.
- EFRAGESRS Knowledge Hub
The revised ESRS with links to the corresponding 2023 paragraphs.
- EFRAGSustainability reporting
Where EFRAG lists its ESRS work, the Q&A Platform and the Knowledge Hub.
- EFRAGExplanatory Note — 2026 Draft List of Datapoints
“does not constitute implementation guidance”; “must not be used as a checklist”.
- EFRAGNews, 28 August 2026 — 2026 Draft List of Datapoints
Feedback by 23 October 2026; final list expected by the end of 2026.
- EFRAGNews, 3 December 2025 — technical advice on draft simplified ESRS
The simplified standards IG 1–3 were not updated for.
- IFRS Foundation / EFRAGESRS–ISSB Standards Interoperability Guidance, 2 May 2024
Financial-materiality definitions aligned; maps the 2023 ESRS.
- GRI / EFRAGEFRAG–GRI Joint Statement of Interoperability (2023)
The same definition of impact materiality.
- GRI / EFRAGGRI–ESRS Interoperability Index, V1, 22 November 2024
Non-authoritative; mapped to the 2023 ESRS.
- Global Reporting InitiativeGRI 3: Material Topics 2021
The impact assessment IG 1 calls “a good basis”.
Continue reading
Read next
The adviser
EFRAG
What it is, who runs it as at 11 October 2026, and what it decides.
The method
The double materiality assessment
The revised ESRS method, step by step.
Datapoints
ESRS datapoints
The 2026 draft list, its count and what it is not.
The impact lens
Impact materiality
Severity, likelihood and the four kinds of impact.