EU reporting · the standards, read from the UK
ESRS: the European Sustainability Reporting Standards, read from the UK
The ESRS, the European Sustainability Reporting Standards, are the twelve standards a company in scope of the EU’s Corporate Sustainability Reporting Directive writes its sustainability statement to.
The set that now governs them is Delegated Regulation (EU) 2026/1563, published on 21 September 2026 and applying to financial years beginning on or after 1 January 2027.
For a UK group the question is not whether the ESRS are UK law — they are not — but which of its EU entities, listings or customers bring them in, and on which year.
Before the twelve standards
Which ESRS rules should this report use?
Answer entity scope, reporting year and material information separately before choosing disclosures from the European Sustainability Reporting Standards.
| Decision | Record for the reporting file | Detailed answer |
|---|---|---|
| Is the entity or group within a reporting route? | The legal reporting entity and the applicable CSRD route; ESRS does not replace that scope assessment. | CSRD population and UK groups |
| Which financial year and version? | The financial-year start and the permitted version applied, with the statement required for a 2026-year choice. | Revision, application dates and options |
| Which matters and information are material? | The double-materiality assessment and the basis for selecting the information disclosed. | Materiality within the standards |
| Which topic-specific requirements follow? | The relevant topical standards alongside the cross-cutting requirements. | The twelve-standard structure |
For climate-specific questions, continue to ESRS E1; for the separate non-EU group route and draft standards, use Article 40a and ESRS-40a.
The standards
Twelve standards, two of them cross-cutting
EFRAG writes the standards as technical advice to the European Commission, and the Commission adopts them as a delegated regulation under Article 29b of the Accounting Directive.
Read the provisions and qualifications
The first set is Delegated Regulation (EU) 2023/2772, whose Annex I carries ESRS 1, ESRS 2 and the ten topical standards.
The 2026 revision replaced that Annex in full, so paragraph numbers do not carry over, but the twelve standards and their names are unchanged.
ESRS 1 sets the rules every reporter applies, ESRS 2’s disclosures are “likely to result in material information for all undertakings”, and a topical standard is reported only where the materiality assessment finds material impacts, risks or opportunities on its topic.
That assessment is a double materiality test: impacts on people and the environment, and financial effects on the undertaking, with either enough to make a matter material.
It is the single largest difference from the UK’s own standards, which apply financial materiality only; UK SRS S1 and S2 sets out what the UK standards ask.
ESRS architecture
Standard setter
ESRS architecture
First set
ESRS architecture
Revision
ESRS architecture
Materiality
Tables and tools
Standard by standard
The twelve ESRS after the 2026 revision
Titles as they appear in the Annex to Delegated Regulation (EU) 2026/1563.
Under the revised ESRS 1 ¶24 a company shall not disclose a datapoint that is not material.
| Standard | Title | What it covers | Reported |
|---|---|---|---|
| ESRS 1 | General Requirements | The rulebook: double materiality, the value chain, reliefs and presentation. Prescribes no datapoints of its own. | Always: the rules |
| ESRS 2 | General Disclosures | Basis of preparation, governance, strategy and the management of impacts, risks and opportunities; the minimum content for policies, actions, metrics and targets. | Likely material for all (ESRS 1 AR 12) |
| ESRS E1 | Climate Change | Mitigation, adaptation and energy, including the transition plan and Scope 1, 2 and 3 emissions. | Where material |
| ESRS E2 | Pollution | Pollution of air, water and soil, and substances of concern. | Where material |
| ESRS E3 | Water | Water withdrawal, consumption and discharge. | Where material |
| ESRS E4 | Biodiversity and Ecosystems | Impacts on and dependencies of biodiversity and ecosystems. | Where material |
| ESRS E5 | Resource Use and Circular Economy | Resource inflows and outflows, including waste. | Where material |
| ESRS S1 | Own Workforce | The undertaking’s own employees and non-employee workers. | Where material |
| ESRS S2 | Workers in the Value Chain | Workers at suppliers and elsewhere in the value chain. | Where material |
| ESRS S3 | Affected Communities | Communities affected by operations and the value chain. | Where material |
| ESRS S4 | Consumers and End-users | The people who buy and use the products and services. | Where material |
| ESRS G1 | Business Conduct | Corporate culture, supplier relationships and payment practices, and political engagement. | Where material |
No sector standards
Omnibus I deleted the Commission’s power to adopt sector-specific ESRS, so there will be no thirteenth standard for an industry.
Directive (EU) 2026/470 leaves only the possibility of non-binding sector guidance.
Anticipated financial effects
The revision removed the anticipated-financial-effects requirements from E2 to E5.
What remains is the general requirement in ESRS 2 and E1-11 for climate, so a citation to “E4-6” or “E5-6” names a paragraph that no longer exists.
The cross-cutting pair
ESRS 1 and ESRS 2: the rulebook and the general disclosures
The two cross-cutting standards do different jobs, and the difference explains the whole set.
Read the provisions and qualifications
ESRS 1, General Requirements, is the rulebook: it sets the double materiality principle, the value-chain boundary, how the statement is presented and the reliefs and phase-ins.
It prescribes no datapoints of its own, and the revised version applies “in conjunction with ESRS 2 General Disclosures (both referred to as ‘cross-cutting standards’) and with the topical standards”.
ESRS 2, General Disclosures, is the part almost every reporter writes, because the revised ESRS 1 says its disclosure requirements are “likely to result in material information for all undertakings” (AR 12).
It opens with the basis of preparation, including a statement that the sustainability statement has been prepared in accordance with the ESRS, and then covers governance, strategy and the management of impacts, risks and opportunities.
Its IRO-1 disclosure describes the materiality process itself, and the revised text tells the undertaking to avoid “boilerplate” that merely says it applied ESRS 1.
IRO-2 then lists what was found material and which disclosure requirements were met, and where climate is judged not material it requires “the basis for concluding that climate change is not material”.
The general disclosure requirements, GDR-P, GDR-A, GDR-M and GDR-T, replaced the old minimum disclosure requirements, and they frame every topical section: if there is no policy, action or target for a material topic, the undertaking says so.
Two additions a 2023-trained preparer will meet early are GOV-4 on internal controls over sustainability reporting and BP-2 on the phasing-in options used.
General standards
ESRS 1
General standards
ESRS 2
General standards
IRO-1
General standards
GDR-P, A, M, T
Tables and tools
| ESRS 2 | What it asks for |
|---|---|
| BP-1, BP-2 | Basis of preparation; the phasing-in options used, if any |
| GOV-1 to GOV-4 | The board’s role and expertise; sustainability-linked pay, if any; where due diligence shows; internal controls over sustainability reporting |
| SBM-1 to SBM-3 | Strategy, business model and value chain; stakeholders’ views; how material matters interact with strategy, and their financial effects |
| IRO-1, IRO-2 | The materiality process; the material impacts, risks and opportunities and the list of disclosure requirements met |
| GDR-P, A, M, T | The minimum content for any policy, action, metric or target on a material topic |
Which ESRS are mandatory?
ESRS 1 always, the rest through the materiality filter
“Which ESRS are mandatory” has a two-part answer.
Read the provisions and qualifications
ESRS 1 sets the rules for every undertaking in scope, and ESRS 2’s disclosures are “likely to result in material information for all undertakings” (ESRS 1 AR 12).
EFRAG’s draft datapoint note goes further: the revised ESRS “have no mandatory datapoints that are to be reported irrespective of materiality assessment” (¶68), and its datapoint count explains what it does and does not measure.
A topical standard becomes mandatory for a company only when its double materiality assessment finds material impacts, risks or opportunities on that topic, and then only for the material sub-topics.
Everything else is not merely optional: under the revised ESRS 1 ¶24 information that is not material “shall not” be disclosed.
Climate is treated with extra care: a company that omits ESRS E1 must explain in IRO-2 why it concluded climate change is not material.
The builder beside this text turns a list of material topics into a draft contents page for the statement, with the ESRS 2 disclosures most reporters make and the topical sections that follow from your choices.
The assessment that decides the list is explained on how to run a double materiality assessment.
After climate, own workforce is the topic most often found material, and ESRS S1, own workforce goes through its sixteen disclosure requirements.
Material information
ESRS 2
Material information
Topical standards
Material information
Not material
Tables and tools
Draft the contents of an ESRS statement
Tick the topics your double materiality assessment found material.
1 · General information — ESRS 2, always
- BP-1 — Basis for preparation: consolidated or individual, the value-chain coverage, a statement that the report follows the ESRS, and any relief or option used.
- BP-2 — Only if you use a phasing-in option: whether the omitted topics were assessed material, and a brief description of them if so.
- GOV-1 — The role, composition, expertise and responsibilities of the administrative, management and supervisory bodies.
- GOV-2 — Only if incentive schemes are linked to sustainability topics: how remuneration is linked.
- GOV-3 — Where the due diligence steps are reflected in the statement.
- GOV-4 — Risk management and internal controls over sustainability reporting.
- SBM-1 — Strategy, business model and value chain.
- SBM-2 — Interests and views of stakeholders.
- SBM-3 — How material impacts, risks and opportunities interact with strategy and business model, and their financial effects.
- IRO-1 — The process used to identify and assess material impacts, risks and opportunities — specific to you, not boilerplate.
- IRO-2 — The material impacts, risks and opportunities, the list of disclosure requirements complied with, and the table of datapoints from other EU law.
2 · Topical sections — 2 of 10
- ESRS E1 Climate Change — E1-1 to E1-11 for the material sub-topics: the transition plan (or a statement that there is none), risks and resilience, policies, actions, targets (gross), energy, gross Scope 1, 2 and 3, and anticipated financial effects. Policies, actions, metrics and targets follow GDR-P, GDR-A, GDR-M and GDR-T; where there is no policy, action or target, say so.
- ESRS S1 Own Workforce — its disclosure requirements for the material sub-topics only. Policies, actions, metrics and targets follow GDR-P, GDR-A, GDR-M and GDR-T; where there is no policy, action or target, say so.
3 · Taxonomy
The Article 8 Taxonomy disclosures, inside the same assurance opinion (they may sit in a separate appendix).
Not reported: ESRS E2, ESRS E3, ESRS E4, ESRS E5, ESRS S2, ESRS S3, ESRS S4, ESRS G1.
Information on a topic that is not material shall not be disclosed.
Rules: revised ESRS 2 BP-1 to IRO-2, ¶¶37–40 (Delegated Regulation (EU) 2026/1563, as rendered in EFRAG’s Knowledge Hub); revised ESRS 1 ¶24; Directive 2013/34/EU Art 34(1).
A drafting aid, not a determination of what your company must report.
Nothing is stored or sent.
Inside the assessment
How the ESRS decide what is material
The revised ESRS 1 Chapter 3 is where the twelve standards are filtered down to a company’s own list.
A matter is material on the impact lens, the financial lens or both, and in general the impact assessment comes first.
Read the assessment rules
Severity is judged on scale, scope and irremediable character, and for a potential human rights impact severity takes precedence over likelihood.
The revised ESRS require no stakeholder survey and no materiality matrix, and they set no universal numeric threshold, as the materiality matrix and materiality thresholds explain.
What the assessment produces is a list of impacts, risks and opportunities, which ESRS 2 IRO-1 and IRO-2 then disclose.
The results of engagement with affected stakeholders, carried out within ongoing due diligence, are a key input, and stakeholder engagement for the assessment sets out what that does and does not require.
The UK’s single (financial) materiality is set beside the ESRS test on single against double materiality.
Double materiality
Two lenses
Double materiality
Impacts first
Double materiality
Severity
Double materiality
No survey
Delegated Regulation (EU) 2026/1563
The revision: four dates, not one
The Commission adopted the revised standards on 3 July 2026, and the Official Journal published them on 21 September 2026 as Delegated Regulation (EU) 2026/1563.
Its Article 3 sets entry into force on 10 November 2026 and application to financial years beginning on or after 1 January 2027.
A company whose financial year starts on 1 April applies the revised ESRS first to the year beginning 1 April 2027.
For financial years that start during 2026, Article 2 offers three routes, and Article 2(2) requires the sustainability statement to “clearly state” which one was used.
1. The 2023 ESRS as last amended by Delegated Regulation (EU) 2025/1416.
2. The revised ESRS in full, a year early.
3. The 2023 ESRS plus eight reliefs from the revised ESRS 1: the top-down materiality approach (¶27), undue cost or effort and the value-chain limitation (¶¶32–33), acquisitions and disposals (¶¶74–75), metrics for non-significant activities (¶90), partial value-chain scope (¶91), joint operations (¶92), Taxonomy disclosures in a separate appendix (¶106) and an executive summary (¶110).
The Commission’s adoption announcement says the revised standards cut mandatory datapoints by over 60% and total datapoints by more than 70%, and expects costs to fall by over 30% per company.
The 61% often quoted beside it is EFRAG’s measure of its own draft, before the Commission made thirteen categories of change, and the total cut is larger because every voluntary “may” datapoint was deleted.
No absolute datapoint count has a Commission source, which is why none appears here; the news note on the adoption records the day itself.
- 26 Feb 2025Omnibus I proposed
The Commission’s simplification package.
- 18 Mar 2026Omnibus I Directive in force
Scope raised to more than €450m and 1,000 employees.
- 3 Jul 2026Revised ESRS adopted
C(2026) 5010, with the voluntary standard, C(2026) 5011.
- 21 Sep 2026Published in the Official Journal
As DR (EU) 2026/1563 and DR (EU) 2026/1560.
- 24 Sep 2026Voluntary standard in force
The third day after publication.
- 10 Nov 2026Revised ESRS in force
Law from this date; nothing yet required by it.
- 1 Jan 2027Revised ESRS apply
Financial years beginning on or after this date; first reports 2028.
How the ESRS were made
From draft Set 1 to the revised standards
The ESRS went through two full cycles of EFRAG advice and Commission adoption in four years.
- November 202201
- 31 July 202302
First ESRS adopted
Delegated Regulation (EU) 2023/2772, published in the Official Journal on 22 December 2023. - 31 May 202403
IG 1–3 finalised
Non-authoritative implementation guidance on materiality, the value chain and datapoints. - End of March 202504
- 29 July 202505
- 3 December 202506
EFRAG’s advice submitted
Approved by EFRAG’s Sustainability Reporting Board on 28 November 2025. - 3 July 202607
Commission adoption
The revised ESRS, with thirteen categories of change to EFRAG’s advice. - 21 September 202608
Published
Delegated Regulation (EU) 2026/1563; in force 10 November 2026; applies to FY2027.
EFRAG advises and the Commission adopts, a division of labour set out on EFRAG’s role and governance.
Who is left
The population the revised ESRS will govern
Figures from the Commission’s staff working document, which counts only companies that remain in scope after Omnibus I.
The same document estimates savings of €2.24 billion a year from 2029 from the revised standards, and about €4.4 billion from the scope reduction; the two measure different things and are never added.
It also puts the Omnibus I scope change at removing about 85% of the companies originally in scope.
Wave 2 is the group a UK reader most often belongs to: large EU undertakings that never reported under the 2023 standards and will start on the revised set.
Omnibus I, recital 31, limits the first wave’s obligation to three financial years from 1 January 2024 and applies the second-wave rule to every in-scope undertaking for financial years starting on or after 1 January 2027.
A first-wave company below the new thresholds therefore falls out from 2027, and a Member State may exempt it for 2025 and 2026 as well; CSRD after Omnibus I sets the old and new scope side by side.
CSRD population
Remaining
CSRD population
Savings
UK groups
Which UK groups report under the ESRS, and when
The ESRS reach a UK company through its EU footprint, not its registered office.
Read the provisions and qualifications
An EU subsidiary, or an EU parent group reporting on a consolidated basis, is in scope where it exceeds both €450 million of net turnover and an average of 1,000 employees, under Articles 19a and 29a of the Accounting Directive.
For those undertakings the revised ESRS govern their first or next report for financial years starting on or after 1 January 2027, subject to their Member State’s transposition of Omnibus I by 19 March 2027.
A UK issuer with securities on an EU regulated market is tested on the same pair and reports on its own behalf.
A UK parent with no reporting EU entity can still be reached on EU turnover alone, under Article 40a, from financial year 2028 — the next section.
And far more UK companies meet the ESRS as suppliers, through questionnaires from EU customers, which the value-chain cap limits.
Our guide to whether CSRD applies to a UK company works through the four routes, and the CSRD reporting requirements for UK groups page sets out what an in-scope entity must produce.
The CSRD explainer covers the Directive itself.
An entity’s figures can be run against the test with the checker on CSRD thresholds, and the order of work for a first report is on the CSRD readiness checklist.
UK and EU
EU subsidiary
UK and EU
EU listing
UK and EU
Article 40a
Tables and tools
CSRD · which route are you in?
Pick the position that fits.
A UK group can stand in more than one: test each EU subsidiary on its own figures and the whole group under Article 40a.
Rules: Directive 2013/34/EU Arts 19a, 29a and 40a and Directive (EU) 2022/2464 Art 5, as amended by Directive (EU) 2026/470.
“Exceed” is strict and both limbs are needed.
Nothing you enter leaves your browser.
A provisional reading, not advice on your group perimeter.
Article 40a · ESRS-40a
Non-EU groups: a separate test and a separate standard
Article 40a of the Accounting Directive reaches a non-EU group directly, and a UK parent is a non-EU parent for this purpose.
The trigger is EU turnover, twice over, with no employee count at all, so a lean UK group can be caught where a larger EU competitor is not.
The obligation sits on an EU subsidiary or branch, which publishes a report about the whole group.
That report will not be written to the ESRS described on this page but to ESRS-40a, a separate standard EFRAG published as an exposure draft on 23 July 2026, with consultation open until 31 October 2026.
ESRS-40a keeps the twelve-standard shape but reports impacts only, dropping the financial side of double materiality.
The test, the draft and the timetable are worked through on ESRS-40a and the €450m/€200m test.
| Articles 19a / 29a | Article 40a | |
|---|---|---|
| Who | EU undertakings and EU parent groups | Non-EU groups with large EU turnover |
| Turnover | Above €450m net turnover | Above €450m of EU net turnover in each of the last two years |
| Employees | Average above 1,000 | No employee test |
| EU foothold | — | EU subsidiary, or failing that a branch, above €200m |
| Standard | Revised ESRS | ESRS-40a, still a draft |
| First year | FY2027 for Wave 2 | FY2028, published 2029 |
Your route, your order of work
Three routes into the ESRS, three different first jobs
The route decides who does the work and what comes first.
It is set by the group’s EU footprint, not by where the UK company is registered.
| Route | Who reports | First job | Then |
|---|---|---|---|
| Direct scope: an EU subsidiary or EU parent group above €450m and 1,000 employees, or an EU-listed issuer | The EU undertaking or issuer, in its management report | Decide the FY2026 version, or plan FY2027 on the revised ESRS | Run the double materiality assessment; build ESRS 2; book the limited-assurance conversation |
| Third-country: a non-EU group under Article 40a | The EU subsidiary or branch, publishing a report on the whole group | Produce EU-generated net turnover for 2026 and 2027 | Track ESRS-40a, still a draft, which reports impacts only |
| Value chain: a supplier to an in-scope EU customer | Nobody: there is no filing | Establish whether you are a protected undertaking | Answer within the voluntary standard; decline what exceeds the cap if you are protected |
A UK group can stand on more than one route at once, and the common combination is direct scope for one large EU subsidiary plus value-chain requests to its UK trading companies.
On the direct route the work belongs to the EU entity and its auditor, so the UK parent’s job is to supply group data, controls and evidence on the EU entity’s timetable.
On the third-country route the order is reversed: the UK head office writes the report and an EU entity puts its name to it.
On the value-chain route the first job is a short self-declaration of size, because the customer may rely on it without verifying it unless it is manifestly incorrect.
The route finder above runs the thresholds on your own figures; the four routes into CSRD are worked through in full on the scoping page.
The climate standard
ESRS E1, against UK SRS S2
E1 is where the ESRS overlap most with UK SRS S2.
Wording from the revised text as rendered in EFRAG’s Knowledge Hub edition of the delegated act.
| Topic | ESRS E1 (revised) | UK SRS S2 |
|---|---|---|
| Transition plan | Disclose the plan; if there is none, say so and indicate whether and, if so, when one is expected. | Information about any climate-related transition plan the entity has; no duty to have one. |
| Targets | Greenhouse gas reduction targets are gross: removals, carbon credits and avoided emissions may not be counted towards them. | Targets disclosed as set, with any planned use of carbon credits described. |
| Scope 2 | Both location-based and market-based figures. | Location-based required; market-based permitted. |
| Scope 3 | Gross Scope 3 where material. | Required, with a one-year relief under the FCA’s rules. |
| GHG boundary | Financial control or operational control approach, at the undertaking’s choice. | The GHG Protocol approach the entity chooses. |
| Anticipated financial effects | E1-11, with a phase-in under ESRS 1 ¶125. | Current and anticipated financial effects, within the strategy disclosures. |
The Scope 2 row is the one that changes the numbers: a UK group reporting under both has to produce a market-based figure for ESRS even where UK SRS S2 does not ask for it; the Scope 2 guide explains the two methods.
On targets, the gross rule means a science-based target met partly with credits is reported without them.
On the boundary, the Commission changed EFRAG’s advice to give undertakings “the flexibility to use either the financial control approach or the operational control approach”.
On anticipated financial effects, ESRS 1 ¶125 lets undertakings above €450m and 1,000 employees omit that information for financial years before 2028 and the quantitative part before 2030 — except for E1-11 ¶¶39(a)(b) and 40(a)(b), which are not deferred.
A group that already reports under SECR has an emissions inventory to start from, but test it against E1’s demands on Scope 3 categories and both Scope 2 methods before relying on it.
For the plan itself, our guide to climate transition plans covers what each regime asks, and TCFD explains the four-pillar architecture both standards inherit.
Climate comparison
Scope 2
Climate comparison
Targets
Climate comparison
Boundary
Climate comparison
Financial effects
ESRS E1, requirement by requirement
What the climate standard asks for, in its own order
The disclosure requirements of the revised ESRS E1, as the delegated act is rendered in EFRAG’s Knowledge Hub.
Its sub-topics are climate change mitigation, climate change adaptation and energy.
| Requirement | What is disclosed | The detail that catches people |
|---|---|---|
| E1-1 Transition plan for climate change mitigation | Key features: targets, decarbonisation levers, key actions, investment and funding, approval by the board, and how the business model is or will be compatible with 1.5°C and EU climate neutrality by 2050; CapEx on coal, oil and gas activities; assumptions and dependencies; locked-in emissions; progress | No plan with those features? Disclose that fact and indicate whether and, if so, when you expect to adopt one |
| E1-2 Climate-related risks and scenario analysis | Whether each material climate risk is physical or transition, and the methodology for assessing exposure over the short, medium and long term | Scenario analysis is not compulsory; if used, say whether at least one high-emission scenario and one 1.5°C scenario were among those run |
| E1-3 Resilience | The results of the resilience analysis, the areas of uncertainty, and the capacity to adapt strategy and business model | Not required annually; updated when the risk assessment is updated |
| E1-4 and E1-5 Policies; actions and resources | Mitigation and adaptation policies under GDR-P; key actions by decarbonisation lever, with achieved and expected reductions | Actions are reported by lever, not as a single list |
| E1-6 Targets | Absolute GHG reduction targets for Scopes 1, 2 and 3, and whether they are science-based and compatible with 1.5°C | Targets are gross: removals, carbon credits and avoided emissions are not counted towards them; a net-zero target must explain how residual emissions will be neutralised |
| E1-7 Energy consumption and mix | Total energy consumption in MWh, split between fossil, nuclear and renewable sources | Undertakings in high climate impact sectors split fossil consumption further, by fuel |
| E1-8 Gross Scope 1, 2 and 3 | Scope 1 with its EU ETS share; Scope 2 location-based and market-based; Scope 3 for each significant category | Both Scope 2 methods are required; biogenic CO₂ from biomass is reported separately from Scope 1 |
| E1-11 Anticipated financial effects | Effects from material physical and transition risks and climate opportunities | Phased in under ESRS 1 ¶125, except E1-11 ¶¶39(a)(b) and 40(a)(b) |
Three rows change what a UK group already reporting under UK SRS S2 must add.
The transition plan row: E1 asks for the plan or a statement that there is none, with an expected date, where the FCA asks a listed company whether it has a plan and where to find it.
The targets row: a target the group meets partly through credits has to be restated gross for the ESRS.
The emissions row: a market-based Scope 2 figure, and Scope 3 by each significant category, are both required.
E1 also fixes its relationship with the other topical standards: it covers the seven greenhouse gases, while nitrogen oxides, sulphur oxides and ozone-depleting substances belong to ESRS E2, and the human side of the transition belongs to the social standards.
Delegated Regulation (EU) 2026/1560
The voluntary standard and the value-chain cap
The second act adopted on 3 July 2026 is not an ESRS; it is a standard for voluntary use by smaller undertakings, built on the Commission’s VSME recommendation.
Read the provisions and qualifications
It was published as Delegated Regulation (EU) 2026/1560 and entered into force on 24 September 2026, the third day after publication.
It also sets the ceiling on what an ESRS reporter may require from its value chain, and the cap itself applies from financial years beginning on or after 1 January 2027.
The Commission’s explanatory note of 6 May 2026 confirms that the cap applies only to requests made for CSRD reporting.
The VSME guide for UK suppliers covers the questionnaire itself, and the ESRS and UK SRS comparison sets the two regimes side by side.
For the UK standards’ own route into the same questions, UK SRS against ESRS works from a UK SRS report outwards.
Value chain cap
Voluntary standard
Value chain cap
The cap
Tables and tools
Protected: an average of 1,000 employees or fewer in the preceding financial year.
Capped: only the datapoints in Annex II of the regulation — a closed list, narrower than the whole voluntary standard.
Above the cap: the customer may ask, but must say what exceeds the cap and that the supplier may decline.
Not capped: requests for other purposes, including EU due diligence.
Sources: Directive 2013/34/EU Art 19a(3) · DR (EU) 2026/1560 (PDF)
EFRAG’s resources
The tools around the standards, and their status
The standards are law; the resources EFRAG publishes around them are not.
The most used are a list of datapoints, a digital taxonomy and the implementation guidance, and each has a different status as at 11 October 2026.
Read what each resource is
EFRAG’s draft datapoint list for the revised ESRS “must not be used as a checklist”, and ESRS datapoints explains its 292 “shall” datapoints and what that count excludes.
Its draft XBRL taxonomy is out for consultation until 11 November 2026, and the ESRS XBRL taxonomy explains why tagging is not yet mandatory.
IG 1 to IG 3 are non-authoritative and were written for the 2023 ESRS, as EFRAG’s implementation guidance sets out.
The joint guidance on reporting under the ESRS and the ISSB standards dates from 2 May 2024 and maps the 2023 ESRS; the ESRS–ISSB guidance covers it, and the CSRD against the ISSB standards sets the two systems side by side.
The revised ESRS name the GRI Standards, including their topic and sector standards, as a source an undertaking may use for entity-specific disclosures (ESRS 1 AR 5), and what a GRI claim adds is on GRI Standards.
EFRAG’s resources
Datapoint list
EFRAG’s resources
XBRL taxonomy
EFRAG’s resources
IG 1–3
The UK side
Where the ESRS sit beside UK reporting duties
People who search for the ESRS from the UK often want to know what the UK’s own rules are, and the honest answer is that the ESRS are not one of them.
The UK’s general standard-setting route is UK SRS, the UK endorsement of the ISSB standards, and the FCA’s final rules of 30 September 2026 ask listed companies to report against it on a comply-or-explain basis.
The UK standards were settled through the UK SRS consultation, which ran from 25 June to 17 September 2025.
Those rules replace the TCFD-aligned disclosure rules listed companies used before, which the TCFD to UK SRS migration guide walks through.
SECR and energy savings opportunity scheme sit under UK company and energy law and apply on their own tests, whatever a group does in the EU.
So a UK group with a large EU subsidiary can owe four things at once: an ESRS statement from the subsidiary, a UK SRS report or explanation from the listed parent, SECR in the directors’ report, and an ESOS notification.
None discharges another, but one emissions inventory built to the GHG Protocol can feed all of them.
The domestic list in full is on UK ESG reporting requirements, and the UK regulation timeline dates each duty.
| Regime | Who | Basis |
|---|---|---|
| UK SRS under the FCA’s rules | Listed companies in UKLR 6, 14, 15, 16 and 22 | Comply or explain, periods from 1 January 2027 |
| UK SRS, voluntary | Anyone else | Voluntary standards since 25 February 2026 |
| SECR | Companies meeting its size tests | Energy and carbon in the directors’ report |
| ESOS | Large undertakings in the scheme | Energy audits and notification |
| ESRS | Only entities the CSRD reaches | Double materiality, limited assurance |
What happens next
The dated items to watch
These are the next dates on the ESRS side, as at 11 October 2026; consultation dates are EFRAG’s and may move.
- 23 October 202601
Datapoint list feedback closes
EFRAG’s survey on its draft list; the final resource is expected by the end of 2026. - 31 October 202602
ESRS-40a consultation closes
The draft standard for non-EU groups; EFRAG’s advice is due in January 2027. - 10 November 202603
- 11 November 202604
XBRL consultation closes
EFRAG intends to submit the final taxonomy to ESMA and the Commission by the end of 2026. - 1 January 202705
Revised ESRS apply
Financial years beginning on or after this date; first reports in 2028. - 19 March 202706
Omnibus I transposed
Member States bring the CSRD articles into national law. - 1 July 202707
Limited-assurance standards
The Commission must adopt them by this date.
The full sequence back to 2022 is on the CSRD timeline, and the assurance opinion on assurance under the CSRD.
Test yourself
Six ESRS claims, true or false
Each statement circulates in commentary on the ESRS, and each is settled by the provision named under it.
The first is the most common and the most expensive: it moves a first reporting year forward by a year in the reader’s mind.
The second reverses the instinct of most preparers, who were taught under the 2023 standards that more disclosure was the safer choice.
The sixth matters to any group with a net-zero target that leans on credits, because the ESRS figure and the marketing figure will differ.
ESRS: true or false?
The revised ESRS apply from 10 November 2026.
Disclosing a datapoint that is not material is allowed, to be safe.
The 2026 revision cut the number of ESRS standards.
An EU company needs more than 1,000 employees and more than €450m net turnover to be in CSRD scope.
A UK company can only be reached by the ESRS through an EU subsidiary.
ESRS E1 lets a company count carbon credits towards its emission reduction targets.
0 of 6 answered.
Nothing you choose is stored or sent.
What goes wrong
Five mistakes in circulation
“The revised ESRS apply from 10 November 2026.”
That is entry into force; application is financial years beginning on or after 1 January 2027.
“Mandatory datapoints fell from 1,144 to about 500.”
Neither number has a Commission source; 1,144 was EFRAG’s 2022 total for a draft.
Citing “ESRS 1 paragraph 37” or “E4-6” with no version: Annex I was replaced in full, so paragraph numbers do not carry over.
Giving both 2026 regulations one in-force date: 10 November 2026 is the revised ESRS, 24 September 2026 the voluntary standard.
Reporting everything “to be safe”: the revised ESRS 1 ¶24 says a company shall not disclose information that is not material.
The instruments are on EUR-Lex: the CSRD as adopted in 2022, read only for its recitals now, and the consolidated Accounting Directive for scope.
EFRAG’s implementation guidance documents relate to the 2023 standards, and its sustainability reporting hub carries the revised set.
The Commission’s corporate sustainability reporting page replaced its old ESRS landing page, which no longer resolves.
Three secondary analyses informed the framing, never a figure: PwC Viewpoint on ESRS (2026), KPMG’s talkbook on simplifying ESRS and Linklaters on the Official Journal publication.
Every fact on this page is cited to the instrument.
To talk your own group through it, you can book a free 15-minute call, or start from the UK SRS reference.
A reading and preparation sequence
ESRS: from the question to the evidence
- Step 0101
ESRS architecture
EFRAG writes the standards as technical advice to the European Commission, and the Commission adopts them as a delegated regulation under Article 29b of the Accounting Directive.Read the detail. - Step 0202
General standards
The two cross-cutting standards do different jobs, and the difference explains the whole set.Read the detail. - Step 0303
Material information
“Which ESRS are mandatory” has a two-part answer.Read the detail. - Step 0404
CSRD population
The same document estimates savings of €2.24 billion a year from 2029 from the revised standards, and about €4.4 billion from the scope reduction; the two measure different things and are never added.Read the detail. - Step 0505
UK and EU
The ESRS reach a UK company through its EU footprint, not its registered office.Read the detail. - Step 0606
Climate comparison
The Scope 2 row is the one that changes the numbers: a UK group reporting under both has to produce a market-based figure for ESRS even where UK SRS S2does not ask for it; the Scope 2 guideexplains the two methods.Read the detail. - Step 0707
Value chain cap
The second act adopted on 3 July 2026 is not an ESRS; it is a standard for voluntary use by smaller undertakings, built on the Commission’s VSME recommendation.Read the detail.
Dates, with their status
The relevant dates, drawn in order
- 3 July 202601
Commission adoption
The Commission adopts the revised ESRS delegated act. Adoption and legal application are separate events. - 21 September 202602
Official Journal publication
Delegated Regulation (EU) 2026/1563 publishes the revised standards. - 10 November 202603
Entry into force
Article 3 sets entry into force on the fiftieth day following publication. - Financial years from 1 January 202704
Revised standards apply
Check the CSRD reporting route and population separately; a standard’s application date does not bring every UK company into scope.
Continue your research
Related reporting guides, one question at a time
Frequently asked
Questions people ask
What are the European Sustainability Reporting Standards (ESRS)?
The ESRS are the standards an undertaking in scope of the EU Corporate Sustainability Reporting Directive uses to prepare its sustainability statement.
EFRAG drafts them as technical advice and the European Commission adopts them as a delegated regulation.
There are twelve: two cross-cutting standards, ESRS 1 and ESRS 2, and ten topical standards, E1 to E5, S1 to S4 and G1.
The revised set, Delegated Regulation (EU) 2026/1563, applies to financial years beginning on or after 1 January 2027.
When do the revised ESRS apply?
To financial years beginning on or after 1 January 2027, so the first reports under them are published in 2028.
Delegated Regulation (EU) 2026/1563 was adopted on 3 July 2026, published in the Official Journal on 21 September 2026 and enters into force on 10 November 2026.
Entry into force is not application: nothing in the regulation is required before a financial year beginning on or after 1 January 2027.
Which version of the ESRS applies to a 2026 financial year?
The undertaking chooses one of three.
The 2023 standards as last amended by Delegated Regulation (EU) 2025/1416; the revised standards in full; or the 2023 standards with eight named reliefs taken from the revised ESRS 1.
Article 2(2) of Delegated Regulation (EU) 2026/1563 requires the sustainability statement to state clearly which version was applied.
How many datapoints did the 2026 revision remove?
The Commission says the revised standards reduce mandatory datapoints by over 60% and total datapoints by more than 70%, and expects reporting costs to fall by over 30% per company.
EFRAG measured its own draft at a 61% cut in mandatory datapoints, before the Commission made thirteen categories of change to it.
The Commission publishes no absolute count, so no before-and-after number is reliable.
Do UK companies have to report under ESRS?
Only if the CSRD reaches them.
That happens through an EU subsidiary or EU parent group above the thresholds, an EU regulated-market listing, or, from financial year 2028, Article 40a for a non-EU group with large EU turnover.
A UK supplier to an in-scope EU customer has no reporting duty of its own but will receive data requests, which the value-chain cap limits.
What is the CSRD threshold that decides ESRS reporting?
An undertaking, or a group on a consolidated basis, must exceed both a net turnover of €450 million and an average of 1,000 employees during the financial year.
The two limbs are cumulative.
For a non-EU group under Article 40a there is no employee test: it is EU net turnover above €450 million in each of the last two consecutive financial years plus an EU subsidiary or branch above €200 million.
Is ESRS-40a part of the ESRS?
No. ESRS-40a is a separate draft standard for non-EU groups caught by Article 40a of the Accounting Directive.
EFRAG published the exposure draft on 23 July 2026, the consultation closes on 31 October 2026, and its technical advice is due in January 2027.
The Commission has set no adoption date.
How do the ESRS differ from UK SRS?
Materiality and breadth.
The ESRS apply double materiality, covering impacts on people and the environment as well as financial effects on the undertaking.
UK SRS S1 and S2, based on the ISSB standards, apply financial materiality only.
The ESRS span twelve standards across environmental, social and governance topics; UK SRS has a general standard and a climate standard.
What does ESRS E1 ask for?
ESRS E1 Climate Change is reported where climate is material.
It asks for a transition plan for climate change mitigation, or a statement that there is none and whether and when one is expected; climate risk identification and resilience; greenhouse gas reduction targets, which must be gross of removals, carbon credits and avoided emissions; gross Scope 1, 2 and 3 emissions, with Scope 2 on both the location-based and market-based methods; and anticipated financial effects, which E1-11 covers.
Can a company report immaterial ESRS datapoints to be safe?
No. The revised ESRS 1 ¶24 says the undertaking shall not disclose information prescribed by a disclosure requirement or datapoint if that information is not material.
The Commission chose "shall not" deliberately, in place of "is not required to".
What is ESRS 1?
ESRS 1 General Requirements is the cross-cutting rulebook of the ESRS.
It sets the double materiality principle, the value-chain boundary, how the sustainability statement is presented, and the reliefs and phase-ins. It prescribes no datapoints of its own.
The revised ESRS 1 also says that information that is not material shall not be disclosed.
What is ESRS 2?
ESRS 2 General Disclosures is the general-disclosures standard; the revised ESRS 1 says its disclosure requirements are likely to result in material information for all undertakings (AR 12).
It covers the basis of preparation (BP-1, BP-2), governance (GOV-1 to GOV-4), strategy (SBM-1 to SBM-3) and the materiality process and its results (IRO-1, IRO-2), and sets the minimum content for policies, actions, metrics and targets (GDR-P, GDR-A, GDR-M, GDR-T).
Which ESRS are mandatory?
ESRS 1 sets the rules every undertaking in scope applies, and ESRS 2’s disclosures are, in the standard’s words, likely to result in material information for all undertakings; EFRAG’s draft datapoint note says no datapoint is to be reported irrespective of materiality.
Each of the ten topical standards applies only where the double materiality assessment finds material impacts, risks or opportunities on its topic, and then only for the material sub-topics.
A company that omits ESRS E1 must explain why it concluded climate change is not material.
What does ESRS stand for?
European Sustainability Reporting Standards.
They are the standards that undertakings in scope of the EU Corporate Sustainability Reporting Directive use for their sustainability statement, adopted by the European Commission as delegated regulations on the technical advice of EFRAG.
Are the ESRS and the CSRD the same thing?
No. The CSRD is the Directive: it decides who must report, where the statement goes and how it is assured.
The ESRS are the standards that say what goes in the statement.
Omnibus I changed the Directive in March 2026; Delegated Regulation (EU) 2026/1563 changed the standards in September 2026.
Where can I read or download the ESRS?
On EUR-Lex: the original set is Delegated Regulation (EU) 2023/2772 and the revised set is Delegated Regulation (EU) 2026/1563, published in the Official Journal on 21 September 2026.
EFRAG’s Knowledge Hub renders the revised text interactively, with links back to the 2023 paragraphs.
Will there be sector-specific ESRS?
No. Omnibus I deleted the Commission’s power to adopt sector-specific sustainability reporting standards, which had a first deadline of 30 June 2026.
What remains is a recital-level possibility that the Commission could support undertakings with non-binding sector guidance.
Is an ESRS sustainability statement assured?
Yes.
The Accounting Directive requires a limited assurance opinion on the statement, covering compliance with the ESRS, the process used to identify the information reported and the Taxonomy Article 8 disclosures.
Omnibus I removed the power to move to reasonable assurance, and the limited assurance standards are due by 1 July 2027.
What does ESRS E1 say about transition plans?
E1-1 asks for the key features of the undertaking’s transition plan for climate change mitigation, including targets, decarbonisation levers, investment and funding, board approval and compatibility with limiting warming to 1.5°C.
If the undertaking does not have such a plan, it must disclose that fact and indicate whether and, if so, when it expects to adopt one.
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.
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 (the revised ESRS), Articles 1–3
Published 21 September 2026; in force 10 November 2026; applies to financial years beginning on or after 1 January 2027; Article 2 sets the three FY2026 options.
- Council of the EUC(2026) 5010 final, Annex I — the revised ESRS 1, ESRS 2 and topical standards
ESRS 1 ¶24 (immaterial information not disclosed), ¶27 (top-down approach), ¶125 (anticipated financial effects relief).
- EUR-LexCommission Delegated Regulation (EU) 2026/1560 (the voluntary standard and value-chain cap), Articles 3–4
In force 24 September 2026; the cap applies from financial years beginning on or after 1 January 2027 and comprises only the Annex II datapoints.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 (ESRS Set 1), Article 1 and Annex I
The original twelve standards, still an FY2026 option as amended by DR (EU) 2025/1416.
- EUR-LexCommission Delegated Regulation (EU) 2025/1416 (the "quick fix")
The amendment Article 2 of 2026/1563 names as the FY2026 baseline.
- EUR-LexDirective 2013/34/EU, consolidated 18 March 2026 — Arts 19a, 29a, 29b, 29ca, 40a
The operative scope test: more than €450m net turnover and an average of 1,000 employees; Article 40a for non-EU groups.
- EUR-LexDirective (EU) 2026/470 (Omnibus I), Articles 2, 3, 5 and 6 and recital 31
In force 18 March 2026; FY2027 application for every undertaking that remains in scope; deleted the sector-standard empowerment.
- European CommissionStaff Working Document SWD(2026) 500 final, §2.3
The 6,753 companies remaining in scope, and the two savings figures that must not be added together.
- European Commission (DG FISMA)Commission adopts revised sustainability reporting standards, 3 July 2026
The adoption event and the Commission’s own percentages ("over 60%", "more than 70%", "over 30%"). Not evidence of when the standards apply.
- European Commission (DG FISMA)Corporate sustainability reporting
The Commission’s live CSRD hub, which replaced the old ESRS landing page.
- EFRAGESRS Knowledge Hub — ESRS E1 Climate Change, delegated-act text, E1-1 to E1-8
The E1 disclosure requirements: transition plan, risks and scenarios, resilience, gross targets, energy, and both Scope 2 methods.
- EFRAGESRS Knowledge Hub — ESRS 2 General Disclosures, delegated-act text
BP-1 to IRO-2 and the GDR-P, GDR-A, GDR-M and GDR-T minimums; IRO-2’s climate-not-material explanation.
- Department for Business and TradeUK SRS S2 Climate-related Disclosures, ¶29(a)(v) and ¶¶B30–B31
UK SRS S2 requires location-based Scope 2 and permits market-based.
- EFRAGEFRAG provides its technical advice on draft simplified ESRS, 3 December 2025
The simplification chronology: mandate, exposure drafts, SRB approval and advice.
- EFRAG2026 Draft List of Datapoints and Draft XBRL Taxonomy — Explanatory Note, 28 August 2026
“It must not be used as a checklist”; no datapoint reported irrespective of materiality (¶68).
- EFRAGDraft ESRS XBRL Taxonomy for the revised ESRS, 17 September 2026
Consultation to 11 November 2026; digital tagging not yet mandatory.
- EFRAGPublic consultation on the ESRS-40a exposure draft, 23 July 2026
Consultation before 31 October 2026; advice due January 2027.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers’ sustainability disclosures with international standards
The UK side: comply or explain against UK SRS for listed companies, periods beginning on or after 1 January 2027.
Continue reading
Read next
ESRS-40a and Article 40a
The €450m/€200m test for non-EU groups and the draft standard they would report under.
Double materiality
The two lenses, where the law writes them down, and how they differ from UK SRS.
CSRD reporting requirements for UK groups
The statement, the FY2026 choice, assurance and the timetable.
Related questions
Follow the question to its dedicated guide
For the publication history, read our EU revised ESRS 2026 source-led news record alongside the standards guide.