It is
A list of all datapoints, linked to the XBRL taxonomy and mapped to IG 3, for gap analysis after the materiality assessment.
EFRAG · the revised ESRS · as at 11 October 2026
ESRS datapoints: how many, on whose count, and what a company actually reports
ESRS datapoints are the individual pieces of information the European Sustainability Reporting Standards define, and EFRAG’s draft list for the revised ESRS counts 292 “shall” datapoints on its own stated definition.
None of them is reported regardless of materiality: a company reports a datapoint only for a topic its double materiality assessment finds material.
The other numbers in circulation — 1,144, 61%, “about 500” — each measure something different, and one of them has no source at all.
What a datapoint is
An ESRS datapoint is one defined piece of information
A datapoint, in EFRAG’s methodology, is a single item of information a disclosure requirement asks for, with one data type.
EFRAG defines them with two logics: a semantic one that follows the wording of each requirement, and a data-type one that sorts each item as narrative, semi-narrative or numerical.
Read the counting rules in EFRAG’s note
The 2026 Draft List removes datapoints that came from application requirements, which the 2024 list had counted (¶29).
Disaggregations, such as a breakdown by country or by gas, are not counted as separate datapoints but sit in a separate column (¶30).
Virtual datapoints, such as references to the general disclosure requirements, are not counted, in line with the method used for IG 3 (¶67).
The datapoints in ESRS 2 BP-1 that are not subject to materiality are counted separately, as six technical datapoints (¶67).
EFRAG adds that the number of datapoints “does not represent the number of ‘facts’ being disclosed in a report” (¶68).
The methodology is the same one used for IG 3, the list EFRAG published in May 2024 for the 2023 standards.
How EFRAG countsExplore
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Semantic logic
Datapoints follow the wording and structure of each disclosure requirement, such as list items and sub-lists.
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Data-type logic
Narrative, semi-narrative (lists, Booleans, dates) or numerical — each datapoint has one data type.
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Not counted
Datapoints from application requirements, disaggregations such as by country, and virtual datapoints.
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Counted apart
Six technical BP-1 datapoints that describe the report itself, not subject to materiality.
EFRAG Secretariat draft count, 28 August 2026
292 “shall” ESRS datapoints, standard by standard
These figures are Figure 1 of EFRAG’s explanatory note, read from the note itself.
They count “shall” datapoints without the general disclosure requirements on policies, actions, targets and metrics.
The list is a draft issued for fatal-flaw feedback, and EFRAG says it may contain errors and may be incomplete.
| Standard | “Shall” datapoints | Of which related to EU legislation |
|---|---|---|
| ESRS 2 General disclosures | 57 | 8 |
| E1 Climate change | 84 | 40 |
| E2 Pollution | 17 | 3 |
| E3 Water | 8 | 3 |
| E4 Biodiversity and ecosystems | 9 | 4 |
| E5 Resource use and circular economy | 15 | 3 |
| S1 Own workforce | 49 | 9 |
| S2 Workers in the value chain | 12 | 4 |
| S3 Affected communities | 12 | 2 |
| S4 Consumers and end-users | 9 | 2 |
| G1 Business conduct | 20 | 5 |
| Total | 292 | 83 (28%) |
Climate change, ESRS E1, has the most, at 84, and nearly half of the datapoints linked to other EU law sit there.
The general disclosure requirements on policies, actions, targets and metrics apply only where a company has adopted them for a material topic, which is why EFRAG counts them apart.
Every one of these datapoints is filtered by the company’s materiality assessment before it can appear in a statement.
- November 202201
Draft first set: 1,144 in total
EFRAG’s cover letter on the draft ESRS reduced the total from 2,161 to 1,144 — a total for a draft, not a mandatory count. - July 202302
First ESRS adopted: 783 “shall”
EFRAG’s 2026 comparison counts 783 “shall” datapoints in the 2023 act, on the same basis as the 292. - May 202403
IG 3 list for the 2023 standards
The Excel list of ESRS Set 1 datapoints, non-authoritative, used as the baseline for EFRAG’s 61%. - December 202504
EFRAG’s advice: 314
The simplified ESRS EFRAG submitted on 3 December 2025, counted on the same basis. - July 202605
Revised act: 292
The Commission’s Delegated Regulation; 195 net of conditional datapoints. - 28 August 202606
- 23 October 202607
- End of 202608
The same basis, four snapshots
783, 314, 292, 195: what EFRAG’s comparison shows
Figure 2 of EFRAG’s note compares four counts made on one basis, which is what makes them comparable with each other and with nothing else.
The fall from 314 to 292 is the difference between EFRAG’s advice and the act the Commission adopted, counted the same way.
Read the per-standard comparison
| Standard | Delegated act, July 2023 | Technical advice, Dec 2025 | Revised act, July 2026 | Net of conditional |
|---|---|---|---|---|
| ESRS 2 | 127 | 63 | 57 | 27 |
| E1 | 187 | 85 | 84 | 47 |
| E2 | 44 | 16 | 17 | 5 |
| E3 | 27 | 8 | 8 | 7 |
| E4 | 54 | 12 | 9 | 5 |
| E5 | 42 | 15 | 15 | 14 |
| S1 | 127 | 57 | 49 | 48 |
| S2 | 47 | 15 | 12 | 9 |
| S3 | 45 | 13 | 12 | 8 |
| S4 | 44 | 12 | 9 | 7 |
| G1 | 39 | 18 | 20 | 18 |
| Total | 783 | 314 | 292 | 195 |
These counts exclude the general disclosure requirements on policies, actions, targets and metrics, so they are comparable with the 292 and with each other, and with nothing else.
Figure 2Explore
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783
“Shall” datapoints in the July 2023 delegated act, excluding the general disclosure requirements.
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314
EFRAG’s technical advice of December 2025, per its Basis for Conclusions.
The numbers people quote
1,144, 61%, “about 500”: what each ESRS datapoint figure measures
Four figures circulate, and they come from four different documents measuring four different things.
Mixing them produces numbers no document states, of which “about 500 mandatory datapoints” is one.
Read where each figure comes from
1,144 is from EFRAG’s November 2022 cover letter on the draft first set, which reduced the draft’s total from 2,161 to 1,144: a total for a draft, not a mandatory baseline.
61% is EFRAG’s: its December 2025 cover letter says the amended ESRS “reduce the ‘shall’ datapoints by 61% as compared to the initial ESRS (71% including the voluntary datapoints)”, measured against IG 3.
The Commission’s explanatory memorandum attributes the 61% to “EFRAG’s revised draft ESRS”, not to the act the Commission adopted after thirteen categories of modification.
The Commission’s staff working document gives its own percentages, over 60% of mandatory and more than 70% of total datapoints, and publishes no absolute count.
“About 500” comes from applying a mandatory-only percentage to the 2022 draft total, and no Commission document states it.
The only absolute count on a stated definition is EFRAG’s 292, and it is a draft.
Whose number?Explore
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1,144
A total for EFRAG’s November 2022 draft, reduced from 2,161. Not a mandatory count.
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61% and 71%
EFRAG’s reduction in “shall” datapoints against IG 3; 71% including voluntary datapoints.
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>60% and >70%
The Commission’s percentages for mandatory and total datapoints; no absolute counts.
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292
EFRAG’s draft list on its stated definition, every datapoint subject to materiality.
Why a statement holds far fewer
No ESRS datapoint is reported regardless of materiality
EFRAG’s note is explicit: “In contrast to the 2023 ESRS, the 2026 Revised ESRS have no mandatory datapoints that are to be reported irrespective of materiality assessment.”
So the list is “a list of all ESRS datapoints, not a list of facts in an ESRS sustainability statement of a company” (¶68).
Read the materiality rules the list sits under
The note restates ESRS 1 ¶24: an undertaking “shall not disclose information prescribed by an ESRS datapoint if that information is not material” (¶2).
Disclosures on policies, actions and targets are required only where the undertaking has adopted them for material topics (¶3).
Where a material topic is not covered with sufficient granularity, entity-specific disclosures are added, under ESRS 1 ¶11 (¶4).
The transitional provisions in ESRS 1 ¶¶125–126 apply to wave-one undertakings and the corresponding datapoints (¶2).
How the assessment itself is run is on the double materiality assessment, and what “material” means across frameworks on materiality explained.
- 1
All datapoints
EFRAG’s list of every datapoint the revised ESRS define.
- 2
Material topics
The double materiality assessment decides which topics and sub-topics are material.
- 3
Material information
Only material information for a material sub-topic is reported (ESRS 1 ¶30).
- 4
Policies and actions
GDR datapoints apply only where the company has adopted them (ESRS 2 ¶¶38–39).
An illustration
From 292 datapoints to one company’s statement
This is an invented example to show the mechanism, not a finding about any company.
A UK group’s EU logistics subsidiary in CSRD scope concludes that climate, own workforce, workers in the value chain and business conduct are material, and that water, biodiversity and affected communities are not.
| Standard | Draft count | Assessment conclusion | What reaches the statement |
|---|---|---|---|
| ESRS 2 | 57 | Fundamental; likely material for all (ESRS 1 AR 12) | The general disclosures, filtered by materiality |
| E1 Climate change | 84 | Material | Material information for the material sub-topics only |
| S1 Own workforce | 49 | Material | Material information for the material sub-topics only |
| S2 Workers in the value chain | 12 | Material | Material information for the material sub-topics only |
| G1 Business conduct | 20 | Material | Material information for the material sub-topics only |
| E3, E4, S3 | 29 | Not material | Nothing: “shall not” be disclosed (ESRS 1 ¶24) |
Within a material standard, only the material sub-topics are reported, so even the material rows do not mean every datapoint in them.
EFRAG’s own “net of conditional” figure of 195 is a reminder that many of the 292 apply only where a stated condition is met.
The practical lesson is to start a gap analysis from the assessment, not from the list.
What the list is for
Use the ESRS datapoint list for a gap analysis, not as a checklist
EFRAG 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 is useful after the assessment, as a basis for a data gap analysis and for amending existing sustainability statements (¶10).
Read the list’s disclaimers and features
It is “non-authoritative supporting material issued by the EFRAG Secretariat” and “does not constitute implementation guidance” (¶1).
EFRAG will release one version with a mapping to IG 3, linking each new datapoint to its 2024 predecessor, and one without (¶11).
The final version will be published “as EFRAG Secretariat supporting material rather than official implementation guidance” (¶16).
EFRAG’s implementation-guidance page lists IG 1–3 for the 2023 ESRS only; the status of each is on EFRAG implementation guidance.
The 2026 Draft List
It is not
A checklist, implementation guidance, or a substitute for the revised ESRS themselves.
The digital twin
The same ESRS datapoints, as XBRL elements
EFRAG developed the list and the ESRS XBRL taxonomy in parallel, and they contain the same datapoints.
The taxonomy adds the technical attributes needed to represent each one in a machine-readable report.
Read what this means for reporting now
EFRAG’s 17 September 2026 release says “Digital tagging of ESRS disclosures is not yet mandatory, as the regulatory framework is still to be established by ESMA and the European Commission.”
So a company preparing a statement for financial year 2026 or 2027 uses the list for its gap analysis, and watches the taxonomy for the tagging rules that will follow.
List and taxonomyExplore
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Draft taxonomy
For machines: the same datapoints as XBRL elements, 17 September 2026.
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Tagging
Not yet mandatory; the framework is still to be set by ESMA and the Commission.
Which ESRS
The ESRS datapoint count depends on the version you report on
The 2026 Draft List describes the revised ESRS adopted in July 2026 and published as Delegated Regulation (EU) 2026/1563.
For a financial year starting in 2026 a company may still report on the 2023 standards, with or without eight reliefs, and must state which version it applied.
Read the application dates
The revised ESRS enter into force on 10 November 2026 and apply to financial years beginning on or after 1 January 2027, as the CSRD timeline sets out.
A company reporting on the 2023 standards for financial year 2026 will find its datapoints in IG 3, not in the 2026 list.
The ESRS page sets out the twelve standards, and the CSRD after Omnibus I page shows who must report from 2027.
Which list for which yearExplore
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FY2026, 2023 ESRS
The 2023 standards as amended by DR (EU) 2025/1416; IG 3 describes their datapoints.
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FY2026, hybrid
The 2023 standards with eight named reliefs, including top-down materiality.
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FY2026, revised
The revised ESRS in full; the 2026 draft list describes these.
Suppliers
The value-chain cap is a different, shorter list
A UK supplier asked about ESRS datapoints by an EU customer is not being asked for the 292.
For its CSRD reporting, the customer may require from a protected supplier only the datapoints in Annex II of the voluntary standard, Delegated Regulation (EU) 2026/1560.
Read the cap’s limits
Omnibus I’s recital 12 says the cap does not prohibit voluntary sharing, does not affect contractual or other legal obligations, and applies only to information gathered for CSRD reporting.
The Commission’s note of 6 May 2026 says the cap “does not impose or imply any obligation on any companies in the value chain to provide sustainability information”.
The capped questions themselves are set out on the VSME guide.
The supplier’s listExplore
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Who is protected
Companies with an average of 1,000 employees or fewer.
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What can be required
Only the datapoints in Annex II of the voluntary standard, for CSRD reporting.
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What it does not do
It does not stop voluntary sharing or override contracts or other law.
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No obligation
The cap “does not impose or imply any obligation” on companies in the value chain.
Have your say
The ESRS datapoint list is open for comment until 23 October 2026
EFRAG invites stakeholders to review the methodology and report any fatal flaws through an online survey.
As at 11 October 2026 the survey is open until 23 October 2026 at 23:59 CET.
Read what EFRAG asks for
The release of 28 August 2026 says the final resource is expected by the end of 2026, after the feedback is considered.
The note warns that the list “may at this stage contain errors and may be incomplete” and that updates “might be provided in the future” (¶5).
EFRAG advises; the Commission adopts the ESRS, and the list changes nothing in them. The wider picture is on EFRAG explained.
The fatal-flaw surveyExplore
Doing it
A gap analysis against the ESRS datapoints, in order
The order matters more than the tool: materiality first, the list second.
This sequence is an illustration, not a method the ESRS prescribe.
- 01 / Version01
Confirm which ESRS apply
The 2023 set, the hybrid or the revised ESRS for FY2026; the revised ESRS from FY2027. - 02 / Assess02
Run the materiality assessment
Decide the material topics and sub-topics before opening the list. - 03 / Filter03
Filter the list to material sub-topics
Only material information for material sub-topics is reported. - 04 / Conditions04
Drop conditional datapoints that do not apply
Policies, actions and targets apply only where adopted. - 05 / Map05
Map existing data and owners
Use the IG 3 mapping if you reported on the 2023 standards. - 06 / Tag later06
Prepare for XBRL, without tagging yet
Tagging is not yet mandatory; the taxonomy is in consultation.
Who this is for
A UK company meets the ESRS only where the CSRD reaches its group, and the ESRS and UK SRS compared shows what carries over.
This site is an independent reference; it does not sell datapoint mapping or software.
Frequently asked
Questions people ask
How many ESRS datapoints are there?
EFRAG’s 2026 Draft List of Datapoints for the revised ESRS counts 292 “shall” datapoints, excluding the general disclosure requirements on policies, actions, targets and metrics and six technical datapoints in ESRS 2 BP-1.
It is a draft, issued for fatal-flaw feedback until 23 October 2026, and EFRAG says it may contain errors.
Every one of those datapoints is subject to the company’s materiality assessment.
Are the 292 ESRS datapoints mandatory?
No. EFRAG’s explanatory note says that, in contrast to the 2023 ESRS, the revised ESRS “have no mandatory datapoints that are to be reported irrespective of materiality assessment”.
The list is a list of all datapoints, not a list of the facts in any one company’s statement.
What does the 1,144 datapoints figure refer to?
1,144 comes from EFRAG’s November 2022 cover letter on the draft first set of ESRS, where the total number of datapoints in that draft was reduced from 2,161 to 1,144.
It was a total for a draft, not a count of mandatory datapoints, and it describes neither the 2023 act nor the revised ESRS.
What does the 61% reduction in ESRS datapoints mean?
It is EFRAG’s figure: its December 2025 advice reduced the “shall” datapoints by 61% against IG 3, its 2024 list for the 2023 standards, or 71% including voluntary datapoints.
The Commission’s own documents say over 60% of mandatory and more than 70% of total datapoints.
Neither publishes an absolute count, and the explanatory memorandum attributes the 61% to EFRAG’s draft, not to the adopted act.
Is it true that the revised ESRS have about 500 mandatory datapoints?
No source for that figure has been found.
The Commission publishes percentages, not absolute counts, and the “~1,144 to ~500” arithmetic applies a mandatory-only percentage to a total from a 2022 draft.
EFRAG’s own count on its stated definition is 292 “shall” datapoints, all subject to materiality.
Can I use the EFRAG datapoint list as a checklist?
EFRAG says it must not.
The disclaimer reads that the list “must not be used as a checklist and should be used only in conjunction with the exercise of judgement underpinning materiality considerations”, after the company has concluded which topics and sub-topics are material.
Is the 2026 datapoint list implementation guidance?
No. It is non-authoritative supporting material from the EFRAG Secretariat, and EFRAG says the final version will be published as supporting material “rather than official implementation guidance”.
The ESRS themselves, in Delegated Regulation (EU) 2026/1563, are the law.
When can I comment on the ESRS datapoint list?
Through EFRAG’s public survey until 23 October 2026, 23:59 CET.
The consultation looks for fatal flaws in the list and its methodology, and EFRAG expects the final resource by the end of 2026.
How does EFRAG decide what counts as a datapoint?
Two logics: a semantic one, based on the wording and structure of the disclosure requirements, and a data-type one, based on whether the information is narrative, semi-narrative or numerical.
Datapoints from application requirements were deliberately removed, disaggregations such as by country are not counted as separate datapoints, and virtual datapoints such as references to the general disclosure requirements are not counted.
How many ESRS datapoints relate to other EU legislation?
EFRAG’s draft count shows 83 of the 292 “shall” datapoints, 28%, as related to EU legislation.
Those are the datapoints the ESRS link to other EU law, listed in Appendix A of ESRS 2.
What is the difference between the datapoint list and the XBRL taxonomy?
They were developed in parallel and contain the same datapoints.
The list is for people to read and use; the taxonomy adds the technical attributes needed to represent each datapoint as a machine-readable XBRL element.
Digital tagging of ESRS disclosures is not yet mandatory.
Do UK suppliers have to answer every ESRS datapoint a customer asks about?
No. A supplier with an average of 1,000 employees or fewer is protected by the value-chain cap, which limits what a CSRD reporter may require, for its CSRD reporting, to the datapoints in Annex II of the voluntary standard.
The Commission says the cap does not impose or imply any obligation on companies in the value chain.
Which ESRS standard has the most datapoints?
In EFRAG’s draft count, ESRS E1 on climate change has 84 “shall” datapoints, followed by ESRS 2 with 57 and ESRS S1 on own workforce with 49.
Whether any of them appears in a statement depends on the company’s materiality assessment.
Do the datapoint counts change for financial year 2026?
For financial years starting in 2026 a company may report on the 2023 ESRS as amended, on those standards with eight reliefs, or on the revised ESRS in full, and must say which.
The 292 count describes the revised ESRS, which apply without choice from financial years beginning on or after 1 January 2027.
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 fromEFRAG SecretariatEFRAGEUR-LexCouncil of the EUEuropean Commission
- EFRAG Secretariat2026 Revised ESRS — Draft List of Datapoints and Draft XBRL Taxonomy: Explanatory Note, 28 August 2026 (¶¶1–17, 29–30, 67–71, Figures 1–2)
The 292 count, its definition, the per-standard table and the comparison with the 2023 act.
- EFRAGEFRAG Secretariat releases 2026 Draft List of Datapoints for revised ESRS, 28 August 2026
Fatal-flaw feedback to 23 October 2026; final resource expected by the end of 2026.
- EFRAGDraft ESRS XBRL Taxonomy for the revised ESRS and public consultation, 17 September 2026
Same datapoints as the draft list, with technical attributes; consultation to 11 November 2026.
- EUR-LexCommission Delegated Regulation (EU) 2026/1563 — the revised ESRS, Articles 2 and 3
The standards the datapoints come from; apply to financial years beginning on or after 1 January 2027.
- Council of the EUC(2026) 5010 final, explanatory memorandum
Attributes the 61% reduction to EFRAG’s revised draft, not to the adopted act.
- European CommissionSWD(2026) 500 final — staff working document on the revised ESRS
The Commission’s own percentages: over 60% of mandatory and more than 70% of total datapoints; no absolute counts.
- EFRAGESRS simplification project page
Records the first set of draft ESRS provided to the Commission in November 2022, and the 2023 delegated act.
- EFRAGEFRAG provides its technical advice on draft simplified ESRS, 3 December 2025
The advice that the 314 figure in EFRAG’s comparison describes.
- EFRAGCover letter to the Commission on the amended ESRS, December 2025
“shall” datapoints reduced by 61% against IG 3 (71% including voluntary datapoints).
- EFRAGESRS implementation guidance documents — project page
IG 1–3 relate to the 2023 ESRS; no guidance for the revised ESRS is listed.
- EFRAGFinalisation of EFRAG IG 1 to 3, 31 May 2024
IG 3, the List of ESRS Datapoints for the 2023 set, in Excel.
- EUR-LexCommission Delegated Regulation (EU) 2026/1560 — the voluntary standard, Annex II
The capped datapoints a protected supplier can be asked for; a different list.
- EUR-LexDirective (EU) 2026/470 (Omnibus I), recital 12
The limits of the value-chain cap.
- European CommissionAdditional explanatory information regarding the value chain cap, 6 May 2026
The cap imposes no obligation on companies in the value chain.
Continue reading
Read next
Digital
ESRS XBRL taxonomy
The same datapoints as machine-readable elements, and the consultation to 11 November 2026.
The body
EFRAG explained
Who EFRAG is, what it advises on, and who adopts the standards.
The filter
The double materiality assessment
The step that decides which datapoints a company reports.
The standards
ESRS, read from the UK
The twelve standards and when they apply.