News · EU regulation · published 23 July 2026, updated 1 October 2026
The EU’s revised ESRS are published: what changes, when, and for UK companies
The revised ESRS adopted by the European Commission on 3 July 2026 are now law: Delegated Regulation (EU) 2026/1563, published in the Official Journal on 21 September 2026.
Beside them, the voluntary standard that sets the value-chain cap, Delegated Regulation (EU) 2026/1560, has been in force since 24 September 2026.
Here is what changed, when each piece applies, and what it means for UK companies reporting under the EU regime or supplying into it.
What happened
Two delegated acts, two different clocks
On 3 July 2026 the European Commission adopted two delegated acts under the Accounting Directive.
The first replaces the text of the European Sustainability Reporting Standards in Delegated Regulation (EU) 2023/2772 with a revised set, often called “ESRS 2026”.
The second establishes a reporting standard for voluntary use, based on the VSME recommendation, for undertakings protected by the value-chain cap.
The adoption completed the ESRS strand of the Omnibus I simplification package, which the Commission proposed in February 2025.
Neither act was objected to during the scrutiny period, and both were published in the Official Journal on 21 September 2026.
They then came into force on different dates.
The revised ESRS enter into force on 10 November 2026, because a standard adopted under Article 29b may not enter into force earlier than four months after adoption.
The voluntary standard entered into force on the third day after publication, 24 September 2026.
Neither date is when anything must be reported: both regulations apply from financial years beginning on or after 1 January 2027.
| Revised ESRS | Voluntary standard | |
|---|---|---|
| Instrument | DR (EU) 2026/1563 | DR (EU) 2026/1560 |
| Commission reference | C(2026) 5010 | C(2026) 5011 |
| What it does | Replaces Annexes I and II of DR (EU) 2023/2772 | Sets standards for voluntary use, and the value-chain cap |
| Official Journal | 21 September 2026 | 21 September 2026 |
| In force | 10 November 2026 | 24 September 2026 |
| Applies to financial years from | 1 January 2027 | 1 January 2027 (the cap) |
Timeline
From proposal to first reports
- 26 Feb 2025Omnibus I proposed
The Commission’s simplification package for sustainability reporting and due diligence.
- 18 Mar 2026Directive (EU) 2026/470 in force
CSRD narrowed to undertakings exceeding 1,000 employees and €450m net turnover from FY2027; the value-chain cap created.
- 6 May 2026The Commission explains the cap
Additional explanatory information on the value chain, published during feedback on the draft standards.
- 3 Jul 2026Both acts adopted
C(2026) 5010 (revised ESRS) and C(2026) 5011 (voluntary standard).
- 23 Jul 2026ESRS-40a consultation opens
EFRAG’s 100-day consultation on the standard for non-EU groups.
- 21 Sep 2026Published in the Official Journal
As DR (EU) 2026/1563 and DR (EU) 2026/1560.
- 24 Sep 2026Voluntary standard in force
Recommendation (EU) 2025/1710 stops producing legal effects.
- 31 Oct 2026ESRS-40a consultation closes
Technical advice to the Commission follows in January 2027.
- 10 Nov 2026Revised ESRS in force
In force, but not yet applying to any reporting year.
- 1 Jan 2027Application begins
Financial years beginning on or after this date report under the revised ESRS, and the cap applies.
- 19 Mar 2027Omnibus I transposition deadline
Member States must have brought the cap and the new scope into national law.
- 2028First reports under the revised ESRS
For financial years beginning in 2027.
ESRS-40a is drafted for the 2028 financial year, with first reports in 2029.
Sources: Directive (EU) 2026/470; DR (EU) 2026/1563 Art 3; DR (EU) 2026/1560 Art 4 and recital (5); EFRAG, ESRS-40a launch and Basis for Conclusions.
The numbers
How much lighter, and whose figures
The Commission says the revision cuts mandatory datapoints by over 60% and total datapoints by more than 70%.
The total falls further because every voluntary “may” datapoint has been deleted.
The explanatory memorandum attributes the sharper 61% figure to EFRAG’s revised draft, not to the act the Commission adopted.
The Commission then made thirteen categories of change to EFRAG’s advice, among them materiality, fair presentation, GHG emissions, climate transition plans and asset management.
The cost saving of over 30% per company is EFRAG’s cost-benefit estimate, and the memorandum says plainly that it rests on EFRAG’s proposed standards and not on the final delegated act.
So the headline percentages are best read as the scale of the change, not a measured result.
Relief is greatest for an undertaking with few material topics: where climate is material, ESRS E1 still asks for a substantial report.
Which version applies
FY2026 is a choice; FY2027 is not
For a financial year beginning in 2026, Article 2 of DR (EU) 2026/1563 lets an undertaking choose between three texts.
It may use the 2023 ESRS as last amended by Delegated Regulation (EU) 2025/1416, the so-called quick fix.
It may use the revised ESRS in full.
Or it may use the 2023 ESRS with eight named reliefs taken from the revised ESRS 1, including the top-down approach to materiality in paragraph 27 and the executive summary in paragraph 110.
Whichever it picks, Article 2(2) requires the sustainability statement to state clearly which version it applied.
From financial years beginning on or after 1 January 2027 there is no choice: Article 3 applies the revised ESRS in full.
The finder beside this text works out which case your year falls in, and it covers a non-EU parent under Article 40a too.
Whether you report at all is a separate question of scope: the CSRD route checker works that out for a UK group.
Which ESRS text applies to our year?
The revised ESRS — no choice
A financial year beginning 1 January 2027 and ending 31 December 2027 is a year “beginning on or after 1 January 2027”, so Article 3 of Delegated Regulation (EU) 2026/1563 applies the revised ESRS in full.
The 2026 options and reliefs in Article 2 do not extend to it.
The sustainability statement for that year follows the year end of 31 December 2027.
Rules: Delegated Regulation (EU) 2026/1563 Arts 2–3; EFRAG ESRS-40a exposure draft, Basis for Conclusions.
Whether you report at all is a scope question under Directive (EU) 2026/470.
A provisional reading, not legal advice.
Inside the standards
What the revision actually changes
| Change | What the revised text says | Where |
|---|---|---|
| Immaterial information | The undertaking “shall not” disclose information prescribed by a disclosure requirement or datapoint if it is not material — a deliberate change from “is not required to”. | ESRS 1 ¶24 |
| Top-down materiality | An undertaking may conclude on a topic’s materiality from an analysis of its strategy and business model, without a full assessment, and must assess specifically where the answer is not evident. The bottom-up route remains. | ESRS 1 ¶¶27–28 |
| Severity | Actual negative impacts are assessed on severity; potential ones on severity and likelihood; severity is scale, scope and irremediable character. | ESRS 1 ¶40 |
| Anticipated financial effects | The separate disclosure requirements in E2 to E5 are gone; anticipated financial effects survive in ESRS 2 ¶27 and in E1-11 for climate. | ESRS 2; ESRS E1-11 |
| GHG boundary | Undertakings may use either the financial control or the operational control approach. | Commission modification |
| Scope 2 | E1 asks for gross Scope 2 emissions on both the location-based and the market-based method. | ESRS E1 |
| Structure | Still twelve standards: ESRS 1 and 2, E1 to E5, S1 to S4 and G1, with the minimum disclosure requirements recast as GDR-P, GDR-A, GDR-M and GDR-T. | ESRS 1 ¶8 |
Paragraph numbers do not carry across: Article 1 replaces Annex I wholesale, so a citation of “ESRS 1 ¶n” needs to say which version it means.
One cross-reference in the published text points the wrong way: ESRS 2 IRO-1 ¶35(b) sends the reader to “ESRS 1 … paragraphs 44 and 45” for severity and likelihood, but in the Official Journal text those rules are ESRS 1 ¶¶40–41.
For the full map of the twelve standards and the double materiality process, see our ESRS guide and double materiality assessment walkthrough.
The voluntary standard
The value-chain cap, and its limits
The voluntary standard does two jobs: it offers smaller undertakings a proportionate way to report if they choose to, and its Annex II sets the ceiling of what a CSRD reporter may require from them.
The cap protects an undertaking in the value chain with an average of 1,000 employees or fewer.
It comprises only the Annex II datapoints, not the whole standard, as Article 3(2) says in terms.
Undertakings with 10 employees or fewer get extra protection: some datapoints that are essential for larger companies are voluntary for them.
Recital (12) of Omnibus I sets the cap’s limits: it does not prohibit voluntary sharing, does not override a contractual or legal duty to provide information, and applies only to information gathered for CSRD reporting.
The Commission’s own explanation adds that the cap “does not impose or imply any obligation” on companies in the value chain to provide anything.
The voluntary standard mentions Scope 3 only as a consideration, and it is not an Annex II datapoint.
From 24 September 2026 the earlier VSME recommendation, Recommendation (EU) 2025/1710, no longer produces legal effects.
The check beside this text works through whether a particular request falls inside the cap.
Value-chain cap · can they require this?
Answer the four questions
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Rules: Directive 2013/34/EU Art 19a(3) and 29a(3) as amended by Directive (EU) 2026/470; Delegated Regulation (EU) 2026/1560 Arts 3–4.
A provisional reading, not legal advice.
Scope
Who reports under the revised ESRS
The standards serve the duty in the Accounting Directive, and Omnibus I, in force since 18 March 2026, narrowed who carries it.
From financial years beginning on or after 1 January 2027, the main duty reaches undertakings that exceed both an average of 1,000 employees and €450 million net turnover.
The test is cumulative: both figures must be exceeded.
A non-EU group reports under Article 40a where its net turnover in the Union exceeded €450 million in each of the last two financial years and it has an EU subsidiary, or failing one a branch, with net turnover above €200 million.
That group-level report will use ESRS-40a, the separate standard EFRAG is drafting, previously called ESRS-TC and N-ESRS; our ESRS-40a guide follows it.
ESRS-40a, for non-EU groups
An EFRAG exposure draft, not law.
Consultation 23 July to 31 October 2026; technical advice to the Commission in January 2027; a Commission consultation before any delegated act.
Drafted for the 2028 financial year, first reports in 2029, covering impacts only.
UK angle
What this means for UK companies
Three groups of UK companies are affected, in different ways.
UK groups in CSRD scope, through EU subsidiaries, EU listings or, from 2028, Article 40a, now face a lighter EU report, and the revised standards sit closer to the ISSB baseline behind the two UK standards.
Closer is not the same: ESRS E1 asks for market-based as well as location-based Scope 2, where UK SRS S2 asks for location-based only.
Our ESRS and UK SRS comparison sets the remaining differences out, and CSRD vs UK SRS covers scope and planning for dual reporters.
UK suppliers to EU customers gain the cap: for CSRD reporting purposes, an in-scope customer may not require more than the Annex II datapoints from a supplier with 1,000 employees or fewer.
Everyone else can read the revision as the direction of travel: fewer datapoints, materiality first, and closer alignment with the ISSB standards that UK SRS is built on.
Under the FCA’s final rules, PS26/19, listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.
No other UK entity is required to use UK SRS.
Updates to this story
What changed since publication
23 July 2026: first published, on the Commission’s adoption of the two acts on 3 July 2026, when both were awaiting publication.
28 September 2026: updated for publication in the Official Journal on 21 September 2026, with the two in-force dates.
1 October 2026: updated for the voluntary standard’s entry into force on 24 September 2026, the FY2026 choice, the ESRS-40a consultation dates and the FCA’s final UK SRS rules of 30 September 2026.
Commentary we read alongside the instruments, never as the source for a figure: Linklaters Sustainable Futures on the adoption and PwC Viewpoint’s in-depth note on ESRS (2026).
More dated stories are on the news page.
Frequently asked
Revised ESRS: quick answers
When do the revised ESRS apply?
Delegated Regulation (EU) 2026/1563 was published in the Official Journal on 21 September 2026, enters into force on 10 November 2026 and applies to financial years beginning on or after 1 January 2027, so the first reports under it are published in 2028.
Entry into force is not application: nothing in the revised standards is required for a year beginning before 1 January 2027.
Which ESRS can we use for FY2026?
For a financial year beginning in 2026, Article 2 of Delegated Regulation (EU) 2026/1563 offers three choices: the 2023 ESRS as last amended by Delegated Regulation (EU) 2025/1416; the revised ESRS in full; or the 2023 ESRS with eight named ESRS 1 reliefs.
The sustainability statement must clearly state which version was applied.
How big is the datapoint reduction?
The Commission says mandatory datapoints fall by over 60% and total datapoints by more than 70%, with reporting costs down by over 30% per company.
EFRAG benchmarked its own revised draft at 61% fewer mandatory datapoints.
The explanatory memorandum says the cost estimates are based on EFRAG’s draft, not on the act the Commission adopted.
Is the voluntary standard in force?
Yes.
Delegated Regulation (EU) 2026/1560 entered into force on 24 September 2026, the third day after publication.
From that date Recommendation (EU) 2025/1710, the earlier VSME recommendation, no longer produces legal effects.
Its Article 3, which sets the value-chain cap, applies from financial years beginning on or after 1 January 2027.
Does the value-chain cap protect UK suppliers?
It can.
A company in CSRD scope may not require an undertaking in its value chain with an average of 1,000 employees or fewer to provide more than the datapoints in Annex II of the voluntary standard, for the purpose of its CSRD reporting.
The cap does not stop voluntary sharing, does not override other legal duties to provide information, and does not cover requests made for other purposes.
Member States must transpose it by 19 March 2027.
Do the revised ESRS change anything for UK companies?
Directly, only for UK groups in CSRD scope through EU subsidiaries, EU listings or, from 2028, Article 40a.
Indirectly, many more UK companies are affected as suppliers: the cap limits what an EU customer may require from them for CSRD reporting.
The revision also narrows some gaps with the ISSB-based UK SRS, although differences remain, such as the market-based Scope 2 figure ESRS E1 requires.
What about non-EU parent groups?
They will report under a separate standard, ESRS-40a, which is still an EFRAG exposure draft.
EFRAG’s consultation runs from 23 July to 31 October 2026, its technical advice is due to the Commission in January 2027, and the Commission will consult again before adopting it.
The draft is written for the 2028 financial year, with first reports in 2029, and covers impacts only.
Who is in CSRD scope now?
From financial years beginning on or after 1 January 2027, Directive (EU) 2026/470 limits the main CSRD duty to undertakings exceeding both an average of 1,000 employees and €450 million net turnover.
For a non-EU group under Article 40a the test is net turnover in the Union above €450 million in each of the last two financial years, with an EU subsidiary, or failing one a branch, above €200 million.
Can a company still disclose immaterial ESRS information?
No. ESRS 1 paragraph 24 of the revised standards says the undertaking shall not disclose information prescribed by a disclosure requirement or datapoint if that information is not material.
The explanatory memorandum records this as a deliberate Commission change from “is not required to”.
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 and Annex I
Published 21 September 2026; in force 10 November 2026; applies to financial years beginning on or after 1 January 2027; the FY2026 choice in Article 2.
- EUR-LexCommission Delegated Regulation (EU) 2026/1560 — the voluntary standard, Articles 2–4 and Annex II
In force 24 September 2026; the value-chain cap is Annex II only and applies from financial years beginning on or after 1 January 2027.
- European Commission (DG FISMA)Commission adopts revised sustainability reporting standards (3 July 2026)
The adoption, and the Commission’s “over 60%”, “more than 70%” and “over 30%” figures.
- Council of the EU (Commission text)C(2026) 5010 final — explanatory memorandum and Articles 1–3
EFRAG’s 61% benchmark for its revised draft; the caveat that the cost estimates are of EFRAG’s draft; the Commission’s thirteen modifications.
- Council of the EU (Commission text)C(2026) 5010 final — Annex I (ESRS 1, ESRS 2 and the topical standards)
ESRS 1 ¶¶24 and 27; anticipated financial effects kept in ESRS 2 ¶27 and E1-11 only.
- Council of the EU (Commission text)C(2026) 5011 final — the voluntary standard, Article 3(2) and recital (5)
The cap comprises only the Annex II datapoints; Recommendation (EU) 2025/1710 ceases to have legal effect.
- EUR-LexDirective (EU) 2026/470 (Omnibus I) — scope, recital (12) and Article 5
The 1,000-employee and €450m test from FY2027, the Article 40a figures, the limits of the cap and the 19 March 2027 transposition date.
- EUR-LexCommission Delegated Regulation (EU) 2023/2772 — the first ESRS
The text the revision amends, and the one most FY2026 reporters may still use.
- EUR-LexDirective 2013/34/EU (consolidated 18 March 2026), Articles 19a, 29a, 29b and 40a
The reporting duties the standards serve.
- European Commission (DG FISMA)Additional explanatory information regarding the value chain (6 May 2026)
The cap “does not impose or imply any obligation” on companies in the value chain; extra protection at 10 employees or fewer.
- EFRAGEFRAG launches public consultation on the ESRS-40a exposure draft (23 July 2026)
A 100-day consultation closing 31 October 2026; technical advice expected January 2027.
- EFRAGESRS-40a exposure draft — Basis for Conclusions
Impacts only; reporting for the 2028 financial year, first reports in 2029.
- EFRAG Knowledge HubRevised ESRS E1, delegated-act rendering
E1 asks for gross Scope 2 emissions on both the location-based and the market-based method.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
The UK side: UK SRS on a comply-or-explain basis for listed companies from 2027.
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