ESRS explained: structure, topical standards, datapoints

What are the ESRS?

The European Sustainability Reporting Standards operationalise the CSRD. EFRAG develops them, the European Commission adopts them as delegated acts. They set out which topics are reported on, which disclosures are required and how they are structured. Without the ESRS the CSRD would have no content.

Which version applies — and from when

Since Omnibus I ((EU) 2026/470, in force since Mar 18, 2026), the ESRS have been revised. The version that counts is Delegated Regulation (EU) 2026/1563.

• Official Journal Sep 21, 2026, in force since Nov 10, 2026
• Applicable to financial years from 2027
• For financial year 2026, companies already reporting may choose: the old set ((EU) 2023/2772 as amended by (EU) 2025/1416) or the new one. The choice must be stated in the report
• Sector-specific ESRS are cancelled, not postponed

Structure: cross-cutting and topical standards

Two cross-cutting standards apply in principle; ten topical standards depend on materiality.

• ESRS 1 – General requirements: presentation principles, quality characteristics, materiality rules
• ESRS 2 – General disclosures: governance, strategy, impacts, risks and opportunities, and management measures
• 10 topical standards: environment E1 climate change, E2 pollution, E3 water and marine resources, E4 biodiversity, E5 circular economy
• Social: S1 own workforce, S2 workers in the value chain, S3 affected communities, S4 consumers and end users
• Governance: G1 business conduct

Materiality decides — and excludes

This is the most important rule and it is often misread. The double materiality assessment determines which topics you report. But the converse also holds: you must not disclose immaterial datapoints. The revised set prohibits it explicitly, to keep reports lean.

• Only ESRS 2 applies regardless of materiality
• If climate (E1) is assessed as not material, ESRS 2 requires you to explain that conclusion
• Datapoints are now split into mandatory and voluntary
• Reporting happens at topic and sub-topic level, not as "the whole standard"

Reliefs in the revised set

Three mechanisms reduce the effort, and all three are new enough that many articles still omit them.

• Top-down approach: materiality may be concluded at a higher level without a full assessment of every single IRO
• Undue cost or effort: only reasonable and supportable information is required, and no exhaustive search is expected
• Phase-ins: E4, S2, S3, S4, single disclosures (S1-6, S1-7, S1-10, S1-11, S1-12, S1-13, S1-14, E2-5) and the anticipated financial effects are deferred and need not be reported in full immediately; the relief comes with conditions and does not last indefinitely

Digital tagging: currently suspended

ESRS reporting is meant to become machine-readable. That obligation is on hold: Omnibus I amended Article 29d of the CSRD, and the mark-up duty rests until the ESEF regulation (EU) 2019/815 is updated. There is currently no application date. EFRAG put a draft ESRS XBRL taxonomy out for consultation in September 2026. Build your data structures to be machine-readable, but do not plan around a deadline that does not exist.

Implementation: how to approach the ESRS

A structured implementation starts with materiality and then works topic by topic.

• Run the double materiality assessment and record the material topics and sub-topics
• Derive the datapoints for material topics, separate mandatory from voluntary, and account for the phase-ins
• Collect the data, document its origin and calculation, assign responsibilities
• Document disclosures in the management report traceably — assurance is at the limited level