Independent reference · September 2026

CSRD reporting software

Judged against the delegated act, not against a vendor list.

Start with a question the lists never ask.
Next — do you need any of it
01 · First

Do you need CSRD software at all?

The United Kingdom is outside the CSRD, so a UK company is never in scope by being British.

Since 18 March 2026 the scope test is a single cumulative one, and it is large.

Does the CSRD reach you?four questions
Each question is one limb of the post-Omnibus test. The turnover and headcount limbs are cumulative: both, or you are out.

The sentence everything follows from

An undertaking is in scope only if it exceeds both €450 million net turnover and 1,000 employees during the financial year.

A tool cannot put you in scope, and buying one does not make you a reporter.

And the year it starts to bite

Omnibus I applies to financial years beginning on or after 1 January 2027, so the consolidated text is ahead of the years it governs.

?
If you do need it, whose advice are you reading?
Next — who wrote the list
02 · Authorship

Who wrote the list you are reading?

Twelve ranking pages for this term were opened and read on 4 September 2026.

Four of them are published by a company that sells a product appearing on its own list.

Publisher, and where it places itselfpick a page
Each entry quotes the page. A publisher selling a ranked product is not disqualifying; it is a fact the reader should have before weighing the ranking.

The counter-example matters as much as the conflict

Socious sells a platform and ranks Workiva first, not itself. That is worth knowing before assuming every vendor list is self-serving.

Name the conflict where it exists, and the counter-example where it exists.

One page contradicts itself in a single screen

The QHSE Standard’s prose says its shortlist is “led by Tekmon, Quentic and Watershed”; its own numbered list runs Quentic, Sweep, Workiva, Enablon, Greenly, and does not contain Tekmon at all.

Several repeat numbers the law repealed.
Next — the figures in circulation
Figures still in circulationfive, and the provision
Each row is a figure found on a page ranking this software, against the provision that governs it.
03 · Stale figures

The numbers they still repeat.

Two of the twelve state a repealed threshold as current, on the same page as a different repealed threshold.

A percentage taken off the wrong baseline is not an estimate. It is a different number.

The datapoint arithmetic, done wrong

The ~1,144 figure is a total for a 2022 draft, so a mandatory-only percentage cannot be subtracted from it.

One page does exactly that and arrives at “around 320”, having also swapped the mandatory and total percentages.

Twelve lists, no reproducible method, and not one of them tests the platforms against the thing the delegated act actually requires for the year now being planned.
Descend into what the act requires of the software.
The version statement nobody mentions — the datapoints deleted on 3 July — the disclosure that is now forbidden rather than optional — and what an assurer will ask to see.
One requirement decides your FY2026 file.
Next — the version statement
04 · The test

The CSRD requirement no list tests for.

For a financial year starting in calendar 2026, an undertaking may apply one of three versions of the ESRS.

Article 2(2) then requires it to state which one it applied.

The three FY2026 optionsArt 2(1)
The hybrid is not a blend of the reader’s choosing. It is ESRS (2023) plus eight named paragraphs of relief, and the act lists them.

Why that is a software requirement, not a drafting note

A disclosure prepared under one version and a disclosure prepared under another are not interchangeable, and the file has to say which was used.

So the tool must carry a standard version against each disclosure and produce that statement.

Ask the vendor to show you the field. Not the roadmap — the field.

And from FY2027 the choice disappears

ESRS (2026) applies to financial years beginning on or after 1 January 2027, with no option.

A tool that hard-codes one version is fine for FY2027 and wrong for the year most readers are planning now.

Then: what 3 July actually deleted.
Next — the datapoints
Who says what, about how muchthree claims
Each figure is attributed to whoever published it. None is a property of the adopted act, and the memorandum says so.
05 · The reduction

What was deleted on 3 July.

The revised standards delete every voluntary datapoint, which is why the total figure is larger than the mandatory one.

61% is EFRAG’s figure for EFRAG’s own draft. The Commission then made thirteen categories of change.

What that means for a tool

Annex I is replaced in its entirety, so a datapoint library built against the 2023 annex is not a subset of the new one.

Ask when the library was rebuilt, not when it was “updated”.

One word changed, and it reverses a default.
Next — immaterial is now forbidden
06 · Materiality

Immaterial disclosure is now forbidden, not optional.

ESRS 1 ¶24 says an undertaking shall not disclose information prescribed by a disclosure requirement or datapoint if that information is not material.

EFRAG’s draft said “is not required to”. The Commission changed it deliberately.

Can your tool leave a datapoint out?four checks
A platform that fills every field it knows about is now producing a defect, not a thorough report.

The top-down route is an option, not a replacement

¶27 permits a top-down assessment; ¶28 preserves the bottom-up route, and the application guidance allows combining them.

A tool that only implements one of those has chosen your methodology for you.

“Complete” used to be a virtue in a reporting tool. Read ¶24 again.
Some paragraphs no longer exist.
Next — what a stale mapping still points at
Where each standard now endsE2 to E5
Anticipated financial effects were removed from the four topical environmental standards. The requirement survives elsewhere, in two named places.
07 · Deletions

Mappings that point at nothing.

Anticipated financial effects were removed from ESRS E2 to E5.

A tool still asking for E4-6 is asking for a paragraph that no longer exists.

The question to ask

Ask which ESRS version the mapping library targets, and what happens to a disclosure mapped to a deleted paragraph.

The honest answer is that it has to be re-mapped, not migrated.

Someone has to sign an opinion on the output.
Next — what an assurer asks for
08 · Assurance

What a CSRD assurer asks your tool to produce.

The opinion is a limited assurance engagement, and the empowerment to escalate to reasonable assurance was deleted.

Any page promising an escalation in 2028 is describing a provision that no longer exists.

Inside the assurance perimeterwhat the opinion covers
The perimeter is set by the Accounting Directive, not by the tool. A platform that covers only the disclosures covers part of it.

The limb most tools ignore

The opinion covers the process carried out by the undertaking to identify the information reported, not only the information itself.

That is a requirement to keep an auditable record of the materiality assessment, not just its conclusions.

Taxonomy Article 8 disclosures sit inside the perimeter too.

And who signs is a national question

The statutory auditor is the default, but Articles 34(3) and 34(4) are member-state options for a different auditor or an accredited independent provider.

And a limit on what it may ask your suppliers.
Next — the value-chain cap
May the tool send that questionnaire?three checks
The cap is measured on the preceding financial year, which is a different reference period from the scope test in the adjacent paragraph.
09 · The cap

What it may ask your suppliers.

A reporter may not require a smaller undertaking in its value chain to provide more than the voluntary standard asks.

A supplier-portal module that asks for everything is a compliance risk, not a feature.

And it protects the opinion too

The assurance opinion must be prepared in a manner that fully respects that right, so an over-broad questionnaire reaches the assurer as well.

£
You will have noticed no prices on this page.
Next — why there are none
10 · Price

Why there is no price on this page.

The published figures disagree with each other, and one page disagrees with itself.

Bands, as publishedand by whom
Each band is quoted from the page that published it. None is a market rate, and this page does not present one.

The one that contradicts itself

KnowESG gives a band of €20K to €200K in one place and €20K to €150K a few lines later, on the same page.

We have not verified any of these figures with any vendor, so we repeat them only as claims, attributed.

A range quoted from a page that contradicts itself is not a budget.
That is what the act requires of the software. What remains is how to put it to a vendor without taking anybody’s word for it.
Rise to the questions, and our own method.
Twelve questions, each with a provision behind it.
Next — what to ask a vendor
11 · The questions

What to ask before you buy.

Every question below exists because a provision creates the requirement, and the provision is named.

Tick the ones a vendor can demonstrate rather than describe.

Can they show you, not tell you?six of the twelve
A demonstration is a screen with your data in it. A roadmap is not a demonstration, and neither is a datasheet.

The six that are not in the instrument

Ask who owns the data if you leave, how a re-mapping is priced, and what happens in the year an annex is replaced again.

Ask for a reference from a company your size in your jurisdiction, and ask what the implementation actually cost that company.

If a vendor cannot show you the version field, it does not have one yet.
And here is how this page was made.
Next — our method
How this page was madefour steps
Reproducible means you can repeat it and get the same list. That is the test none of the twelve meets.
12 · Method

Our method, published.

Twelve ranking pages were opened and read in full on 4 September 2026, and every quotation on this page comes from one of them.

We rank nothing, because we have not tested the products.

What we did not do

We did not trial any platform, take a briefing, or accept a fee, so we make no claim about what any named product can do.

Buy against the act, not the list.
Then ask to see the field.

— · The refusal

Why there is no CSRD software ranking here.

Ranking a product means testing it, and we have not tested any of them.

Publishing an order without a method is the defect this page spends its first act describing.

Doing it ourselves would be the same defect with better citations.

What we can do is name the requirements, cite each to its provision, and show you who wrote every other list.

— · The omissions

What this page does not cover.

It does not price anything, recommend anything, or state what any named product is capable of.

It does not cover UK SRS tooling, which is a different regime with different standards and its own page.

No clients, no certifications, no accreditations, no affiliate fees.

Nor does it give the post-Omnibus population of in-scope companies, because no reliable figure exists and the one in circulation predates the reset.

— · Questions

CSRD reporting software: questions readers ask.

Do I need CSRD reporting software?
Only if the CSRD reaches you, and since 18 March 2026 far fewer companies are in scope. The test is cumulative: an undertaking is in scope only if it exceeds both €450 million net turnover and an average of 1,000 employees during the financial year. The United Kingdom is outside the CSRD, so a UK company is never in scope by being British — exposure comes from an EU undertaking of your own, securities on an EU regulated market, or the third-country regime. Buying a platform does not make you a reporter.
What is the single most useful question to ask a CSRD software vendor?
Ask them to show you the field that records which version of the ESRS a disclosure was prepared under. For a financial year starting in calendar 2026 an undertaking may apply one of three versions, and Article 2(2) of the delegated act requires it to state which one it applied. That makes standard-version tagging a hard requirement rather than a nicety — and of the twelve ranking pages read for this page, not one mentions it.
What are the three ESRS options for a financial year starting in 2026?
Article 2(1) of C(2026) 5010 gives three: ESRS (2023) as last amended by Delegated Regulation (EU) 2025/1416; ESRS (2026) in full; or a hybrid of ESRS (2023) plus eight named paragraphs of relief — ESRS 1 ¶27, ¶¶32–33, ¶¶74–75, ¶90, ¶91, ¶92, ¶106 and ¶110. The hybrid is not a blend of your own devising; the act lists the paragraphs. Article 2(2) then requires you to state which route you took.
Is the revised ESRS in force?
Not yet. C(2026) 5010 was adopted on 3 July 2026 and is subject to the European Parliament and Council scrutiny period, which runs two months from adoption and is extendable by a further two. It applies to financial years beginning on or after 1 January 2027 under its own Article 3. Note two traps: no OJ number exists yet, so it must be cited as C(2026) 5010 final and never as "(EU) 2026/xxxx"; and its entry-into-force date is an unresolved placeholder in the transmitted text, so no specific date should be printed for it.
How many ESRS datapoints are there now?
There is no single defensible number, and the figures in circulation are being misused. The Commission's own press release claims the revision cuts mandatory datapoints by over 60% and total datapoints by more than 70%. EFRAG's 61% is EFRAG's figure for EFRAG's own revised draft, and the Commission then made thirteen categories of modification to that draft. The widely-quoted ~1,144 is a total count from EFRAG's November 2022 letter about a draft of ESRS Set 1 — so subtracting a mandatory-only percentage from it produces a number that means nothing.
Why does the revision delete more total datapoints than mandatory ones?
Because ESRS (2026) removes every voluntary datapoint — the ones previously expressed as "may" disclosures. Deleting a category that was entirely voluntary reduces the total more than it reduces the mandatory count, which is why the two percentages differ and why quoting one for the other inverts the picture.
Can a tool still ask for ESRS E4-6 or E5-6?
Those paragraphs no longer exist. Anticipated financial effects were removed from the four topical environmental standards: ESRS E2 now ends at E2-5, E3 at E3-4, E4 at E4-5 and E5 at E5-5. The requirement survives in two other places — ESRS 2 ¶27 and ESRS E1-11 ¶¶38–40. A mapping library still pointing at E4-6 is pointing at nothing, and the fix is a re-mapping rather than a migration.
My platform says it is "ESRS ready". Is that enough?
Ask which version, and when the datapoint library was rebuilt. Annex I of Delegated Regulation (EU) 2023/2772 is replaced in its entirety by the revised act, so the new annex is not a subset of the old one — a library that was "updated" against the 2023 annex has not necessarily been rebuilt against the 2026 one. This page makes no claim about what any named product actually does.
Should a CSRD tool fill in every datapoint it knows about?
No, and this reversed on 3 July 2026. ESRS 1 ¶24 now says an undertaking "shall not" disclose information prescribed by a disclosure requirement or datapoint if that information is not material. EFRAG's draft said "is not required to"; the Commission changed it deliberately. So a platform that fills every field it can is producing a defect, not a thorough report, and completeness is no longer the right setting.
Does the revision force a top-down materiality assessment?
No. ESRS 1 ¶27 permits a top-down assessment, but ¶28 preserves the bottom-up route and the application guidance allows the two to be combined. A tool that implements only one of them has chosen your methodology for you, which is worth knowing before it is embedded in a year of data.
What will an assurer ask my software to produce?
More than the disclosures. The opinion is a limited assurance engagement covering the compliance of the sustainability reporting with the standards, the compliance of the Taxonomy disclosures under Article 8 of Regulation (EU) 2020/852, and — the limb most often missed — "the process carried out by the undertaking to identify the information reported". That last one means an auditable record of how the materiality assessment was carried out, not just its conclusions.
Does CSRD assurance escalate to reasonable assurance in 2028?
No. The empowerment to adopt reasonable-assurance standards was deleted by Omnibus I — recital (5) says "the requirement to adopt reasonable assurance standards should be removed", and Article 1(3) does it. There is no legislated escalation, and any page or vendor promising one is describing a provision that no longer exists. The deadline for limited-assurance standards moved to 1 July 2027, so a page citing 1 October 2026 is stale.
Who is allowed to sign the assurance opinion?
The statutory auditor by default, but Articles 34(3) and 34(4) of the Accounting Directive are member-state options — a member state may permit a different statutory auditor, or an accredited independent assurance services provider. So "who may assure us?" has up to 27 answers depending on where you file, and the cluster fact record holds no verified list of which member states have opened which option.
Can a supplier questionnaire module ask my suppliers anything it likes?
No. Article 19a(3) gives an undertaking in the value chain that does not exceed 1,000 employees the right to decline to provide information beyond what the voluntary standard asks — the VSME standard at Commission Recommendation (EU) 2025/1710, in its original version. Note the reference period differs from the scope test in the adjacent paragraph: the cap is measured on the preceding financial year, scope during the financial year. An over-broad questionnaire is a compliance risk, and the assurance opinion must be prepared in a manner that fully respects that right.
How much does CSRD reporting software cost?
We do not publish a figure, because no reliable one exists. The bands in circulation disagree with each other and one page disagrees with itself: KnowESG gives €20K–€200K in one place and €20K–€150K a few lines later, on the same page, while The QHSE Standard's quick-facts band is €35k–€140k. We have verified none of these with any vendor, so we repeat them only as those publishers' claims. A range quoted from a page that contradicts itself is not a budget.
Why does this page not rank the platforms?
Because ranking a product means testing it, and we have not tested any of them. Of the twelve ranking pages read for this page, none publishes a method you could repeat to get the same list, four are published by a company selling a product that appears on its own list, and one names a different leader in its prose than in its own numbered table. Publishing an order without a method is the defect this page describes; doing it ourselves would be the same defect with better citations.
Are the "best CSRD software" lists written by the vendors?
Some are, and not all of them behave the same way. Of the twelve pages read on 4 September 2026, four are published by a company that sells a product on its own list. Manglai names itself first in its opening sentence. The QHSE Standard's prose leads with Tekmon, and its own navigation carries a "Talk to Tekmon" call to action. But Socious sells a platform and ranks Workiva first rather than itself, and Watershed's guide states the datapoint figures correctly and attributes them — so vendor authorship is a fact to weigh, not an automatic disqualification.
Is CSRD software the same as UK SRS software?
No. They are different regimes with different standards, a different materiality basis and, at present, a different legal status — UK SRS is available for voluntary use and is required of nobody, while the CSRD is a directive with a transposition deadline of 19 March 2027 for Articles 1 to 3. A tool built around the ESRS datapoint model is not thereby a UK SRS tool, and this page does not cover UK SRS tooling.
— · The record

Every claim, and where it came from.

Requirements are cited to the provision that creates them; claims about other pages are quoted from those pages and linked.

Each entry says what kind of document it is — a directive, a delegated act, a recommendation, or a page published by somebody with something to sell.

Where a measure is adopted but not yet in force, it says so.

  • Accounting Directive 2013/34/EU — consolidated textConsolidated legislation, 02013L0034, current to 18 March 2026. Arts 19a(1) scope, 19a(3) the value-chain cap, 29a(1) the group analogue, and 34(1)–(4) assurance. ⚠ The consolidated text is AHEAD of the years it governs: Art 19a(1) already reads €450m and 1,000 employees, but that applies from FY2027.
  • Directive (EU) 2026/470 — Omnibus I, Official Journal PDFDirective. OJ L 470, 26 February 2026; in force 18 March 2026. Recital (5) and Art 1(3) remove the reasonable-assurance empowerment and move the limited-assurance standards deadline to 1 July 2027. The PDF view is used because the OJ HTML view truncates before Articles 5–7.
  • Directive (EU) 2022/2464 — the CSRDDirective. The instrument Omnibus I amends, and the one the software in this market is named after.
  • C(2026) 5010 final — the revised ESRSCommission delegated regulation, adopted 3 July 2026, amending Delegated Regulation (EU) 2023/2772. Art 2(1) gives three FY2026 options; Art 2(2) requires the undertaking to state which it applied; Art 3 sets application to financial years beginning on or after 1 January 2027. ⚠ ADOPTED, SUBJECT TO SCRUTINY — not yet in force, and no OJ number exists. Never cite it as “(EU) 2026/xxxx”.
  • Council 11667/26 — the transmitted delegated actCouncil cover note, received 3 July 2026. The transmission that starts the scrutiny period, and the reason the act can be cited precisely while it still has no OJ number.
  • C(2026) 5010 final — the AnnexThe annex to the delegated act. Annex I of Delegated Regulation (EU) 2023/2772 is REPLACED IN ITS ENTIRETY, which is why a datapoint library built against the 2023 annex is not a subset of the new one. Carries ESRS 1 ¶¶24, 27, 28 and the E2–E5 standards as replaced.
  • Delegated Regulation (EU) 2023/2772 — ESRS (2023)The delegated act the revised standards amend, and the version most existing mapping libraries were built against. The first FY2026 option points at it “as last amended by Delegated Regulation (EU) 2025/1416” — naming it without that amendment names a version the provision does not point at.
  • Commission Recommendation (EU) 2025/1710 — VSMECommission recommendation, 30 July 2025. The voluntary standard “in its original version” is the ceiling the value-chain cap points at, so it is the limit on what a supplier-portal module may ask a protected undertaking.
  • Regulation (EU) 2020/852 — the Taxonomy RegulationRegulation. Its Article 8 disclosures sit inside the assurance perimeter, which is a scope question for any tool claiming to produce an assurance-ready file.
  • Manglai — “7 best sustainability management software tools for the CSRD in 2026”A ranking list published by a company that sells a platform, which it names first in its own opening sentence. ✅ States the post-Omnibus scope test correctly. ❌ Describes the Art 3(1)(c) transitional relief as an automatic exemption; it is a member-state option, and its test is OR.
  • The QHSE Standard — “CSRD Software Comparison — 2026 Top 5”A ranking list on a domain whose own navigation carries a “Talk to Tekmon” call to action. ⚠ Its prose says the shortlist is “led by Tekmon, Quentic and Watershed”; its numbered list runs Quentic, Sweep, Workiva, Enablon, Greenly and does not contain Tekmon. ❌ States the pre-Omnibus in-scope population.
  • Socious — “10 Platforms Ranked for CSRD, ISSB, and AI Automation”A ranking list published by a platform vendor that ranks a competitor first rather than itself, and the only page in the set to publish named evaluation criteria. ⚠ Criteria are not a method: it does not say how anything was scored against them.
  • Watershed — “The best CSRD software in 2026: a buyer’s guide”A buyer’s guide published by a platform vendor. ✅ Its July 2026 update states the datapoint reduction correctly and attributes it — “over 60%” mandatory, “over 70%” total, “30%+” cost. Quoted here as the counter-example to the arithmetic errors elsewhere.
  • tinyctl — “Best CSRD Compliance Software in 2026”A roundup by a publisher with nothing on the list. ✅ The only page in the set to disclose its own method — it declares AI assistance and states it carries no affiliate links. ❌ Says the revision “cuts mandatory data points by roughly 70%, to somewhere around 320”, which swaps the mandatory and total percentages and applies the result to a draft total.
  • KnowESG — “CSRD Compliance Software: Compare EU Reporting Tools”A comparison describing itself as “independent” while operating a directory of “211+ ESG providers”. ❌ States two different repealed thresholds as current on one page, repeats the pre-Omnibus population, and gives its price band as €20K–€200K in one place and €20K–€150K in another.

Carried over, so no citation is lost

The fact record from which every entry is drawn is the cluster’s reference at uksrs.org.uk.

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