European Sustainability Reporting Standards — the twelve, and what changed in 2026

Six documents decide what ESRS means, and three of them are from 2026

ESRS is not one text.

It is a directive, a delegated regulation carrying the standards, and a run of amending instruments — and knowing which is which is the difference between reading the law and reading a summary of a version of it.

The three that changed the position most recently are the "stop-the-clock" postponement of April 2025, the Omnibus amendments of February 2026, and the two delegated acts adopted on 3 July 2026One replaces the standards; the other establishes the voluntary standard that defines the value-chain cap. Both are in the same scrutiny window, so they will take effect together. that are still in scrutiny.

Everything on this page is traceable to one of them, and the full list is in the sources at the foot.

The twelve European Sustainability Reporting Standards — two cross-cutting, ten topical

The European Sustainability Reporting Standards, as Set 1, comprise twelve standards: two cross-cutting and ten topical, split across environment, social and governance.

The 2026 revision replaced the text of both annexes in full but kept the architecture — still two cross-cutting standards and ten topical ones, in the same four reporting areas.

One naming change matters, because every list published before July 2026Including the technical documentation for the 2023 set, which remains live and correct for its own version. Two versions of the same standard now coexist, and a list is only wrong if it does not say which one it describes. has it wrong: ESRS E3 is now "Water", and marine resources moved into E5 as a resource-inflow category.

Only ESRS 2 applies unconditionally.

Every other standard applies only where the company's double materiality assessmentThe test of whether a topic matters, run in two directions: the company's impacts on people and the environment, and the effect of sustainability matters on the company. Chapter 11 sets out how the 2026 revision changed the method. says the topic is material — which is why two companies in the same sector can publish statements of very different lengths and both be compliant.

The revised European Sustainability Reporting Standards adopted on 3 July 2026 are not law yet

On 3 July 2026 the Commission adopted a delegated act, C(2026) 5010 final, replacing Annexes I and II of Delegated Regulation (EU) 2023/2772 in full.

It has no "(EU) 2026/…" number, because it has not been published in the Official Journal.

Adopted delegated acts pass to the European Parliament and the Council for a two-month scrutiny period, extendable by a further two monthsEither co-legislator may object within the window, and either may extend it. Silence is what lets the act proceed to publication, so "no news" here is the expected path rather than a delay., and take legal effect only on publication afterwards.

As at 6 August 2026 that window is open, and EFRAG's own site carries the same caution — the revised ESRS "will become legally effective only after its publication in the Official Journal".

The revised standards apply to financial years beginning on or after 1 January 2027So a December year-end reports under them for the first time in the annual report published in 2028. A June year-end reaches them a year later than a calendar-year peer., with FY2026 a three-way choice covered in chapter 11.

There is one planning consequence nobody states plainly: EFRAG confirmed on 28 July 2026 that no Implementation Guidance exists for the revised set, and the draft revised datapoint list and draft XBRL taxonomy were only tabled at its Sustainability Reporting Board on 29 July 2026.

Eight things about the European Sustainability Reporting Standards that were true in 2024 and are not true now

The largest problem with ESRS guidance in August 2026 is not that it is thin.

It is that a great deal of it is confidently wrong, because it was written before Directive (EU) 2026/470 and never revisited.

Each row below is a claim still in wide circulation, with the instrument that displaced itEvery correction here is traceable to a numbered article or recital, not to commentary. Where an instrument is adopted but not yet published, the page says so rather than treating adoption as force..

Two of them are load-bearing for planning: sector-specific ESRS will not exist, and reasonable assurance is not coming.

If either is in a budget or a roadmap, it is money committed against a rule that was repealed.

What the revision actually removed, and what the saving is worth

The headline is a cut in datapoints, and the two numbers in circulation are both correct because they measure different things.

The Commission's explanatory memorandum states a 61% reduction in mandatory datapoints; its press release states more than 60% of mandatory and more than 70% of total datapoints, the second figure including the voluntary ones that were deleted outright.

The mechanism is structural rather than cosmeticThe reduction did not come from deleting topics. It came from removing optionality and from moving requirements closer to the disclosure they serve, which is why the twelve standards survive intact.: every voluntary "may" datapoint is gone, Application Requirements were cut and moved next to the disclosure they serve, and the Minimum Disclosure Requirements were replaced by General Disclosure Requirements sitting inside ESRS 2.

The saving the Commission claims is more than 30% of reporting cost per company, averaging 34% of baseline across 2027 to 2031 and reaching an estimated EUR 3.7 billion cumulatively, or EUR 4.7 billion once value-chain effects are counted.

Those are Commission estimates of a futureModelled against a baseline the Commission does not publish in full. They are the best available figures and they are also an interested party's figures; both things are true., not observed outcomes, and the page states them as such.

The practical caution is simple: the revised datapoint list is still in draft, so anyone sizing a data-collection programme in August 2026 is working from the 2023 list and should expect it to move.

Who has to report against the European Sustainability Reporting Standards

Directive (EU) 2026/470 rewrote the first subparagraph of Article 19a(1) of the Accounting Directive, and the replacement wording is a cumulative test on two criteria.

An undertaking reports if it exceeds a net turnover of EUR 450,000,000 and an average of 1,000 employees during the financial year.

Both, not either — and the balance-sheet-total criterionUnder the old test an undertaking was "large" if it met two of three: 250 employees, EUR 50m turnover, EUR 25m balance sheet. That structure is gone from CSRD scope entirely. that used to sit in the "large undertaking" test has no role here at all.

Article 29a mirrors the same test at consolidated group level.

There are three routes into the regimeAn EU undertaking above the thresholds in its own right; a non-EU parent reached through Article 40a; and the value-chain cap, which is not a reporting obligation at all but is how most UK businesses will meet CSRD. and they are genuinely different obligations, which is why the instrument below asks about all three rather than one.

For UK-specific scope questions, the fuller treatment is on CSRD for UK companies.

The reporting years, after two rounds of postponement

The timetable in Article 5(2) of the CSRD has been amended twice: by the "stop-the-clock" Directive (EU) 2025/794 in April 2025, and again by Directive (EU) 2026/470.

The result is a single scope gate from FY2027 rather than a sequence of waves.

The point most guidance still misses is what happens to wave oneThe roughly 1,535 NFRD-legacy public-interest entities that began reporting for financial year 2024. They are the companies that built CSRD processes first, and a large share of them are below the new thresholds..

Those companies — the NFRD-legacy large public-interest entities above 500 employees — report for financial years starting between 1 January 2024 and 31 December 2026, and then, if they are below EUR 450m or 1,000 employees, they simply stop.

Recital 31 of the amending directive says so in terms"Undertakings falling within the scope of point (a) but not within the scope of point (b) as amended will fall outside the scope of this Directive as of financial years starting on or after 1 January 2027.".

A separate provision lets member states exempt sub-threshold undertakings for financial years starting between 1 January 2025 and 31 December 2026, so a group with subsidiaries in three member states can face three different answers for 2026.

How a UK group is reached — and which entity actually files

Article 40a is the provision that reaches non-EU parent undertakings, and the common description of it is wrong in a way that matters.

It does not place an obligation on the UK company.

It obliges the EU subsidiary or EU branchArticles 40c and 40d put the duty on that entity's directors, or on the branch itself. A UK board that assumes its Dutch subsidiary reports only on Dutch operations has the shape of this wrong. to publish a sustainability report drawn up at the level of the ultimate non-EU parent or its group, with responsibility resting on that subsidiary's directors or on the branch.

So a UK plc whose Dutch subsidiary crosses the threshold ends up with a group-level report about the whole UK group, filed in the Netherlands.

Three tests must all be met, and the turnover test is measured on EU-generated revenue over two consecutive yearsNot global revenue, and not a single-year snapshot. A group that crosses the line in one year and falls back the next is outside the test., in euro.

For a sterling-reporting group sitting near EUR 450m, the exchange-rate assumption is the difference between in and out of scope, and there is no relief for that.

One new derogation is worth knowing: where the non-EU parent is a financial holding undertaking whose subsidiaries operate independently of one another, its EU subsidiaries and branches may decide not to publish.

The standard UK groups will report under is still being consulted on

EFRAG published the ESRS-40a Exposure Draft on 23 July 2026, opening a 100-day public consultation that closes on 31 October 2026.

Technical advice goes to the Commission in January 2027, and a delegated act follows after that — roughly a year before the first reporting year begins.

The draft keeps the same twelve-standard architecture and strips out everything except impactsRisks, opportunities, resilience and dependencies are excluded by the directive itself, not by EFRAG's choice. Article 40a reporting is a one-directional account of what the group does to people and the environment..

The contested part is a proposed mixed approach: for every topic except climate, an in-scope group could limit its reporting to EU-related impacts — those arising from EU activities and from products and services sold into the EU — while climate stays global.

For a UK group with a small European footprint and a large one elsewhere, that election is the difference between a European report and a worldwide one.

It is worth knowing that EFRAG is consulting on it under protestA letter from the Sustainability Reporting Board's chair to DG FISMA on 6 July 2026 records the reservations and the vote. Publishing that letter alongside the draft is unusual and it is a signal about how settled the proposal is..

Its Sustainability Reporting Board approved the draft 13–0 with four abstentions while recording "clear and broadly shared reservations" about the mixed approach, which is in the consultation "because, and only because, this reflects the Commission's request".

A UK group that expects to be caught in FY2028 can still respond to the consultation.

Double materiality survived the Omnibus, but the way you assess it changed

The amended Article 19a(1) keeps both limbs word for word: information necessary to understand the undertaking's impacts on sustainability matters, and information necessary to understand how sustainability matters affect its development, performance and position.

Nothing in Directive (EU) 2026/470 removes or qualifies either.

What changed sits in the revised ESRS 1, and it is a change of method rather than principleThe question a company must answer is identical. What moved is how much process the standard prescribes for answering it, and how much of the topic tree it must walk to get there..

A top-down pathway is now codified, undue-cost-or-effort and value-chain limitations are written in, and the Appendix A list of topics is no longer mandatory — it is non-binding guidance, and its sub-sub-topic tree is gone.

That last point has a practical edge for anyone who has already done this workMost wave-one reporters built their assessment against the 2023 Appendix A tree because it was mandatory. That work is not wasted; it is simply no longer the required depth..

An assessment built on the 2023 Appendix A tree is now more granular than the standard requires, which is a de-scoping decision rather than a compliance problem — but it is a decision somebody has to take deliberately.

One boundary is worth naming: double materiality does not apply under Article 40a, because that regime is impact-only by operation of the directive.

For a financial year 2026 report, three versions of ESRS are available

Article 2 of the 3 July delegated act gives companies reporting on financial year 2026 a choice of three, and requires them to disclose which one they used.

Most coverage presents this as a compliance fact.

It is a decision with trade-offsAdopting the revised standards early avoids a restatement but commits to a text that is not yet in the Official Journal and has no implementation guidance. Staying on the existing standards is safer and, for a company still in scope next year, more expensive., and the right answer depends on whether the company expects to still be in scope in FY2027.

A company that will fall out of scope has little reason to adopt the revised standards early; a company that will remain in scope has every reason to, because it avoids restating a year later.

The middle route — the 2023 standards plus eight named reliefsESRS 1 paragraphs 27, 32 to 33, 74 to 75, 90, 91, 92, 106 and 110. Specific paragraph references, applied early, and nothing beyond them. from the revised ESRS 1 — is the pragmatic one, and it is the least understood.

The eight reliefs are specific paragraph references, not a general easement, and the tabs below list them.

Most UK companies will meet CSRD as a supplier, not as a reporter

The provision that will touch the largest number of UK businesses is not a reporting obligation at all.

Directive (EU) 2026/470 creates a value-chain cap: an undertaking in a reporting company's value chain that does not exceed an average of 1,000 employees is a protected undertaking, and it has a statutory right to decline requests for information beyond what the voluntary standard covers.

The protection is not limited to SMEsThe cap is drawn by headcount, not by the Accounting Directive's size categories. A company with 900 employees and substantial turnover is protected; one with 1,100 and modest turnover is not., and a contractual clause purporting to override it does not bind.

The reporting company also carries a positive duty: it must tell the protected undertaking which parts of its request exceed the cap, and that it may refuse.

There is one boundary that will catch people out, and it is the reason a blanket refusal is the wrong instinctRefusing on cap grounds a request that has a different legal basis puts the supplier in breach of a rule the cap never touched. The useful question is which of three categories a request falls into, not whether it can be refused..

The cap applies only to information sought for sustainability reporting under the Accounting Directive.

A request driven by deforestation rules, forced-labour rules, the customer's own risk management, or an existing contract sits outside it entirely.

The companion voluntary standard, C(2026) 5011 final, defines where that line falls; like its sibling it was adopted on 3 July 2026 and is not yet in force.

Limited assurance is now the destination, not a staging post

The original CSRD design was limited assurance first, with a power for the Commission to move to reasonable assurance later.

Directive (EU) 2026/470 removed that power, and recital 5 gives the reason plainly — to avoid an increase in the cost of assurance.

Reasonable assuranceA higher level of comfort: the assurance provider gives a positive opinion that the information is fairly stated, rather than the negative "nothing has come to our attention" of a limited engagement. It costs materially more. will not be mandated unless the EU legislates again.

Limited assurance itself remains mandatory, and the Commission is still required to adopt assurance standards by delegated act — but the deadline moved from 1 October 2026 to 1 July 2027.

In the meantime there is no binding EU standardPractitioners work to national requirements and to the CEAOB guidelines, which means the depth of a limited-assurance engagement is not yet uniform across the EU..

The reference point is the CEAOB's non-binding guidelines of 30 September 2024, and the Commission wrote to the CEAOB on 27 January 2026 refocusing its mandate onto EU-specific add-ons and carve-outs to ISSA 5000, with advice due 30 September 2026.

For a UK group the asymmetry is worth naming: an EU reporting subsidiary buys limited assurance indefinitely, while the same group's UK sustainability reporting carries no mandatory assurance at all.

What it costs, and why nobody credible publishes a number

Every incumbent guide to ESRS is silent on cost, and the silence is not an oversight.

There is no published, observed figure for what a CSRD sustainability statement costs to produce, because the regime is three reporting cycles old and the firms that know are the firms selling the work.

What does exist is the Commission's own modelling, and it is a claim about a reduction, not a levelA 34% saving against an unpublished baseline tells you the direction of travel and nothing about the absolute number. Both facts are useful; only one of them is a budget..

The useful thing to give a finance director is therefore not a total but a shape — where the money goes, and which lines are one-off against recurring.

The table beside this sets out that shape, drawn from what the regime actually requires rather than from a survey.

Two lines in it are genuinely unbounded at the moment: the double materiality assessment, because the revised standard has no implementation guidance yet, and digital tagging, because the taxonomy for the revised standards is a draft.

Anyone quoting a fixed price for either in August 2026 is pricing a specification that does not exist.

Digital tagging is suspended, and the taxonomy for the revised standards is still a draft

CSRD required sustainability statements to be marked up in a machine-readable format, and companies had begun buying tooling for it.

The amended Article 29d now says that until the marking-up rules are adopted in the ESEF delegated regulation, undertakings are not required to mark up their sustainability reporting.

The obligation is suspended rather than removedArticle 29d still contains the mark-up requirement. What it now says is that it does not bite until the ESEF delegated regulation carries the rules for it., so the tooling question is deferred, not answered.

The picture underneath is the same: EFRAG published an XBRL taxonomy for ESRS Set 1, but the taxonomy for the revised standards was only tabled in draft at its board on 29 July 2026.

The sustainability statement still has to sit inside an XHTML management report under ESEF, so the containing format is settled even while the tagging of its contents is not.

Anyone specifying a reporting system in 2026 should treat the tagging layer as a moving target and buy the ability to change it.

What happens if you get it wrong is a national question, and mostly unanswered

There is no EU-level penalty for a defective sustainability statement.

Sanctions sit in national law under the Accounting and Transparency Directives, and they vary widelyFrom administrative fines to public statements naming the company to personal liability for directors. The same defect can carry very different consequences in two member states. — from administrative fines to public statements to director liability.

The honest position in August 2026 is that the post-Omnibus enforcement regime largely does not exist yet, because member states have until 19 March 2027 to transpose the amendments.

Any table of CSRD fines circulating today describes the pre-Omnibus national rules, some of which will change.

One number is settled, and it belongs to the due-diligence directiveThe CSDDD, Directive (EU) 2024/1760. It is a separate regime with separate thresholds, and Omnibus raised those to EUR 1.5 billion turnover and 5,000 employees. rather than this one: the Omnibus capped the maximum CSDDD penalty at 3% of net worldwide turnover, where the previous text set 5% as a floor.

The directive also creates new statutory grounds to omit information — serious commercial prejudice, trade secrets, classified information, and information prejudicial to a person's privacy or security — with an express carve-out for defence undertakings.

Notably, the fact that competitors outside the EU face no equivalent obligation does not count as commercial prejudice.

ESRS, UK SRS and IFRS S1 and S2 — and why one report will not serve both

A UK group with an EU reporting obligation can end up preparing two sustainability reports on two different definitions of materiality, and there is no equivalence route between them.

UK SRS is the UK's adoption of the ISSB standards with six UK amendments, published by the Department for Business and Trade on 25 February 2026, and it uses single, financial materiality.

ESRS uses double materiality, and its impact limb has no IFRS equivalentIFRS S1 and S2 ask what sustainability matters do to enterprise value. Nothing in them asks what the company does to the world, which is the half of ESRS that cannot be satisfied by a UK SRS process. at all.

Reporting under UK SRS does not discharge an EU subsidiary's CSRD obligation, and reporting under ESRS does not discharge a UK listing rule.

Climate is where the overlap is real: ESRS E1 is interoperable with IFRS S2, and EFRAG and the IFRS Foundation published joint interoperability guidance in May 2024.

That guidance is mapped against the 2023 ESRSPublished May 2024, before the revision existed. The climate mapping is unlikely to have moved much; the surrounding references have., not the revised set, and nobody has yet republished it — so a group relying on it in 2026 should treat the mapping as indicative.

The practical answer most large groups reach is one data platform and two presentations, with the impact limb and the non-climate topical standards carried as ESRS-only work.

What is worth doing in August 2026, and in what order

The single most valuable action this month is not data collection.

It is re-running scope, because a large number of companies that budgeted for CSRD are no longer in it, and a smaller number that assumed they were safe are reached through Article 40a.

The order below puts the decisions that could waste money firstScope, member state, and version election. Each of them can invalidate work done before it, which is why they come before any data collection., and the work that cannot be wasted last.

Nothing here requires the revised standards to be in force, which is deliberate — every item is actionable while the scrutiny window is open.