Revised ESRS: key changes
The revised ESRS retains the general structure of the ESRS, whilst substantially simplifying the individual disclosure requirements. They also reduce the number of data points, give greater priority to quantitative information (at the expense of descriptive text), distinguish more clearly between mandatory and voluntary data points, clarify the application of dual materiality and improve consistency with other EU legislation and international sustainability reporting standards.
Key changes include:
Materiality and fair presentation
Dual materiality is retained, but a “top-down” assessment approach is now expressly permitted, alongside the “bottom-up” approach. In the top-down approach, the company starts with its business model, strategy, sectors of activity, geographical areas and value chain to identify material issues, whilst in the bottom-up approach, it starts with specific impacts, risks and opportunities to assess their materiality. Fair presentation is a new requirement that demands a faithful representation of the company in its disclosure of information; that is, the company must present a complete, neutral and accurate representation of its material impacts, risks and opportunities – the information disclosed must be comparable, verifiable and understandable. Fair presentation is assessed in relation to the sustainability report as a whole, taking into account the overall picture conveyed by the information disclosed in the sustainability report rather than individual disclosures considered in isolation (this may result, for example, in the addition of entity-specific information).
Aggregation, disaggregation and geographical information
Companies now have greater discretion to determine the appropriate level of aggregation and disaggregation of information and to take relevant geographical circumstances into account when assessing materiality and preparing disclosures.
Omission of information
Commercially sensitive information, trade secrets, classified information and other legally protected information may be omitted in accordance with the conditions set out in the revised ESRS.
Expected financial effects
Reporting remains mandatory in relation to material risks and opportunities. However, estimates and subsequent changes to those estimates are not treated as reporting errors, and other transitional exemption provisions also apply.
Greenhouse gas emissions
Companies may choose between the financial control approach and the operational control approach to determine the scope of disclosure, thereby facilitating alignment with international standards. The chosen approach must be applied consistently and explained in the sustainability statement.
Pollutants, microplastics and substances of concern
The revised ESRS narrow the scope of and clarify certain environmental disclosure requirements, including the treatment of primary microplastics, material pollutants and substances of concern, including substances of very high concern.
Human rights-related incidents
The revised ESRS amend the requirements regarding the reporting of human rights-related incidents and incidents of discrimination, reducing the information required in certain circumstances.
Alignment with the CSDDD
Rechnical adjustments have been made to improve alignment between the ESRS and the Directive on corporate sustainability due diligence — Directive (EU) 2024/1760 — with regard to disclosures relating to due diligence.
The Voluntary Standard
The Voluntary Standard is available to companies that are not subject to the sustainability reporting obligations set out in the CSRD and is structured into two modules:
Core module
Covers general information, the basis for preparation, sustainability-related practices and policies, certain environmental and labour-related information, as well as basic information on governance.
Comprehensive module
Complements the core module with disclosures relating to the business model and strategy, climate targets and transition information, climate-related risks, additional labour-related information, human rights policies, certain revenues and governance-related information. The core module forms the basis for the application of the comprehensive module.
A key feature of the Voluntary Standard is the value chain cap. Under the Voluntary Standard, a company subject to the reporting obligations under the CSRD may not require companies in its value chain with an average of no more than 1,000 employees to provide sustainability information going beyond the data points listed in Annex II. A shorter list of data points applies to companies with 10 employees or fewer.
In turn, Directive 2013/34/EU (the “Accounting Directive”), as amended by the Omnibus I package, introduces the concept of a “protected company”, which covers companies in the value chain that meet the aforementioned employee threshold. The Accounting Directive expressly provides that companies subject to sustainability reporting obligations may not require protected companies, through contractual provisions, to provide information exceeding the limits established by the Voluntary Standard (failing which such provisions shall not be binding). Furthermore, the Accounting Directive grants protected companies the right to refuse to provide information exceeding the limits set out in the Voluntary Standard.
These limits apply only to information requested for the purposes of a company's own reporting under the CSRD and do not affect other statutory information requirements.
Finally, it should be noted that whilst the voluntary standard represents a limit to be observed in requests for information from the value chain, it may also constitute an obligation for those companies, provided that it is included in their contracts.
Entry into force and application
The two delegated acts have different dates of entry into force.
The Revised ESRS Regulation enters into force on 10 November 2026 and applies to financial years beginning on or after 1 January 2027. The Revised ESRS will therefore, as a general rule, apply to sustainability statements relating to financial years beginning in 2027, which will typically be published from 2028 onwards.
For financial years beginning between 1 January 2026 and 31 December 2026, companies falling within the scope of Delegated Regulation (EU) 2023/2772 may choose between the current ESRS, as last amended by Delegated Regulation (EU) 2025/1416, and the Revised ESRS. Alternatively, they may apply the current ESRS in conjunction with eight specific exemptions introduced by the Revised ESRS, relating, among other aspects, the top-down approach to assessing double materiality, undue costs or burdens and value chain limitations, new acquisitions and disposals, metrics for non-significant activities, the partial scope of value chain reporting, joint operations, the presentation of disclosures under the Taxonomy in a separate appendix, and the summary. Companies applying any of these versions must clearly state, in their sustainability statement, which version they have applied.
The Regulations for the Voluntary Standard came into force on 24 September 2026. The Voluntary Standard has been available for voluntary application since that date. The upper limit for the value chain applies to financial years beginning on or after 1 January 2027.
