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ESRS Reporting Standards under CSRD

Adopted 2026-06-29 · ≈ 2 min read · Dirk Baaijen

Commission Delegated Regulation (EU) 2023/2772 establishes twelve sector-agnostic European Sustainability Reporting Standards (ESRS) that undertakings must use when preparing their sustainability report under the CSRD.

Short answer: Commission Delegated Regulation (EU) 2023/2772 — applicable from 1 January 2024 — establishes twelve ESRS: two cross-cutting standards (ESRS 1 and ESRS 2), five environmental standards (E1–E5), four social standards (S1–S4), and one governance standard (G1). Undertakings report on the basis of a double materiality assessment, covering only those topics that are material to them. The Omnibus proposal of February 2025 and the 'stop-the-clock' directive of April 2025 have delayed entry into application for companies not yet reporting and may narrow the scope to undertakings with more than 1,000 employees.

What are the ESRS?

The European Sustainability Reporting Standards (ESRS) are the substantive reporting requirements that flow from the Corporate Sustainability Reporting Directive (CSRD, Directive 2022/2464/EU). They are set out in Commission Delegated Regulation (EU) 2023/2772, adopted on 31 July 2023 and published on 22 December 2023.

The regulation establishes a total of twelve standards, organised in two layers:

Cross-cutting standards (2)

  • ESRS 1 – General Requirements (reporting principles, double materiality)
  • ESRS 2 – General Disclosures (mandatory for all reporting undertakings)

Topical standards (10)

  • Environmental: ESRS E1 (Climate Change), E2 (Pollution), E3 (Water and Marine Resources), E4 (Biodiversity and Ecosystems), E5 (Resource Use and Circular Economy)
  • Social: ESRS S1 (Own Workforce), S2 (Workers in the Value Chain), S3 (Affected Communities), S4 (Consumers and End-users)
  • Governance: ESRS G1 (Business Conduct)

Core concept: double materiality

ESRS 1 introduces double materiality: undertakings assess both financial materiality (risks and opportunities for the undertaking itself) and impact materiality (the undertaking's effects on people and the environment). Full disclosure is required only for topics that are material on at least one dimension. ESRS 2 is the sole standard that is mandatory for all reporting entities regardless of the materiality outcome.

Phasing and scope

The first wave (financial year 2024, reporting in 2025) covered large public-interest entities (PIEs) with more than 500 employees. For undertakings originally scheduled to report from financial year 2025 or 2026, the application has been delayed by the 'stop-the-clock' directive (April 2025). The Omnibus simplification package (Commission proposal COM(2025) 80, February 2025) proposes to limit the CSRD scope to undertakings with more than 1,000 employees; as of mid-2026 this proposal remains in the EU legislative procedure.

Status of the revised ESRS

On 3 December 2025, EFRAG published draft simplified ESRS as technical advice to the Commission, following a public consultation in summer 2025. The Commission is now preparing a new delegated act based on this advice. Until that act is formally adopted, Commission Delegated Regulation (EU) 2023/2772 remains the applicable legal basis.

Sources

  1. https://eur-lex.europa.eu/eli/reg_del/2023/2772/oj/eng
    Commission Delegated Regulation (EU) 2023/2772 — adopted 31 July 2023, published 22 December 2023 in the Official Journal; contains the full ESRS Set 1…
  2. https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202302772
    Official Journal text OJ L 2023/2772 — confirms twelve standards and application date of 1 January 2024
  3. https://www.efrag.org/en/draft-simplified-esrs
    EFRAG draft simplified ESRS (3 December 2025) — technical advice to the Commission; not yet a formally adopted delegated act
  4. https://finance.ec.europa.eu/capital-markets-union-and-financial-markets/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en
    European Commission — CSRD phasing overview and Omnibus proposal (stop-the-clock, April 2025)

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Dirk Baaijen

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