Revised ESRS 2026: What Has Changed for CSRD Reporting Teams?

The revised European Sustainability Reporting Standards reduce the volume and complexity of CSRD reporting, but they do not remove its core requirements. Companies that remain within scope still apply double materiality, report material sustainability information, prepare a sustainability statement within the management report, and support limited assurance.

What changes is how reporting teams determine, collect, organize, and present that information. The revised ESRS introduce fewer datapoints, a clearer materiality filter, more proportionate approaches to materiality assessment, new reliefs, and greater flexibility in selected areas such as estimates, value chain information, reporting boundaries, and presentation.

The European Commission adopted the revised ESRS on July 3, 2026. They are intended to apply from financial year 2027, with early application permitted for financial year 2026 once the delegated regulation becomes legally effective. At the time of writing, the Commission’s CSRD delegated acts page states that the regulation is not yet in force and will take effect after publication in the Official Journal. Companies considering early application should confirm the final legal status before proceeding.

This article focuses on changes to the reporting standards. The separate changes to CSRD scope were introduced through Directive (EU) 2026/470 and should be assessed according to the reporting period, group structure, jurisdiction, and national transposition.

Revised ESRS 2026 at a Glance

Reporting area	What has changed	What it means for reporting teams
Datapoints	Mandatory data points have been reduced by more than 60%, while total data points have been reduced by more than 70%.	Existing data inventories and disclosure maps will need to be updated rather than carried forward unchanged.
Double materiality	Double materiality remains, but the assessment can follow a clearer and more proportionate top-down approach.	Teams can focus first on topics likely to be material and use more granular assessment where it could change the conclusion.
Material information	The standards more explicitly direct companies not to report non-material information, except in defined circumstances.	Reports should become more focused, with supplementary information clearly separated so it does not obscure material disclosures.
Data and estimates	Reasonable estimates and information available without undue cost or effort have a clearer role.	Sources, assumptions, estimation methods, limitations, and improvement actions still need to be documented.
Value chain	The standards provide more proportionate approaches to value chain information, supported by a separate value chain cap.	Supplier requests should be targeted to the information genuinely needed for CSRD reporting.
Financial effects	Additional reliefs and phase-ins apply to anticipated financial effects.	Sustainability and finance teams still need a connected process for qualitative and quantitative assessment.
Climate and GHG reporting	Selected requirements and reporting boundary options have been clarified.	Companies should review their climate methods, organizational boundaries, assumptions, and disclosures.
Presentation	Companies have more flexibility to use summaries, appendices, cross-references, and an alternative structure with explanation.	The sustainability statement can be easier to navigate, but the reporting structure and rationale should remain clear.
Assurance	Limited assurance remains, while the standards aim to reduce unnecessary reporting and interpretive friction.	Assurance readiness continues to depend on evidence, controls, traceability, and documented judgment.

1. The Number of ESRS Datapoints Has Been Substantially Reduced

The most visible change is the reduction in data points. According to the European Commission, the revised standards reduce mandatory data points by more than 60% and total data points by more than 70%. The standards are also shorter and structured more clearly.

This does not mean that reporting teams can simply remove a fixed percentage of their existing data requests. The impact will differ by company because ESRS reporting continues to depend on materiality. Some retained requirements may still involve several data owners, business units, calculations, assumptions, and supporting documents.

Companies that have already reported under the 2023 ESRS may need to map their existing disclosures against the revised standards. This can help distinguish information that remains required, information that has changed, and information that may now be supplementary. First-time reporters can begin directly with the revised structure instead of building processes around requirements that no longer apply.

2. Double Materiality Remains, but the Assessment Can Be More Proportionate

Double materiality remains the basis of ESRS reporting. Companies continue to assess both how their activities affect people and the environment, and how sustainability-related risks and opportunities affect their financial position, performance, and development.

The revised ESRS 1 clarifies that companies are not expected to assess every possible impact, risk, or opportunity across every part of their operations and value chain. They may use a top-down approach, starting with the business model, activities, sectors, geographies, and value chain characteristics to identify topics that are likely to be material.

When materiality is clear at the topic or subtopic level, a company may reach its conclusion without assessing every individual impact, risk, or opportunity. A more detailed assessment is still needed where additional granularity could reasonably change the materiality conclusion. Companies can also combine top-down and bottom-up approaches across different topics.

This gives reporting teams greater flexibility, but it does not remove the need for a structured and supportable process. The basis of the assessment, information considered, thresholds, assumptions, stakeholder inputs, conclusions, reviews, and approvals should remain visible.

For companies updating their approach, this may be a useful time to review whether their double materiality assessment is focused on decision-useful conclusions rather than unnecessary scoring and documentation.

3. Material Information Is More Clearly Prioritized

The revised ESRS make the materiality filter more explicit. Except for specified supplementary disclosures, companies should not include information prescribed by an ESRS disclosure requirement or datapoint when that information is not material.

Companies may still include supplementary information required by other legislation or needed by a particular user. However, it should be clearly identified as information that did not result from the materiality assessment and presented in a way that does not obscure material disclosures.

The standards also clarify that fair presentation applies to the sustainability statement as a whole rather than to every individual datapoint. This should help reduce the tendency to treat every datapoint as equally important or to include excessive information simply to avoid perceived assurance risk.

For reporting teams, the practical task is not only to determine what to collect. It is also to decide what belongs in the sustainability statement, where it should appear, and how the report can remain balanced, understandable, and focused on material information.

4. Estimates and Partial Data Have a Clearer Place in Reporting

Complete direct data may not always be available, particularly across complex groups and value chains. The revised ESRS recognize that reasonable estimates are an essential part of sustainability reporting and do not make information less useful when significant assumptions and estimation methods are explained.

The standards use the concept of reasonable and supportable information available without undue cost or effort across materiality assessment, value chain scoping, metrics, and current and anticipated financial effects. The revised ESRS annexes also clarify that an exhaustive search is not required.

Where reliable direct or estimated data is available for only a defined part of the operations or value chain, a company may report a metric on a partial scope in certain circumstances. It should explain the limitation, the actions taken to improve coverage and quality, and the progress made over time. Specific rules continue to apply to Scope 1, Scope 2, and Scope 3 GHG emissions.

This is a relief from impractical data expectations, not a reason to leave data methods undocumented. Reporting teams will still need visibility into:

• whether information is direct, estimated, or based on a proxy;
• the source and reporting boundary;
• the assumptions and calculation method;
• known limitations;
• review and approval; and
• planned improvements for future reporting periods.

The revised approach makes a governed data process more important because the report must show not only the result, but also the basis on which that result was prepared.

5. Value Chain Data Requests Should Become More Targeted

Material impacts, risks, and opportunities may arise upstream or downstream, so value chain information remains relevant to CSRD reporting. At the same time, the revised framework seeks to reduce disproportionate requests to smaller companies.

The separate voluntary sustainability reporting standard adopted alongside the revised ESRS establishes the value chain cap. For CSRD reporting purposes, an in-scope company cannot require a value chain company with 1,000 employees or fewer to provide more information than the content covered by the voluntary standard. The cap is differentiated by company size: undertakings with 10 employees or fewer benefit from a narrower information cap, while a broader set of specified data points applies to undertakings with 11 to 1,000 employees. A reporting company may request additional information, but it must identify that the request exceeds the cap and explain that the value chain company has the right to decline it. The European Commission has explained these distinctions in its value chain cap guidance.

The cap does not mean that every supplier should be asked to provide the full set of information permitted by the standard. The Commission’s guidance emphasizes that reporting companies should request only the information they genuinely need.

This may require reporting teams to review supplier questionnaires, distinguish CSRD-related requests from other commercial or regulatory requests, and connect each requested datapoint with a material topic or disclosure need. A structured value chain management process can help teams understand where material matters arise and where direct data, estimates, or other supportable information may be appropriate.

6. Anticipated Financial Effects Have Additional Reliefs

Connecting sustainability-related risks and opportunities with financial effects has been one of the more difficult areas of implementation. The revised ESRS annexes acknowledge that anticipated financial effects are likely to involve estimates and that those estimates may change as better information becomes available. Updating an estimate in a later period does not necessarily mean that the previous disclosure contained an error.

The revised standards also provide circumstances in which quantitative information need not be reported—for example, where effects are not separately identifiable, measurement uncertainty is so high that the information would not be useful, or the company lacks the skills, capabilities, or resources to prepare the quantitative information. In such cases, related qualitative information and explanations may still be required.

The revised ESRS contain differentiated phase-ins for anticipated financial effects. Subject to specified climate-related exceptions, wave-one undertakings may omit all anticipated-financial-effects information for financial years before FY2028 and quantitative information for financial years before FY2030. Other undertakings may omit all such information for their first two reporting years and quantitative information for their first four reporting years. The applicable relief therefore depends on the undertaking’s reporting category and reporting year.

For reporting teams, this calls for closer coordination between sustainability, finance, risk, strategy, and relevant operational teams. The process should preserve the assumptions, methodologies, ranges, affected financial statement areas, review history, and reasons for using any available relief.

7. Reporting Boundaries and Presentation Offer More Flexibility

The revised ESRS introduces greater discretion in selected areas of reporting boundaries, aggregation, and presentation.

For GHG emissions, ESRS 1’s reporting boundary—corresponding broadly to the financial-control approach under the GHG Protocol—is the starting point. Revised ESRS E1 alternatively permits the equity-share or operational-control approach defined in the GHG Protocol. The selected approach must be disclosed and applied consistently, while specific ESRS rules concerning leases, employee-benefit assets, joint operations and reporting boundaries continue to prevail.

The standards also clarify that the level of detail used to perform a materiality assessment does not automatically determine the level at which information must be reported. Companies can aggregate or disaggregate information based on what is needed to present material information clearly without obscuring important differences.

For the sustainability statement itself, the revised ESRS allow the use of an executive summary, appendices, separate subparts, internal cross-references, and cross-reference tables. A company may also use a structure other than the standard four-part sequence if it provides a reasoned explanation and continues to meet the other presentation requirements.

These options can improve readability, but flexibility should not come at the cost of consistency. Reporting teams should document structural decisions, maintain clear links between requirements and disclosures, and consider whether readers can understand how the information connects across the report.

8. Selected Topical Requirements Have Also Changed

The revised ESRS include several targeted changes across the environmental and social standards. Some of the more practical changes include:

• Climate transition plans: Where a company reports a transition plan with targets that are not compatible with limiting global warming to 1.5°C, it must be transparent about that position. If the company does not have a transition plan with the specified key features, it discloses that fact and indicates whether and when it expects to adopt one.
• Climate scenario analysis: Scenario analysis is not prescribed as a universal method. When it is used, the company discloses relevant information about the scenarios, scope, assumptions, and timing.
• Pollution: Reporting on microplastics is limited to primary microplastics, while the materiality of pollutants is informed by a managerial assessment that considers the company’s activities and sector.
• Substances of very high concern: A new one-year phase-in applies in specified circumstances for companies that use articles containing these substances.
• Human rights and discrimination incidents: The standards clarify that reporting relates to substantiated, verified instances.

These changes will not affect every company in the same way. Reporting teams should review the standards connected to their material sustainability matters rather than treating every technical amendment as universally applicable.

What Has Not Changed Under the Revised ESRS?

The revised standards simplify the reporting framework, but the underlying CSRD process remains recognizable.

• Double materiality remains the basis for determining material sustainability information.
• Material impacts, risks, and opportunities remain central to the sustainability statement.
• ESRS reporting remains part of the management report.
• Relevant value chain information remains necessary where material.
• Limited assurance remains part of CSRD reporting.
• Governance, evidence, review, and accountability remain important throughout the reporting cycle.

Fewer data points may reduce volume, but they do not turn CSRD reporting into a simple document-production exercise. The final sustainability statement still depends on connected work across materiality, data, policies, actions, metrics, targets, evidence, controls, review, and approval.

What Should CSRD Reporting Teams Do Now?

The revised ESRS will affect companies differently depending on whether they have already reported under the 2023 standards or are preparing for their first reporting cycle. The following actions can help both groups prepare.

Prepare for Revised ESRS Reporting with EcoActive

EcoActive is an AI-native, end-to-end ESG disclosure management platform that brings CSRD requirements, double materiality, data collection, value chain information, energy and climate-related assessments, governed workflows, assurance preparation, and report generation into one environment.

Teams can start with information from previous reports and existing sources, identify gaps against the revised requirements, coordinate data collection and review, maintain supporting evidence, and carry approved information into the next reporting cycle. Quantitative and qualitative information remains connected with the requirements it supports, helping teams manage changes without losing context or traceability.

Users can apply native AI to assist with reviewing previous reports, identifying potentially reusable information, supporting gap assessment, and preparing report content. AI-assisted outputs remain subject to human review, while materiality judgments, regulatory interpretation, reporting decisions, and final approvals remain with responsible professionals.

The EcoActive AI Trust Centre provides visibility into where AI was used, who initiated it, what information was affected, and how the output was reviewed. This supports governed, human-in-the-loop use of AI across the CSRD reporting process.

Frequently Asked Questions

When will the revised ESRS apply?

The revised ESRS are intended to apply to financial years beginning on or after January 1, 2027. Companies may choose to apply them for financial year 2026 once the delegated regulation becomes legally effective. At the time of writing, the European Commission states that the regulation is not yet in force pending publication in the Official Journal.

Does double materiality still apply under the revised ESRS?

Yes. Double materiality remains the basis for ESRS reporting. The revised standards clarify how companies can apply a more proportionate top-down, bottom-up, or combined assessment.

Do fewer data points mean companies need less data governance?

No. The volume of information may be lower, but reported data and narrative disclosures still need clear sources, methods, assumptions, evidence, review, approval, and traceability.

Is climate scenario analysis mandatory under the revised ESRS?

Climate scenario analysis is not prescribed as a universal method. It may be used to support the identification and assessment of climate-related risks and opportunities. When it is used, the company provides relevant information about the scenarios, scope, assumptions, and timing.

Do the revised ESRS remove CSRD assurance requirements?

No. Limited assurance remains part of CSRD reporting. The simplifications are intended to reduce unnecessary reporting and make the standards clearer without removing the need for assurance-ready information and supporting documentation.

See how EcoActive can help your team manage revised ESRS requirements across double materiality, data collection, review, evidence, and CSRD reporting within one governed, AI-native environment.