Revised CSRD sustainability reporting standards published for consultation

One of the key elements of the Omnibus sustainability simplification agenda is the revision of the sector-agnostic CSRD sustainability reporting standards (ESRS) set out in Delegated Regulation (EU) 2023/2772. These are the standards on the basis of which "first wave" companies currently prepare their sustainability statements under the CSRD.

On 6 May 2026, the European Commission published proposed revised ESRS for public consultation.

Background

The changes to the CSRD as implemented by the Omnibus Directive require the European Commission to adopt revised, simplified ESRS by no later than 18 September 2026. For further details on this directive, see article.

In December 2025, EFRAG, the organisation responsible for advising the Commission on European reporting standards, issued its technical advice on the revision. EFRAG's advice modified the existing ESRS by shortening and clarifying text; introducing flexibility measures such as reliefs and phase-ins; reducing mandatory datapoints by 61%; enhancing interoperability with global standards; and simplifying the materiality assessment.

The Commission prepared its consultation documents on the basis of this advice and introduced a number of targeted changes.

A key point of discussion in the lead-up to the consultation has been the relationship between the revised ESRS and the international sustainability reporting standards of the International Sustainability Standards Board (ISSB). The Commission has examined how undertakings can use their CSRD reporting to simultaneously satisfy ISSB standards, thereby reducing reporting burdens. However, despite media coverage suggesting that the Commission had considered introducing much closer alignment with the ISSB standards, the proposed revised ESRS do not adopt full alignment. In particular, the "double materiality” approach has been retained in the proposed revised ESRS.

Key changes compared to EFRAG's technical advice

The Commission’s draft revised ESRS maintain most of the changes from EFRAG’s technical advice, while introducing a number of targeted amendments compared to the EFRAG technical advice. The most significant changes are set out below.

Materiality and materiality assessment: no reporting of non-material information

The draft revised ESRS clearly state that the undertaking is not expected to meet the specific information needs of each individual user. The proposal stresses that the objective of the standards is to ensure the reporting of information that is decision-useful for users. A clear definition of the concept of “informed assessment" is also introduced.

The draft revised ESRS further specify that undertakings “shall not” report information that is not material, except in certain clearly defined circumstances, rather than stating that the undertaking “is not required to” report such information.

Lastly, a new provision emphasises that the “top-down” approach to materiality assessment allows the undertaking to avoid unnecessary work and in general to avoid assessing the materiality of each individual impact, risk or opportunity.

Fair presentation applies to sustainability statement as a whole

In relation to fair presentation, the draft revised ESRS clarify that this concept applies to the overall sustainability statement and does not apply to each individual datapoint. It is also states more clearly that the application of ESRS "results in" fair presentation, rather than "is presumed to result in".

Omission of information

The draft revised ESRS integrate new provisions derived from the Omnibus Directive that allow undertakings to omit certain information in certain circumstances, including information that could be seriously prejudicial to the commercial position of the undertaking.

Anticipated financial effects: estimates may be updated

As to anticipated financial effects, the revised standards acknowledge that reporting is likely to involve estimates and that these can be updated in the future in light of new information without this constituting a reporting “error”. It is also clarified that the provisions that allow undertakings to omit certain information in certain circumstances, including information that could be seriously prejudicial to the commercial position of the undertaking, also apply to reporting on anticipated financial effects.

Climate transition plans: transparency required on 1.5°C alignment

If the undertaking discloses information about a transition plan which refers to GHG emission reduction targets that are not compatible with limiting global warming to 1.5°C, it must explain that in the sustainability statement. In particular, it must explain how its target values compare with the reference values and how it has considered future developments.

The draft revised ESRS provide no explicit definition of or guidelines for when a target is or is not compatible with the 1.5°C target.

Greenhouse gas emissions reporting flexibility

In terms of greenhouse gas emissions reporting, the draft revised ESRS align more closely with global sustainability reporting standards by providing undertakings with flexibility in determining which entities’ emissions are included in their GHG reporting. Undertakings may choose to apply either a “financial control approach", or an "operational control approach" when defining the reporting boundary to be applied.

Better alignment and coherence with the CSDDD

The draft ESRS include a number of technical modifications regarding due diligence to ensure better alignment and coherence with the CSDDD.

Comparative information

"Wave-one" is not required to report comparatives for metrics that change from the existing ESRS to the draft revised ESRS.

Revisions and clarifications related to topical standards

The draft revised ESRS clarify and revise certain disclosure requirements related to microplastics, emission of pollutants, substances of very high concern, human rights incidents and incidents of discrimination.

Next steps

Stakeholders have until 3 June 2026 to submit their views. The Commission aims to finalise the standards in the second quarter of 2026. Once adopted, the delegated acts will be transmitted to the European Parliament and the Council for a scrutiny period of two months. If neither legislative body objects or extends the scrutiny period, the delegated acts will enter into force.

If this timeline is met, undertakings can apply the standards on a voluntary basis from the 2026 financial year, with mandatory application from the 2027 financial year onwards.

Voluntary standards for out-of-scope companies

Simultaneously with the publication of the revised ESRS, the European Commission has published a consultation on a delegated act introducing voluntary sustainability reporting standards for undertakings outside the CSRD's scope that are confronted with information requests from undertakings that fall within that scope. This proposal is designed to help smaller companies in the value chains of larger CSRD-reporting entities manage information requests in a proportionate manner, also with the newly introduced value chain cap in mind. The consultation documents provides that only disclosures marked “necessary” in the voluntary standards fall under the value chain cap. See this article. for more information on the value chain cap.

We will continue to monitor developments and keep you informed of any further changes. Please do not hesitate to contact us if you have any questions.