How to run a CSRD/ESRS gap assessment against the final Simplified ESRS (C(2026) 5010 final, adopted 3 July 2026). By TomorrowWorks. Last updated: July 2026.
What is an ESRS gap assessment?
An ESRS gap assessment is a structured comparison of a company’s current reporting and data against every disclosure requirement of the European Sustainability Reporting Standards, to identify what is already covered, what is missing, who owns each gap and in which order to close them.
The five steps in short:
(1) determine which ESRS standards apply,
(2) assess materiality per Disclosure Requirement,
(3) screen individual paragraphs and document exclusions,
(4) assess coverage gaps with evidence, owners and priorities, and
(5) steer progress with a dashboard. The 2 – 4 month scrutiny period before the standards enter into force is the ideal window to do this. [Read more in the Simplified ESRS FAQ article]
Why start from the legal text, not a summary?
The ESRS are legal text: obligations sit at the level of individual paragraphs and their Application Requirements (ARs), and wording matters word by word. The final Simplified ESRS contain 475 assessable requirements – 283 numbered paragraphs and 192 Application Requirements across ESRS 2, E1–E5, S1–S4 and G1. A gap assessment built on a summary will miss conditional requirements (‘if applicable’), voluntary provisions (‘may disclose’) and the AR-level detail that determines what evidence is actually needed.
Step 1 – Which ESRS standards apply?
ESRS 2 General Disclosures is mandatory for every reporting undertaking – no materiality filter applies. The ten topical standards apply based on the double materiality assessment (DMA). If a topic is not material, the whole standard drops out – but record the conclusion: assurance providers will ask how you got there. Also check the phase-in reliefs in ESRS 1, paragraphs 125–127: depending on size and reporting wave, entire standards (E4, S2, S3, S4) may be lawfully deferred for the first reporting years.
Step 2 – Which Disclosure Requirements are material?
Within each applicable standard, assess materiality per Disclosure Requirement (DR). This is where the simplification pays off: if a DR is not material, all of its underlying paragraphs and ARs are eliminated in one decision. Make this a one-way street in your tooling – a DR marked ‘not material’ should automatically take its paragraphs out of scope, but a DR marked material must never auto-include them, because paragraph-level screening comes next.
Step 3 – Screen the individual paragraphs
Material DRs still contain paragraphs that may not apply – conditional provisions, sector-specific items, disclosures about instruments the company does not use. Screen each remaining paragraph and record a rationale for every exclusion. This paragraph-level audit trail is what turns a gap assessment from a working document into assurance-ready documentation.
Step 4 – Assess the gaps
Only now assess coverage, and only for what is in scope: is each requirement covered, partially covered or not covered? What is the current source or evidence? What action closes the gap, who owns it, and at what priority? Three rules keep this honest:
- Assess against evidence, not intentions. ‘Covered’ means the information exists today, at the quality the standard requires, and you can point to it.
- Include the Application Requirements. ARs define calculation methods, tables and boundaries – gaps hide there, not in the headline requirement.
- Split qualitative from quantitative requirements. Narrative gaps close in weeks with writing and governance work; data gaps need pipelines, definitions and controls. In TomorrowWorks’ classification of the final standards, ESRS S1 and E1 carry most of the quantitative load, while S2, S3 and S4 contain no purely quantitative requirements – the data effort is more concentrated than most companies expect.
Step 5 – Steer with a dashboard
Aggregate results per standard: requirements in scope, coverage status, priority distribution, and the share of remaining work that is quantitative. This gives leadership a defensible readiness view and lets you track progress quarter by quarter as gaps close.
Common ESRS gap assessment mistakes
- Building the assessment on the 2023 ESRS or the May 2026 draft – the final act changed targeted but important wording (for example on GHG target boundaries and human rights incident disclosures).
- Merging the materiality assessment and gap assessment into one exercise – scoping decisions get buried and cannot be evidenced.
- No rationale for exclusions – every ‘not applicable’ needs one sentence explaining why.
- Ignoring phase-ins – teams waste effort closing gaps on disclosures they may lawfully defer.
Get a head start
TomorrowWorks has built an ESRS 2.0 Gap Assessment tool on the final adopted standards – every paragraph and AR verbatim, with the scoping cascade, qualitative/quantitative classification and steering dashboard described above built in. For the toolkit, or support with your DMA and gap assessment, contact Nishant at nishant@tomorrowworks.eu.