The revised ESRS apply from FY2027, and EFRAG has published the datapoint list. What this means for wave one and wave two companies, and three actions to take before year-end.
The Commission published revised ESRS on 3 July 2026
On 3 July 2026 the European Commission published a delegated act revising the European Sustainability Reporting Standards. The act is Delegated Regulation C(2026) 5010 final. It amends Delegated Regulation (EU) 2023/2772 as part of the Omnibus I simplification package, and replaces the standards and the glossary in full.
The structure stays the same: ESRS 1, ESRS 2 and ten topical standards. Companies have to disclose considerably less.
The act is now in the scrutiny period of the European Parliament and the Council. If neither objects, it comes into effect on 10 November 2026.
EFRAG published the datapoint list on 28 August 2026
Stakeholders asked for help with implementation. In response, EFRAG published a detailed list of datapoints on 28 August 2026, with a 23-page explanatory note.
The list contains 292 “shall” datapoints across ESRS 2 and the ten topical standards. Only 195 of them apply without a condition attached. EFRAG has issued the list for a fatal flaw consultation that closes on 23 October 2026, and says it may contain errors. It is not a checklist and does not replace the standard. Use it to work out what is in scope. Read the standard to write the disclosure.
For background on the revised standards — what they are, who reports and when, and how the reliefs and phase-ins work — see our Simplified ESRS (ESRS 2.0): Frequently Asked Questions.
The revised standards are mandatory from FY2027
Every company in scope must use the revised standards for financial years starting on or after 1 January 2027. What happens before that depends on your wave.
Wave one companies choose how to report FY2026
Wave one companies are the former NFRD reporters. Their CSRD obligation applies for financial years starting between 1 January 2024 and 31 December 2026. They have already published at least one sustainability statement under the 2023 ESRS.
Article 2 of the new act gives them three ways to report FY2026.
Option 1: the 2023 ESRS with the Quick Fix. You report on Delegated Regulation (EU) 2023/2772, as last amended by Delegated Regulation (EU) 2025/1416. You may leave out E4, S2, S3 and S4 for FY2025 and FY2026. If you have up to 750 employees, you may also leave out S1. The full 2023 datapoint set applies otherwise. You then rebuild the statement completely for FY2027.
Option 2: the 2023 ESRS with the Quick Fix, plus eight reliefs from the revised standards. The same basis as Option 1. You may also use the eight reliefs listed in Article 2(1)(b): top-down materiality (ESRS 1 §27); undue cost or effort and the value chain limit (§32–33); acquisitions and disposals (§74–75); leaving out activities that are not significant (§90); partial reporting scope for metrics (§91); joint operations (§92); the Taxonomy appendix (§106); and an executive summary (§110). FY2026 gets easier. You still have to replace the 2023 datapoint set for FY2027.
Option 3: the revised ESRS in full, a year early. You get all the reliefs in the revised standards, plus its own phase-ins for FY2026. If you are above EUR 450 million net turnover and 1,000 employees, you may leave out E4, S2, S3 and S4 (ESRS 1 §125). If you are below both thresholds, you may leave out every topical standard (§126). That is wider than the Quick Fix. No rebuild is needed for FY2027.
What to do: Choose one of the three options. State the choice in your sustainability statement, as Article 2(2) requires. Record it in the FY2026 basis of preparation, and agree it with your audit committee and your auditor, including which phase-ins you plan to use.
Wave two companies start with the revised standards
Wave two companies are everyone else in scope. Their reporting obligation starts for financial years beginning on or after 1 January 2027. Their first statements are published in 2028.
They have nothing to transition. Their first reporting year is the first year the revised standards apply, so they report on the revised standards from the start.
Many wave two companies have spent two years preparing against the 2023 ESRS. They have built datapoint inventories, supplier questionnaires and data models on a standard they will never report under.
Wave two also gets its own phase-in. Under ESRS 1 §127, these companies may leave out E4, S2, S3 and S4, and most information on anticipated financial effects, for their first two reporting years. If you leave out a topic that is material, you still have to explain why under ESRS 2 §7–10.
What to do: Stop preparing against the 2023 ESRS. Rebase your datapoint inventory, data model, supplier questionnaires and system requirements on the revised text. See action 3 below for how to move across.
Three actions to take now
The act is not yet in force, and the datapoint list is a draft. Neither stops you from doing the following. All three hold whatever happens during the scrutiny period, and whichever option you pick.
1. Refresh your double materiality assessment
Both waves should do this. The revised standards clarifies certain concepts that may affect your existing DMA. The standard clarifies
- whether mitigation measures can be considered while assessing impacts
- positive impacts definition and their netting with negative impacts
- treatment of leased assets
Watch our webinar on ESRS 2.0 key changes, strategic implications and next steps
What to do: Refresh the assessment to cover these changes and clarification in ESRS 2.0. Record the process, material topics and the Disclosure Requirements.
2. Wave one: map your published statement against the revised standards
Take your FY2025 statement, or the FY2026 statement you are preparing. Go through it disclosure by disclosure and sort each item into three groups.
Still required. The disclosure survives, though the DR number, the definition or the calculation may have changed. Several metrics fall into this trap:
- The remuneration ratio now excludes the highest-paid individual from the median.
- The S1-5 country breakdown changed from “50 or more employees and at least 10% of the workforce” to “50 or more employees and among the ten largest countries”.
- The S1-9 adequate wages method was rewritten.
- Human rights incidents must now be substantiated and verified.
Deleted. Energy intensity, GHG intensity and water intensity per net revenue are all gone. So are the E-PRTR pollutant list as a mandatory basis, the 2023 waste breakdown by recovery and treatment type, the confirmed corruption and bribery incident counts in G1-4, and around half the S1 metric datapoints.
New or expanded. Total water withdrawal and total water discharge become required line items in E3-4. E5-5 adds product durability, repairability and designed recyclability rate. E1-2 is a new Disclosure Requirement for identifying climate risks. G1-3 is a new targets Disclosure Requirement.
Then decide what to do with each deleted item. Some are worth keeping: investors ask for them, a rating agency uses them, another framework requires them, or your own management needs them. Dropping those breaks your time series. Others exist only because the 2023 standard asked for them. Retire the collection process behind those.
What to do: Build the three-group map. For every deleted item, decide whether to keep reporting it or stop, and write down the reason. Where you stop, say so in the statement so readers know why a number has disappeared.
3. Wave two: use the mapped datapoint list to switch across
EFRAG published the datapoint list in two versions. One is a clean list. The other maps each datapoint to the 2024 IG 3 list of 2023 ESRS datapoints.
If your preparation is already organised around the 2023 datapoints, use the mapped version to move across. You do not have to start again.
Two cautions. The list is a draft that EFRAG says may contain errors and may be incomplete, and the final version will be EFRAG Secretariat supporting material rather than implementation guidance. Do not build against the XBRL taxonomy yet either: the draft taxonomy goes to consultation shortly and reaches ESMA and the Commission in November 2026. The 2024 taxonomy never came into force at all.
What to do: Download the mapped version of the datapoint list. Use it to convert your existing 2023 datapoint inventory to the revised standards. Check each converted item against the standard text before you rely on it. Leave the XBRL work until the taxonomy is final.