Demystifying ESRS: An introductory Guide to European Sustainability Reporting Standards and CSRD Disclosure Requirements

The European Sustainability Reporting Standards (ESRS) are the EU's reporting standards for sustainability information. Set 1 consists of 12 sector-agnostic standards: two cross-cutting standards and ten topical standards covering environment, social and governance matters. This page lists all 12 with their codes and status, and states who has to apply them and from when.

What the ESRS are, and how they relate to the CSRD

The Corporate Sustainability Reporting Directive (CSRD) is EU law. It determines who must report, when, and under which assurance and digital tagging obligations. The ESRS are the technical standards that define what has to be disclosed and how. They were developed by the European Financial Reporting Advisory Group (EFRAG) and adopted by the European Commission as Delegated Regulation (EU) 2023/2772 in July 2023. That adopted package is what is meant by ESRS Set 1.

I have covered this in more depth here: China's Corporate Sustainability Disclosure Standards (CSDS): What Applies from 30 April 2026.

The output of the standards is the sustainability statement: a clearly identified section of the management report, tagged in XBRL and audited to limited assurance.

The 12 ESRS in one table: ESRS 1, ESRS 2, E1 to E5, S1 to S4, G1

Two cross-cutting standards apply to every reporting company. The ten topical standards apply where the double materiality assessment identifies the topic as material. Sector-specific standards were announced as a second set and have not been adopted.

Every topical standard follows the same four-part logic: strategy, policies, actions, targets. A standard-by-standard walkthrough of all 12 covers the individual disclosure requirements in detail, and the climate standard is expanded in the guide to climate risk assessment.

Which disclosures are mandatory and which depend on double materiality

ESRS 2 is the one standard no company in scope can skip. Its disclosures on governance, strategy, the materiality process and the basis of preparation apply regardless of what the materiality assessment concludes. Everything else runs through double materiality: a topic is material if it is impact-material, meaning the company affects people or the environment through it, or financially material, meaning it affects cash flows, financing or the cost of capital. Either direction triggers the associated disclosure requirements.

ESRS E1 is the practical exception. A company may conclude that climate change is not material, but it then has to disclose and justify that conclusion, which rarely survives auditor and investor scrutiny. In effect, climate is reported by everyone in scope.

In the adopted Set 1 this adds up to 82 disclosure requirements and 1,144 data points: 161 mandatory irrespective of materiality, 622 conditional on it and 269 voluntary. A revision cutting that count is part of the simplification agenda but is not yet in force, so the standards above are the ones that apply. Two obligations are easy to underestimate: every disclosure has to be tagged in the ESRS XBRL taxonomy, and the whole sustainability statement is subject to limited assurance from the first reporting year.

Who must apply the ESRS, and from when

Omnibus I, Directive (EU) 2026/470, in force since 18 March 2026, narrowed the scope sharply. A company reports only if it exceeds both thresholds at once: more than 1,000 employees and more than 450 million euros in net turnover. Listed SMEs are out. Companies below the thresholds are not on a postponed timetable, they are outside the scope entirely, and smaller suppliers asked for data by customers who are in scope can answer with the voluntary standard for SMEs instead of the full ESRS.

Companies that dropped out of scope still tend to keep a reduced data set running, because customers and the EU Taxonomy keep asking for the same figures. Sequencing that work is covered in the guide to ESG integration for medium-sized companies.

What companies actually disclose under these standards

The standard list describes what should be in a report. What is in filed reports is a different question, and I can answer it from my own extraction pool of 1,401 European sustainability statements. Climate and own workforce carry the reporting: E1 and S1 appear with usable data almost everywhere, while the tail beyond them thins out quickly, and S2 and S3 in particular are often present as narrative without figures behind them. On emissions data specifically, 69 percent of the reports carry all three scopes in extractable form and 13 percent contain no extractable scope data at all.

My position on that gap: ESRS compliance is not sustainability. A conforming document can be produced without a single decision changing, and the pattern in the filings suggests that happens often. The value sits in the internal steering the data makes possible, in capital planning, procurement and site decisions, not in the statement itself.

Last reviewed against the EFRAG Set 1 status on 4 September 2026.

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