EFRAG 2026 Draft ESRS Datapoints List: The 23 October Deadline

On 28 August 2026 the EFRAG Secretariat published the 2026 Draft List of ESRS datapoints together with an Explanatory Note. EFRAG also said that a draft XBRL taxonomy had been prepared in parallel and would be published separately for public consultation. The list rebuilds the full inventory of sustainability datapoints against the revised European Sustainability Reporting Standards that the European Commission adopted through a Delegated Act on 3 July 2026. Anyone who mapped a reporting solution to the 2023 standards now has a moving target underneath it.

The list is open for a fatal-flaw review. Comments go through an online survey until 23 October 2026 at 23:59 CET, and EFRAG expects to publish the final resource by the end of 2026. For a sustainability-reporting team inside a bank, insurer or asset manager already in scope of the Corporate Sustainability Reporting Directive, that window is the moment to run a gap analysis: which datapoints were removed, which changed, and which now depend entirely on a materiality assessment rather than being reported by default.

The 2026 Draft List is non-authoritative support material. As at 31 August 2026, the Commission’s 3 July 2026 amending Delegated Regulation had been adopted but was not yet in force. Commission Delegated Regulation (EU) 2023/2772, as amended by Delegated Regulation (EU) 2025/1416, therefore remained the current ESRS legal text. The 3 July act provides for the revised ESRS to apply to financial years beginning on or after 1 January 2027 and includes transitional choices for financial years beginning in 2026 once the act is in force.

Related reading: our guide to the revised ESRS and simplified CSRD reporting.

The dates that anchor the 2026 ESRS datapoints list

The calendar is short and the sequence matters, because the datapoint list, the standards it reflects and the taxonomy behind it are all on separate tracks.

• 3 July 2026: the European Commission adopts the revised ESRS through a Delegated Act. This is the standard the 2026 Draft List reflects.
• 28 August 2026: the EFRAG Secretariat publishes the 2026 Draft List of ESRS datapoints and its Explanatory Note.
• 23 October 2026, 23:59 CET: the fatal-flaw survey closes. EFRAG directs stakeholders to use that public survey to report fatal flaws in the methodology or the list.
• End of 2026: EFRAG expects to publish the final list of datapoints after considering the feedback received.
• Shortly after the Draft List: EFRAG plans to issue the draft XBRL taxonomy separately for formal public consultation, before handing it to ESMA and the Commission in November 2026; no exact consultation launch date is stated.

Treat 23 October as the hard date and the end-of-year publication as the point where your gap analysis stops being provisional. The taxonomy consultation is a distinct event you will need to track on its own.

What the 2026 Draft List actually is, and what it is not

The Explanatory Note is blunt about the status of the document. The 2026 Draft List is non-authoritative supporting material issued by the EFRAG Secretariat, and it must not be used to substitute the revised ESRS. It lists all the datapoints defined in the standards, but it does not constitute implementation guidance and it is not a checklist.

That last point is where teams go wrong. A datapoint list looks like a to-do list, and the temptation is to hand it to a preparer as a set of fields to fill in. The Note closes that door directly: the list should be used only in conjunction with the materiality judgement that underpins ESRS. Under ESRS 1 paragraph 24, except for supplementary information that an undertaking may decide to disclose under section 8.2, an undertaking shall not disclose information prescribed by an ESRS disclosure requirement or datapoint if that information is not material. The GDR datapoints describing policies, actions and targets apply where the undertaking has adopted those policies, actions or targets for a material topic. Separately, ESRS 2 paragraph 39 requires the undertaking to disclose the fact that it has no policies, actions or targets for a topic related to material impacts, risks or opportunities.

So the list is a reference inventory, useful for building tagging logic, structuring a reporting solution and running a data gap analysis. Whether a datapoint is reportable flows from the revised ESRS, including its materiality and conditionality provisions; EFRAG separately treats the ESRS 2 BP-1 technical datapoints as not subject to the double materiality assessment.

How it differs from the 2024 IG 3 list

EFRAG built the 2026 Draft List on the same methodology it used for the IG 3 List of ESRS Datapoints released in May 2024. If your team already worked with the IG 3 list, the structure will feel familiar. The changes are in usability and in the underlying standard, and both matter for a data gap analysis.

Three usability changes stand out. Datapoints are now categorised using distinct data types, which makes the list easier to translate into a data model. References to the interactive ESRS in EFRAG’s ESRS Knowledge Hub are embedded as hyperlinks, so a datapoint links straight to the paragraph that defines it. And EFRAG is issuing a separate version that carries paragraph references back to the ESRS as adopted in 2023, so you can see how each disclosure requirement evolved.

The most useful feature for a transition is the mapping. EFRAG is releasing two versions of the list: a clean version without the mapping, and a version that links each new datapoint to its counterpart in the 2024 IG 3 wherever a match exists. That mapping is a starting point for a gap analysis because it links each new datapoint to its 2024 IG 3 counterpart wherever a match exists. To identify 2024 IG 3 datapoints with no successor, compare the full 2024 inventory against the mapped 2026 IDs rather than treating the absence of a mapping on a new datapoint as proof that an old datapoint was dropped. Start from the mapped version, not the clean one.

The materiality change reporting teams keep missing

The headline substantive change is easy to state and easy to get wrong. Under the 2023 ESRS, some datapoints in ESRS 2 and the environmental standards were treated as mandatory irrespective of the materiality assessment. The revised ESRS remove that category: the Explanatory Note records that the 2026 Revised ESRS have no mandatory datapoints that must be reported irrespective of the materiality assessment.

Read that carefully. EFRAG treats the datapoints in ESRS 2 BP-1 as a specific exception: because they are metadata about the report itself, they are not subject to the double materiality assessment and are counted separately in the list’s statistics. That treatment should not be generalised to all ESRS 2 datapoints. What changed is the removal of the former category of datapoints treated as mandatory irrespective of the materiality assessment. The practical effect is that more of the list is now gated by your own materiality conclusions than before.

This feeds a second misconception worth killing early. The number of datapoints in the list is not the number of facts a company reports. An undertaking can assess whole topics or individual datapoints as not material and report none of them. EFRAG makes the point explicitly: the list is a catalogue of all ESRS datapoints, not a projection of the facts in any one company’s sustainability statement. Do not treat the raw datapoint count as the number of facts a particular undertaking must disclose; the applicable disclosure set depends on the revised ESRS materiality and conditionality provisions.

Where the list plugs into the rest of your reporting stack

For a financial undertaking, the ESRS statement never lives on its own. It shares data with the prudential and product-disclosure regimes, and the datapoint list is where those connections become visible. EFRAG carried the mapping in Appendix A of ESRS 2 into both the 2026 Draft List and the draft taxonomy. That mapping covers ESRS datapoints connected with SFDR, Pillar 3, the Benchmark Regulation and the EU Climate Law; it does not map Article 8 Taxonomy Regulation disclosures. Separately, revised ESRS 1 paragraph 106 requires Article 8 disclosures, where prepared, to be included in the sustainability statement and states that those disclosures are not subject to ESRS except for that presentation requirement.

The reuse cuts several ways. Banks report climate and ESG information under the prudential framework as well, so a change to an ESRS datapoint can ripple into the data feeds behind the EBA ESG Pillar 3 disclosure templates, even though those templates are governed by their own implementing standard rather than by ESRS. Asset managers reusing ESRS-tagged data for SFDR disclosures face the same re-mapping exercise. And the Taxonomy KPIs sit across both regimes, which is why the EU Taxonomy Article 8 KPI simplification needs to be read alongside this list, not separately.

One gap is worth flagging so nobody assumes coverage that is not there. EFRAG notes that mapping to some other EU laws not already in Appendix A, such as the Corporate Sustainability Due Diligence Directive, has not yet been carried out. If your control framework relies on the datapoint list to trace due diligence obligations, that trace does not exist in this version.

The XBRL taxonomy is moving too, and it is still a working draft

Alongside the datapoint list, EFRAG prepared a draft XBRL taxonomy aligned to the revised datapoints, so that the digital tagging layer keeps pace with the standard. The general architecture stays close to the 2024 taxonomy, but several changes affect anyone building a tagging pipeline. The file structure has been simplified and the number of files reduced, which should make processing faster without changing the elements themselves. Overlapping datapoints that existed in the 2023 standards have been largely eliminated, producing a flatter narrative tagging hierarchy. And the phrase “whether and how” has been stripped out in most places, which cuts the number of Boolean elements sharply.

The caveat is that this is explicitly a working draft. Validation rules on the existence of disclosures have not yet been implemented, except for the existence assertion on EU datapoints, and EFRAG recommends adding validation rules after the first wave of companies has digitised their reports. The list of Substances of Very High Concern has not been implemented, so that element carries a string datatype as a placeholder for now. If a vendor tells you the tagging model is ready to lock, the Explanatory Note says otherwise. This taxonomy will be finalised for its own exposure draft and consultation, which is a separate step from the datapoint list you are reviewing now. Teams tracking the digital reporting angle should watch it the same way they watch the ESEF taxonomy update for financial statements.

How to run the gap analysis before the window closes

The point of publishing during a fatal-flaw window is that EFRAG wants defects found now, while the list can still change. A gap analysis serves both purposes at once: it prepares your own build and it surfaces anything worth reporting through the survey.

Work from the mapped version of the list and line it up against the datapoints your current ESRS solution already produces. Sort the results into the datapoints that carried over unchanged, the ones that were reworded or reclassified into a new data type, and the ones the revised standard dropped. Flag every datapoint whose reporting now turns on a materiality conclusion rather than a hard requirement, because those are the ones most likely to change your disclosure footprint. Keep Article 8 Taxonomy disclosures as a separate adjacent workstream rather than treating them as ESRS datapoints. For cross-regime reuse, use the Appendix A cross-references for SFDR and Pillar 3. Where the methodology or a specific datapoint looks wrong, that is what the online survey exists to capture, and 23 October is the cut-off.

For the wider CSRD context behind all of this, including the scope changes that reshaped who prepares a statement at all, our CSRD sustainability reporting overview sets out the directive itself.

Frequently Asked Questions

Does the 2026 Draft List change our legal reporting obligations?

No. The list is non-authoritative support material issued by the EFRAG Secretariat. As at 31 August 2026, the 3 July 2026 amending Delegated Regulation had been adopted but was not yet in force. Current ESRS requirements remained under Delegated Regulation (EU) 2023/2772 as amended by Delegated Regulation (EU) 2025/1416. The 3 July act provides for the revised ESRS to apply to financial years beginning on or after 1 January 2027, with transitional choices for financial years beginning in 2026 once the act is in force. The statutory sustainability-reporting framework is contained in Directive 2013/34/EU as amended, including by Directive (EU) 2026/470.

Which version of the standards does the list reflect?

The 2026 Revised ESRS, as published by the European Commission in the Delegated Act of 3 July 2026. The earlier list, IG 3 from May 2024, reflected the original ESRS Set 1 under Commission Delegated Regulation (EU) 2023/2772.

We already report under the 2023 ESRS. What is the fastest way to use the list?

Use the version that carries the mapping to the 2024 IG 3 and run a data gap analysis against the datapoints your current solution produces. The mapping links each new datapoint to its 2024 IG 3 counterpart where one exists. To identify 2024 IG 3 datapoints with no successor, compare the full 2024 inventory against the mapped 2026 IDs; the absence of a mapping on a new datapoint does not by itself show that an old datapoint was dropped.

Are any datapoints still mandatory regardless of materiality?

EFRAG treats the ESRS 2 BP-1 datapoints as a specific exception: because they are report metadata, they are not subject to the double materiality assessment and are counted separately. More generally, EFRAG states that the 2026 Revised ESRS no longer contain datapoints classified as mandatory irrespective of the materiality assessment; whether other information is reported must be determined under the revised ESRS materiality provisions.

Can we start XBRL tagging from the draft taxonomy now?

Not against the taxonomy package yet. As at 31 August 2026, EFRAG had prepared the draft taxonomy but had not yet published it; EFRAG says it will issue it separately for public consultation. The Explanatory Note describes the working draft, including validation rules that remain to be implemented and a string placeholder for Substances of Very High Concern, so teams can prepare their tagging architecture but cannot yet lock a production model to the unpublished taxonomy package.

Does the list map ESRS datapoints to CSDDD or other EU laws?

It carries the Appendix A mapping from ESRS 2 to the EU legislation listed there, covering SFDR, Pillar 3, the Benchmark Regulation and the EU Climate Law. It does not map Article 8 Taxonomy Regulation disclosures; those are addressed separately by ESRS 1 paragraph 106. EFRAG states that mapping to further laws not in Appendix A, such as the Corporate Sustainability Due Diligence Directive, has not yet been carried out, so do not rely on the list for that trace.

What happens after the survey closes on 23 October?

EFRAG considers the feedback and expects to publish the final list of datapoints by the end of 2026. Separately, EFRAG says the draft XBRL taxonomy will be issued for public consultation before it is handed to ESMA and the Commission in November 2026.

Related Articles

• Revised ESRS and Simplified CSRD Reporting 2026: how the 2025 simplification reshaped the standards the datapoint list now reflects.
• CSRD Sustainability Reporting: the directive behind ESRS, including who prepares a sustainability statement and when.
• EU Taxonomy Article 8 KPI Simplification: the Taxonomy disclosures addressed separately from ESRS Appendix A, via ESRS 1 paragraph 106.
• EBA ESG Pillar 3 Disclosure Templates: the prudential ESG disclosures that reuse much of the same source data as ESRS.
• ESMA ESEF Taxonomy Update 2026: the digital tagging framework for annual financial reports, a parallel track to the ESRS taxonomy.
• EFRAG ESRS Knowledge Hub: the interactive ESRS that the 2026 datapoint list hyperlinks into.

Key Takeaways

• The fatal-flaw survey on the 2026 Draft List closes 23 October 2026 at 23:59 CET; the final list is expected by the end of 2026.
• The list reflects the revised ESRS adopted by the Commission on 3 July 2026; as at 31 August 2026, Commission Delegated Regulation (EU) 2023/2772 as amended by (EU) 2025/1416 remained the current ESRS text; the 3 July act had been adopted but was not yet in force.
• The list is non-authoritative EFRAG Secretariat material, not implementation guidance and not a checklist; the standard and the materiality assessment still govern what you report.
• Use the version mapped to the 2024 IG 3 list as the starting point for a gap analysis; to identify dropped datapoints, compare the full 2024 inventory against the mapped 2026 IDs.
• EFRAG states that the 2026 Revised ESRS no longer contain datapoints classified as mandatory irrespective of the materiality assessment; it separately treats the ESRS 2 BP-1 report-metadata datapoints as not subject to the double materiality assessment.
• A raw datapoint count is not a count of facts a particular undertaking must report; the applicable disclosure set depends on the revised ESRS materiality and conditionality provisions.
• The draft XBRL taxonomy had not been published as at 31 August 2026; EFRAG plans to issue it for public consultation before handing it to ESMA and the Commission in November 2026, and it remains a working draft with most existence validation rules not yet implemented.
• Appendix A mapping covers SFDR, Pillar 3, the Benchmark Regulation and the EU Climate Law, but not CSDDD. Article 8 Taxonomy Regulation disclosures are addressed separately by ESRS 1 paragraph 106 and are not part of that Appendix A datapoint mapping.

Sources and References

• EFRAG, “EFRAG Secretariat Releases 2026 Draft List of Datapoints for Revised ESRS” (28 August 2026): efrag.org news release.
• EFRAG, “2026 Revised ESRS – Draft List of Datapoints and Draft XBRL Taxonomy – Explanatory Note” (28 August 2026): Explanatory Note (PDF).
• Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 (Corporate Sustainability Reporting Directive), OJ L 322, 16.12.2022: EUR-Lex.
• Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing Directive 2013/34/EU as regards sustainability reporting standards (ESRS Set 1), OJ 22.12.2023: EUR-Lex.
• Commission Delegated Regulation (EU) 2025/1416 amending Delegated Regulation (EU) 2023/2772 as regards postponement of certain application dates, OJ 10.11.2025: EUR-Lex.
• European Commission, C(2026) 5010 final, “Commission Delegated Regulation of 3 July 2026 amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standards”, together with its Annexes: EUR-Lex.
• European Commission, “Implementing and delegated acts – CSRD” (3 July 2026 status page): finance.ec.europa.eu.
• Directive (EU) 2026/470 of the European Parliament and of the Council of 24 February 2026 amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760 as regards certain corporate sustainability reporting requirements and certain corporate sustainability due diligence requirements, OJ L, 2026/470, 26.2.2026: EUR-Lex.
• Regulation (EU) 2020/852 of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (Taxonomy Regulation), Article 8: EUR-Lex.
• European Commission, “Corporate sustainability reporting”: finance.ec.europa.eu.

Before the 23 October window closes

The 2026 Draft List is a preparatory document with a short comment period and a clear next step. Pull the mapped version, line it up against the datapoints your current ESRS solution produces, and separate the carry-overs from the removals, the reclassifications and the newly materiality-gated items. Anything that reads as an error in the methodology or the list itself goes into the online survey before 23 October 2026 at 23:59 CET. EFRAG expects the final datapoint list by the end of 2026. The XBRL taxonomy follows a separate timetable: EFRAG says its draft will be issued for public consultation before handover to ESMA and the Commission in November 2026.

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