Revised ESRS: The 60% Datapoint Cut Facing CSRD Reporters

ByOfficer

On 3 July 2026 the European Commission adopted two delegated acts that rewrite how the European Sustainability Reporting Standards work: a revised set of ESRS and a new voluntary standard for smaller companies. The revised ESRS cut the number of mandatory datapoints by more than 60% and the total number of datapoints by more than 70%, on the Commission’s own estimate, and are expected to lower reporting costs by more than 30% per company. For teams that filed a sustainability statement for financial year 2024 or 2025, the next reporting cycle requires a version decision, a datapoint remap, and assurance alignment.

The revised ESRS amend Commission Delegated Regulation (EU) 2023/2772, the delegated act that carries the original ESRS Set 1 adopted in July 2023. They sit inside the wider Omnibus I simplification package, which also cut the number of companies that have to report at all. What arrives on a reporting officer’s desk now is a sequencing problem. The standards are lighter, the scope has shifted underneath them, and the option to use the lighter version a year early carries its own conditions.

This change note is written for CSRD reporters preparing their next disclosure cycle. It covers what the Commission actually adopted, when the revised ESRS take legal effect, who is still in scope after the Omnibus content directive, and what the new voluntary standard does for the data requests firms send down their value chains.

Related reading: our guide to CSRD sustainability reporting and the ESRS framework.

The dates that drive your next disclosure cycle

The adoption on 3 July is one point on a two-year sequence. The calendar below is the part worth pinning to the wall, because the timing gap between adoption and legal effect is where reporting plans usually go wrong.

  • 26 February 2025: the Commission proposes the Omnibus I simplification package.
  • April 2025: the stop-the-clock Directive (EU) 2025/794 enters into force, postponing the second and third reporting waves by two years.
  • 2 December 2025: EFRAG submits its technical advice on the amended ESRS to the Commission, together with the accompanying cost-benefit analysis, log of amendments, and comparative table of texts submitted on 23 December 2025.
  • 24 February 2026: Directive (EU) 2026/470, the Omnibus content directive, is adopted and published on 26 February 2026, narrowing who has to report.
  • 6 May 2026: the Commission opens a one-month feedback window on its draft revised ESRS, closing 3 June 2026.
  • 3 July 2026: the Commission adopts the revised ESRS delegated act and the voluntary standard delegated act.
  • Scrutiny period: two months from transmission to the European Parliament and the Council, which can be extended by a further two months.
  • Financial years starting between 1 January 2026 and 31 December 2026: undertakings in scope of Delegated Regulation (EU) 2023/2772 may choose the revised ESRS once the delegated regulation has entered into force; Article 3 states that entry into force is the date of adoption plus four months and one week.
  • Financial year 2027: the revised ESRS apply on a mandatory basis, and the narrowed CSRD scope applies to financial years starting on or after 1 January 2027.

What the Commission actually adopted on 3 July

Two separate instruments were adopted on the same day, and it helps to keep them apart from the start. The first is a delegated act amending Delegated Regulation (EU) 2023/2772, which revises the ESRS that in-scope companies must use. The second is a delegated act establishing a voluntary reporting standard for companies that fall outside the scope of the Corporate Sustainability Reporting Directive. They travel together, but they do different jobs and they hit different populations.

The revised ESRS keep the shape of the original framework. The architecture from 2023 remains in place: two cross-cutting standards, ESRS 1 on general requirements and ESRS 2 on general disclosures, sitting above the topical standards for environment, social matters, and governance. Double materiality, the principle that a company reports both on how sustainability matters affect it financially and on its own impacts on people and the environment, is still the basis for deciding what goes into the statement. The Commission has trimmed the content inside that structure while keeping the structure itself.

Alongside the two legal texts, the Commission published an explanatory memorandum setting out where it departed from the draft standards that EFRAG submitted, and a staff working document describing the revision of ESRS Set 1 and the development of the voluntary standard. Those two documents are where the detail lives. The one-page news announcement gives the headline percentages; the binding annexes to the revised ESRS delegated regulation are what a reporting team needs to read against its own current datapoint mapping, supported by the explanatory memorandum and staff working document.

A point teams get wrong early: adoption by the Commission is not the same as the standards being in force. A delegated act adopted on 3 July still has to clear a scrutiny period before it applies. The lighter framework exists on paper from July, but the obligation to report against it, or the right to choose it early, depends on the steps that follow.

Reading the “over 60%” datapoint cut without overstating it

The two headline figures measure different things, and conflating them produces a materially wrong impression of the workload change. The reduction of more than 60% applies to mandatory datapoints, meaning the datapoints a company has to report where the relevant topic is material. The reduction of more than 70% applies to the total number of datapoints in the standards, a count that also includes voluntary datapoints a company may choose to report. When someone in a steering meeting says “70% of the work is gone”, they are usually quoting the wrong number for a reporting obligation.

The cut does not mean 60% of your current statement disappears. What a specific company reports has always depended on its materiality assessment, so two firms using the same ESRS can already produce statements of very different size. The datapoint reduction changes the ceiling of what can be asked, not the floor of what any one company was actually disclosing. A firm that had already scoped its FY2024 statement tightly through materiality may see a smaller practical reduction than the top-line percentage suggests.

The revised standards also simplify the materiality assessment itself, which is the process that decides what a company must report in the first place. The Commission describes the revised ESRS as shorter and clearer, with new flexibilities and simpler core processes. For a preparer, the operational consequence sits in the mapping layer: every datapoint that has been deleted, converted to voluntary, or moved needs to be reconciled against the data pipelines, controls, and narrative sections built for the original ESRS. The saving is real, but it is realised through a remapping exercise, not automatically.

The scrutiny clock: when the revised ESRS actually bind

Both delegated acts now go to the European Parliament and the Council of the EU for scrutiny. Under the delegated-act procedure, neither co-legislator amends the text. They either raise no objection, in which case the act enters into force, or they object, in which case it does not. The scrutiny period runs for two months from transmission and can be extended by a further two months at the request of the Parliament or the Council. In practice that means the revised ESRS could complete scrutiny in the early autumn of 2026, or later if the window is extended.

The timing matters because two application dates are in play. The Commission has framed the revised ESRS to apply on a mandatory basis for financial years beginning on or after 1 January 2027, with an option for undertakings falling within the scope of Delegated Regulation (EU) 2023/2772 to apply them for financial years starting between 1 January and 31 December 2026 once the delegated regulation has entered into force. This is the practical hook for the current cycle. A large company still in scope for FY2026 can choose to prepare its next statement under the lighter standards rather than the 2023 version, provided the act is published in time and the company meets the conditions in the final text.

Where teams get this wrong is treating early application as automatic or as a formality. Early application is a deliberate choice with knock-on effects on comparability, on the assurance engagement, and on internal controls that were designed around the original datapoints. The auditor signing the limited-assurance opinion needs to know which version of the standards the statement is built on before fieldwork begins. Deciding late, or deciding by default, is how a reporting team ends up assured against one framework and drafted against another.

Simplification is not the same as exemption: who still reports

The revised ESRS change how in-scope companies report. A separate instrument in the same package changed which companies are in scope at all, and the two are easy to blur. The scope change comes from Directive (EU) 2026/470, adopted on 24 February 2026, which amends the Accounting Directive 2013/34/EU, the CSRD itself (Directive (EU) 2022/2464), the Audit Directive, and the Corporate Sustainability Due Diligence Directive. It raises the reporting threshold so that, broadly, an undertaking is captured only where it exceeds a net turnover of EUR 450 million and an average of more than 1,000 employees during the financial year. That narrowed scope applies to financial years starting on or after 1 January 2027.

Layered on top is the stop-the-clock Directive (EU) 2025/794, in force since April 2025, which pushed the second and third reporting waves back by two years. The second wave of large undertakings that had not yet started reporting moved to financial year 2027, and the third wave of listed small and medium-sized enterprises moved to financial year 2028. The content directive then removed most of that third wave from the mandatory perimeter altogether by lifting the employee and turnover thresholds.

The practical read for a reporting officer sitting inside a first-wave group is this. If the group already reported for FY2024 or FY2025 and still clears the 1,000-employee and EUR 450 million turnover bar, it stays in scope and will use the revised ESRS. If a first-wave entity now falls below the new thresholds, it may drop out of the mandatory regime for financial years from 2027, subject to how each Member State transposes the transitional provisions. That is a scoping decision to make with legal counsel and the group auditor, and it should not be carried into the planning cycle as an assumption. Cross-border groups with subsidiaries in several Member States should also watch the third-country and non-EU group provisions under the CSRD, which follow their own timeline.

The voluntary standard and the value-chain cap

The second delegated act creates a voluntary reporting standard for companies that sit outside CSRD scope. It gives smaller companies a single, proportionate reference framework instead of a scatter of bespoke questionnaires, and it is built on EFRAG’s voluntary standard for non-listed small and medium-sized undertakings, the VSME. A company that is not obliged to report can use it to answer requests for sustainability information from large financial institutions and large corporate customers.

The provision with the widest reach is the value-chain cap. A company subject to the CSRD cannot require protected undertakings in its value chain (undertakings that do not exceed an average of 1,000 employees during the preceding financial year) to provide, for CSRD sustainability reporting purposes, more sustainability information than the datapoints specified in Annex II to the voluntary-standard delegated regulation. For a large reporting group, that is a hard limit on what its own CSRD data-collection templates can require from protected value-chain undertakings. Procurement and sustainability teams that built supplier questionnaires around the full ESRS dataset will need to check those questionnaires against the cap, because a request that goes beyond the voluntary standard is no longer one a smaller counterparty is obliged to answer.

The cap is often misread as a ban on collecting value-chain data. It is a ceiling on what an in-scope company can compel from smaller value-chain partners, and it does not stop a supplier from volunteering more, nor does it remove the reporting company’s own obligation to disclose material value-chain information where it can reasonably obtain it. We covered the mechanics of that limit in detail in our note on the Omnibus value-chain cap; the 3 July adoption is the point at which the cap moves from proposal to an adopted delegated act awaiting scrutiny.

What to check before the next filing

The revision rewards teams that treat it as a controlled change to an existing reporting process rather than a fresh start. A handful of checks carry most of the value.

First, decide the version question deliberately. Confirm whether the group is still in scope under the Directive (EU) 2026/470 thresholds for the years ahead, then decide whether early application of the revised ESRS for FY2026 is worth pursuing. That decision drives everything downstream and should be made with the auditor in the room.

Second, remap the datapoints. Take the current datapoint inventory from the last statement and mark each item as retained, deleted, converted to voluntary, or moved under the revised standards. The binding annexes to the revised ESRS delegated regulation are the reference for that reconciliation, supported by the explanatory memorandum and staff working document. This is where the more-than-60% figure becomes a concrete list of controls and data feeds that can be retired or repurposed.

Third, re-examine the materiality assessment against the simplified process, and document the reasoning. Even a lighter assessment has to be defensible to an assurance provider, and the trail from assessment to disclosed topics is what an auditor tests.

Fourth, align the value-chain data requests with the cap before the next procurement cycle sends them out. A questionnaire that overreaches wastes effort chasing data a counterparty can decline to give. Firms that also tag their sustainability statements digitally should keep an eye on how the taxonomy tracks the revised standards, a point we cover in our note on the ESEF digital tagging update.

This revision is one strand of a broader EU push to cut reporting cost across frameworks, sitting alongside moves like the EU tax simplification package. Treating them as a single burden-reduction programme makes the resourcing case easier to explain internally.

Frequently Asked Questions

Do the revised ESRS apply to my next sustainability statement automatically?

No. The revised ESRS were adopted on 3 July 2026 but still have to clear a scrutiny period of two months, extendable by a further two months, before they apply. They apply on a mandatory basis from financial year 2027. Undertakings falling within the scope of Delegated Regulation (EU) 2023/2772 may choose the revised ESRS for financial years starting between 1 January and 31 December 2026 once the delegated regulation has entered into force, but that is an election, not a default.

What is the difference between the more-than-60% and more-than-70% figures?

The more-than-60% reduction applies to mandatory datapoints, the items a company must report where the topic is material. The more-than-70% reduction applies to the total datapoints in the standards, which also includes voluntary datapoints. For estimating a reporting obligation, the mandatory figure is the relevant one; the total figure overstates the change to what any single company was actually required to disclose.

Does simplification mean my group no longer has to report?

Not by itself. The revised ESRS change how in-scope companies report. Whether a company is in scope is governed by Directive (EU) 2026/470, which raises the threshold to broadly more than 1,000 employees and net turnover above EUR 450 million for financial years starting on or after 1 January 2027. Scope and standards are two different questions, and a group can remain fully in scope while using the lighter standards.

Is double materiality still part of the revised ESRS?

Yes. The Commission retained double materiality as the basis for the standards. A company still assesses both how sustainability matters affect it financially and its own impacts on people and the environment. What the revision changes is that the materiality assessment process is simplified and the number of datapoints behind it is smaller.

What does the value-chain cap stop me from doing?

If your company is subject to the CSRD, you cannot require a protected value-chain undertaking to give you, for CSRD sustainability reporting purposes, more sustainability information than the datapoints specified in Annex II to the voluntary-standard delegated regulation. It does not stop a smaller partner from volunteering additional data, and it does not remove your own duty to disclose material value-chain information you can reasonably obtain. It caps what you can compel from smaller suppliers.

Where are the authoritative details, beyond the Commission’s announcement?

The one-page news release carries the headline percentages. The binding detail is in the two delegated acts amending Delegated Regulation (EU) 2023/2772, the explanatory memorandum describing where the Commission diverged from EFRAG’s draft, and the staff working document on the revision process. Those are the documents to reconcile against your current datapoint mapping.

Should we apply the revised ESRS early for financial year 2026?

That is a judgement for each group with its auditor. Early application can reduce the FY2026 workload, but it affects comparability with prior statements and requires the assurance engagement and internal controls to be aligned to the revised datapoints from the outset. The decision needs to be made before assurance fieldwork begins.

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Key Takeaways

  • On 3 July 2026 the Commission adopted two delegated acts: a revised set of ESRS amending Delegated Regulation (EU) 2023/2772, and a new voluntary standard for smaller companies.
  • The revised ESRS cut mandatory datapoints by more than 60% and total datapoints by more than 70%, on the Commission’s estimate, with expected cost savings of more than 30% per company.
  • Adoption is not application. The acts face a scrutiny period of two months, extendable by two more, before they take effect.
  • The revised ESRS apply on a mandatory basis for financial years beginning on or after 1 January 2027, with an option to apply them for financial years starting between 1 January and 31 December 2026 once the delegated regulation has entered into force.
  • Scope is a separate question, set by Directive (EU) 2026/470: broadly more than 1,000 employees and net turnover above EUR 450 million, for financial years starting on or after 1 January 2027.
  • Double materiality and the ESRS 1, ESRS 2, and topical-standard architecture are retained; the content inside the structure is what shrank.
  • The value-chain cap limits what CSRD companies can require from protected value-chain undertakings, for CSRD sustainability reporting purposes, to the datapoints specified in Annex II to the voluntary-standard delegated regulation.
  • The practical work is a datapoint remap and a version decision made with the auditor, not a fresh build.

Sources and References

  • European Commission, “Commission adopts revised sustainability reporting standards to reduce administrative burdens for EU businesses while maintaining high-quality disclosures” (3 July 2026): finance.ec.europa.eu news article
  • European Commission, Commission Delegated Regulation of 3 July 2026 amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standards: delegated regulation
  • European Commission, Annexes to the Commission Delegated Regulation amending Delegated Regulation (EU) 2023/2772: revised ESRS annexes
  • European Commission, Commission Delegated Regulation of 3 July 2026 supplementing Directive 2013/34/EU by establishing sustainability reporting standards for voluntary use by undertakings protected by the value chain cap: voluntary-standard delegated regulation
  • European Commission, Annexes to the voluntary-standard delegated regulation: voluntary-standard annexes
  • European Commission, Staff working document accompanying the delegated acts: staff working document
  • European Commission, Corporate sustainability reporting and delegated acts overview: finance.ec.europa.eu corporate sustainability reporting
  • European Commission, “Commission seeks feedback on revised sustainability reporting standards” (6 May 2026): finance.ec.europa.eu feedback notice
  • Commission Delegated Regulation (EU) 2023/2772 (original ESRS Set 1): EUR-Lex CELEX 32023R2772
  • Directive (EU) 2022/2464 (Corporate Sustainability Reporting Directive): EUR-Lex CELEX 32022L2464
  • Directive (EU) 2026/470 of 24 February 2026 (Omnibus content directive, sustainability reporting and due diligence): EUR-Lex CELEX 32026L0470
  • Directive (EU) 2025/794 (stop-the-clock directive): EUR-Lex CELEX 32025L0794

Getting the sequencing right this cycle

The revised ESRS are a genuine reduction in reporting content, but the value only lands for teams that treat this as a change-control exercise on a live process. Fix the version decision first, remap the datapoints against the Commission’s memorandum second, and align the value-chain requests and the assurance plan around whichever framework the next statement is built on. The saving is available from financial year 2026 for companies that choose it and clear the conditions; missing the sequencing is how a lighter standard turns into a heavier cycle.

Last updated: July 2026

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