Your 2027 sustainability report will not be built on the ESRS you studied in 2024. Commission Delegated Regulation (EU) 2026/1563 replaces the text of the standards and sets precise dates: entry into force set for 10 November 2026, application to financial years starting on or after 1 January 2027. For a sustainability or finance team, the question is no longer whether the simplified ESRS are coming, but what to adjust and in what order.

This article covers what the regulation changes and what it leaves in place: the timeline and the option open for 2026, the 12 standards kept, the cut in data points, double materiality, ESRS E1 on climate, phase-in, and the link with Directive (EU) 2026/470 and the voluntary standard. It ends with an action list.

Facts checked on 8 and 9 October 2026 against the texts in the Official Journal of the European Union (OJEU) and the European Commission and EFRAG websites.

Delegated Regulation 2026/1563: what was adopted

Commission Delegated Regulation (EU) 2026/1563 of 3 July 2026 amends Delegated Regulation (EU) 2023/2772, which adopted the European Sustainability Reporting Standards (ESRS). Its Article 1 replaces Annexes I (the standards) and II (the glossary). The framework is therefore rewritten in a simplified version, with the same architecture.

The text was published in the OJEU on 21 September 2026: the version published in the OJEU is the one to cite.

This regulation is the "content of the standards" part of the Omnibus I package. The "scope, assurance and due diligence" part is Directive (EU) 2026/470, covered below. For the overall framework, our guide to the CSRD after the Omnibus remains the reference.

The timeline: from 10 November 2026 to financial year 2027

Three dates structure the topic:

  • 21 September 2026: publication in the OJEU.
  • 10 November 2026: date of entry into force set by Article 3, not "the twentieth day following publication".
  • 1 January 2027: application to financial years starting on or after that date. For a calendar-year company, the first report under the revised ESRS covers 2027 and is published in 2028.

The option open for financial year 2026

For financial years starting in 2026, Article 2 lets undertakings within the scope of Regulation 2023/2772 choose between two routes:

  • apply either the 2023 ESRS as amended by Delegated Regulation (EU) 2025/1416 (the "quick fix"), or the new ESRS directly;
  • or stay on the 2023 ESRS (as amended by Regulation 2025/1416) and add eight reliefs from the new text: the top-down approach to double materiality (ESRS 1 §27), undue cost or effort and the value chain limit (§§32-33), acquisitions and disposals (§§74-75), non-significant activities (§90), partial value chain coverage (§91), joint ventures (§92), Taxonomy information in a separate annex (§106) and the executive summary (§110).

The company must state clearly in its sustainability statement which version it applies for 2026. Reports published in 2027 on financial year 2026 can therefore follow the old or the new framework; those for financial year 2027 must follow the revised ESRS. The choice belongs to the company and its advisers.

Twelve standards kept, same structure

The simplification removes no standard. The framework keeps 12 standards:

  • Cross-cutting: ESRS 1 (general requirements) and ESRS 2 (general disclosures);
  • Environment: E1 climate change, E2 pollution, E3 water, E4 biodiversity and ecosystems, E5 resource use and circular economy;
  • Social: S1 own workforce, S2 workers in the value chain, S3 affected communities, S4 consumers and end-users;
  • Governance: G1 business conduct.

What changes is the volume asked for in each standard and how materiality is decided. For the content of each standard, see our article on the ESRS standards. Sector-specific standards will not exist: Directive 2026/470 removed the empowerment that allowed the Commission to adopt them.

The cut in data points: what the published figures say

The regulation aims to reduce the number of data points, favour quantitative over narrative information, separate mandatory from voluntary content more clearly and clarify materiality (recital 2). Two sets of figures circulate.

The Commission (press release of 3 July 2026) states that the revised ESRS cut mandatory data points by more than 60% and total data points by more than 70%. It estimates the drop in reporting costs at more than 30% per company.

EFRAG, in its technical advice of November 2025, measured its draft against the 2023 ESRS data point list: minus 61% of mandatory data points, minus 71% including voluntary ones, all of which are removed. For ESRS E1 it reported minus 57% of data points.

The Commission did, however, amend the final text on 13 points compared with EFRAG's advice (greenhouse gases, transition plans, materiality, human rights, among others; recital 3). EFRAG's per-standard percentages are therefore not guaranteed to match the published text. Prefer the Commission's figures, presented as estimates.

Three ESRS 1 rules lighten the work: an undertaking does not report information prescribed by a requirement if it is not material (§24), it may report only on material sub-topics (§30), and additional non-material information is framed (§8.2).

Double materiality: the top-down approach enters the text

The double materiality assessment remains the entry point of the report, with less exhaustiveness required. Our article on double materiality covers the method; here is what changes.

  • Top-down approach (§27). The undertaking may conclude that a topic is or is not material without a finer assessment, based on its strategy, business model, sectors, geographies and value chain. If the conclusion is not obvious, a specific assessment remains mandatory. The bottom-up approach remains possible (§28), and the two can be combined.
  • Reasonable information (§32). The undertaking relies on information available without undue cost or effort and focuses on the areas where impacts, risks and opportunities are likely.
  • Value chain (§33). The assessment can be made without direct input from value chain actors, using regional averages or sector data.
  • Qualitative analysis. It can be enough to conclude on materiality (AR 13).
  • Severity. For a potential negative human rights impact, severity takes precedence over likelihood (§40).
  • Frequency (§34). At each reporting date, the undertaking checks whether significant changes affect its conclusions. The text therefore calls for a review at each close and an update when a significant change occurs.

The process (ESRS 2, IRO-1) and its results remain to be published: the list of material impacts, risks and opportunities and of the requirements retained (SBM-3, IRO-2). If climate is judged not material, the undertaking publishes the basis for that conclusion. A topic is reported if it is material from either perspective (impact or financial), not both. The text prescribes no matrix format.

ESRS E1 climate: what changes for the carbon footprint

The 2023 version is detailed in our article on the ESRS E1 standard. Here are the points to retain from the revised version.

Eleven disclosure requirements: E1-1 transition plan, E1-2 climate risks and scenarios, E1-3 resilience, E1-4 policies, E1-5 actions and resources, E1-6 targets, E1-7 energy, E1-8 gross greenhouse gas (GHG) emissions, E1-9 removals and carbon credits, E1-10 internal carbon pricing, E1-11 anticipated financial effects.

E1-8, gross emissions. Emissions in tCO2e: scope 1 with the share under the EU ETS, scope 2 location-based and market-based, scope 3 for each significant category, in total and by category. Direct biogenic CO2 is separated from scope 1. The default boundary follows financial control. The disaggregation table (AR 26) contains neither a total of scopes 1, 2 and 3 nor an intensity per revenue.

For scope 3, AR 24 expects:

  • the GHG Protocol Scope 3 standard (2011 version) as a basis, with the option to consider Recommendation (EU) 2021/2279 or ISO 14064-1:2018;
  • a screening of the 15 GHG Protocol categories (or the ISO 14064-1:2018 categories) and the identification of significant categories (estimated magnitude, spend, influence, transition risks and opportunities, stakeholder views);
  • a preference for specific, verified data;
  • an annual update of each significant category, and of the full inventory at least every three years or after a significant event;
  • where applicable, disclosure of cloud services and data centres as a subset of category 1.

For the method, see scope 3 and the GHG Protocol.

E1-6, targets. Absolute reduction targets for scopes 1, 2 and 3 (separate or combined), and intensity targets "where applicable". If only an intensity target exists, the associated absolute values are disclosed. The base year must be recent and representative, and the undertaking states whether its targets are science-based and compatible with 1.5 °C. No fixed year is imposed: the example table is illustrative.

E1-1, transition plan. An undertaking that has one discloses its key features (targets, levers, investments, approval, integration into strategy, locked-in emissions). One that has none says so and states whether and when it intends to adopt one (§13): the obligation is one of transparency. Scenario analysis (E1-2) is mentioned conditionally ("if used").

Phase-in: transitional reliefs

ESRS 1 (§§121-127) keeps transitional reliefs. They are counted from the first year the undertaking is subject to reporting: earlier voluntary application does not start the count.

  • First wave (financial years starting from 1 January 2024 to 31 December 2026) above EUR 450 million net turnover and 1,000 employees: may omit E4, S2, S3 and S4 before 2027, information on anticipated financial effects before 2028 (the quantitative part before 2030), quantitative information on substances of concern (E2-5) before 2030 and several S1 requirements before 2027.
  • First wave below at least one of the two thresholds: may omit all requirements of the topical standards before 2027, plus the same deferrals.
  • Other undertakings (financial years from 2027): may omit E4, S2, S3 and S4 for two years, anticipated financial effects for two years (four for the quantitative part), quantitative information on substances of concern for three years and certain S1 requirements for one year.
  • Value chain (§123): for three years, if not all information is available, the undertaking explains its efforts, the reasons and its plan to obtain it.

An undertaking using phase-in discloses it (ESRS 2, BP-2). The detail per requirement should be read in the OJEU text before deciding what to omit.

Regulation 2026/1563 says how to report. Directive (EU) 2026/470 of 24 February 2026, published on 26 February and in force since 18 March 2026, says who reports and what is assured.

Thresholds. An undertaking is in scope if it exceeds both EUR 450 million net turnover and 1,000 employees on average, on a consolidated basis for a group. The balance sheet total criterion is removed and the "two out of three" regime (250 employees, EUR 50 million turnover, EUR 25 million balance sheet) is obsolete. Listed SMEs drop out of scope. The thresholds apply to financial years starting from 1 January 2027, and Member States may exempt undertakings below the new thresholds for financial years 2025 and 2026.

Transposition. Member States must bring the necessary provisions into force by 19 March 2027 at the latest (Article 5 of the directive). This European date is the reference point for the French timeline.

Assurance. It remains limited. The Commission must adopt limited assurance standards by delegated act by 1 July 2027 at the latest (initially 1 October 2026), and the provision for adopting reasonable assurance standards is removed. The audit opinion covers compliance with the ESRS, the process to identify information, digital tagging and Article 8 of the Taxonomy. In France, absent a European standard, assurance providers follow the H2A guidelines (Haute Autorité de l'audit, formerly H3C) of January 2026.

For teams, the point to retain is evidence. Requirement GOV-4 (ESRS 2) asks for the scope of the risk management and internal control processes over reporting to be disclosed, with the completeness and integrity of data and the accuracy of estimates. Information is verifiable if the information or the inputs that produced it can be corroborated.

The value chain cap and voluntary standard 2026/1560

Delegated Regulation (EU) 2026/1560, adopted on 3 July and published in the OJEU on 21 September 2026, provides for entry into force on the third day after publication, i.e. 24 September 2026. Its cap applies to financial years starting from 1 January 2027. The mechanics, set by Directive 2026/470 (Article 19a(3) of amended Directive 2013/34/EU):

  • protected undertakings are those with 1,000 employees or fewer on average over the previous financial year that sit in the value chain of a reporting undertaking. There is no turnover criterion;
  • they may refuse any information beyond the voluntary standard, for a request made for sustainability reporting purposes;
  • a contrary contractual clause is not binding, and size is evidenced by self-declaration unless there is a manifest error;
  • a reporting undertaking that asks for more must flag what goes beyond the cap and recall the right to refuse.

The cap does not apply to due diligence or to purposes other than sustainability reporting, and imposes no obligation to provide information. A trap: a mid-cap with 1,200 employees and EUR 300 million turnover is outside the CSRD but not protected, since it exceeds 1,000 employees. The detail is in our article on the voluntary standard.

What to do before the 2027 close

These points are organisational recommendations, not legal obligations. The choice to apply an option or a relief rests with your lawyer or adviser.

  • Check your status on 1 January 2027: consolidated net turnover and average headcount against the two cumulative thresholds, and any first-wave membership.
  • Decide the framework for financial year 2026 and prepare the explicit statement in the sustainability statement.
  • Revisit your double materiality in light of §27: topics you can conclude top-down, topics to assess, documented basis for each conclusion.
  • Map your data points by material standard, and drop from collection what is no longer requested.
  • Rebuild your scope 3 per AR 24: screening of the 15 categories, significance criteria, annual update of significant categories, full inventory every three years.
  • Align your E1-6 targets: absolute targets, base year, science-based statement.
  • Settle your position on the transition plan: publish it, or state you have none and whether and when you intend to adopt one.
  • Draw up the phase-in schedule: deferred requirements, starting year, BP-2 statement.
  • Put traceability in place: supporting documents, owner of each data point, internal controls described in the sense of GOV-4.
  • Revise your supplier questionnaires against voluntary standard 2026/1560 and flag what goes beyond it.
  • Track three deadlines: the regulation's entry-into-force date (10 November 2026), transposition of the directive by 19 March 2027, limited assurance standard before 1 July 2027.

How Kabaun supports 2027 report preparation

Kabaun is a carbon management platform for groups and mid-caps. It covers the three GHG Protocol scopes with the 15 scope 3 categories (CBC-002) and generates CSRD and ESRS reports, notably ESRS E1 (REG-002). Three features address the list above:

  • automated supplier questionnaires, with response tracking and scheduled reminders, for scope 3 collection (AUT-005);
  • an audit trail of data, changes, calculations and validations, with timestamps and author identification (CERT-003), and supporting documents attached to each data point (CERT-004);
  • a regulatory watch module that covers the 2026 Omnibus (REG-001).

To discuss your preparation, use the Kabaun contact page.

FAQ: the simplified ESRS

When do the simplified ESRS enter into force?

Delegated Regulation (EU) 2026/1563 provides in its Article 3 for entry into force on the fixed date of 10 November 2026. It applies to financial years starting on or after 1 January 2027. A calendar-year company therefore prepares its first report under the revised ESRS for 2027, published in 2028.

Must the financial year 2026 report follow the new ESRS?

No, it is an option. For financial years starting in 2026, the undertaking may apply the 2023 ESRS amended by Regulation 2025/1416, the new ESRS, or the 2023 ESRS with eight reliefs from the new text. It states clearly in its sustainability statement which version it applied.

By how much do data points fall?

According to the European Commission (3 July 2026), mandatory data points fall by more than 60% and total data points by more than 70%. EFRAG measured minus 61% and minus 71% on its November 2025 draft.

Who must report under the ESRS in 2027?

Undertakings that exceed both EUR 450 million net turnover and 1,000 employees on average, on a consolidated basis for a group, for financial years starting from 1 January 2027 (Directive 2026/470). Listed SMEs are out of scope. National transposition is due by 19 March 2027 at the latest.

Is a full double materiality assessment still needed?

The assessment remains mandatory, but ESRS 1 allows the top-down approach (§27) and a sufficient qualitative analysis, without undue cost or effort. A specific assessment is still needed when the conclusion is not obvious, and the process and results must still be published.

Can a company with 1,000 employees or fewer refuse a client's questionnaire?

It can refuse any information beyond the voluntary standard (Regulation 2026/1560) when the request is made for sustainability reporting. The right to refuse does not apply to due diligence, and a contrary contractual clause is not binding.

Conclusion

The simplified ESRS keep the CSRD architecture and reduce the volume: 12 standards, fewer data points, a less exhaustive double materiality, and targets and a transition plan framed with more flexibility. The dates to remember are 10 November 2026, the entry-into-force date set by the regulation, and 1 January 2027 for application, with an option for financial year 2026.

To organise this preparation on your carbon data, contact the Kabaun team.

Official sources

  • Delegated Regulation (EU) 2026/1563: https://publications.europa.eu/resource/celex/32026R1563
  • Delegated Regulation (EU) 2026/1560: https://publications.europa.eu/resource/celex/32026R1560
  • Directive (EU) 2026/470: https://publications.europa.eu/resource/celex/32026L0470
  • European Commission, press release of 3 July 2026: https://finance.ec.europa.eu/news/commission-adopts-revised-sustainability-reporting-standards-2026-07-03_en
  • EFRAG, amended ESRS and technical advice: https://www.efrag.org/en/draft-simplified-esrs
  • H2A, guidelines of January 2026 (in French): https://h2a-france.org/referentiel-normatif-et-code-de-deontologie/lignes-directrices-de-la-h2a/