The Revised ESRS are final: how to prepare for 2026 sustainability reporting
After more than a year of simplification work under Omnibus I, undertakings in scope of the CSRD now have final standards, and the EFRAG Secretariat has released the datapoint list to go with them. The main decision is which standards to apply for financial year 2026.
From Delegated Act to Official Journal
On 3 July 2026, the European Commission adopted two Delegated Acts: the Revised ESRS and the Voluntary Standard (VS). They passed the scrutiny period without any objection and publication took place on 21 September 2026, and the Revised ESRS enter into force on 10 November 2026.
The Revised ESRS are mandatory for financial years beginning on or after 1 January 2027. Undertakings already reporting for FY2026 may opt to apply them early.
The Commission states that mandatory datapoints are reduced by over 60% and total datapoints by over 70%. Double materiality is retained, but unlike the 2023 ESRS there are no datapoints to report irrespective of the materiality assessment. Under the value chain cap, undertakings cannot require value chain undertakings with 1,000 employees or fewer to provide more than the VS requires.
The 2026 Draft List of ESRS Datapoints
On 28 August 2026, the EFRAG Secretariat published the 2026 Draft List of ESRS Datapoints, containing 292 datapoints. It uses the same methodology as the 2024 IG 3 List of Datapoints and links to the interactive ESRS on the EFRAG ESRS Knowledge Hub. A separate version references the corresponding 2023 ESRS paragraphs.
The list is non-authoritative supporting material, not Implementation Guidance. It is open for a public fatal-flaw review until 23 October 2026, and the final version is expected in November 2026. A Draft XBRL Taxonomy for ESRS has been prepared in parallel.
Preparing for 2026 reporting
1. Decide which standards to apply for FY2026. Choose between the 2023 ESRS and early application of the Revised ESRS. Applying the Revised ESRS now avoids a second transition in 2027. Agree the choice with your assurance provider.
2. Revisit the double materiality assessment. The assessment now determines almost the entire scope of the sustainability statement. Review your impacts, risks and opportunities (IROs) and document the reasoning so that it can be assured.
3. Map your datapoints. Use the Draft List and the version with 2023 ESRS references to identify which datapoints fall away, change or are still missing.
4. Align value chain requests and systems. Keep supplier requests within the VS cap, and update data systems, disclosure controls and XBRL tagging.
5. Submit feedback and set the timeline. Report any fatal flaws to EFRAG by 23 October. Then work backwards from your reporting date, with a buffer for the final list in November.
Undertakings that make their FY2026 decision now and rebuild their data model around the Revised ESRS will be best prepared for 2027.
Contact Erik Alendal to know more!
Erik Alendal
erik.alendal@ethos.se
About Ethos
Ethos is one of the Nordic region’s oldest and leading sustainability-focused consultancies, with over 20 experts covering environmental issues, human rights, and anti-corruption. We help medium to large companies and financial market actors address sustainability challenges—from strategic boardroom decisions to operational policy compliance on the factory floor. Ethos tailors each project to clients' needs, supporting compliance with CSRD, SFDR, EU Taxonomy, and CSDDD regulations while guiding their strategic sustainability journeys.