What are ESRS?
European Sustainability Reporting Standards (ESRS) specify the information used in sustainability statements under the Corporate Sustainability Reporting Directive (CSRD). Regulation (EU) 2023/2772 contains ESRS 1, ESRS 2, and ten topic standards. The Germany requirements guide connects ESRS to national implementation and supplier requests.
On 19 August 2026, the Commission's 3 July 2026 revised ESRS act was not yet in force because it had not reached the Official Journal. It is designed to apply from financial years beginning on or after 1 January 2027, with optional use for financial year 2026 once in force. Record the reporting year and ESRS version beside each disclosure requirement.
Why do ESRS matter to you?
ESRS 1 paragraphs 63-69 bring upstream and downstream value-chain information into the statement. A reporting customer may therefore ask you for a site, period, unit, method, assumption, and source record even when you do not publish an ESRS statement.
“Send ESRS data” is incomplete. E1-5 paragraph 37 asks for energy in megawatt-hours by source; E1-6 paragraph 44 asks for emissions in metric tonnes of CO2e. Confirm the disclosure requirement, entity boundary, dates, unit, and permitted estimate first.
How do ESRS work?
ESRS use two materiality tests. Paragraph 43 asks whether the company has a material impact on people or the environment. Paragraph 49 asks whether a sustainability matter could have a material financial effect on the company. A topic enters the statement if it passes either test or both. ESRS 2 disclosures and the listed disclosures about how the company ran its assessment are always required under ESRS 1 paragraph 29. Paragraph 30 adds the detailed disclosures for each material topic.
Due diligence informs the assessment under paragraphs 58-61; paragraphs 63-69 cover value-chain information and estimates. Paragraph 77 defines short term as the financial reporting period, medium term as the following period up to five years, and long term as more than five years. Paragraphs 78-80 permit justified adjustments.
ESRS 2 covers reporting basis, governance, strategy, material impacts, risks and opportunities, policies, actions, metrics, and targets. ESRS 1 paragraph 29 makes these cross-cutting disclosures mandatory even when a topic is not material.
The 2025 phase-in is not a general exemption. Reporters that started with financial year 2024 may omit ESRS E4 Biodiversity and ecosystems, S2 Workers in the value chain, S3 Affected communities, and S4 Consumers and end-users from their first three statements, covering financial years 2024, 2025, and 2026. If an omitted topic is material, amended ESRS 2 paragraph 17 still requires the materiality result, the sustainability matters involved, their effect on strategy, and how the company responds to negative impacts or risks.
The published standards are sector-agnostic, so they apply across industries. Directive (EU) 2026/470 recital 20 and Article 2(6)(a) deleted the mandate for mandatory sector-specific ESRS. Industry guidance may help apply the common set but cannot replace it.
What mistakes should you avoid?
- Using ESRS to decide legal scope instead of checking Directive (EU) 2026/470 and national law.
- Citing paragraphs 37-39 as the materiality tests; the operative impact and financial criteria are in ESRS 1 paragraphs 43 and 49.
- Dropping ESRS 2 after finding a topic immaterial, despite ESRS 1 paragraph 29.
- Claiming phase-in without naming the Appendix C row, the reporting year, and the ESRS 2 paragraph 17 information still due.
Are ESRS and CSRD the same?
No. The CSRD amends Directive 2013/34/EU and sets the reporting obligation. Regulation (EU) 2023/2772 tells an in-scope reporter how to prepare the information. One ESRS datapoint request does not place a supplier in CSRD scope.
What should you send when a customer asks for ESRS data?
Send the disclosure requirement, datapoint, period, entities and sites, unit, method, assumptions, exclusions, owner, and source documents. For E1-5, that can mean energy invoices, meter exports, and supplier source-mix statements, not a complete ESRS report.