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Tag: ESRS

  • ESRS-40a: CSRD Is Back for Non-EU Parent Companies

    For eighteen months, the message reaching boardrooms in New York, London, Zurich and Singapore has been reassuringly simple: the Omnibus package gutted CSRD, our European subsidiaries fell out of scope, file closed. For the EU entities, broadly true. What it missed is that the obligation did not disappear — it moved up the corporate structure, to the non-EU parent.

    On 23 July 2026, EFRAG published the Exposure Draft of ESRS-40a — the sustainability reporting standard for certain non-EU undertakings — and opened a 100-day consultation running to 31 October 2026. It implements Article 40a of the Accounting Directive, and applies a test with nothing to do with how many people you employ in Europe. If your group sells enough into the EU, you report.

    What ESRS-40a actually is

    Articles 19a and 29a of the Accounting Directive catch EU companies and EU-parented groups. Article 40a is the extraterritorial arm: it catches groups headquartered outside the EU that do significant business inside it. ESRS-40a is the standard telling them what to disclose, and the logic is a level playing field — a US or Japanese group booking hundreds of millions in EU revenue competes with EU companies carrying a full ESRS burden.

    The scope test: run it before you do anything else

    The threshold is two-part, and both parts must be met. A third-country undertaking not listed on an EU regulated market is in scope if it meets:

    • Turnover test. Net turnover in the Union above €450 million in each of the last two consecutive financial years; and
    • Presence test. Either an EU branch with net turnover above €200 million in the preceding financial year, or it is the ultimate parent of EU subsidiaries with net turnover above €200 million in the preceding financial year.

    These behave differently from the tests your European finance team has been applying: no employee headcount criterion, no balance-sheet criterion. It is a revenue test measured at group level on turnover booked in the Union — so a group with modest European operations and a lean legal footprint can still clear the bar on distribution revenue alone.

    Who actually publishes the report

    The parent is the reporting undertaking, but it does not file. The report is published on the parent’s behalf by an EU subsidiary that would itself fall within CSRD scope, or by a large EU branch. That puts a European entity — often one with no sustainability function of its own — on the hook for making a group-level disclosure public. Flag it early to your European legal and finance leads: the people who sign and file are rarely the people who produce the data.

    What you report — and, importantly, what you don’t

    ESRS-40a is deliberately lighter than a full ESRS sustainability statement. The Article 40a report focuses on impacts — the effects of the group’s activities on people and the environment. It generally excludes the risk-and-opportunity architecture Articles 19a and 29a demand: resilience analysis, dependencies, and the financial-materiality half of double materiality sit outside its content.

    For teams that have watched EU peers build scenario analysis and transition plans, that is good news. But narrower is not easier — the hard part of ESRS-40a is not the disclosure list. It is the boundary.

    The “mixed approach” is the fight that decides your cost

    This is the detail that deserves attention during the consultation window. The draft requires a blend of EU-scoped and global-scoped information — some disclosures drawn from the group’s European activities, others from the group as a whole.

    EFRAG’s own Sustainability Reporting Board did not approve this comfortably. It released the Exposure Draft while recording reservations about the mixed approach, and Chair Kerstin Lopatta published a letter setting out those concerns before launch, noting the approach reflects a request from the European Commission. The objection is practical as much as legal: separating EU-related impacts from global ones is difficult, and in places arbitrary.

    For a reporting team, that is not standard-setting politics — it is the single biggest driver of your data-collection cost. A global-scope disclosure can usually be sourced from systems you already run. An EU-scope disclosure means carving European activity out of consolidated data — by site, by entity, by supplier — for metrics your systems were never designed to slice that way. Every requirement landing on the EU-scoped side adds a pipeline you do not have.

    Which is why the consultation matters. Feedback closes 31 October 2026 and EFRAG’s technical advice goes to the Commission in January 2027. After that, the boundary question is settled and you are implementing someone else’s answer.

    The timeline looks distant. It isn’t.

    Reporting becomes mandatory for financial years beginning on or after 1 January 2028, with first reports published in 2029. Three years is comfortable — right up until you work backwards.

    • 2029 — first report published.
    • FY2028 — the reporting year. Data must be complete, consistent and evidenced across twelve months, from day one.
    • FY2027 — the dry run: find the gaps in EU-scoped data and fix them. Anyone through a first ESRS cycle knows this year is not optional.
    • 2026–2027 — scoping, system selection, and getting European entities collecting data in a form that consolidates.

    That leaves roughly eighteen months of genuine slack, not three years — landing on organisations that spent the last year actively de-resourcing European sustainability compliance.

    Why the scope cut makes this more exposing, not less

    EFRAG has estimated that the Omnibus changes cut the number of non-EU companies in scope from roughly 10,000 to around 1,200 — a 90% reduction, reported as relief. Consider it from the other direction: the remaining population is small, large and identifiable. Any regulator, NGO or journalist can assemble a credible list of who should be reporting and check whether they did. In a group of 10,000, a thin disclosure is noise. In a group of 1,200, it is a story.

    This is the same pattern we described when the SEC’s climate rollback failed to free US multinationals: deregulation in one jurisdiction rarely reduces total disclosure obligation for a global group. It relocates it.

    What to do before 31 October

    • Run the test properly. Get an accurate group-level figure for net turnover in the Union for the last two financial years. Not EU-entity revenue — turnover generated in the Union, which can include sales routed through non-EU entities.
    • Identify the filer. Determine which EU subsidiary or branch would carry the publication obligation, and tell them now.
    • Respond to the consultation. If you are in scope, the mixed approach will shape your cost base for a decade. This is the last practical window to influence it.
    • Map EU-scoped data. Take a first pass at which impact metrics you could already report at EU boundary and which need new collection. That gap list is your 2027 project plan.
    • Do not rebuild in a silo. Much of what ESRS-40a asks for overlaps with what you already produce for CDP, ISSB-aligned reporting, or an EU subsidiary’s own CSRD timeline. One data layer with multiple outputs beats a separate European reporting exercise.

    One honest caveat: ESRS-40a is a draft, its content will change before the Commission’s delegated act, and the mixed approach may not survive in its current form. What will not change is the scope test and the FY2028 start date — those sit in the Directive, not the standard. You can wait on the detail. You cannot wait on knowing whether you are in.

    If your group clears the €450 million test, the work starts with knowing what you can already produce at EU boundary. Horizon ESG helps multinational teams collect sustainability data once and report it against multiple frameworks — so a new obligation becomes a mapping exercise, not a new programme. Book a free demo.

  • Data Centres Just Became an ESG Disclosure Risk

    On 14 July 2026, New York became the first US state to slam the brakes on data centre construction. Governor Kathy Hochul signed an executive order barring the Department of Environmental Conservation from issuing discretionary permits for new data centres above 50 MW of power demand for up to a year, while regulators write comprehensive standards from scratch. The trade press read it as an energy-and-AI story. For sustainability teams, it is something else entirely: the moment data centre energy stopped being a line in your Scope 2 footnote and became a strategic disclosure risk your climate reporting has to describe.

    If your business runs a material digital estate — and in 2026 most do — this is the clearest signal yet that compute energy is moving from an efficiency talking point to a permitting, siting, and transition-risk question. The reporting frameworks you already comply with anticipated this. Most disclosures have not caught up.

    What New York actually did

    The order does not ban data centres. It pauses discretionary environmental permitting for the largest facilities — those drawing more than 50 MW, roughly the scale of a hyperscale or large colocation site — for up to twelve months while the state builds a standing regulatory regime. The stated concern is straightforward: surging AI and cloud demand is loading the grid faster than New York can plan for, and the existing permitting process was never designed to weigh that.

    The specifics matter less than the precedent. A US state has now formally treated large-scale compute as an environmental externality worth constraining. That is exactly the kind of policy shift that climate-risk frameworks classify as a transition risk — a change in the regulatory environment that alters the cost, feasibility, or location of your operations. And New York is unlikely to be the last mover; when one jurisdiction sets a template, disclosure-conscious investors start asking every data-centre-intensive issuer the same questions.

    Why this is a disclosure problem, not just an energy one

    Here is the disconnect. Most companies account for data centre electricity as a Scope 2 emissions figure — a number to be measured, reduced, and reported. That framing is correct but incomplete. It captures what your compute emitted last year. It says nothing about whether you can build, power, or expand that compute next year.

    From Scope 2 line item to transition risk

    A permitting moratorium changes the calculus. If a company’s growth assumes new data centre capacity in a jurisdiction that has just paused approvals, that assumption now carries policy risk — potential delay, higher cost, or forced relocation. Under a climate-risk lens, that is a material forward-looking exposure, not a historical emissions total. The same logic extends to grid connection queues, rising industrial power prices, and local opposition, all of which are tightening in the markets where compute demand is highest.

    The physical-risk angle teams forget

    Transition risk is only half the picture. Large data centres are also water-intensive — cooling can consume millions of litres a year — and they concentrate that demand in specific locations. That exposes them to physical climate risk: drought, heat stress, and water-access restrictions that can throttle operations regardless of how clean the power is. A disclosure that reports Scope 2 emissions but ignores where the facilities sit and what they depend on is telling investors half a story.

    What ISSB S2 and ESRS E1 already require

    None of this requires a new rule. The two frameworks most reporters are already inside — IFRS S2 from the ISSB, and ESRS E1 under the CSRD — both demand exactly the forward-looking narrative that data centre exposure calls for.

    • IFRS S2 requires disclosure of the climate-related risks and opportunities that could reasonably affect your prospects, split into transition and physical risk, plus how they feed strategy, financial planning, and resilience under different scenarios. A permitting-constrained compute footprint is a textbook example of what S2 expects you to surface.
    • ESRS E1 requires a transition plan, disclosure of material physical and transition risks, and reporting of energy consumption and mix alongside gross Scopes 1, 2, and 3. The connective tissue between your energy dependency and your strategic resilience is precisely what E1’s risk disclosures are for.

    In other words, the standards already ask the question. New York just made it concrete. For teams still treating climate risk and carbon accounting as separate exercises, this is the argument for joining them up — a theme we explored in our look at how TCFD and CSRD climate disclosure align.

    What a defensible disclosure looks like

    Most current data centre disclosure is boilerplate: an efficiency metric, a PUE figure, maybe a renewable-energy commitment. That is not what a climate-risk framework is asking for. A disclosure that would survive scrutiny does four things:

    • Locates the exposure. Identify where your material compute capacity sits — owned, colocated, or cloud — and flag jurisdictions where permitting, grid access, or water stress is tightening. Generic group-level statements are not enough.
    • Connects energy to strategy. Explain how future capacity needs interact with transition risk. If growth depends on new facilities, say what a permitting delay would mean for the plan.
    • Treats water as a risk, not a footnote. Disclose cooling water dependency in high-stress locations as a physical risk with operational consequences, not just a sustainability metric.
    • Quantifies where it can. Move from “we are committed to efficiency” to ranges, timelines, and scenario-tested impacts. Frameworks reward specificity and penalise vagueness.

    The reporting teams that get ahead of this will not be the ones with the lowest emissions. They will be the ones who can show investors they understand where their digital infrastructure is exposed — and have a credible plan for it. Reliable, location-aware energy and emissions data is the foundation for that; measuring your Scope 1, 2 and 3 footprint accurately is the first step, but connecting it to forward-looking risk is what turns a number into a disclosure.

    Turning compute energy into an audit-ready climate disclosure starts with data you can trust. Horizon ESG helps reporting teams link emissions, energy, and transition-risk narrative in one place — so when the next New York arrives, your disclosure is already ready. Book a free demo to see how.

  • CSRD Value-Chain Cap: What You Can Still Ask Suppliers

    Update, 30 September 2026: Both delegated acts have now been published in the Official Journal (21 September 2026). The Voluntary Standard is Commission Delegated Regulation (EU) 2026/1560, in force since 24 September 2026, and the cap applies to financial years beginning on or after 1 January 2027. The scrutiny caveats below are resolved. For the supplier side, read the value chain cap is now law: what customers can require.

    Most of the coverage of the European Commission’s 3 July package led with the same number: a 60% cut in mandatory ESRS datapoints. That is the headline, and it is real. But buried in the second delegated act is a change that will reshape more programmes than the datapoint cut ever will - and almost nobody is briefing their procurement team on it.

    It is called the value-chain cap. In short: from financial year 2027, a CSRD-scope company will no longer be able to require its smaller suppliers to hand over sustainability data beyond a defined ceiling. If your supplier-engagement programme is built on a 200-question ESG questionnaire pushed down the chain, that programme now has a legal boundary running through the middle of it.

    What the Commission adopted on 3 July 2026

    The Commission adopted two delegated acts. The first is the revised set of European Sustainability Reporting Standards - the concrete landing of the Omnibus I simplification agenda. It cuts mandatory datapoints by over 60%, total datapoints by over 70%, and is expected to reduce reporting costs by more than 30% per company.

    The second is the one to read carefully: a Voluntary Sustainability Reporting Standard, built on the VSME, giving companies outside CSRD scope a single proportionate framework to report against. It is voluntary in the sense that no smaller company is obliged to use it. It is emphatically not voluntary in its effect on the companies above them in the chain - because it sets the ceiling.

    Both acts are now in a two-month scrutiny period before the European Parliament and Council, extendable by a further two months. If neither institution objects, they are published in the Official Journal and enter into force. That caveat matters, and we return to it at the end.

    The value-chain cap, precisely

    The cap protects companies with 1,000 employees or fewer that sit in the value chain of a CSRD reporter. Under the Omnibus I Directive, those companies are entitled to decline requests for sustainability information that go beyond what the Voluntary Standard covers. Micro-enterprises of ten employees or fewer get further relief on top. For CSRD-scope companies, the cap bites from financial year 2027.

    Read plainly, that inverts a decade of supplier-engagement practice. The implicit deal until now was that a large buyer could ask its suppliers for whatever its own reporting obligations demanded, and commercial leverage did the rest. From FY2027, the supplier has a statutory answer: no, and here is the standard that says so.

    Three things the cap does not do

    This is where the early commentary is getting it wrong, so it is worth being exact.

    • It caps what you can require, not what you can ask. The Commission has confirmed that a CSRD reporter may still request information beyond the cap - provided it clearly identifies which parts of the request exceed the cap and informs the supplier of their right to refuse. The cap creates a duty of transparency in the ask, not a prohibition on asking.
    • It applies only to CSRD reporting. The cap operates when fulfilling CSRD reporting obligations. It does not govern information you request for other purposes - commercial qualification, contractual assurance, product compliance, or your own risk management.
    • It does not stop a supplier volunteering more. Plenty of smaller suppliers will keep sharing data, because being easy to buy from is a competitive advantage. The cap removes the obligation, not the incentive.

    Together those three points reframe the cap. It is not a wall. It is a consent boundary - and crossing it now requires you to say out loud that you are crossing it.

    Where the cap collides with CSDDD

    Here is the tension nobody has resolved. The Corporate Sustainability Due Diligence Directive still requires in-scope companies to conduct risk-based human rights and environmental due diligence across their chain of activities - an approach Omnibus I preserved rather than narrowing to tier one. You cannot discharge a risk-based due-diligence obligation without information from the chain. Yet the ESRS package has just capped what you may require from a large part of that same chain.

    The reconciliation is in the scoping: the cap is tied to CSRD reporting obligations, and CSDDD due diligence is a separate legal duty. In principle, a due-diligence request is not a CSRD reporting request, and the cap does not extinguish it.

    In practice, that distinction is going to be tested hard - because it is usually the same supplier, receiving the same questionnaire, from the same buyer, in a single email. If your data requests do not distinguish their legal basis, you invite a supplier to refuse the whole thing on cap grounds, including the parts you are entitled to insist on. The operational bar for all of this is still being written: the Commission’s consultation on CSDDD implementation guidelines closes on 24 July 2026, with the guidelines expected in principle by July 2027. If your supplier programme is material to your business, that consultation is a genuine, closing opportunity to shape it.

    What to do in the next 90 days

    FY2027 sounds distant. It is not - supplier programmes have long lead times, and the contracts you sign this year will still be running when the cap bites.

    1. Re-baseline your supplier questionnaire against the Voluntary Standard. Every question you currently push down the chain now sorts into one of two buckets: inside the cap, or outside it. You cannot manage the boundary until you can see it.
    2. Get headcount into your supplier master data. The 1,000-employee line is now a legal boundary, and most procurement systems do not hold supplier headcount at all. This is the least glamorous item on the list and probably the one with the longest lead time.
    3. Redesign the ask, not just the question set. Beyond-cap requests need to be explicitly flagged as such, with the right to refuse stated. Build that into the template now rather than retrofitting it under deadline.
    4. Separate your legal bases. Split CSRD-reporting requests from due-diligence and commercial requests, and label them. This is the single change that most protects your CSDDD position.
    5. Plan for refusal. Assume a meaningful share of smaller suppliers will exercise the cap. That means leaning harder on estimation, sector averages and spend-based proxies for value-chain data - and being able to document why an estimate was used and how it was derived.

    Prepare - but do not decommission

    One final discipline. Both delegated acts are still in scrutiny, and the revised ESRS are set to apply to financial years beginning on or after 1 January 2027, with early application permitted. Nothing is in the Official Journal yet.

    So the correct posture is prepare, don’t freeze - and above all, don’t switch anything off. The most expensive mistake available right now is to read “60% fewer datapoints” as permission to dismantle data pipelines that a scrutiny objection, an early-adoption decision, or an investor’s own SFDR-driven data request could make you rebuild in eighteen months. Simplification is not the same as less work. A 70% datapoint cut creates a migration project before it creates a saving.

    The companies that will handle this well are the ones that can see, in one place, which datapoints they collect, which regime each one serves, and where in the value chain it came from. That is a data-architecture question long before it is a compliance one - and it is exactly what our CSRD readiness checklist is built to help you work through. If you would like to see how Horizon ESG maps a single data foundation across CSRD, CSDDD and the voluntary standard, book a short demo - we will walk your own supplier data through it.

  • ESRS 2.0: Should You Early-Adopt for FY2026?

    For two years, CSRD preparers have built data pipelines, mapped value chains, and wrestled with more than a thousand ESRS datapoints. That groundwork is about to shift. The European Commission is expected to adopt a simplified set of European Sustainability Reporting Standards - informally “ESRS 2.0” - by delegated act in late June or early July 2026, following a public consultation that closed on 3 June. EFRAG’s advice cuts mandatory datapoints by roughly 61% and removes voluntary datapoints altogether.

    Crucially, the revised standards allow voluntary early adoption from financial year 2026, becoming mandatory only for financial years beginning on or after 1 January 2027. That leaves teams with a genuine decision to make now: keep building to the old standard, or pivot to the lighter regime a year early? This guide walks through what is changing and how to weigh the choice with clarity rather than guesswork.

    What ESRS 2.0 actually changes

    The revision is a simplification exercise, not a rewrite of the directive. Three changes matter most for reporting teams:

    • A ~61% cut in mandatory datapoints, with all voluntary datapoints removed. The aim is to concentrate disclosure on what is decision-useful and drop the long tail of marginal metrics.
    • A “top-down” approach to materiality. Rather than testing each datapoint from the bottom up, teams start from the sustainability matters that are material to the business and work down to the disclosures that follow - reducing the assessment burden that has dominated first-cycle projects.
    • Fair presentation applied to the statement as a whole, rather than to each individual datapoint. This is a meaningful audit and governance shift: the question becomes whether the report as a whole gives a true and fair view, not whether every line item is independently perfect.

    The companion Voluntary SME standard (VSME) is on the same adoption track. It underpins the “value-chain cap,” which limits what CSRD reporters can demand from counterparties with 1,000 or fewer employees - directly relevant if your Scope 3 and supply-chain data depend on smaller suppliers.

    The timeline you are actually working against

    Two dates frame the decision. After the Commission adopts the delegated act, a scrutiny period of up to four months by the European Parliament and Council must conclude before the standards are published in the Official Journal. So while the substance is effectively settled, formal finality arrives later in 2026. Early adoption applies from FY2026; mandatory application begins for financial years starting on or after 1 January 2027.

    This sits on top of the February 2026 Omnibus changes, which narrowed mandatory scope to companies with more than 1,000 employees and more than €450m turnover. Many mid-caps that were preparing to report are now outside mandatory scope entirely - yet still face value-chain data requests from larger customers. If that is you, the early-adoption question is less “must we?” and more “what is the most efficient basis to respond on?” For the fuller picture, see our CSRD timeline for 2025-2028.

    The case for early-adopting ESRS 2.0 for FY2026

    • You report on the lighter regime sooner. If your first mandatory report is FY2027 anyway, early adoption lets your FY2026 disclosure - voluntary or value-chain-driven - use the reduced datapoint set rather than the legacy one.
    • You avoid building data flows you are about to retire. Continuing to engineer collection for datapoints that the revision deletes is sunk cost. Pausing those builds now protects budget and analyst time.
    • Top-down materiality is cheaper to run. Re-scoping your materiality assessment around the new model can shrink the single most expensive part of a first cycle.
    • You signal maturity. A clean, focused report aligned to the final standards reads better to investors and assurance providers than an over-stuffed one built to a superseded draft.

    The case for waiting

    • The act is not yet final. Until the scrutiny period concludes and the text is published in the Official Journal, detail can still move. Building to a near-final draft carries some rework risk.
    • Mid-cycle re-scoping has its own cost. If you are deep into an old-ESRS data build with assurance lined up, switching frameworks mid-stream can create more disruption than it saves.
    • Comparability gaps. Reporting on a different basis from peers for one year can complicate year-on-year and benchmark comparisons until everyone converges in FY2027.
    • Internal readiness. Top-down materiality is conceptually simpler but demands confident judgement about what is material. Teams that built bottom-up muscle memory may need time to adjust.

    How to decide: a practical filter

    Work through four questions in order:

    1. When is your first mandatory report? If FY2027, early adoption mainly affects voluntary or value-chain disclosure in FY2026 - lower stakes, easier to trial. If you are still in mandatory scope for FY2026, the calculus is sharper.
    2. How far is your data build? Early-stage projects can pivot to the reduced set cheaply. Near-complete builds with assurance booked may be better finished as planned.
    3. How exposed are you to value-chain requests? If larger customers are asking for data, aligning early to the final standards - and the VSME value-chain cap - can simplify what you owe them.
    4. Can your assurance provider support it? Confirm they are comfortable giving assurance on an early-adopted basis before you commit. The new statement-level fair-presentation model is worth discussing with them directly.

    Whichever way you lean, the foundational work does not change: a defensible double materiality assessment still anchors the report, and your underlying data still needs to be traceable and audit-ready. For a fuller walkthrough of the standards themselves, see our complete ESRS reporting guide.

    The bottom line

    ESRS 2.0 is the most consequential operational change for CSRD preparers since the directive itself. For most teams whose first mandatory report is FY2027 - and especially those early in their data build or responding to value-chain requests - early adoption is the more efficient path, provided your assurance provider is on board. Teams deep into a near-complete old-ESRS cycle have a stronger case to finish as planned and converge in FY2027. Either way, decide deliberately now rather than drifting into the deadline.

    Horizon ESG helps reporting teams navigate ESG complexity with clarity - including scoping and collecting against the right datapoint set the first time. If you are weighing your ESRS 2.0 options, see how our CSRD reporting software keeps your data audit-ready whichever basis you report on.

  • ESRS Reporting: Complete Guide for 2026

    ESRS Reporting: Complete Guide for 2026

    What Are the European Sustainability Reporting Standards?

    The European Sustainability Reporting Standards, known as ESRS, are the mandatory disclosure standards that underpin the Corporate Sustainability Reporting Directive. Developed by EFRAG and adopted by the European Commission, these standards define exactly what information companies must disclose about their environmental, social, and governance performance. Understanding ESRS is essential for any organisation that falls within CSRD scope - and increasingly relevant for companies in global supply chains that need to provide data to their European partners.

    ESRS Structure: The Complete Framework

    The ESRS framework consists of twelve standards organised into three groups, plus two cross-cutting standards that apply to every reporting organisation.

    Cross-Cutting Standards

    ESRS 1 - General Requirements. Defines the architecture of the standards, including the concepts of double materiality, due diligence, and the reporting boundary. Every organisation subject to CSRD must understand and apply ESRS 1.

    ESRS 2 - General Disclosures. Requires all in-scope companies to disclose information about governance, strategy, impact and risk management, and metrics and targets. ESRS 2 disclosures are mandatory for every reporting entity regardless of materiality assessment results.

    Environmental Standards (E1 through E5)

    • E1 - Climate Change. Covers greenhouse gas emissions (Scope 1, 2, and 3), transition plans, climate-related risks and opportunities, and energy consumption. For most organisations, this is the most data-intensive standard.
    • E2 - Pollution. Addresses air, water, and soil pollution, including substances of concern and microplastics.
    • E3 - Water and Marine Resources. Covers water consumption, withdrawal, discharge, and impacts on marine ecosystems.
    • E4 - Biodiversity and Ecosystems. Addresses impacts on biodiversity, land use change, and ecosystem services.
    • E5 - Resource Use and Circular Economy. Covers material flows, waste management, and circular economy practices.

    Social Standards (S1 through S4)

    • S1 - Own Workforce. Covers employment practices, working conditions, diversity, health and safety, and labour rights for direct employees. See our guide to ESRS S1 own workforce reporting.
    • S2 - Workers in the Value Chain. Extends workforce disclosures to workers in the supply chain and downstream value chain.
    • S3 - Affected Communities. Addresses impacts on communities where the company operates or sources materials.
    • S4 - Consumers and End-Users. Covers product safety, data privacy, and responsible marketing practices.

    Governance Standard

    • G1 - Business Conduct. Covers corporate culture, anti-corruption, whistleblowing, political engagement, and payment practices.

    How Double Materiality Determines Your Scope

    Not every topical standard applies to every organisation. The ESRS framework uses double materiality to determine which standards and data points are material to your business. You must assess both impact materiality - your organisation’s actual or potential impacts on people and the environment - and financial materiality - how sustainability matters create risks or opportunities that affect your financial position.

    Standards and data points deemed non-material through a rigorous, documented assessment can be excluded from your report. However, ESRS 2 general disclosures and E1 climate change disclosures carry a rebuttable presumption of materiality, meaning you must provide a detailed explanation if you exclude them.

    Phased Adoption Timeline

    Update, 23 September 2026: The waves below predate the Omnibus I Directive, in force since 18 March 2026. CSRD now applies only to companies with more than 1,000 employees and more than EUR 450m net turnover, both tests together, and the revised ESRS cut mandatory datapoints by more than 60%. Companies below those thresholds are most likely to meet ESRS through customer data requests.

    The original CSRD and ESRS timeline set out the following waves:

    • 2025 reporting (FY 2024): Large public-interest entities already subject to the Non-Financial Reporting Directive.
    • 2026 reporting (FY 2025): Other large undertakings meeting two of three criteria - more than 250 employees, more than EUR 50 million turnover, or more than EUR 25 million total assets.
    • 2027 reporting (FY 2026): Listed SMEs, with an option to opt out for up to two additional years.
    • 2029 reporting (FY 2028): Non-EU companies with significant EU operations meeting specified thresholds.

    What Data Do You Need?

    The data requirements for ESRS reporting are extensive. At a minimum, organisations need to prepare the following:

    • Greenhouse gas emissions data across all three scopes with supporting activity data and emission factors.
    • Energy consumption broken down by renewable and non-renewable sources.
    • Workforce metrics including headcount, diversity breakdowns, training hours, and health and safety statistics.
    • Governance data covering board composition, sustainability oversight structures, and business conduct policies.
    • Policies, targets, and action plans for each material topic.
    • Financial effects of sustainability risks and opportunities.

    How Software Helps with ESRS Compliance

    Managing over one thousand data points across twelve standards in spreadsheets is a recipe for errors, missed deadlines, and audit failures. Dedicated ESRS compliance software addresses these challenges by providing structured data collection workflows mapped to each ESRS standard, automated emission calculations with up-to-date factor databases, materiality assessment tools that determine your reporting scope, progress dashboards that show completion status across all standards, assurance-ready audit trails for every data point, and report generation in the required European Single Electronic Format.

    The right ESG reporting software does not just make compliance possible - it makes it efficient, reducing the cost and effort of annual reporting while improving data quality and stakeholder confidence.

    Preparing Your Organisation

    Start with these practical steps:

    1. Determine your reporting timeline. Identify which wave of CSRD applies to your organisation and work backwards to set internal milestones.
    2. Conduct a gap analysis. Compare your current data collection and reporting processes against ESRS requirements to identify what you already have and what you need.
    3. Complete your double materiality assessment. This determines the scope of your report and should involve internal and external stakeholders.
    4. Select your technology platform. Choose software that covers all applicable ESRS standards and integrates with your data sources.
    5. Build your data collection network. Identify data owners across the organisation and establish collection workflows and timelines.
    6. Engage your auditor early. Discuss your reporting approach and data management processes with your assurance provider before the reporting deadline.

    Related reading: CSRD Software Comparison and Automated ESG Reporting with AI.

    Start Your ESRS Reporting Journey

    ESRS reporting is a significant undertaking, but with the right preparation and tools, it is entirely manageable. Horizon ESG provides purpose-built software for ESRS compliance, covering every standard from E1 through G1 with structured workflows, automated calculations, and assurance-ready documentation. Book a demo to see how we can help your organisation meet its CSRD obligations with confidence.

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