Revised ESRS: changes and options for the 2026 financial year

The revised European Sustainability Reporting Standards (ESRS) were published in the Official Journal of the European Union on 21 September 2026 through Delegated Regulation (EU) 2026/1563. They enter into force on 10 November 2026 and become mandatory for financial years beginning on or after 1 January 2027. For the 2026 financial year, the text allows a choice between 3 options: retain the 2023 standards, apply the revised standards early or retain the 2023 standards with 8 reliefs drawn from the new ones.

This choice primarily concerns companies in the first wave of the Corporate Sustainability Reporting Directive (CSRD) (in French), which have reported since the 2024 financial year and are preparing their third statement. In France, the framework remains unsettled: the Omnibus Directive, which reduces the CSRD's scope, has not been transposed, and these companies are still required to report on 2026. The following sections explain the texts, the changes to the standards and the criteria for making this choice.

1What the revised ESRS are

The ESRS (European Sustainability Reporting Standards) determine the content of the sustainability statement required by the CSRD. The 2023 version contained 12 standards; the 2026 revision simplifies them without changing their architecture.

A regulation replacing the 2023 annexes

Delegated Regulation 2026/1563, adopted by the Commission on 3 July 2026, does not create a new text: it replaces Annexes I and II of Delegated Regulation (EU) 2023/2772, which contained the original ESRS and was amended in 2025 by an initial relief measure, Delegated Regulation (EU) 2025/1416, known as the quick fix. Like every EU regulation, it applies directly in France, without transposition, unlike the directive defining which companies are covered.

4 dates to distinguish

The text was adopted on 3 July 2026, then underwent 2 months of scrutiny by the European Parliament and the Council, ending without objection, before its publication on 21 September 2026. Article 3 sets entry into force on 10 November 2026, the date from which a company may apply it early, and mandatory application to financial years beginning on or after 1 January 2027, meaning statements published in 2028 for a calendar-year financial year.

The voluntary standard and value chain cap

On the same day, the Commission adopted Delegated Regulation (EU) 2026/1560, a voluntary reporting standard derived from the Voluntary Sustainability Reporting Standard for SMEs (VSME), EFRAG's simplified standard for small and medium-sized enterprises (SMEs). EFRAG is the European Financial Reporting Advisory Group. Annex II serves as the value chain cap: a company subject to the ESRS cannot require a supplier or customer with 1,000 employees or fewer to provide more information than this annex specifies. Our article on the CSRD after Omnibus explains what this changes for SMEs receiving requests from clients.

2Who must apply the ESRS, and when

The standards define the statement's content, while the directive defines which companies must publish it. The 2 texts were simplified at the same time, but only the directive still needs to be incorporated into French law.

Omnibus thresholds: 1,000 employees and €450 million

Directive (EU) 2026/470 of 24 February 2026, known as Omnibus, restricts the CSRD to companies exceeding both an average of 1,000 employees and €450 million net turnover, compared with 2 of 3 criteria (250 employees, €50 million turnover and a €25 million balance sheet total) previously. Listed SMEs leave the scope, and third-country groups are covered only above €450 million turnover in the Union, with a subsidiary or branch exceeding €200 million. According to the Commission staff working document of 3 July 2026, around 6,753 companies would remain in scope in the Union, including 1,535 from the first wave.

In France, the directive has not yet been transposed

The Omnibus Directive must be transposed by 19 March 2027 at the latest. The bill to adapt French law to EU law (DDADUE), which incorporates its transposition through an amendment, was adopted by the Senate on 18 February 2026, then sent to the National Assembly, where it had not yet been examined as of 2 October 2026. The applicable law therefore remains Ordinance No 2023-1142, amended by Law No 2025-391 of 30 April 2025, which postponed the second wave to the 2027 financial year: first-wave companies report on the 2026 financial year, including those that will fall below the new thresholds. The directive allows them to be exempted, but only a French law can make this exemption available.

Companies leaving scope become subject to the BEGES again

Since the law of 30 April 2025, a company subject to the CSRD that publishes an emissions inventory, including its activities in France, and a transition plan in its sustainability statement is exempt from France's mandatory greenhouse gas emissions report (BEGES) under Article L. 229-25 of the French Environmental Code. A company leaving CSRD scope loses this exemption: if it has more than 500 employees (250 in the French overseas territories), it becomes subject to the BEGES again, to be renewed every 4 years with a transition plan.

3What changes in the standards

Recital 2 of the regulation sets 6 objectives for the revision, 3 of which shape the text: reducing the number of data points, prioritising quantitative data over narrative text and distinguishing mandatory from voluntary information more clearly. The others concern applying materiality, consistency with EU law and interoperability with other standards.

More than 60% fewer mandatory data points

According to the Commission's press release of 3 July 2026, the revised ESRS reduce the number of mandatory data points by more than 60% and the total number of data points by more than 70%, with reporting costs falling by more than 30% per company. The text largely follows the technical advice submitted by EFRAG in December 2025, with differences on 13 points, including materiality, anticipated financial effects, greenhouse gas emissions and transition plans.

A top-down double materiality assessment

The double materiality assessment remains the statement's starting point: it determines which topics the company addresses. The new version of ESRS 1 allows a top-down approach, starting from the main issues arising from the business rather than an exhaustive list, and clarifies that the company is not required to assess every possible impact, risk or opportunity: it focuses on areas where it considers material ones likely to exist. It may also limit its value chain assessment to information available without undue cost or effort.

Climate: 3 permitted consolidation approaches and justification of the transition plan

For greenhouse gas emissions, the ESRS E1 climate standard defaults to the financial control boundary defined by the Greenhouse Gas Protocol (GHG Protocol), but now also allows the equity share approach or the control approach under the same protocol (Application Requirement AR 19). A company whose transition plan sets reduction targets incompatible with 1.5°C must explain this in its statement, while in France the SNBC 3 (France's third National Low-Carbon Strategy) (in French) serves as the reference pathway. Our article on the climate transition plan (in French) compares these requirements with those of the BEGES, while the article on Bilan Carbone® (the French carbon accounting method) and the CSRD explains what the E1 standard requires.

4The 2026 financial year: Article 2's 3 options

Article 2 of Regulation 2026/1563 sets the transition arrangements for financial years beginning between 1 January and 31 December 2026. It offers 3 routes and requires, in every case, a clear statement in the report of which version is applied.

Option 1: retain the 2023 standards

The company applies the 2023 ESRS as amended by the 2025 quick fix. This is the continuity route: the same data points, the same double materiality assessment and direct comparison with the 2024 and 2025 statements. This also means one final financial year using more demanding standards, which will be replaced a year later.

Option 2: apply the revised standards early

The company switches to the revised ESRS for the 2026 financial year, which is possible from their entry into force on 10 November 2026. It benefits from all the reliefs and changes its reporting framework only once, but must redo its double materiality assessment and list of data points within a few months, and its 2026 metrics will not always be comparable with those of 2025.

Option 3: the 2023 standards with 8 reliefs

This route, added in the final version of the text, retains the structure of the 2023 ESRS while incorporating 8 reliefs from the revised standards. They mainly concern methodology, rather than the content of the topical standards.

• The double materiality assessment: the top-down approach (ESRS 1, paragraph 27), undue cost or effort and value chain limitation (paragraphs 32 and 33).
• The boundary for metrics: acquisitions and disposals during the financial year (paragraphs 74 and 75), non-significant activities (paragraph 90), partial value chain coverage (paragraph 91) and joint operations (paragraph 92).
• Presentation: Taxonomy disclosures in a separate appendix (paragraph 106) and an optional executive summary of key messages in the sustainability statement (paragraph 110).

This third option preserves substantive comparability with 2025, as the topical standards do not change, while easing the double materiality assessment and value chain data collection, which account for the greatest share of the cost of preparing a statement.

5How to choose: 4 criteria

No option suits every company. The choice depends on progress with the 2026 statement, the quality of previous statements and readers' expectations.

Comparability with 2025

Investors and rating agencies, from EcoVadis (in French) to non-financial rating agencies, compare metrics from year to year. In its 2025 response to EFRAG's consultation, the Autorité des marchés financiers (France's financial markets regulator) advocated retaining the gross approach to materiality assessment, partly because it limits methodological changes compared with previous periods. A company whose climate or social pathways are closely monitored benefits from retaining the 2023 basis, with or without reliefs.

The quality of the double materiality assessment

A company whose 2024 or 2025 double materiality assessment was considered too broad, with many issues included as a precaution, benefits from redoing it using the top-down approach, which options 2 and 3 allow. A recent, sound assessment, by contrast, favours continuity.

The year-end timetable and team workload

For a calendar-year financial year ending on 31 December 2026, there are 7 weeks between the revised standards' entry into force on 10 November 2026 and year-end. A full switch to option 2 requires a finalised list of data points, reconfigured collection tools, emissions data recalculated if the boundary changes and a statutory auditor informed in advance: it is feasible for a company that prepared in advance, but risky for others.

The change of reporting framework in 2027

The revised ESRS will be mandatory for the 2027 financial year regardless of the option chosen in 2026. Retaining the 2023 standards therefore means postponing the change of reporting framework by one year, without avoiding it, and changing frameworks when Omnibus will have redefined the scope in France.

At Projet Celsius, we consider option 3 the most reasonable choice for a first-wave company that has already published 2 statements: it retains comparable metrics and uses the reliefs that cost least to implement, leaving the full switch until 2027, when the French rules will be settled. Our CSRD reporting support starts with this comparison of options.

6Deadlines over the next 6 months

Several texts still need to clarify the framework before the 2027 statements.

• 31 October 2026: close of EFRAG's consultation on ESRS-40a, the standard for third-country groups, for initial reporting on the 2028 financial year.
• 10 November 2026: the revised ESRS enter into force, allowing early application.
• Late 2026 or early 2027: examination of the DDADUE bill by the National Assembly, leaving French thresholds to a decree and potentially allowing an exemption for 2026; the 2027 presidential election timetable (in French) could affect this schedule.
• 19 March 2027: deadline for transposing the Omnibus Directive.
• 1 July 2027: deadline for adopting the European limited assurance standard.

7Key takeaways

• The revised ESRS were published on 21 September 2026 and are mandatory for the 2027 financial year.
• For the 2026 financial year, 3 options: the 2023 standards, early application of the revised standards or the 2023 standards with 8 reliefs, to be stated in the report.
• In France, the first wave reports on 2026 while the Omnibus Directive remains untransposed.
• More than 60% fewer mandatory data points, a top-down double materiality assessment and 3 consolidation approaches allowed for greenhouse gas emissions.

We recommend preparing to choose an option with the statutory auditor before year-end, even though the version applied need only be stated in the report published in 2027. For companies leaving scope, the mandatory BEGES, whose cost varies by method (in French), and Scope 3 (in French), which the law does not always require (in French), remain areas of work to resume.

Further resources

Frequently asked questions

1When do the revised ESRS apply?

Delegated Regulation (EU) 2026/1563 enters into force on 10 November 2026 and is mandatory for financial years beginning on or after 1 January 2027, meaning statements published in 2028 for a calendar-year financial year. For the 2026 financial year, a company may apply it early from 10 November 2026 or retain the 2023 standards with or without 8 reliefs.

2What are the 3 options for the 2026 financial year?

Article 2 of Regulation 2026/1563 allows a company whose financial year begins in 2026 to choose either the 2023 ESRS as amended by the 2025 quick fix, early application of the revised ESRS or the 2023 ESRS with 8 reliefs drawn from the revised standards. The company must clearly state in its report which version it applies.

3Must a first-wave company report on the 2026 financial year?

Yes: in France, while the Omnibus Directive remains untransposed, Ordinance No 2023-1142 as amended in April 2025 applies, and first-wave companies report on the 2026 financial year. The directive allows those falling below the new thresholds to be exempted for 2025 and 2026, but this exemption requires a French law, under parliamentary examination as of 2 October 2026.

4How many fewer data points do the revised ESRS contain?

According to the European Commission, the revised ESRS reduce the number of mandatory data points by more than 60% and the total number of data points by more than 70%, with reporting costs falling by more than 30% per company. They prioritise quantitative data over narrative text and distinguish mandatory from voluntary information more clearly.

5What is the value chain cap?

It is a limit set by Annex II to Delegated Regulation (EU) 2026/1560: a company subject to the CSRD cannot require a company with 1,000 employees or fewer in its value chain to provide more information than this voluntary standard, derived from the VSME, specifies. It protects SMEs receiving requests from customers or suppliers subject to the ESRS.

6Must a company leaving CSRD scope prepare a BEGES again?

Yes, if it is otherwise subject to the requirement: the BEGES exemption under Article L. 229-25 of the French Environmental Code applies only to companies subject to the CSRD that publish an emissions inventory, including their activities in France, and a transition plan in their sustainability statement. A company with more than 500 employees (250 in the French overseas territories) leaving CSRD scope becomes subject to the BEGES again, to be renewed every 4 years.

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