European Sustainability Reporting Standards
Binding European sustainability reporting standards under the CSRD. 12 Set 1 standards adopted as Commission Delegated Regulation (EU) 2023/2772, in force since 1 January 2024.
Context
The ESRS (European Sustainability Reporting Standards) are the binding sustainability information standards under the CSRD. Commission Delegated Regulation (EU) 2023/2772 adopts them as positive European law: directly applicable in all Member States since 1 January 2024.
Structure of Set 1
Set 1 includes 12 standards organised into 4 groups: 2 cross-cutting (ESRS 1 General Requirements + ESRS 2 General Disclosures), 5 environmental (E1-E5), 4 social (S1-S4) and 1 governance (G1). Each topical standard deploys specific Disclosure Requirements that are reported after the double materiality assessment.
«These standards specify the information that companies must disclose about their material impacts, risks and opportunities in relation to environmental, social and governance matters.»
View verbatim quote in English
“these standards specify the information that undertakings are to disclose about their material impacts, risks and opportunities in relation to environmental, social and governance sustainability matters”
Conditional application by topical standard
ESRS 1 §29 establishes the golden rule: regardless of the outcome of the double materiality analysis, the company always reports the cross-cutting Disclosure Requirements of ESRS 2 plus the IRO-1 specific to each topical ESRS. Only the other Disclosure Requirements of the topical standards are subject to the materiality filter.
Timeline
Delegated Regulation adopted
The European Commission adopts Commission Delegated Regulation (EU) 2023/2772 with the 12 Set 1 standards.
OJEU L publication
Published in OJEU L 22.12.2023 · fully in force.
Wave 1 application
First mandatory application to large listed companies.
Revised ESRS
EFRAG delivers revised ESRS after Omnibus I.
Post-Omnibus application
Companies >1,000 employees AND >EUR 450M report in accordance with the revised ESRS.
Applied case
A textile brand subject to CSRD wave 1 reports its first sustainability statement applying the ESRS Set 1. The typical process deploys 4 concrete layers.
Carries out the double materiality assessment over the 10 topicals with a methodology documented in IRO-1. Identifies as material: E1 Climate change, E2 Pollution, E5 Resource use and circular economy, S1 Own workforce and S2 Workers in the value chain.
Tags the sustainability statement with the ESRS XBRL taxonomy published by EFRAG. The report is integrated into the management report and is subject to limited verification by an external auditor.
Common mistakes
The ESRS are not a voluntary standard comparable to GRI or SASB.
The ESRS are positive European law: Commission Delegated Regulation (EU) 2023/2772 is binding in its entirety and directly applicable in all Member States (Art. 2). The GRI Standards and SASB Standards are voluntary international frameworks. The ESRS-ISSB Interoperability Guidance (May 2024) facilitates simultaneous reporting where the company also applies IFRS S1/S2, but it does not equate the binding force.
Double materiality does not allow any topical to be excluded without reinforced justification.
ESRS 1 ¶32 is explicit: if the company concludes that climate change (ESRS E1) is not material and therefore omits all the Disclosure Requirements of ESRS E1, it must disclose a detailed explanation of the conclusions of its analysis including a forward-looking analysis of the conditions that could lead it to conclude that it is material in the future. For the other topicals, the explanation of the non-materiality conclusion may be more concise.
ESRS 2 is always mandatory, regardless of the double materiality analysis.
ESRS 1 ¶29 establishes in faithful paraphrase: regardless of the outcome of its materiality assessment, the company must always disclose the information required by the General Disclosures of ESRS 2 (that is, all the Disclosure Requirements and datapoints specified in ESRS 2) and the Disclosure Requirements (including their datapoints) of the topical ESRS related to the Disclosure Requirement IRO-1. Only the Disclosure Requirements of the topicals (beyond IRO-1) are subject to the materiality filter.
The 2025 Omnibus is not the simplification in force of Delegated Regulation 2023/2772.
What is in force is Commission Delegated Regulation (EU) 2025/1416 of 11 July 2025 ("QuickFix") which amends Annex I, Appendix C, of ESRS 1 by extending the phase-in for entities up to 750 employees, and Directive (EU) 2025/794 "stop-the-clock" (in force 17 April 2025) which postpones CSRD application dates but does not amend the ESRS. The "Omnibus Simplification Package" proposed by the Commission on 26 February 2025 (recital 3 Delegated Reg. 2025/1416) proposes a second, deeper review, pending legislative processing.
Frequently asked questions
What are the ESRS?
European Sustainability Reporting Standards (Commission Delegated Regulation EU 2023/2772 Set 1, OJEU L of 22.12.2023). 12 standards: 2 cross-cutting (ESRS 1 General Requirements + ESRS 2 General Disclosures) + 10 topical (5 environmental E1-E5, 4 social S1-S4, 1 governance G1) that detail the mandatory datapoints and those subject to materiality of the CSRD.
Who must apply the ESRS?
Any company subject to the CSRD drafts its sustainability statement under ESRS. The ESRS are binding with no alternative framework option: GRI or ISSB CANNOT be used instead (although ESRS-ISSB have an EFRAG-IFRS interoperability guidance for data reuse).
How is the double materiality of the ESRS applied?
In accordance with ESRS 1 §3 + IRO-1 + SBM-3: (i) impact materiality identifies impacts on people and the environment, (ii) financial materiality identifies risks and opportunities for the company. A matter is material if it is so under EITHER of the two perspectives. Result: a matrix of material matters that defines the scope of the applicable datapoints.
What is the difference between ESRS Set 1 and the upcoming sectoral ESRS?
Set 1 (in force since 2024) is cross-cutting: applicable to all sectors. The sector-specific ESRS by industry are in preparation at EFRAG and will be introduced progressively. For textiles-clothing, there is no sectoral ESRS yet — Set 1 applies until then.
How many mandatory datapoints are there in ESRS Set 1?
According to EFRAG IG 3 (List of ESRS Datapoints v2024): 84 mandatory datapoints + 622 subject to materiality assessment. Total >1,100 potential datapoints. The company only reports those applicable after a robust materiality assessment documented in IRO-1.
What did the EU Regulation 2025/1416 quick-fix change?
Commission Delegated Regulation (EU) 2025/1416 published on 11 Jul 2025 amends Regulation 2023/2772 by postponing certain specific obligations to reduce the initial burden without altering the general ESRS framework. It affects the validity of certain requirements in waves 2 and 3 (listed SMEs and subsidiaries).
Fuentes oficiales
- European Commission · OJEU L of 22.12.202331 jul 2023regulation
- European Parliament · European Council · OJEU L of 16.12.202219 abr 2024directive
- European Financial Reporting Advisory Group (EFRAG)11 jul 2025standard
- EUR-Lex · Publications Office of the European Unionmayo 2024database
