CSRD and ESRS news: July-August 2026 edition

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CSRD and ESRS news: July-August 2026 edition

CSRD and ESRS are EU legislation, but Swiss companies can fall within their reporting requirements through turnover generated in the EU or through EU subsidiaries and branches. Forvis Mazars in Switzerland summarises the July-August 2026 CSRD and ESRS updates: the EFRAG State of Play report, the ESRS-40a exposure draft for non-EU companies and the consultation deadlines.

Key takeaways 

  • EFRAG's 2026 State of Play report analyses 905 assured sustainability statements prepared under the ESRS for the 2025 reporting period 
  • The share of companies disclosing a climate transition plan rose from 55% to 69%, and the average sustainability statement shortened from 115 to 95 pages 
  • The ESRS-40a exposure draft for certain non-EU companies has been open for comments since 23 July 2026, until 31 October 2026 
  • ESRS-40a would apply to non-EU companies with EU net turnover above €450m and an EU subsidiary or branch above €200m, for financial years beginning on or after 1 January 2028 
  • The revised ESRS and the Voluntary Standard, adopted by the European Commission on 3 July 2026, are available on the EFRAG ESRS Knowledge Hub since 28 July 2026 
  • Sustainability reporting work continues at pace at European level, with the initial findings of the 2026 EFRAG report on sustainability statements, the consultation on the ESRS-40a standards applicable to certain non-EU entities and the release of new interactive resources for use with the revised ESRS. 

The CSRD and ESRS updates at a glance 

Topic 

What happened 

Dates 

EFRAG State of Play 2026 Report on 2025 sustainability statements prepared under the ESRS Published on 1 July 2026 
ESRS-40a for certain non-EU companies Exposure draft published by EFRAG, public consultation open Consultation from 23 July to 31 October 2026; EFRAG technical opinion expected in January 2027; delegated act expected mid-2027; application for financial years beginning on or after 1 January 2028 
Revised ESRS and Voluntary Standard Adopted by the European Commission by means of delegated acts Adopted on 3 July 2026; interactive version on the EFRAG ESRS Knowledge Hub since 28 July 2026 

EFRAG State of Play 2026: findings on 2025 sustainability statements under ESRS 

On 1 July 2026, EFRAG published a report entitled 2026 State of Play, providing an overview of corporate sustainability reporting practices for the 2025 reporting period.  

It is based on an analysis of 905 assured sustainability statements prepared in accordance with the European Sustainability Reporting Standards (ESRS) as adopted in July 2023 (Set 1) and published between 1 January and 20 April 2026. It follows the report published by EFRAG covering the first year of mandatory application of the CSRD. 

This year's study expands the scope of the analysis with new insights into companies' Double Materiality Assessment (DMA) methodology, the linkage of material topics with executive incentive schemes and the geographical disaggregation of environmental metrics. The key lessons advanced in EFRAG's press release are as follows: 

Area 

Key findings 

Double Materiality Assessment Reporting practices remain broadly stable. E1 Climate Change (99%), S1 Own Workforce (99%) and G1 Business Conduct (95%) remain the most frequently identified material topics across all sectors and countries. 82% of companies updated their DMA; 67% adopted a hybrid approach combining top-down and bottom-up methodologies 
Climate transition The share of companies disclosing a Climate Transition Plan increased from 55% to 69%; 57% report near and long-term decarbonisation targets aligned with a 1.5°C pathway 
Integration into corporate strategy Companies identify on average 6.4 material ESRS topics but set measurable targets for only 3.3 of them. 63% link sustainability performance to executive incentive schemes 
Length of sustainability statements The average sustainability statement decreased from 115 to 95 pages, suggesting increased familiarity with the ESRS framework and a maturing approach. Sustainability statements continue to represent around one-third of annual reports 
Social and governance reporting Average unadjusted gender pay gap of 14.3%. Widespread disclosure of human rights policies (89% of companies). Increasing use of ESG criteria in supplier selection (81%) 

ESRS-40a: EFRAG consults on sustainability reporting standards for certain non-EU companies

EFRAG launched a public consultation on the proposed ESRS-40a sustainability reporting standards for certain non-EU companies with significant operations in the EU. The consultation focuses on the alignment of ESRS-40a with the ISSB standards (IFRS S1 and IFRS S2), the scope of reporting requirements and potential simplifications for non-EU entities. The final standards are expected to be adopted in 2027 and would apply from 2029.

23 July 2026 marked the start of the public consultation on the draft sustainability reporting standards applicable to certain companies based outside the EU, referred to as ESRS-40a in reference to the relevant article of the Accounting Directive as amended by the CSRD, with the publication by EFRAG of an exposure draft open for comments until 31 October 2026.

Which non-EU companies are concerned by ESRS-40a 

The cumulative criteria for identifying companies based outside the EU that are required to prepare a sustainability report under the ESRS-40a for financial years beginning on or after 1 January 2028 (first publication in 2029), recently revised by the Content Directive, are as follows: 

Criterion 

Threshold 

EU net turnover More than €450m in the EU, at individual or, where appropriate, group level, for each of the last two consecutive financial years. The revised CSRD, like the original text, provides no details on how to calculate this amount (by destination or by origin) 
EU subsidiary or branch At least one subsidiary in the EU generating a net turnover of more than €200m in the preceding financial year, or one branch located in the EU generating a net turnover of more than €200m in the preceding financial year. For a subsidiary, this threshold is assessed solely at the individual level, even if the subsidiary is itself an intermediate parent company 

This reporting requirement aims to ensure a level playing field for all companies operating in the EU market, as well as transparency regarding the impacts, on both people and the environment, of non-EU companies carrying out significant activities in the EU. 

What the ESRS-40a consultation covers 

EFRAG's public consultation seeks the views of stakeholders on four topics in particular: 

  • Deletions from and additions to the revised ESRS reporting requirements, including the removal of information relating to sustainability risks, opportunities and dependencies, as well as the company's resilience to these risks 
  • The use of references to EU laws and regulations, as set out in the revised ESRS, where these apply to activities carried out outside the EU 
  • Feasibility of the option, described as a "mixed approach", to limit the reporting to EU-related impacts only, subject to certain conditions being met and to ensuring transparency in the report as to the application of this option, in particular regarding the methodology adopted by the company (assumptions and limitations) and the level at which the option has been applied (topic, sub-topic or impact groups). According to ESRS-40a 1, this option applies to impacts other than climate-related impacts: (i) arising from products and services that were, or can reasonably be assumed to be, sold or provided in the EU market, including by third parties such as distributors and traders, and (ii) arising from the company's activities carried out within the EU, if not already taken into account under (i) 
  • Interoperability of ESRS-40a with the ISSB standards (IFRS S1 and IFRS S2), with regard to the disclosure requirements and the conditions for applying the mechanism of incorporation by reference 

ESRS-40a timeline 

Date 

Step 

23 July 2026 Start of the public consultation, publication of the exposure draft 
31 October 2026 End of the comment period 
January 2027 EFRAG technical opinion expected to be submitted to the European Commission 
Mid-2027 Adoption of the delegated act by the European Commission expected 
Financial years beginning on or after 1 January 2028 First application 
2029 First publication 

Revised ESRS and Voluntary Standard available on the EFRAG ESRS Knowledge Hub 

On 28 July 2026, the revised ESRS and the Voluntary Standard (VS), as adopted by the European Commission on 3 July 2026 by means of delegated acts, were incorporated into EFRAG's interactive online platform, the ESRS Knowledge Hub, which centralises the available resources on sustainability reporting.

Keep up with CSRD and ESRS updates with Forvis Mazars in Switzerland

The ESRS-40a consultation closes on 31 October 2026, and the revised ESRS and Voluntary Standard, adopted on 3 July 2026, are available in interactive form on the EFRAG ESRS Knowledge Hub.

Contact Forvis Mazars in Switzerland to discuss what these CSRD and ESRS updates mean for your sustainability reporting.
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FAQ: CSRD and ESRS news July-August 2026 edition 

What is the EFRAG State of Play 2026 report? 

A report published by EFRAG on 1 July 2026 providing an overview of corporate sustainability reporting practices for the 2025 reporting period, based on 905 assured sustainability statements prepared under the ESRS (Set 1) and published between 1 January and 20 April 2026. 

What are the main findings of the EFRAG State of Play 2026? 

E1 Climate Change, S1 Own Workforce and G1 Business Conduct remain the most frequently identified material topics. The share of companies disclosing a climate transition plan rose from 55% to 69%, and the average sustainability statement shortened from 115 to 95 pages, around one-third of annual reports.

What is ESRS-40a? 

The draft sustainability reporting standards applicable to certain companies based outside the EU with significant operations in the EU, named after the relevant article of the Accounting Directive as amended by the CSRD. EFRAG published the exposure draft on 23 July 2026, open for comments until 31 October 2026.

Which non-EU companies would have to report under ESRS-40a? 

Companies based outside the EU generating net turnover of more than €450m in the EU, at individual or, where appropriate, group level, for each of the last two consecutive financial years, and having at least one EU subsidiary or branch generating net turnover of more than €200m in the preceding financial year. For a subsidiary, the €200m threshold is assessed solely at individual level, even if it is an intermediate parent company. Both criteria are cumulative.

When would ESRS-40a apply? 

For financial years beginning on or after 1 January 2028, with first publication in 2029. EFRAG is expected to submit its technical opinion to the European Commission in January 2027, and the Commission is expected to adopt the delegated act in mid-2027.

Where are the revised ESRS available? 

The revised ESRS and the Voluntary Standard, adopted by the European Commission on 3 July 2026, have been available in interactive form on the EFRAG ESRS Knowledge Hub since 28 July 2026.

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