Navigating the revised ESRS

On 3 July 2026, the European Commission adopted a delegated regulation on the revised ESRS (European Sustainability Reporting Standards). In a regulatory context where sustainability reporting is rapidly evolving, our experts have analysed it to highlight the main changes compared with Set 1 published in July 2023 and to help wave 1 companies to choose the most appropriate framework for the 2026 financial year.

Emphasis on the fair presentation principle, clarification of the flexibility available when conducting the double materiality assessment and presenting sustainability information, introduction of the "undue cost or effort" principle and several other relief measures, and a restructuring of the standards, etc. Our analysis outlines an overview of the main changes adopted by the EC to reduce companies’ reporting burden, with simplifications both by overall lever, as well as by individual standards.

This analysis also sets out the three options available to wave 1 companies who are preparing their sustainability statement for 2026. This choice must be assessed in light of the transitional provisions set out in ESRS 1, depending on which version of the standard is applied (i.e. ESRS 1 Set 1, including amendments made by the so-called “quick fix” delegated regulation of July 2025, or the revised ESRS 1 of July 2026).

What changes

The modifications adopted by the EC bring significant changes to Set 1 and are structured around six levers to address the complexities encountered by wave 1 companies when implementing the ESRS:  

• Simplification of the materiality assessment
• Better readability and conciseness of the sustainability statements 
• Significant changes to the relationship between general disclosures and topical standards
• Improved understandability, clarity and accessibility of standards
• Introduction of burden-reduction reliefs
• Enhanced interoperability with generally accepted reporting standards or frameworks

The new standards should therefore result in clearer reporting, with a stronger focus on information that is truly decision-useful for users.

In practice, these proposals reduce the number of mandatory datapoints (DPs) by about 60%. The revised standards also no longer contain any voluntary DPs, reducing the length of the standards by more than half. 

However, companies now need to assess to what extent the revised ESRS will ease their preparation of sustainability statements, as the reduction in the number of DPs does not necessarily translate into a proportional reduction in reporting burden.

The fundamentals of sustainability reporting, as set out by the CSRD, indeed remain unchanged. However, numerous reliefs have been introduced, which should make it easier for companies, particularly those in wave 2 (which are required to publish a sustainability statement in accordance with the revised CSRD for financial years beginning on or after 1 January 2027).

Next steps

The final text is expected to be published in the Official Journal of the European Union (OJEU) by the autumn of 2026, provided that the European Parliament and the Council of the EU do not reject it during their scrutiny period, which is set to last two months and may be extended once. The revised standards will only enter into force once the European legislative process has been completed.

How we can help

Our objective is to help you anticipate the changes introduced by the EC, assess their impact on your reporting processes and ensure compliance. Thanks to active and rigorous monitoring, we can help you take a step back and consider the changes introduced by the revised ESRS, to help you make the best possible choices from among the options available to you, starting with the 2026 financial year.

At Forvis Mazars, we have already assisted many clients with ESRS implementation and sustainability reporting, staying involved across all key steps to ensure a robust and dependable outcome.

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