EU CSRD: revised ESRS and ESRS for voluntary use published for consultation

On 6 May 2026, the European Commission launched two consultations:

• consultation on the revised European Sustainability Reporting Standards (ESRS); and 

• consultation on the Sustainability Reporting Standard for Voluntary Use. 

Both consultations close on 3 June 2026. Commission adoption of both the revised ESRS and voluntary standards is planned for Q2 2026.

Revised ESRS

The Omnibus I Directive (Recital (18)) recognises that the Commission, within six months of Omnibus I entering into force, will adopt a delegated act amending the existing ESRS. As required by the Accounting Directive, the Commission must adopt these revised standards taking into consideration technical advice provided by EFRAG, which sent its recommendations to the Commission on 3 December 2025 (see our previous blog post).

According to the Explanatory Memorandum to the draft Delegated Act containing the revised ESRS, the key changes made by the Commission to EFRAG’s version relate to: 

• materiality and materiality assessment (explicitly prohibiting the reporting of immaterial information);

• fair presentation;

• the level of aggregation and disaggregation;

• the possibility to omit certain information in certain circumstances;

• anticipated financial effects; 

• aligning greenhouse gas (GHG) emissions reporting with global standards; 

• the possibility to report and transparency on climate transition plans with targets that are not compatible with the 1.5°C target;

• limiting microplastics disclosures to primary microplastics only; 

• decisions on the materiality of emissions of pollutants; and 

• a new phase-in provision for reporting on substances of very high concern.

The Explanatory Memorandum also confirms that the text includes technical modifications regarding due diligence to ensure better alignment with the Corporate Sustainability Due Diligence Directive (CSDDD / CS3D). The revised ESRS also clarifies that the reporting of human rights incidents and incidents of discrimination should be limited to “substantiated” instances, and includes provisions to avoid irrelevant reporting by asset managers.

Undertakings within the scope of the Corporate Sustainability Reporting Directive (CSRD) must use the revised ESRS for financial years beginning on or after 1 January 2027. However, undertakings subject to the CSRD for financial year 2026 may choose to apply the revised ESRS for that financial year instead of the existing ESRS.

Standards for voluntary use

On 30 July 2025, the Commission adopted a Recommendation on voluntary sustainability reporting for non‑listed small and medium‑sized enterprises (SMEs). The voluntary standard for SMEs (VSME) covers the same sustainability topics as the ESRS, but in a proportionate way that reflects SME characteristics. For more information, see our previous blog post.

The Omnibus I Directive introduced a value chain cap. This means that companies in the value chain with fewer than 1,000 employees have the right to decline to provide sustainability information beyond that set out in a voluntary reporting standard. The Omnibus I Directive also empowered the Commission to adopt voluntary sustainability reporting standards for undertakings with no more than 1,000 employees. 

In the Explanatory Memorandum to the draft Delegated Act containing the draft voluntary standards, the Commission concludes that, in the context of the reduced scope of CSRD following Omnibus I, a voluntary standard that is closely aligned with the VSME (which was originally conceived for SMEs) is considered proportionate for undertakings with up to 1,000 employees.

However, the Commission has made some changes to the VSME. According to the Explanatory Memorandum, these include reducing the number of data points in line with the revised set of ESRS, clarifying the application of the value chain cap and indicating which data points are included under the cap and specifying that certain disclosures (particularly some environmental disclosures) are voluntary in the case of undertakings with 10 employees or fewer that apply the standard.

This new voluntary standard is intended to apply from financial year 2027 for value chain reporting by undertakings subject to the CSRD, irrespective of their option to carry out sustainability reporting in accordance with the revised ESRS for financial year 2026 on a voluntary basis. It will also apply from the date of entry into force to undertakings that, on their balance sheet dates, do not exceed an average number of 1,000 employees during the preceding financial year and that wish to report voluntarily.

Next steps

Both consultations close on 3 June 2026. 

Commission adoption of the draft Delegated Acts containing the revised ESRS and the voluntary standard is planned for Q2 2026.

After the consultations and adoption of both standards by the Commission, they will be subject to scrutiny by the Council and the European Parliament for two months (extendable by two additional months).

If neither institution objects within the review period, the revised ESRS will be adopted in final form and will take effect in Member States' laws.

For more information on the CSRD and ESRS, see our Quick Guide and EU CSRD demystified materials.