ESMA 2026 sustainability reporting priorities: what you need to know

ESMA, the EU’s financial markets regulator and supervisor, has published the enforcement priorities (ECEP) for upcoming sustainability reports covering FY 2026.

ESMA makes one thing clear: regulators are moving beyond checking whether companies publish sustainability information and are now focusing on whether that information is material, connected, consistent, transparent and decision-useful.

For FY2026, ESMA’s sustainability priorities concentrate on two areas:

  1. Improving the quality of double materiality assessments (DMA) and IRO disclosures

  2. Strengthening the connections between IROs, policies, actions, targets and metrics (PATs)

The priorities outlined by ESMA provide useful guidance on where companies should focus their efforts in FY2026.


First: Understand the FY2026 Transition Rules

FY2026 is a transition year. Companies may prepare their sustainability statements using:

  • ESRS Set 1 2023 (as amended by the Quick Fix Regulation)

  • Revised ESRS 2026 (simplified ESRS)

  • ESRS Set 1 plus certain specific reliefs from revised ESRS 2026 allowed by Regulation (EU) 2026/1563.

What companies need to do

  • Clearly disclose which reporting framework was used.

  • Indicate the chosen framework in the “Basis for Preparation” section.

  • If using ESRS Set 1 with revised ESRS reliefs, only use the reliefs specifically listed in the regulation. No additional exemptions are permitted.

Taxonomy reminder

Although ESMA has not included specific EU Taxonomy recommendations this year because Taxonomy rules are under revision, regulators will continue reviewing Taxonomy disclosures. Companies should therefore not reduce attention to Taxonomy reporting.


Priority 1: Improve Double Materiality Assessment (DMA) and IRO Reporting

Why this matters

ESMA considers the DMA and the identification of Impacts, Risks and Opportunities (IROs) to be the foundation of the entire sustainability statement.

If the DMA is weak, everything built upon it becomes questionable.


1. Treat Positive and Negative Impacts Equally

A common issue identified by ESMA is that companies often describe positive impacts in great detail while providing limited information on negative impacts.

What to do

Instead of:

✅ Detailed discussion of social programs

❌ Little information on labour issues, emissions or negative impacts

Companies should provide:

  • equivalent analysis of positive impacts

  • equivalent analysis of negative impacts

  • balanced discussion of risks and opportunities

  • transparent rationale for materiality conclusions.

Practical test

Ask:

“Would a reader understand our major negative impacts as clearly as our positive contributions?”

If not, the disclosure probably needs improvement.


2. Be Transparent About Materiality Thresholds

Many companies use thresholds to determine which impacts are material.

ESMA expects companies to explain:

  • the thresholds used

  • how they were determined

  • whether different thresholds were applied to positive and negative impacts.

What good disclosure looks like

Instead of:

“The company assessed material impacts.”

Provide:

“An impact was considered material when severity exceeded X and affected more than Y stakeholders.”


3. Cover the Full Value Chain

A recurring issue is excessive focus on direct operations.

ESMA reminds companies that material impacts, risks and opportunities must include own operations, upstream value chain and downstream value chain.

Common mistake

Climate risks discussed only for owned facilities.

Better approach

Climate risks assessed across:

  • suppliers

  • transport

  • distribution

  • product use

  • end-of-life impacts

where relevant.


4. Make DMA Disclosures Topic-Specific

ESMA reminds us that information on the DMA process is most valuable when it is concise, company-specific and linked to the topic that is being assessed for material IROs.

Many companies have created generic descriptions of their DMA process.

ESMA recommends disclosures that explain how the assessment differs by topic.

Example

The process used to assess:

  • climate change

  • biodiversity

  • own workforce

  • human rights

may be different.

Explain those differences when they exist.


5. Use Entity-Specific Disclosures Sparingly

ESMA encourages companies to use ESRS categories whenever possible, to promote comparability across sustainability statements.

Entity-specific categories should only be used when ESRS does not adequately cover a material issue.

Ask before creating an entity-specific topic

Can this issue already be reported usingan ESRS topic or sub-topic?

If yes, use the ESRS structure.


Priority 2: Connect IROs, Policies, Actions, Targets and Metrics

This is perhaps the most important message in the 2026 priorities.

Many companies disclose:

  • IROs in one section

  • policies in another

  • actions elsewhere

  • targets in yet another section

without clearly linking them together.

ESMA expects a connected story.


Build a Clear Chain of Logic – the IRO-response-logic.

For each material IRO, report users should understand:

The issue

What impact, risk or opportunity exists?

↓

The policy

What policy addresses it?

↓

The actions

What is the company doing?

↓

The target

What outcome is expected?

↓

The metric

How will progress be measured?


Example

IRO

Workplace discrimination risk

Policy

Human Rights and Equal Opportunity Policy

Actions

  • mandatory training

  • whistleblowing mechanism

  • supplier audits

Target

Reduce discrimination incidents by 50% by 2030

Metrics

  • number of incidents

  • training completion rate

  • remediation rate

This is the type of connectivity ESMA expects.


Explain Gaps

If a material IRO exists but there is:

  • no policy

  • no action

  • no target

you must say so.

Many companies try to hide such gaps.

ESMA explicitly requires transparency.


Clearly Explain Coverage Limitations

Another recurring issue is overstating coverage.

Example

A climate target addresses only Scope 1, Scope 2 but not Scope 3.

Companies should clearly explain the limitation.

Similarly:

If an IRO affects:

  • operations

  • suppliers

but actions only cover operations,

that fact should be disclosed.


Disclose Financial Resources

ESMA expects transparency regarding significant:

  • CapEx

  • OpEx

supporting sustainability actions.

Companies should explain

  • what resources are allocated

  • what actions they support

  • expected future investments

If major actions require little or no investment, companies should consider explaining why.


Ensure Consistency with Financial Reporting

ESMA found cases where:

  • sustainability risks appeared in the sustainability statement

  • but were absent from the Annual Financial Report

or vice versa.

Practical action

Cross-check:

  • material climate risks

  • supply chain risks

  • workforce risks

  • litigation risks

against:

  • principal risks section

  • management commentary

  • IFRS disclosures

The story should be consistent across the report.


Improve Year-on-Year Comparability

Comparability remains a major regulatory focus.

Companies should clearly explain

  • methodology changes

  • presentation changes

  • restatements

  • revised comparative figures

Example

If Scope 3 emissions increase because of improved data quality:

do not leave investors guessing.

Explain:

  • what changed

  • why it changed

  • how it affected reported performance.


Targets: One of the Biggest Regulatory Focus Areas

ESMA devotes considerable attention to targets.


Every Target Should Be:

Measurable

Bad:

“Improve diversity.”

Good:

“Increase women in leadership to 40% by 2030.”

Time-Bound

Include target dates.

Outcome-Oriented

Focus on outcomes rather than intentions.


Report Progress Honestly

If a target:

✅ has been achieved

say so.

✅ has been missed

say so.

✅ is unlikely to be achieved

say so.

✅ has been abandoned

say so.

ESMA is looking for transparency, not selective reporting.


Explain Methodological Changes

If you change:

  • baseline year

  • baseline value

  • target year

  • target value

  • calculation methodology

disclose and explain the change.

Example

A climate target originally used:

2020 baseline

Later revised to:

2022 baseline due to acquisition activity.

Investors should understand exactly how this affects reported progress.


Be Careful with “Science-Based” Claims

ESMA specifically criticises companies that state:

  • “science-based”

  • “1.5°C aligned”

without explaining why.

Companies should disclose

  • whether the target is science-based

  • how it is science-based

  • why it supports a 1.5°C pathway

Evidence is required.


Report Absolute Targets

Do not rely exclusively on intensity metrics.

Example:

❌ “20% reduction per unit produced”

✅ “500,000 tCO₂e to 300,000 tCO₂e”

ESMA expects disclosure of absolute values unless ESRS provides otherwise.


Distinguish Commitments from Targets

One issue ESMA observed frequently:

Companies blur the line between:

Commitments

“We aim to be an employer of choice.”

and

Targets

“Achieve employee engagement score of 80% by 2028.”

Targets must be measurable, time-bound and outcome-oriented.


The 2026 Checklist for Companies

Before finalising your sustainability statement, ask:

Governance

  • Have we disclosed which ESRS version we use?

  • Have we explained any reliefs applied?

DMA

  • Are positive and negative impacts assessed equally?

  • Have we disclosed materiality thresholds?

  • Are value-chain impacts included?

IROs

  • Are all material IROs clearly explained?

  • Are entity-specific disclosures justified?

Connectivity

  • Is every material IRO linked to policies, actions, targets and metrics?

  • Have we disclosed gaps?

Financial Effects

  • Have we connected sustainability risks with financial reporting?

  • Have we disclosed current financial effects where required?

Targets

  • Are targets measurable and time-bound?

  • Are progress and setbacks reported honestly?

  • Are methodological changes explained?

  • Are science-based claims substantiated?

  • Have we provided absolute values where required?

Comparability

  • Are restatements and revisions clearly disclosed?

  • Can users compare FY2026 with prior years?


Final Takeaway

The central message from ESMA is simple: sustainability reporting should tell a coherent, traceable and evidence-based story.

Material impacts, risks and opportunities must clearly connect to policies, actions, targets, metrics, financial effects and progress reporting.

Companies that can demonstrate these links clearly will be best positioned to meet regulatory expectations and build trust with investors, auditors and regulators.


From Regulatory Expectations to Operational Execution

ESMA’s 2026 enforcement priorities send a clear message: sustainability reporting is no longer a standalone compliance exercise.

Regulators increasingly expect companies to demonstrate clear links between material Impacts, Risks and Opportunities (IROs), policies, actions, targets and metrics, while ensuring consistency with financial reporting and maintaining robust audit trails.

The era of generic sustainability narratives is coming to an end. Companies must now provide evidence-based, traceable and decision-useful disclosures.

Meeting these expectations can be challenging. Many organisations struggle with fragmented data collection processes, inconsistent documentation, weak traceability between disclosures, and limited visibility over how sustainability information connects across the report.

This is where Cleerit can help.

Cleerit is designed to operationalise the full ESRS framework, enabling organisations to move from compliance-driven reporting to structured sustainability governance. The platform supports:

  • IRO-to-PATM connectivity, helping organisations create clear links between Impacts, Risks and Opportunities, Policies, Actions, Targets and Metrics.

  • Datapoint-level completeness and traceability, ensuring disclosures can be supported by documented evidence and audit-ready records.

  • Structured governance, workflows and controls, supporting the level of discipline increasingly expected by regulators, investors, lenders and ESG rating providers.

  • Machine-readable and audit-ready sustainability reporting, aligned with ESRS requirements and the growing role of AI-driven reviews, ESG ratings and digital assurance processes.

  • Consistent reporting across topics, metrics and reporting periods, helping organisations improve comparability and reduce the risk of gaps, inconsistencies and greenwashing concerns.

As ESMA’s priorities make clear, the companies best positioned for future reporting cycles will be those that can demonstrate not only what they report, but also how they arrived at their conclusions, how they monitor progress, and how sustainability information connects to strategy, risk management and financial performance.

By providing a structured ESRS architecture, audit-ready documentation and end-to-end traceability, Cleerit helps organisations build the governance, transparency and reporting quality required in an environment where sustainability information is increasingly scrutinised with the same rigour as financial reporting.

Ultimately, compliance is only the starting point. Companies that establish robust ESRS processes today will be better positioned to build trust with investors, maintain rating credibility, facilitate access to financing and create long-term business value.

Cleerit is built to help organisations achieve exactly that.


Source: https://www.esma.europa.eu/sites/default/files/2026-10/ESMA32-2064178921-9738_Statement_-_2026_European_Common_Enforcement_Priorities__ECEP_.pdf

Reducing greenwashing risk in sustainability communications: key lessons from ESMA

Sustainability claims increasingly influence investor decisions, customer trust and corporate reputation. At the same time, regulators are paying closer attention to the risk of greenwashing.

To support companies, ESMA, the EU’s financial markets regulator and supervisor, has recently published two new thematic notes offering practical advice on how to reduce the risk of greenwashing by ensuring non-regulatory sustainability communications are clear, fair and not misleading.

ESMA notes that sustainability claims may be misinterpreted and may mislead investors, even where this is not the intention of the company.

Key Takeaways

  • Show, don’t just claim impact
  • Support impact and transition claims with evidence
  • Explain assumptions, limitations and methodologies
  • Distinguish between outputs, outcomes and impact
  • Connect transition ambitions to implementation plans and measurable progress
  • Ensure consistency across all sustainability communications
  • Use ESRS-based reporting as the foundation for transparent, traceable and defensible sustainability claims

Impact claims

ESMA’s thematic note on impact claims is a practical warning against using “impact” language unless companies can clearly explain and evidence how that impact is created.

The note stresses that claims about creating positive environmental or social outcomes must be accurate, accessible, substantiated and up to date.

Companies should avoid vague statements such as “making a positive difference” or “delivering impact” unless they can articulate a clear impact objective, a credible theory of change, and measurable indicators showing progress.

Communications should clearly distinguish between

  • what the company or product intends to achieve (intentionality),
  • why its actions make a difference beyond what would have happened anyway (additionality), and
  • how outcomes are measured (measurability).

Cherry-picking data, relying on broad sustainability aspirations (e.g., SDG alignment alone), using impact terminology without evidence, or omitting limitations and assumptions are highlighted as common greenwashing risks.

The practical message is: show, don’t just claim.

If you communicate impact, explain the specific environmental or social problem being addressed, how your activities contribute to solving it, the criteria used to assess impact, and the KPIs used to monitor results.

Be transparent about whether metrics measure

  • outputs (activities undertaken),
  • outcomes (changes achieved), or
  • actual impact (real-world benefits).

Disclose key assumptions, data limitations and methodologies.

Avoid taking credit for outcomes that cannot reasonably be attributed to the company’s actions.

Ensure that all marketing, sustainability reports and other communications are consistent with one another.

Climate transition claims

ESMA’s thematic note on transition claims focuses on how to communicate climate transition ambitions without creating greenwashing risk.

The key message is that transition claims are inherently forward-looking and subject to uncertainty, as their achievement may depend on future actions, assumptions and external factors.

They therefore require a higher level of transparency than claims about current sustainability performance.

Don’t treat transition claims as a marketing narrative about future intentions.

The note highlights the importance of clearly communicating what the transition ambition is, how it is expected to be implemented and how progress will be assessed and communicated, including relevant assumptions, data limitations and dependencies.

Companies should clearly explain three elements:

  • the transition ambition (what is being achieved and by when),
  • the implementation strategy (how the ambition will be delivered), and
  • progress achieved (whether the company remains on track).

Any targets should include a baseline year, metrics, intermediate milestones and underlying assumptions, while references to net-zero, decarbonisation pathways, Paris alignment or science-based targets should be accompanied by explanations of what those concepts mean in the company’s specific context.

Broad aspirational statements without measurable objectives, methodologies or evidence are identified as a key greenwashing risk.

The practical recommendation is straightforward: every transition claim should be supported by evidence.

Explain how investments, projects, products or operational changes contribute to the stated transition objective, and disclose any material assumptions, dependencies and uncertainties.

Be transparent about exposure to high-emitting activities, the role of climate targets and transition plans, and the methodologies used to measure progress.

Report regularly against previously disclosed targets, use consistent metrics over time, disclose setbacks and explain changes in methodology instead of highlighting only positive developments.

Using ESRS as the foundation for transparent and defensible sustainability claims

ESMA’s guidance reinforces a trend that is becoming increasingly clear: sustainability communications can no longer be separated from sustainability reporting.

The requirements identified by ESMA closely mirror many of the principles embedded in ESRS reporting, including traceability, transparency, consistency and the use of measurable metrics and targets.

Companies that build their communications on robust ESRS data, transparent methodologies and documented evidence will be better positioned to avoid greenwashing risk and build trust with investors, customers and regulators.

Solutions such as Cleerit help organisations operationalise these requirements through

  • structured governance,
  • datapoint-level traceability,
  • audit-ready documentation and
  • clear linkages between impacts, policies, actions, targets and metrics,

creating a reliable foundation for credible sustainability claims.

Ultimately, the most effective defence against greenwashing is not better wording but better evidence. Companies that can clearly demonstrate how sustainability claims are supported by data, methodologies and measurable results will be best positioned to build trust with investors, customers and regulators.


Download ESMA’s thematic notes on positive impact and climate transition:

https://www.esma.europa.eu/press-news/esma-news/esma-promotes-clarity-claims-impact-and-transition