AI Governance and ESRS G1 Disclosures Using Cleerit and OECD Guidance

Companies are increasingly deploying AI in core operations, decision‑making, and customer‑facing services.

As this happens, ESRS G1 Business Conduct is a good place to demonstrate that governance systems, policies and disclosures can prevent misconduct, protect rights and ensure responsible behaviour.

To do so, AI‑related impacts and risks should be integrated into the relevant ESRS sub‑topics.

If AI is related to material impacts, risks or opportunities that are not covered, or not covered with sufficient granularity, by existing ESRS topics, AI should be added as an entity‑specific topic in accordance with revised ESRS 1 paragraph 11.

The OECD Due Diligence Guidance for Responsible AI provides a practical, internationally recognised framework that companies can use to build these systems.

This article translates the OECD guidance into concrete steps that companies can implement to strengthen governance and produce high‑quality ESRS G1 disclosures:

AI Governance and ESRS G1 Disclosures Using Cleerit and OECD Due Diligence Guidance for Responsible AI

To supports organisations throughout this process Cleerit offers a governance‑ready, compliant, efficient and ESRS‑aligned solution that makes responsible AI governance practical and manageable.

You are welcome to contact us for a demonstration >>>

EFRAG has released the 2026 Draft List of ESRS Datapoints

EFRAG has released the 2026 Draft List of ESRS Datapoints — a list of datapoints reflecting the Revised ESRS and underpinning the upcoming XBRL taxonomy

If you work with ESRS reporting, digital readiness, or sustainability data architecture, this release is worth your attention.

But before diving into the Excel file, it’s essential to understand how datapoints are defined according to the methodology described in the accompanying Explanatory Note.

The Draft List is built on a clear methodology that combines the structure of ESRS paragraphs with the underlying data type logic. Without understanding this foundation, the list can easily be misread.

Also keep in mind that a datapoint does not equal a fact. A “fact” is the actual piece of information the company discloses in an ESRS sustainability statement after applying the materiality filter — not the datapoint itself. Counting datapoints in an Excel list is therefore of limited relevance.

The Draft List is released as support material, not implementation guidance, nor a substitute for the standards themselves – and it is not a checklist.

It helps report preparers see how disclosures are structured, how datapoints are separated, and how they will connect to the upcoming XBRL taxonomy for digital reporting.

Users of the 2026 Draft List are advised to exercise their own judgment in applying ESRS, and EFRAG reminds users that the list should not be substituted for the services provided by an appropriately qualified professional.

👉 We have summarised the key points and practical implications for you in this note:

2026 Draft List of ESRS Datapoints – EFRAG 28 August 2026

 

Note that the information does not replace the information provided by EFRAG in the Explanatory note available here >>>

 


Have your say: take EFRAG’s online survey the 2026 Draft List of ESRS Datapoints

EFRAG Secretariat invites stakeholders to review the methodology used to compile the Draft List of ESRS Datapoints and to report any fatal flaws through the online survey by 23 October 2026.

The final resource is expected to be published by the end of 2026 following consideration of the feedback received.

Access the online survey here: https://survey.alchemer.eu/s3/91158320/Collecting-Feedback-on-Fatal-Flaws-in-the-Draft-List-of-Datapoints

Public consultation on ESRS-40a for non-EU undertakings with significant EU market activity

Have your say on ESRS-40a for non-EU undertakings with significant EU market activity

On July 23 EFRAG launched a 100-day public consultation on the Exposure Draft of the European Sustainability Reporting Standards (ESRS-40a ED) for certain non-EU undertakings, developed under Article 40a of the Accounting Directive.

All interested stakeholders are invited, both within and outside the EU, to share their views before 31 October, including on the practical implementation challenges and the relevance of the resulting disclosures.

The objective of the ESRS-40a sustainability report, taken as whole, is to present fairly all the parent undertaking or group’s material sustainability-related impacts, and how the parent undertaking or group manages them.

The aim is to ensure that there is a level playing field for undertakings operating in the EU market, as well as to ensure transparency on impacts on people and the environment of non-EU undertakings with relevant EU activities.

ESRS-40a standards were previously denominated in EFRAG preliminary documents as Non-EU ESRS (N-ESRS) or ESRS for third countries (ESRS-TC). By naming the standard ESRS‑40a, EFRAG makes the legal anchor visible and unambiguous. This reinforces that it is not a separate framework, but a CSRD‑mandated ESRS standard.

Click here to access the standard: ESRS-40a_Exposure_Draft.pdf

Click here to submit your feedback: EFRAG Launches Public Consultation on the ESRS-40a Exposure Draft for Certain Non-EU Undertakings | EFRAG


Who will be in-scope?

Non‑EU groups with >€450M EU turnover and at least one EU subsidiary or branch with >€200M EU turnover (no employee threshold) will need to publish an ESRS-40a sustainability report targeting financial years starting on or after January 1, 2028.

Around 1,200 companies are expected to fall in scope, including 350–450 US groups and 150–200 UK groups.

ESRS-40a is an impact‑only standard

Disclosures on risks, opportunities, financial effects and resilience are removed, because Article 40a legally limits the EU to requiring transparency on impacts on people and the environment (IFRS S1/S2 cover financial risks). However, companies may still include financial information when needed to explain. This is the core design choice: ESRS-40a = ESRS minus the financial‑materiality.

12 ESRS‑aligned standards

The standard requires disclosures across 12 ESRS‑aligned standards, covering strategy, governance, policies, targets, due diligence, impacts, actions and metrics.

Groups can choose between three reporting perimeters:

  • Global (default) — report global impacts for all topics
  • Mixed — EU‑related impacts only (but climate-related impacts are always global),
  • Full ESRS — voluntary, enabling subsidiary exemption if the non‑EU parent applies full ESRS

When assessing EU-related impacts, the following are examples of factors that the undertaking may consider:

  • (a) existence of a separate business segment dedicated to serving the EU market;
  • (b) products or services specifically designed for the EU-market;
  • (c) separate management of EU-related impacts; or
  • (d) value chains dedicated to products and services that were or can be reasonably assumed to be sold or provided in the EU market.

Timeline

Exposure Draft mid‑July 2026, consultation until October, technical advice in January 2027, adoption mid‑2027, first reports published in 2029 (on FY 2028).

ESRS-40a will reshape sustainability reporting for non‑EU groups with significant activities in the EU. Impact transparency becomes mandatory, global climate data collection will be essential, and early preparation is key.

New EU Oversight of ESG Ratings: Implications for CSR Communication and ESRS Reporting

EU’s ESG Ratings Regulation (EU 2024/3005) came into effect on 2 July

In short:

EU’s new ESG Ratings Regulation introduces mandatory ESMA supervision of all ESG rating providers from 2 July 2026. The goal is to fix longstanding issues of opacity, inconsistency and low reliability in ESG ratings that companies use in CSR, sustainability and investor communication. During the transition period (July–November 2026), companies may reference ESG ratings only if the provider has notified ESMA. From 2 November 2026, ratings may be used exclusively from providers that appear in ESMA’s Article 14 public register.

This creates new compliance checkpoints for companies: 

Before publishing annual reports, sustainability webpages or investor presentations, companies will need to verify the regulatory status of any ESG rating provider to ensure that referenced ratings come from transparent, supervised and trustworthy sources.

It also raises expectations for ESRS reporting quality. 

ESRS sustainability statements must be complete, traceable and auditready, as ESG rating providers will increasingly crosscheck ESRS disclosures with their own supervised methodologies. Strong governance around sustainability data is essential documenting sources, reinforcing controls and clarifying responsibilities.

At the same time, investors and assurance providers will apply greater scrutiny to data quality, methodological alignment and consistency between ESRS disclosures and any ESG ratings referenced.

Cleerit’s guided digital ESRS endtoend templates and governance processes help organisations get a head start, avoid wasted effort and build the robust, wellstructured sustainability statements required under this new regulatory landscape.


What the ESGR Regulation mean for you

If you use ESG ratings in your communication, it is essential to understand that the ESG Ratings Regulation (EU 2024/3005) places all ESG rating providers under direct ESMA supervision to enhance transparency, integrity and comparability, and to reduce greenwashing risks. From 2 November 2026, companies may only reference ESG ratings from providers that have submitted their application or notification and appear in ESMA’s Article 14 public register.

ESMA will maintain this public register on its website, along with a transitional list (July–November 2026) of providers that have notified ESMA of their intention to apply. To avoid market disruption, ESMA confirms that third parties may continue publishing or distributing ESG ratings from notified providers between 2 July and ESMA’s decision on their application. This temporary list will be updated regularly until the full register goes live.

From 2 November 2026 onward, only ESG ratings from providers that have applied and are listed in the Article 14 register may be published or distributed. This ensures continuity for financial market participants while the new supervisory framework is phased in.

For CSRD/ESRS‑aligned communication, companies should integrate a provider‑status check into their publication workflow – especially for annual reports, sustainability webpages and investor presentations.

Why this regulation came to be

The ESGR Regulation was introduced because the ESG ratings market had grown rapidly and become highly influential, yet operated without EU‑level rules. The Commission identified persistent issues: low reliability and timeliness, opaque methodologies, unsolicited ratings, and a lack of oversight – all of which created risks for investors and rated companies.

ESMA supervision aims to make ESG ratings clearer, more consistent and more trustworthy, while supporting the EU’s broader sustainable‑finance architecture (Green Taxonomy, SFDR, CSRD).

What problems does it aim to resolve?

  1. Low reliability, accuracy, and timeliness of ratings

Investors and companies observed that ESG ratings often differed widely, were based on outdated data, or lacked clear justification.

  1. Lack of transparency in methodologies and data sources

Providers used very different approaches, often without disclosing how ratings were constructed or what data they relied on. This made ratings hard to interpret or compare.

  1. Unsolicited ratings and unclear provider practices

Companies were sometimes rated without engagement or visibility into the process, creating confusion and reputational risks.

  1. No oversight or control of rating providers

Before this regulation, ESG rating providers were not subject to EU rules on governance, conflicts of interest, or operational integrity.

  1. Consequences for markets and investors

These issues undermined investor confidence in sustainable products and created risks of misallocation of capital.

The EU’s objectives are clear:

  • Improve trust in ESG ratings and sustainable finance.
  • Ensure fair and transparent rating practices for companies.
  • Support the EU’s broader sustainable finance architecture (Green Taxonomy, SFDR, CSRD).
  • Create a level playing field for rating providers operating in the EU.

How the ESGR Regulation connects to ESRS and CSRD reporting

The link to ESRS is direct: ESRS disclosures feed ESG ratings, and ESG ratings shape how ESRS information is interpreted externally.

The ESGR Regulation governs how ESG ratings are produced and supervised, while ESRS governs how companies disclose their own sustainability information.

The ESGR Regulation aims to ensure ratings are “independent, impartial, systematic and of adequate quality”.

Rating providers must now disclose:

  • which E, S, G factors they use,
  • how they weight them,
  • what data limitations exist,
  • whether they assess financial materiality, impact materiality, or both.

Companies should expect their ESRS disclosures to be evaluated against these methodological choices, meaning that ESRS disclosures will be scrutinised more systematically and weaknesses will be reflected in ratings.

This creates new expectations for accuracy, traceability, and communication discipline. ESRS disclosures must be reliable because ESG ratings will become more reliable.

For companies, this raises the bar for ESRS reporting quality.

Your ESRS sustainability statement must be well structured, complete, traceable and audit‑ready, as rating providers will rely more heavily on ESRS disclosures – and will be supervised by ESMA.

Strong governance around sustainability data is essential – documenting sources, reinforcing controls and clarifying responsibilities.

Investors and assurance providers will also apply greater scrutiny to data quality, methodological alignment and consistency between ESRS disclosures and any ESG ratings referenced.

New criteria to stop companies from making misleading sustainability claims including through ESG Credentials

In parallel, the European Union is also targeting greenwashing and forcing companies to prove their environmental impact in other ways. The Empowering Consumers for the Green Transition Directive (ECGT) will become fully enforceable on September 27, 2026, banning generic claims like “eco-friendly” or “green” without proof (https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng).

ESMA has also recently published two thematic notes on clear, fair & not misleading sustainability-related claims, addressing greenwashing risks in support of sustainable investments (see one of the notes enclosed). They specifically targeted ESG Credentials:

  1. References to ESG credentials are among the most prominently used claims in retail-investor focused communications. These include references to qualifications, labels, ratings, certificates (henceforth referred to as “ESG credentials”): and can be misleading in several ways. For instance, by overstating the significance of having a given label, of receiving an ESG award, of being signatory to a voluntary framework, etc.
  1. Notably, these claims are of relevance for the following parties: fund managers (claims about funds’ and asset managers’ credentials), benchmark administrators (benchmarks’ credentials), investment service providers (claims at entity and/or product level) and issuers (entity-level claims).
  1. The ESG credential claim types below are considered in particular:
  • a) Industry initiatives: actual significance of market participants’ involvement in net zero alliances, in voluntary ESG initiatives, including doing voluntary ESG reporting under specific international frameworks. Sometimes, being a signatory to some of these initiatives leads to receiving an external ESG rating/assessment from the third party, which may be based on self-reported ESG information.
  • b) Labels and awards: actual significance of having a given credential like a national or regional label or perceived labels or of having won any type of ESG award (such as sustainability reporting awards for issuers); and
  • c) Comparisons to peers: actual significance of ESG credentials that are based on comparing ESG characteristics of a product or an entity (including ESG metrics like carbon footprint, ESG ratings, etc.) to competitors, peer groups, etc. Very often, it is not clear whether a credential is absolute or whether it is based on a comparison to peers.

How to prepare

A well‑structured, machine‑readable ESRS statement not only ensures ESG rating readiness – it strengthens governance, accelerates internal learning, reveals strategic blind spots and positions your organisation for the EU’s dual green and digital transition.

If your first ESRS report is due for FY2027, remember: early reporters will already be on their fourth cycle. Building processes, collecting data, and aligning teams takes time. Waiting until 2027 means falling years behind, so starting now is essential.

👉 Cleerit’s guided digital ESRS end‑to‑end templates and governance processes help you get a head start by saving time, avoiding wasted effort and ensuring a higher‑quality, more trustworthy sustainability statement. Contact us here >>>


Sources:

Regulation (EU) 2024/3005 on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities: https://eur-lex.europa.eu/eli/reg/2024/3005/oj/eng

ESMA rules for ESG rating providers: https://www.esma.europa.eu/esmas-activities/investors-and-issuers/esg-rating-providers

Public Statement from ESMA on what third parties may legally do with ESG ratings during the transition to the new EU ESG Ratings Regulation: https://www.esma.europa.eu/sites/default/files/2026-07/ESMA84-1427279869-1396_Public_Statement_on_Publication_or_distribution_of_ESG_ratings_by_third_parties_in_the_period_from_2_July_2026_until_authorisation__recogniti.pdf

ESMA’s thematic notes on clear, fair & not misleading sustainability-related claims addressing greenwashing risks in support of sustainable investments : ESMA36-429234738_-154_Thematic_notes_on_clear__fair___not_misleading_sustainability-related_claims.pdf

Today the European Commission adopted the revised ESRS

The EU has just reshaped sustainability reporting.

Today, on 3 July 2026, the European Commission adopted the revised ESRS — the biggest update since CSRD came into force. The new Delegated Act cuts mandatory datapoints by 61%, strengthens interoperability with ISSB and the EU Taxonomy, and clarifies how materiality should be applied in practice.

For companies preparing their next sustainability report, this is a turning point:

  • Optional early adoption in 2026
  • Mandatory application from 2027
  • New reliefs, clearer rules, and lower reporting burden
  • Stronger focus on standardized, decision‑useful, material information

Below we have summarized the key changes — and what they mean for your reporting processes.

You can download the revised ESRS here: https://ec.europa.eu/finance/docs/level-2-measures/csrd-delegated-act-2026-5010-annex_en.pdf

The 2026 CSRD Delegated Act: What You Need to Know for Your Next Sustainability Report

On 3 July 2026, the European Commission adopted a major update to the European Sustainability Reporting Standards (ESRS). This Delegated Act simplifies the reporting framework, reduces mandatory datapoints, and clarifies how companies should apply materiality. It is the most significant revision since ESRS was first introduced in 2023—and it directly affects how companies will report from financial year 2027, with optional early adoption in 2026.

  1. Why the ESRS were revised

The revision is part of the Omnibus I simplification package, which aims to reduce administrative burden while preserving the core objectives of the CSRD. The Commission explains that the update was needed to:

“remove datapoints deemed least important… prioritise quantitative datapoints… further distinguish between mandatory and voluntary datapoints… and provide clear instructions on how to apply the materiality principle.”

The goal is to make sustainability reporting simpler, clearer, and more proportionate, especially for companies with complex value chains.

  1. When the new standards apply

The Delegated Act states:

“Undertakings must use the revised ESRS from financial year 2027. They may choose to use the revised ESRS also for financial year 2026.”

Timeline

  • 2026: Optional early adoption
  • 2027: Mandatory application for all companies in scope
  • Entry into force: Four months + one week after adoption at the latest (≈ November 2026)

Companies reporting for FY2026 must explicitly state which version of ESRS they apply.

  1. Key simplifications companies will notice

3.1 Fewer mandatory datapoints (‑61%)

EFRAG’s technical advice led to a dramatic reduction in mandatory disclosures:

“Reducing the mandatory datapoints by 61% while retaining the core objectives of the European Green Deal.”

This means shorter reports, fewer tables, and more focus on what is truly material.

3.2 Clearer and more practical materiality rules

Materiality is the central mechanism for determining what to report.

The Commission clarifies that companies:

“shall not report information that is not material, except in certain clearly defined circumstances.”

New guidance includes:

  • A top‑down approach allows the undertaking to avoid unnecessary work and in general to avoid assessing the materiality of each individual impact, risk or opportunity.
  • Explicit permission to omit information that is commercially sensitive.
  • More flexibility regarding the need to consider specific geographical contexts when carrying out the materiality assessment – also clarifies that the level of disaggregation for materiality assessment does not imply that information must be reported at that same level of disaggregation.
  • The text states that reporting anticipated financial effects is likely to involve estimates and that these can be updated in the future in light of new information without this constituting a reporting “error” – and an additional year of phasing-in is introduced for both qualitative and quantitative information.
  • Reliefs for undue cost or effort and value chain limitations

3.3 More interoperability with global standards

The revised ESRS improves alignment with:

  • ISSB standards
  • EU Taxonomy
  • CSDDD (Corporate Sustainability Due Diligence Directive)

For example, companies may now use either financial control or operational control when defining GHG reporting boundaries—matching global practice.

3.4 New reliefs and phase‑ins

Companies get additional flexibility, including:

  • Extra year of phase‑in for anticipated financial effects
  • One‑year phase‑in for substances of very high concern
  • Reliefs for new acquisitions, joint operations, and non‑significant activities

These changes reduce the risk of non‑compliance and lower implementation costs.

  1. What remains mandatory

Despite simplification, several core areas remain essential:

  • Double materiality and reporting on IROs, policies, actions, targets and metrics
  • Climate transition plans (with transparency if not aligned with 1.5°C)
  • Primary microplastics disclosures
  • Pollutant emissions (based on managerial assessment)
  • Human rights incidents (only “substantiated verified” cases)

The Commission emphasizes that simplification must not undermine the European Green Deal.

  1. Expected cost savings

EFRAG’s cost‑benefit analysis shows substantial reductions:

“Reporting cost savings correspond on average to 34% of baseline costs… cumulative savings raise to around EUR 4.7 billion over 2027–2031.”

This is one of the strongest signals that ESRS aim to become more manageable for companies.

  1. What to do now

Step 1 — Decide whether to adopt early (FY2026)

Early adoption may simplify your 2026 report, but requires clear disclosure of the chosen ESRS version.

Step 2 — Update internal reporting systems

The revised ESRS structure is simpler, but companies must ensure:

  • updated templates
  • updated data models
  • updated governance and controls
  • alignment with CSDDD and EU Taxonomy

During summer we will update Cleerit with the final texts. We will then contact you to plan the implementation in your application.

  1. Final takeaway

The 2026 Delegated Act marks a turning point and the end of a long period of uncertainty. ESRS becomes more proportionate, more aligned with global standards, and significantly easier to understand and implement. Companies that embrace the materiality‑driven standardized reporting approach will produce shorter, clearer, and more decision‑useful sustainability reports—with lower cost and less administrative burden.

A well‑structured, machine‑readable sustainability statement also strengthens governance, accelerates internal learning, reveals strategic blind spots, and positions your organization for the EU’s dual green and digital transition.

If your first ESRS report is due in FY2027, remember: early reporters will already be on their fourth cycle. Building processes, collecting data, and aligning teams takes time. Waiting until 2027 means falling years behind. Now is the time to start.

👉 Contact us if you want to use our guided digital ESRS end-to-end templates to get a head start.


Source: Commission adopts revised sustainability reporting standards to reduce administrative burdens for EU businesses while maintaining high-quality disclosures – Finance

Summary of the EFRAG State of Play 2026 Report

EFRAG’s second State of Play edition, based on the FY2025 reporting cycle, analyses 905 assured FY2025 sustainability statements, offering the most comprehensive evidence to date of how companies are applying ESRS in their second CSRD reporting year.

The findings show continuity with refinement, not structural transformation.

The message is clear: ESRS reporting is becoming more consistent and evidence-based. The next frontier is strengthening the link between materiality, measurable targets, and strategic decision-making.

Geographies and sectors in scope

The FY2025 sample shows a shift in which countries are most represented in the sustainability reports analysed. Last year, France, Germany, and Finland had the largest share. This year, Sweden is in the lead (14%), followed by Germany (12%) and France (11%). There is also a strong Nordic increase, with Norway growing from 2% to 7% of the sample.

However, the report warns that these numbers are partially influenced by the cut-off date (20 April 2026). Some countries publish their reports (especially English versions) later in the year, so they are under‑represented in this dataset.

Among the non-financial companies, Manufacturing remains by far the largest sector, accounting for 36% of the entire baseline.

Cross-cutting insights

  • Materiality remains stable: Companies report on average 6.4 material topics, with E1 Climate Change, S1 Own Workforce, and G1 Business Conduct material for >95% of undertakings.
  • DMA methodology: 67% use a hybrid approach combining the benefits of bottom-up and top-down analysis for different topics. 82% updated their DMA since FY2024 through modifications ranging from minor refinements to scope changes.
  • IROs: Companies disclose ~30 IROs, heavily concentrated in E1 and S1 followed by G1 (60%). At country level, Spain leads with an average of 44 total IROs per company followed by Italy with 40 IROs and France at 35 while Sweden is positioned at 24 IROs. IROs are a key component of double materiality assessment, helping companies to determine which sustainability topics they should report on, and to identify how their business affects people and the environment (impacts), and how sustainability matters are material from a financial perspective.
  • Targets & incentives: Only 50% of material topics have measurable targets and 63% embed sustainability in executive remuneration, revealing a widening discrepancy between declared materiality and strategic commitment. At country level, France leads with 4 average number of material topics with targets.
  • Structure: Sustainability disclosures represent 34% of annual report length. Only 6% include an executive summary.

Environmental standards

  • Climate Transition Plans: Adoption increased from 55% to 69%, reflecting continued momentum in corporate climate planning.
  • 1.5°C alignment: 57% disclose near‑ and long‑term targets compatible with 1.5°C.
  • Non-climate topics (E2–E5): Slight rise in materiality. However, 77% report metrics only at global level, with minimal geographic disaggregation at regional and site level.

Social standards

  • Gender pay gap: Average unadjusted gap is 14.3% in favor of men, with the widest gaps concentrated in the financial sector. Only 12% of companies have enriched this figure with the adjusted pay gap to better account for the particularities of their workforce (i.e. geographic distribution and roles of their employees across the undertaking). At country level, Belgium has the lowest gap (7.7%) followed by Finland (10.7%) and Sweden (12.5%).
  • Discrimination & human rights incidents: Disclosure is high (85% and 93% respectively).
  • Human rights policies: 89% have policies covering Workers in the Value Chain and/or Affected Communities.

Governance (G1)

  • Materiality: a slight increase with Supplier relationship management, including payment practices, material for 54% of the undertakings vs. 50% in FY2024.
  • Supplier ESG criteria: 81% reference ESG criteria, but the nature of that integration is predominantly declarative – mostly via codes of conduct – operational integration remains limited.
  • SME payment terms: Only 7% disclose SME-specific terms. Average SME payment term is 24 days. This requirement has proved particularly challenging given – amongst others – the limitations of standard ERP systems in segmenting supplier data by company size.

If your first ESRS report is due in FY2027, remember: early reporters will already be on their fourth cycle. Building processes, collecting data, and aligning teams takes time. Waiting until 2027 means falling years behind.

🌿 A well‑structured, machine‑readable sustainability statement strengthens governance, accelerates internal learning, reveals strategic blind spots, and positions your organization for the EU’s dual green and digital transition.

👉 Contact us if you want to use our guided digital ESRS end-to-end templates to get a head start.

 

Read the full report from EFRAG here: EFRAG_State of Play 2026_vShared_Layout checked – DD.pdf

Understanding Eligible, Aligned, Enabling & Transitional economic activities under the EU Green Taxonomy

One of the most common sources of confusion in Article 8 reporting is the distinction between eligible, aligned, enabling, and transitional KPIs (i.e., Turnover, CapEx and OpEx).

Here is a breakdown:

⭕ Eligible activity – is “in scope”

Turnover (or CapEx or OpEx) is eligible when it comes from an economic activity listed in the EU Taxonomy (i.e., it appears in the Climate Delegated Act or Environmental Delegated Act), regardless of whether the company meets the technical screening criteria.

➡️ Eligibility = in scope, not green. It is the first filter in Article 8: companies must disclose the share of turnover, CapEx, OpEx associated with Taxonomy‑eligible activities before assessing alignment.

⭕ Aligned activity – is “fully compliant”

Turnover (or CapEx or OpEx) is aligned when the activity:

🌿 Substantially contributes to one EU environmental objective

🌿 Does no significant harm to the other environmental objectives

🌿 Complies with the technical screening criteria

🌿 Meets minimum safeguards (on an enterprise level)

➡️ Alignment = fully Taxonomy‑compliant. This is the KPI investors look at to understand how “green” a company truly is.

⭕ Enabling activity – “makes others green”

Enabling activities generate turnover (or CapEx or OpEx) by helping other activities achieve substantial contribution (e.g., components for wind turbines, low‑carbon inputs). They are not green on their own, but they are essential to green outcomes.

➡️ Enabling activities are a subset of aligned activities – not an alternative.

Financial products must disclose enabling activities separately.

⭕ Transitional activity – is “on the pathway”

Transitional activities apply where no low‑carbon alternative exists yet, but the activity is on a credible decarbonisation pathway. They must:

▪️ Have lower emissions than the sector average
▪️ Avoid lock‑in
▪️ Not hinder low‑carbon alternatives
▪️ Tighten criteria over time

➡️ Transitional = necessary interim activities on the path to net zero. Also disclosed separately in financial product reporting.

👉 How they fit together in Article 8 KPI reporting:

▪️ Eligible = activity appears in the Taxonomy

▪️ Aligned = meets all SC + DNSH + safeguards + TSC

▪️ Enabling = subset of aligned

▪️ Transitional = subset of aligned

Enabling and transitional activities do not replace alignment – they refine it.

🌿 A well‑structured, machine‑readable sustainability statement strengthens governance, accelerates internal learning, reveals strategic blind spots, and positions your organization for the EU’s dual green and digital transition.

👉 Contact us if you want to use our guided digital ESRS end-to-end templates to get a head start.

The EU is tightening the rules on green claims

The EU is tightening the rules on green claims as of September 2026 – and 20 Member States are already facing infringement procedures for failing to fully transpose the Empowering Consumers Directive (EU) 2024/825 in time.

For companies, this Directive is not “just another compliance exercise”. It fundamentally reshapes how sustainability is communicated to consumers – and it directly links to CSRD and ESRS reporting.

What changes?

The Directive bans misleading environmental and social claims, prohibits offset‑based “climate neutral” claims, regulates sustainability labels, and requires clear information on durability, reparability and software updates. It also targets early obsolescence and misleading digital practices.

Who is in scope?

All traders engaging in B2C practices: manufacturers, importers, retailers, marketplaces (for their own offers), digital service providers, and anyone acting on behalf of a business. SMEs included.

To comply:

  • Map and audit all environmental and social claims used in public documents and communication – remove generic claims (“eco‑friendly”, “green”, “biodegradable”) unless backed by recognised excellent environmental performance.
  • Eliminate offset‑based neutrality claims – “climate neutral”, “CO₂ compensated”, “net zero” are banned unless based on actual lifecycle emissions.
  • Ensure future climate claims are credible and verifiable – requiring public commitments, measurable targets, a detailed implementation plan, independent verification, and published progress.
  • Review all sustainability labels – only labels based on credible certification schemes or public authorities remain allowed.
  • Provide durability and reparability information – including spare parts, repair restrictions, and minimum software update periods.
  • Update product design and marketing to avoid early obsolescence practices.

The Directive and CSRD/ESRS now form a single consistency framework:

👉 A company cannot say to consumers what it cannot prove in its ESRS disclosures.

This means marketing, product teams, sustainability, legal and finance must work from the same evidence base.

How CSRD/ESRS help you comply

The Directive’s requirements for credible climate claims map directly to ESRS:

  • Public climate-related commitments → ESRS E1 strategy & transition plan
  • Measurable, time‑bound targets → ESRS GDR-T
  • Implementation plan →ESRS E1 transition plan (actions, investments, milestones)
  • Independent verification → CSRD assurance
  • Published progress →ESRS GDR-M and GDR-A annual performance reporting

If you build robust ESRS disclosures, they automatically create the documentation needed to substantiate consumer‑facing claims – reducing legal risk and strengthening trust.

Key takeaway

This Directive is not only about avoiding greenwashing fines. It is an opportunity to align sustainability strategy, reporting, and consumer communication – and to use CSRD/ESRS as the backbone for credible, defensible climate and sustainability claims.

 


The EU’s Empowering Consumers Directive: What It Means for Companies — and How CSRD/ESRS Can Help You Comply

The EU is entering a new era of consumer protection. As of September 2026, companies operating in the EU/EEA will face a fundamentally different regulatory landscape for environmental claims, sustainability labels, durability information, and digital product practices. The Empowering Consumers for the Green Transition Directive (EU) 2024/825 is designed to ensure that consumers can make informed, sustainable choices — and that businesses communicate honestly and transparently.

The European Commission has already taken action: on 28 May, it opened infringement procedures against 20 Member States for failing to fully transpose the Directive. This is a clear signal that enforcement will be strict and that companies should not expect leniency.

This article explains the Directive, who is affected, what companies must do, and how CSRD/ESRS reporting can be leveraged to comply.

1. Why This Directive Was Introduced

The Directive amends two pillars of EU consumer law — the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD) — to make them fit for the green transition.

The rationale is straightforward:

Consumers cannot make sustainable choices if the information they receive is misleading, incomplete, or unverifiable.

The Directive therefore targets:

  • Greenwashing
  • Misleading environmental or social claims
  • Non‑credible sustainability labels
  • Early obsolescence
  • Hidden repair restrictions
  • Misleading software update practices

It aims to create a level playing field where genuinely sustainable products can compete fairly — and where consumers can trust what they are told.

2. Infringement Procedures: A Warning Signal

Member States had until 27 March 2026 to transpose the Directive. Twenty have not yet communicated full transposition. The Commission has therefore issued letters of formal notice, the first step in an infringement procedure.

If Member States fail to respond satisfactorily within two months, the Commission may issue a reasoned opinion — a formal, detailed statement explaining the breach and setting a compliance deadline. This is the final step before referral to the Court of Justice.

For companies, this matters because it shows the Commission’s determination to enforce the Directive — and because national transposition delays do not delay the obligations for businesses.

3. Who Is in Scope?

The Directive applies to all traders engaging in B2C commercial practices in the EU/EEA, including:

  • Manufacturers
  • Importers and distributors
  • Retailers (online and offline)
  • Marketplaces (for their own offers)
  • Providers of digital goods, digital content, and digital services
  • Repair and subscription service providers
  • Anyone acting on behalf of a business (agencies, franchisees, intermediaries)

SMEs are explicitly included.

4. What the Directive Changes 

A. Combatting Greenwashing and Misleading Claims

The Directive introduces strict rules to ensure that environmental and social claims are accurate, substantiated, and not misleading.

Ban on generic environmental claims

  • Terms like “eco‑friendly”, “green”, “biodegradable”, “climate friendly” are prohibited unless backed by recognised excellent environmental performance.

Ban on offset‑based climate claims

  • Claims such as “climate neutral”, “CO₂ compensated”, “net zero” are banned unless based on actual lifecycle emissions, not offsets outside the value chain.

Ban on claims about an entire product or business when only part is sustainable

  • Example: “Made with recycled materials” when only the packaging is recycled.

Future climate claims must be credible

A trader must have:

  • Public commitments
  • Measurable, time‑bound targets
  • A detailed implementation plan
  • Independent third‑party verification
  • Published progress

B. Regulating Sustainability Labels

The Directive prohibits sustainability labels that:

  • Are not based on a certification scheme, or
  • Are not established by a public authority

Certification schemes must meet minimum standards of transparency, independence, and monitoring (e.g., ISO 17065).

This will significantly reduce the proliferation of private, non‑credible labels.

C. Addressing Early Obsolescence and Digital Practices

The Directive bans:

  • Features designed to limit durability
  • Software updates that degrade performance
  • Practices inducing premature replacement of consumables
  • Withholding information about negative impacts of updates

It requires transparency when third‑party consumables or spare parts impair — or do not impair — functionality.

D. Strengthening Pre‑Contractual Information

Companies must provide clear information on:

  • Durability
  • Reparability score (when available)
  • Spare parts availability and cost
  • Repair restrictions
  • Minimum software update periods
  • Commercial guarantees of durability >2 years (with a harmonised EU label)

A harmonised legal guarantee notice must also be displayed.

5. What Companies Must Do to Comply

Map and audit all environmental and social claims

  • Remove or substantiate generic claims.

Eliminate offset‑based neutrality claims

  • Rebuild climate messaging around actual emissions reductions.

Ensure future climate claims are credible

  • Update transition plans, set measurable targets, engage verifiers, and publish progress.

Review all sustainability labels

  • Remove labels that lack credible certification.

Provide durability and reparability information

  • Update packaging, product pages, and pre‑contractual disclosures.

Review product design and software practices

  • Avoid early obsolescence and misleading update practices.

Train marketing, product, and legal teams

  • Ensure consistent understanding of the new rules.

6. How CSRD/ESRS Help Companies Comply

The Directive and CSRD/ESRSreinforce each other:

  • The Directive protects consumers from greenwashing.
  • CSRD/ESRS protect investors and regulators from greenwashing.

Together they create a single consistency requirement:

A company cannot say to consumers what it cannot prove in its ESRS disclosures.

This is where CSRD becomes a strategic asset.

Robust ESRS disclosures provide the evidence base needed to substantiate consumer‑facing claims -reducing legal risk and strengthening trust.

This means:

  • Marketing claims must be aligned with ESRS data
  • Climate neutrality claims must reflect ESRS rules on offsets
  • Future‑oriented climate-related claims must match the ESRS transition plan
  • Any inconsistency becomes both a consumer‑law breach and a CSRD compliance risk

7. The Strategic Opportunity

This Directive is not only about avoiding greenwashing fines. It is an opportunity to:

  • Align sustainability strategy, reporting, and consumer communication
  • Strengthen credibility with consumers and regulators
  • Use CSRD/ESRS as the backbone for all climate‑ and sustainability‑related claims
  • Build trust through transparency and evidence

Companies that act early will be better positioned — legally, commercially, and reputationally — when enforcement begins in September 2026.

 

Sources:

Commission takes action to ensure complete and timely transposition of EU directives

Frequently asked questions related to Directive (EU) 2024/825 – Empowering consumers for the green transition through better protection against unfair practices and through better information

Sustainable consumption – European Commission

Directive – EU – 2024/825 – EN – EUR-Lex

7 Pillars Shaping the Next Generation of Sustainability Reporting in Europe

At the EFRAG 25th Anniversary Conference, Chiara Del Prete outlined what is becoming the new reference framework for high‑quality sustainability reporting in the EU. Europe is not simply implementing standards – it is building a coherent, future‑proof system designed to stand on equal footing with financial reporting.

🌿 1. Double Materiality as a Cornerstone

Europe’s model starts where others hesitate: recognising that impacts and financial risks & opportunities are inseparable. Double materiality ensures reporting reflects both a company’s footprint on the world and the world’s effects on the company – enabling realistic, holistic and forward‑looking analysis.

🌿 2. Robust Characteristics of Quality

Sustainability information must meet the same qualitative bar as financial reporting: relevance, fair representation, comparability, verifiability and understandability. This is the quiet revolution – sustainability reporting is no longer “extra‑financial” but co‑equal corporate reporting.

🌿 3. Holistic Coverage of Topics

Environmental, social and governance matters are treated as interacting dimensions, not separate chapters. This reflects how real‑world impacts and dependencies unfold – and how they translate into regulatory exposure, supply‑chain fragilities, reputational effects or shifts in market demand, while governance determines resilience.

🌿 4. Principle‑Based Approach

In line with the EU’s standard‑setting culture, ESRS remain principle‑based, enabling proportionality, judgement and sector‑specific relevance. The result is a system that is rigorous yet adaptable in a fast‑evolving landscape.

🌿 5. Structured Sustainability Statements

Sustainability reporting is now the “second leg” of standardised corporate reporting, structurally connected to financial statements. This strengthens connectivity, coherence and long‑term value understanding – anchoring sustainability firmly within the corporate reporting package.

🌿 6. Interoperability by Design

The EU framework is built to onboard other EU regulations and global frameworks (GRI, ISSB & others) through a single, coherent report. This reduces duplication, increases comparability and ensures a holistic view across reporting requirements.

🌿 7. Digital Readiness as a Prerequisite

With digital taxonomies and AI‑compatible structures, sustainability reporting enters the era of machine‑readable, assurance‑ready, decision‑useful data – the foundation for future supervision, analytics and capital‑market integration.

A European Reporting System Built for the Next Decade

These 7 pillars show how far the EU has come: from fragmented disclosures to a coherent, interoperable, digitally ready reporting system supporting Europe’s economic, environmental and social ambitions.

Sustainability reporting is no longer an add‑on – it is a strategic, structured and globally influential pillar of corporate reporting.

 


What happens when financial reporting, sustainability, geopolitics and technology converge?

EFRAG’s 25‑year milestone offered a rare moment to step back and see the full picture: a reporting system in transformation, a new governance logic, and a Europe determined to lead.

From the political battles of IFRS adoption to the emergence of a fully integrated sustainability reporting system, EFRAG’s 25th Anniversary Conference showed just how far Europe has come – and how much is still ahead.

Sustainability reporting is now strategic and central to capital markets. Sustainability impacts, risks and opportunities are business risks and opportunities. No company can afford blind spots.

I’ve summarised key messages that emerged across panels and keynotes – from connectivity to anticipated financial effects, AI, interoperability, digitalisation and the future of double materiality – and where corporate reporting is heading next. 👇

Enjoy the reading

Leila Hellgren

EFRAG at 25: Corporate Reporting Enters Its Next Era

The 2026 EFRAG Conference marked more than an anniversary. It captured a turning point in Europe’s corporate reporting journey – from the political battles of IFRS adoption to the emergence of a fully-fledged, interconnected system where financial and sustainability reporting stand side by side.

Across panels and keynotes, one message resonated: sustainability reporting is no longer an adjunct. It is reshaping corporate reporting, governance and capital markets – and Europe intends to lead.

From Accounting Debates to a European Reporting System

Speakers revisited the origins of EFRAG: a time when accounting was anything but technical. As Karel Van Hulle put it, “accounting is too important to be left to the accountants.”

The early 2000s were marked by divergent national views, resistance to IFRS, and the political realisation that only an EU regulation could ensure simultaneous adoption across Member States. The 2008 financial crisis then pushed accounting rules onto the front page of the Financial Times, revealing how standards can influence behaviour, market stability and public trust.

This history matters because it sets the stage for today’s transformation: sustainability reporting is now just as political, consequential and contested as financial reporting once was.

The Shift to Sustainability: A More Complex, More Political Landscape

Speakers acknowledged that sustainability reporting has become deeply intertwined with geopolitics, energy security and societal expectations. The ESRS revision – and the forthcoming Delegated Act – reflect this broader shift: not only a rethinking of the role of the economy in society, but also the recognition that corporate activity does not operate in isolation from an increasingly polarised world.

Supply‑chain disruptions, geopolitical tensions, social fragmentation and the energy transition all shape the risks companies face, and the expectations placed upon them. Sustainability reporting is therefore becoming a tool to navigate complexity, demonstrate resilience and maintain trust in a context where economic decisions are inseparable from political and societal dynamics.

Interoperability and the Global Landscape

In this contexte, Europe and the ISSB “have different north stars but look in the same direction.” The EU’s choice to remain independent – driven by its own political goals and double materiality approach – was widely seen as the right one.

Interoperability is the pragmatic solution: a way to reduce duplication, support global comparability and ensure that companies can access capital markets across jurisdictions.

Over 40 jurisdictions have adopted ISSB standards, each with their own policy objectives. Europe’s voice is heard – and increasingly influential – in this global dialogue.

Connectivity: Europe’s Distinctive Contribution to Corporate Reporting

A central theme of the conference was connectivity – the structured linkage between sustainability information and financial statements.

Speakers stressed that:

  • Sustainability goals influence financial decisions, provisions and performance.
  • Impacts drive risks and opportunities, which ultimately shape financial outcomes.
  • Financial reporting is the X‑ray; sustainability reporting is the MRI scan.
  • Together, they offer a full picture of a company’s resilience and long‑term value creation.

Connectivity is not consolidation. It is coherence: consistent boundaries, reconciliations, cross‑references and a shared narrative. As one preparer put it: “It is difficult to connect on paper what has not been connected in internal processes.”

This is why connectivity is ultimately a governance issue, not a reporting one.

Anticipated Financial Effects: The Next Frontier

Anticipated financial effects (AFE) remain one of the most challenging areas. Practices are immature, methodologies differ, and companies fear disclosing assumptions that may change.

Yet investors see AFE as “an analyst’s dream”: numbers build confidence, especially when accompanied by transparent methodologies and scenario‑based narratives.

The long phase‑in period until 2030 reflects this complexity – and the need for learning, capacity building and cross‑disciplinary collaboration.

Digitalisation and AI: Opportunity and Risk

Digitalisation was another recurring theme. Despite lobbying to remove XBRL, Sébastien Harushimana (FCCA) stressed that research shows that AI complements structured data – it does not replace it.

AI can streamline reporting and enable real‑time analysis, but it also introduces risks:

  • Models are probabilistic and may produce different outputs: press the button again and you may have another outcome.
  • Sustainability data is less mature and less structured than financial data. AI systems perform best when the data they analyse is consistent, standardised, complete and historically rich. Financial reporting meets these conditions: decades of harmonised standards, clear definitions and structured formats. Sustainability data does not – yet.

Structured formats remain the backbone of reliable, machine‑readable reporting. And transparency about which AI models are used becomes essential.

Sustainability Risks and Opportunities are Business Risks and Opportunities

No company can afford blind spots. If you truly understand your business, you also know where the vulnerabilities lie – even if speaking about them feels uncomfortable at first.

And if a company chooses not to disclose, investors will construct their own view from external data sources. Reporting is where companies can tell their story on their own terms.

Why Companies Should Not Wait

A strong warning was issued to companies outside the CSRD scope: the wait‑and‑see approach is dangerous.

Not understanding your impacts, risks and opportunities is a governance failure. Value‑chain due diligence obligations will still apply. And investors will create their own assessments if companies do not disclose.

Early movers gain:

  • better internal management of impacts, risks and opportunities
  • clearer value‑creation logic
  • stronger investor trust
  • readiness for future regulatory or market expectations

As one speaker noted: “The topics on the CSO’s table will be on the CFO’s table within two to three years.”

The Future: A More Integrated, More Strategic Reporting System

Several themes emerged as defining the next decade:

  • Standardisation is replacing the “alphabet soup” of voluntary frameworks.
  • Double materiality will remain Europe’s distinctive contribution.
  • Performance, strategy, risk and resilience will shape sustainable business models.
  • Connectivity will reduce “cheap talk” and reward companies that tell a coherent story across financial and sustainability sections.
  • Technology will bring real‑time communication between companies and investors.

Above all, sustainability reporting is not a burden – it is a strategic tool for risk management and decision‑making.

A System Still Evolving – But Here to Stay

The conference closed with a clear message: sustainability reporting and connectivity are here to stay.

Europe must continue learning, adjusting and balancing ambition with operational feasibility. But the direction is set: a reporting system that is relevant, reliable, connected and forward‑looking.

N-ESRS is coming for large non-EU groups active in the EU

ESRS for Non-EU Groups (N‑ESRS): What Your Group Needs to Know and Do

N‑ESRS is the EU’s new sustainability reporting standard that requires large non‑EU groups with significant EU turnover to disclose their impacts on people and the environment.

It will reshape sustainability reporting for large non‑EU groups active in the EU.

An estimated 1200 companies will be in the scope of N-ESRS:

  • 350-450 USA
  • 150-200 UK
  • 100-150 Switzerland, Japan
  • 20-50 Cayman Islands, China, Canada, Rep. of Korea
  • 10-20 Brazil, Mexico, Hong Kong, India, Bermuda, Virgin Islands

The objective of your N-ESRS sustainability report, taken as whole, will be to present fairly all your group’s material sustainability-related impacts, and how it manages them (through policies, actions, metrics and targets), reported at a global level.

N-ESRS is an impact-only reporting standard – the EU cannot impose full financial risk reporting on non-EU parents, and the legal mandate (Article 40a) is impact focused – but there are benefits to applying full ESRS on a voluntary basis:

  • If the non-EU ultimate parent company applies full ESRS, the CSRD in-scope subsidiaries of that non-EU company could benefit from subsidiary exemption. But only if the non-EU parent company applies full ESRS.

Timeline: What happens when

  • Mid‑July 2026: Exposure Draft published by EFRAG
  • Mid‑July – October 2026: Public consultation (100 days)
  • Early June 2026: Call for interest to participate field test
  • July – October 2026: Field tests with report preparers
  • January 2027: EFRAG delivers technical advice to the European Commission
  • Mid‑2027: N-ESRS adoption as delegated act
  • FY 2028: First reporting year
  • 2029: First N‑ESRS report published

Source : EFRAG SRB Online Meeting 3 June 2026, https://vimeo.com/event/5947235

 

  1. Who must report and when

Your group is in scope if it meets the both these two threshold criteria (Article 40a after Omnibus I):

  • Criteria 1: EU turnover > EUR 450 million for two consecutive years (at group level)

AND

  • Criteria 2: at least one EU subsidiary or branch with a net turnover in EU > EUR 200 million during the previous financial year

First reporting year: FY 2028, report published in 2029

  1. What you must report 

N‑ESRS is based on simplified ESRS, but focuses only on impacts, not financial materiality:

  • Disclosures on risks, opportunities, financial effects, resilience and dependencies are removed.
  • But financial information is per se strictly not excluded, it is needed to provide contextual information to understand impacts!

This is the core design choice: N‑ESRS = ESRS minus the financial‑materiality pillar.

Mandatory disclosure areas (Article 40a)

Strategy & business model

  • Plans to align with 1.5°C and climate neutrality by 2050
  • How stakeholder interests and sustainability impacts are considered
  • How sustainability strategy is implemented

Governance

  • Role, expertise and skills of administrative/management bodies in sustainability oversight
  • Incentive schemes linked to sustainability matters

Policies

  • Description of the group’s policies in relation to sustainability matters

Targets

  • Time‑bound sustainability targets, including at least GHG targets for 2030 and 2050
  • Progress toward targets
  • Whether environmental targets are based on scientific evidence

Due diligence

  • Description of due diligence process implemented by the group with regard to sustainability matters (aligned with EU requirements where applicable)

Impacts

  • Principal actual and potential adverse impacts across own operations and value chain, including products and services, business relationships and supply chain

Actions

  • Actions taken to identify and monitor those impacts, and other adverse impacts which your group is required to identify according to other EU requirements to conduct a due diligence process
  • Actions taken to prevent, mitigate, remediate or bring to an end actual or potential adverse impacts, and the results of such actions

Indicators

  • Metrics relevant to all disclosures above (governance, strategy, policies, actions, targets)

Topics covered

You must report across 12 standards (same structure as ESRS): Climate, pollution, water, biodiversity, circularity, own workforce, value‑chain workers, communities, consumers, business conduct, plus general requirements and disclosures.

  1. What perimeter to use (global vs EU‑related)

You will choose between three approaches (no final drafting yet):

Option 1 – Global approach (default)

  • Report global impacts for all topics.

Option 2 – Mixed approach (flexible by topic)

  • Climate impacts: always global
  • Other topics: option to report only EU‑related impacts, if:
    • Impacts are managed separately (e.g., EU segment, EU products)
    • EU‑related impacts include customer‑based and location‑based components

Option 3 – Full ESRS (voluntary)

  • If the non‑EU parent applies full ESRS, EU subsidiaries may benefit from the subsidiary exemption.
  1. Interoperability with IFRS S1/S2

The objective is to avoid double reporting:

  • Large overlap between ESRS 2 / IFRS S1 and ESRS E1 / IFRS S2 (governance, risk management, targets, GHG emissions, transition plan).
  • N‑ESRS adds impact‑focused requirements (e.g., compatibility with 1.5°C).

Incorporation by reference to the IFRS sustainability report is an option!

 

What your group should do now (practical preparation plan)

Confirm scope

  • Assess EU turnover at group level for the past two years.
  • Identify EU subsidiaries/branches with turnover > EUR 200M.

Decide your reporting perimeter

  • Global? Mixed? (topic‑by‑topic feasibility assessment) Full ESRS? (if aiming for subsidiary exemption)

Map your current disclosures

  • Start from existing sustainability reporting (TCFD, GRI, IFRS S1/S2, local laws…).
  • Identify gaps vs. N‑ESRS impact‑focused requirements.

Build or strengthen your due diligence system

  • Map and assess actual and potential impacts across entire value chain.
  • Document processes, policies, targets, actions and remediation results.

Prepare climate‑related disclosures

  • Transition plan aligned with 1.5°C
  • GHG inventory (Scopes 1–3)
  • 2030 and 2050 targets + progress tracking

Prepare governance & incentives disclosures

  • Roles, expertise, oversight mechanisms
  • Sustainability‑linked remuneration

Prepare for data collection

  • Global data for climate
  • EU‑related data for other topics (if mixed approach)
  • Value‑chain data (workers, communities, consumers)

Plan for interoperability

  • Decide what will be disclosed in the IFRS sustainability report
  • Decide what will be incorporated by reference into N‑ESRS

Engage early

  • Participate in EFRAG’s consultation and field tests
  • Align internal teams (finance, sustainability, legal, operations)

 

Why N‑ESRS focuses only on impacts (and not risks & opportunities)

  1. Article 40a of the CSRD requires transparency on impacts, not financial materiality

The policy objectives of Article 40a are: “Level‑playing field” and “Accountability and transparency of non‑EU companies on impacts”.

This is the legal anchor: The EU wants non‑EU companies to disclose their impacts on people and planet when they operate in the EU market. It is not intended as a full double‑materiality regime for foreign groups.

  1. The EU cannot impose financial‑risk reporting on non‑EU parent companies

  • ESRS for EU companies are not policy neutral, they support the EU Green Deal and transition agenda.
  • The EU can require disclosure of impacts caused by non-EU groups in the EU market.
  • But it cannot realistically require a non‑EU parent to disclose global financial risks, opportunities, or resilience assessments.

Thus, N‑ESRS focuses on what the EU can legitimately require from non-EU parent companies: impact transparency, not financial risk analysis.

Requiring non-EU groups to perform full double materiality at global level (including financial risks, opportunities, and resilience analysis) would be disproportionate and legally complex.

You may still mention financial data if it helps explain an impact, but you do not perform the ESRS financial‑materiality assessment.

  1. Interoperability with IFRS S1/S2 already covers risks for those who need it

  • IFRS S1/S2 = financial risks & opportunities
  • N‑ESRS = impacts only
  • Overlap exists for climate, but N‑ESRS adds impact‑specific requirements

This separation avoids double reporting and respects the different purposes of each framework.

 

Want to participate in EFRAG’s field test?

🌿 EFRAG has launched a call for interest to participate in the field test of the draft Non-EU ESRS (N-ESRS) ahead of its public consultation in July 2026. Register here before 1 July and secure direct interaction with EFRAG shaping the future sustainability reporting standard for non EU groups 👉 EFRAG Resumed Work on the European Sustainability Reporting Standard for Non-EU Groups and Launches Field Test Call for Interest | EFRAG

 

The best way to prepare for N-ESRS reporting? Guided digital ESRS end-to-end templates.

Contact us if you want to use our guided digital ESRS end-to-end templates to get a head start.