The Commission has updated ESRS\u202f1 – and the adjustments matter.<\/p>\n
From a stricter materiality filter to new guidance on top\u2011down assessments, clearer rules on what can be omitted, a new value\u2011chain cap aligned with the voluntary standard, strengthen transparency around omissions, and new exemptions for investment managers under fiduciary duty, these adjustments make ESRS reporting more focused.<\/p>\n
For companies, this means less noise, more relevance, and a clearer path to audit\u2011ready sustainability reporting.<\/p>\n
If ESRS preparation is on your agenda, this overview will help you understand what\u2019s changed – and why it matters for your 2026 reporting cycle.<\/p>\n
Read the full article for the key takeaways and practical implications. \ud83d\udc47<\/p>\n
The European Commission has introduced a series of targeted adjustments to ESRS 1, refining how undertakings determine materiality, report value\u2011chain information, and apply exemptions. Below is a synthesis of the most significant updates.<\/p>\n
A new clarification confirms that undertakings must not disclose non\u2011material information<\/strong>, whether prescribed by an ESRS Disclosure Requirement or arising from entity\u2011specific disclosures. This strengthens the materiality filter and explicitly prevents \u201cover\u2011reporting\u201d that could obscure relevant information.<\/p>\n A new Application Requirement (AR 8) explains that informed assessments<\/em> are the reasonable evaluations made by the category \u201cother users of general-purpose sustainability statements\u201d when forming decisions about the undertaking. This addition clarifies the role of non\u2011financial users – business partners, social partners (trade unions and employer organisations), civil society and NGOs – in the materiality logic.<\/p>\n The Commission adds explanatory guidance confirming that a top\u2011down approach can avoid unnecessary work by allowing undertakings to conclude on materiality at topic level without assessing every individual impact, risk, or opportunity. However, a more granular assessment is required when it could change the materiality conclusion.<\/p>\n A new AR (AR 16) explains that the level of materiality assessment is distinct from the level of aggregation for reporting. This separation ensures that undertakings can assess materiality at one level (e.g., topic or geography) while reporting at another, depending on what best supports faithful representation.<\/p>\n Two new ARs (AR 17 and AR 37) introduce an important exemption:<\/p>\n This reduces the reporting burden for asset managers operating under strict fiduciary mandates.<\/p>\n A new paragraph (66) explains how undertakings must apply the value\u2011chain cap when requesting information from protected undertakings in their value chain. Key points include:<\/p>\n This addition aligns ESRS 1 with the forthcoming voluntary standard and clarifies the legal boundaries of information requests.<\/p>\n The Commission has substantially rewritten the rules governing when information may be omitted. The revised section:<\/p>\n This rewrite strengthens transparency while preserving legitimate protections.<\/p>\n A new AR explains that:<\/p>\n This provides comfort to preparers and aligns ESRS with financial\u2011reporting logic.<\/p>\n The changes introduced by the European Commission:<\/p>\n The Commission\u2019s updates to ESRS\u202f1 sharpen the rules and make compliance more focused. For companies, the priority now is to tighten their materiality process, structure value\u2011chain requests, and apply omission rules with clear justification.<\/p>\n Strengthened guidance on top\u2011down assessments, estimates, and fiduciary\u2011duty exemptions gives organisations room to streamline their work – provided they document decisions and maintain traceability.<\/p>\n In practice, this means building a controlled, well\u2011evidenced ESRS workflow that avoids unnecessary disclosures, protects sensitive information, and ensures consistent, audit\u2011ready reporting year after year.<\/p>\n These changes make ESRS reporting more focused – but also more demanding in terms of structure, documentation, and traceability. Cleerit is designed precisely for this.<\/p>\n The solution integrates the full ESRS logic – from materiality assessment and governance to ESRS compliant sustainability reporting – so you can move from interpretation to execution with confidence and ensure your disclosures flow directly into the right ESRS datapoints.<\/p>\n If you\u2019d like to explore how Cleerit can support your ESRS preparation, just reach out >><\/a><\/p>\n \u2014<\/p>\n\n
New Guidance on \u201cInformed Assessments\u201d<\/strong><\/h3>\n<\/li>\n<\/ol>\n
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Clarified Expectations for the Top\u2011Down Materiality Approach<\/strong><\/h3>\n<\/li>\n<\/ol>\n
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Clarification on the Level at Which Materiality Is Assessed<\/strong><\/h3>\n<\/li>\n<\/ol>\n
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New Rules for Undertakings Managing Investments Under Fiduciary Duty<\/strong><\/h3>\n<\/li>\n<\/ol>\n
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Introduction of a New Paragraph on the Value\u2011Chain Cap<\/strong><\/h3>\n<\/li>\n<\/ol>\n
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Complete Rewrite of Section 7.7 on Omission of Information<\/strong><\/h3>\n<\/li>\n<\/ol>\n
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Additional Clarifications on Anticipated Financial Effects<\/strong><\/h3>\n<\/li>\n<\/ol>\n
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Overall Impact of the Commission\u2019s Amendments<\/strong><\/h2>\n
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ESRS\u202f1 Is Evolving – Cleerit Gets You Ready<\/strong><\/h2>\n