On May 6 the European Commission published the final draft of the Delegated Act revising the ESRS. What EFRAG had estimated as a 70% cut now has concrete figures: a 61% reduction in mandatory datapoints (from the original 1,073). The public consultation is open until June 3. If your company is already reporting under ESRS, you have a decision to make before year end.
What just happened
The ESRS simplification process had been running for a year. Omnibus I entered into force on March 18, 2026 and required the Commission to adopt a simplified Delegated Act before September 18. EFRAG delivered its technical advice on December 3, 2025. On May 6, the Commission published its final draft and opened a four-week consultation.
The published figures are essentially final, pending minor adjustments:
- Mandatory datapoints: a 61% cut (from the original 1,073).
- Total datapoints: -70%+ (all voluntary ones disappear).
- Estimated reporting cost: -30% per company. The Commission projects 3.7 billion euros in cumulative savings over five years, rising to 4.7 billion when value chain effects are included.
If the Commission adopts the Delegated Act in June or July (which looks likely), it then enters a two to four month scrutiny period by the Parliament and Council. Publication in the OJEU is expected in Q3-Q4 2026. Mandatory application from FY2027.
And here is the interesting part: companies already reporting under the original ESRS can apply the simplified version voluntarily for FY2026.
ESRS 2.0 timeline
| Date | Milestone |
|---|---|
| 3 Dec 2025 | EFRAG delivers its technical advice to the Commission |
| 18 Mar 2026 | Omnibus I enters into force |
| 6 May 2026 | Commission publishes the final draft Delegated Act |
| 3 Jun 2026 | Public consultation closes |
| Jun-Jul 2026 | Expected adoption of the Delegated Act |
| 18 Sep 2026 | Legal deadline for adoption (6 months from Omnibus) |
| Q3-Q4 2026 | Publication in the OJEU after scrutiny (2-4 months) |
| FY2026 | Voluntary application possible for companies already reporting |
| FY2027 | Mandatory application for everyone |
The 5 technical changes that matter
1. Datapoints: fewer and reorganized
It is not just that there is less data. What remains is more focused on the quantitative: emissions, energy, water, waste, workforce, governance. A lot of narrative that did not add verifiable value is removed.
If your company already collects solid data on carbon footprint, workforce, and consumption, most of your work remains valid. What likely disappears are the long narrative sections and the voluntary datapoints you were collecting “just in case”.
2. Simplified double materiality
It remains central, but the process becomes more flexible. Companies can use a top-down approach: reaching conclusions at the topic level without having to justify each individual datapoint. This significantly reduces the burden of the DMA (Double Materiality Assessment) that used to consume so many hours.
The “shall not report non-material information” principle is reinforced. If something is not material, you do not report it. Period.
3. Limited assurance stays, reasonable is dropped
The planned transition to reasonable assurance (the verification level equivalent to financial statements) is dropped. Limited assurance is kept, significantly reducing audit costs.
For your finance team, this is good news. For the Big 4 auditors who had already sized their ESG teams assuming reasonable assurance, not so much.
4. Microplastics and human rights: reduced scope
Two examples of the “less narrative, more verifiable data” approach:
- Microplastics: only primary microplastics are reported (microbeads, glitter in cosmetics). Secondary ones (those from the degradation of larger plastics) are out of scope.
- Human rights: only “substantiated” cases and “ongoing” procedures. The obligation to report unfounded allegations or closed cases is removed.
5. Voluntary standard for companies under 1,000 employees
In parallel, the Commission published a second draft: the voluntary standard for companies that fell out of scope after the Omnibus. It is based on VSME and also works as a “value chain cap”: a large company cannot request from a small supplier more information than this standard covers.
If you are a supplier to a large company, this gives you leverage. If you are a large company requesting data from your value chain, you have to adapt your questionnaires.
The decision: do you adopt ESRS 2.0 for FY2026?
This is what we get asked the most these days, and the answer is not automatic. It depends on three things: how mature your systems are, whether your auditor is aligned, and how solid your original DMA was.
| Factor | Adopt voluntarily for FY2026 | Wait for FY2027 |
|---|---|---|
| Systems and processes | Data infrastructure already in place | Still in your first reporting cycle |
| Auditor | Aligned and available to coordinate before June | No clear call yet |
| Original DMA | Solid, can be reused with fewer datapoints | Weak. The new top-down approach forces a redo |
| Signal to investors | ESG management maturity | Consolidate the first cycle before moving |
| Maintenance burden | Drops significantly | You carry the original ESRS load for 12 more months |
What NOT to do
- Stop collecting data. Fewer mandatory datapoints does not mean stakeholders ask for less. Investors, customers, and banks still ask the same things: emissions by scope, intensity, targets, physical and transition risks.
- Assume the simplified version is “less serious”. It remains mandatory reporting with external verification. Double materiality is still central. The cut is in burden, not in rigor.
- Leave the decision for September. By September the Commission will have adopted the final text and scrutiny will be underway. If you want to apply it to FY2026, your team needs to be ready earlier.
What to do this week
- Read the draft. It is on the Commission’s Have Your Say portal until June 3. If your company has a position on any technical aspect, this is the window.
- Review your current datapoint map. How many of the ones you collect remain in the new framework? Which stay? Which were voluntary that you can stop collecting?
- Talk to your auditor. Bring three options: (a) stay on the original ESRS for FY2026 keeping the quick fix, (b) adopt ESRS 2.0 voluntarily for FY2026, (c) wait for FY2027. Let them tell you which is cleanest.
- Look at your DMA critically. The new top-down approach allows you to rethink materiality more strategically. If your original DMA was reactive, this is the chance.
- Prepare the conversation with leadership. The board will ask. Bring the numbers: 61% fewer datapoints, 30% lower cost, voluntary decision before year end.
Where Dcycle fits
The operational problem for the next 12 months is that you will have two regimes running in parallel: the original ESRS (if you do not adopt voluntarily or are still closing FY2025) and ESRS 2.0 (if you move early or once FY2027 arrives). Your data system has to support both.
Dcycle connects your physical data (purchases, suppliers, workforce, fleet, energy, water, waste) once and automatically maps it to any framework you need: original ESRS, ESRS 2.0, VSME, GHG Protocol, EU Taxonomy. When the standard changes, you do not redo the collection: only the mapping is updated.
If your team is reworking the plan because of the May 6 publication, let’s talk. For additional context on the process, check our CSRD collection or the supported frameworks.