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Executive summary
The 2026 ESRS are now final text. Here is what actually changes.
The revised ESRS were published in the EU Official Journal on 21 September 2026 and enter into force on 10 November. They apply from January 2027 to companies with more than 1,000 employees and €450M in turnover.
What changes is not what you report, it is how much
- Mandatory datapoints: down 60%, from around 1,100 to 292.
- Double materiality: can now be done top-down, splitting topics into IROs, instead of analyzing IRO by IRO.
- Repeated narratives: policies, actions and targets are described once in ESRS 2, not in every topical standard.
- Moratorium: E4 (biodiversity) and S2-S4 can be skipped in your first two reporting years, for every company, not just small ones.
- Same language as the rest of the world: closer alignment with the GHG Protocol and ISSB.
Where there is no relief
- Emissions are not simplified: Scope 1, 2 and 3 stay as they are, with Scope 3's significant categories following the GHG Protocol's own Scope 3 standard. You still have to choose and justify your consolidation boundary.
- Your value chain still forces you to estimate: if suppliers under 1,000 employees cannot give you the data, you have to calculate it yourself, with a documented methodology.
- The moratorium is not free: to skip E4 or S2-S4 you need double materiality already done, and you have to justify the omission.
- Everything left standing goes to assurance: every datapoint that remains has to be traceable to its source.
The real deadline: 14 weeks, not 14 months
By 1 January 2027 you need the gap analysis (starting in October, against the 21 September text) and double materiality done, plus FY2027 budget approved. From that date you only collect what is missing. If your double materiality is already done, what changes is the datapoint count: from 783 to 292.
If you already report under ESRS, you are not starting from zero
The data you already collect for your carbon footprint (Scope 1, 2 and 3), EcoVadis, CDP, the EU Taxonomy (Article 8), your ISO certifications, PPWR or supplier risk feeds straight into CSRD. Nothing new to collect.
If your company has under 1,000 employees
Spain's Law 11/2018 still applies to you. And from 1 January 2027, the Voluntary Standard (VSME) becomes the language your large customers and your bank will ask for, even where CSRD does not apply directly. It is what stops fifteen customers sending you fifteen different questionnaires.
Dcycle reuses this same data for your carbon footprint. See it in a demo
Download the slides
Get the full presentation, with the before/after tables for every ESRS and the four scenarios depending on where you stand today.
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