What do the simplified ESRS change compared with the 2023 ESRS?
Delegated Regulation (EU) 2026/1563 replaces Annexes I and II of Delegated Regulation (EU) 2023/2772 of 31 July 2023, that is, the text of the standards themselves. The twelve standards remain: ESRS 1 and ESRS 2, five environmental standards (E1 to E5), four social standards (S1 to S4) and one governance standard (G1).
According to recital 2, the revision cuts the number of datapoints, puts quantitative data ahead of narrative text and separates mandatory from voluntary datapoints more clearly. It builds on EFRAG’s technical advice, whose draft was published on 3 December 2025, and which the Commission changed on thirteen points, including greenhouse gas emissions and transition plans (recital 3). For a supplier, six differences matter:
Point | 2023 ESRS | Simplified ESRS |
|---|---|---|
GHG emissions | Disclosure Requirement E1-6: scopes 1, 2 and 3 and total emissions, with an intensity per net revenue | Disclosure Requirement E1-8: scope 1, scope 2 location-based and market-based, scope 3 per significant category; no intensity per net revenue |
Structure of ESRS E1 | E1-1 to E1-9 | E1-1 to E1-11 |
Scope 3 in the first year | Could be omitted by companies of up to 750 employees | No omission in the phase-in list (ESRS 1, paragraphs 125 to 127) |
Value chain, first three years | Metrics could leave out value-chain data, except datapoints from other EU laws (ESRS 1, paragraph 133) | Duty to explain the efforts made, the gaps and the plans to close them (ESRS 1, paragraph 123) |
Incomplete data | No general rule | Partial reporting scope allowed, except for E1-8 emissions (paragraph 91) |
Suppliers with 1,000 employees or fewer | No cap | Value-chain cap, non-EU suppliers included (paragraph 66) |
When do the simplified ESRS apply?
To financial years beginning on or after 1 January 2027, under Article 3 of the regulation; financial year 2026 is optional.
Date | Step |
|---|---|
24 February 2026 | Omnibus I Directive, (EU) 2026/470: narrower CSRD scope and value-chain cap |
3 July 2026 | Delegated Regulation (EU) 2026/1563 adopted |
21 September 2026 | Published in the Official Journal |
10 November 2026 | Entry into force |
1 January 2026 to 31 December 2026 (start of the financial year) | Choice between the amended 2023 ESRS, with or without certain reliefs, and the simplified ESRS; the version applied is stated (Article 2) |
1 January 2027 | Mandatory application; value-chain cap for the same financial years |
For a calendar-year company, the first report that must follow the simplified ESRS covers 2027 and comes out in 2028: it relies on suppliers’ 2027 data.
Who is affected by the simplified ESRS?
Directly, companies within the CSRD: more than 450 million euros of net turnover and more than 1,000 employees on average. ESRS 1 distinguishes “wave one” undertakings, which have reported since financial years 2024 to 2026, from “other undertakings”, which start in 2027 and may omit E4, S2, S3 and S4 for their first two financial years (paragraph 127).
Exporters in Morocco and across Africa
An automotive supplier in Kenitra, a fish canner in Safi or a garment maker in Nairobi does not apply the ESRS. It sits in the value chain of a customer that does, and Directive (EU) 2026/470 protects it if it had 1,000 employees or fewer on average in the previous financial year:
- Self-declaration. Your customer may rely on your own statement of headcount to treat you as a “protected undertaking”.
- Right to refuse. You may refuse any information beyond the voluntary standard; a contract clause to the contrary is not binding, and the customer must tell you what goes beyond the cap.
- Outside the EU too. Paragraph 66 of ESRS 1 expressly extends the limitation to non-EU undertakings.
- Limit. The cap covers only the sustainability report. A request under due diligence rules, for example, falls outside it.
Above 1,000 employees, no cap applies.
What will your customer ask for under ESRS E1?
Mainly data for its scope 3, the only topical metric that covers the value chain (ESRS 1, AR 38). Disclosure Requirement E1-8 requires every significant scope 3 category, and paragraph 91 does not let the customer stop at a partial scope.
To get there, it screens the 15 categories of the GHG Protocol (Scope 3 Standard of 2011, under revision) or those of ISO 14064-1:2018 (under revision, draft at stage 20.60 on iso.org on 11 November 2026). It prioritises activity-specific data that reflect the country and the technology, and verified data; it updates significant categories every year and the full inventory at least every three years (AR 24). Otherwise it may estimate, notably from spend or sector averages (paragraph 65).
Request received | Basis at the customer | Within the cap, more than 10 employees |
|---|---|---|
Total energy consumption in MWh | E1-8, scope 3 | Yes (B3) |
Location-based scope 1 and 2 | E1-8, scope 3 | Yes (B3) |
Market-based scope 2, electricity contracts | E1-8 | No |
Your own scope 3 or a product carbon footprint | E1-8, specific data (AR 24) | No |
Reduction targets and transition plan | Customer’s E1-1 and E1-6 | No |
For a company with 10 employees or fewer, Annex II of Delegated Regulation (EU) 2026/1560 does not even include energy or emissions. Each disclosure is explained in our VSME standard guide. Giving more remains possible: it is a commercial choice, and verified data are more useful to the customer than a spend-based estimate.
What should you do now?
- Before your 2026 year-end: establish your status. Work out your average headcount and prepare a protected-undertaking self-declaration.
- In the first quarter of 2027: sort the requests you receive. Three piles: within the cap, beyond the cap, other purpose (due diligence, CBAM). Our ESG and CSR overview maps which rule applies to which request.
- During financial year 2027: measure. Energy in MWh and location-based scope 1 and 2, with the source and year of every emission factor; see our ISO 14064-1 guide.
- Decide what you give beyond the cap. Market-based scope 2, scope 3, product footprint: customer by customer, in writing.
- Prepare for verification. Verified data carry more weight in your customer’s scope 3.
- At your 2027 year-end: deliver a single file. The same figures for every EU customer, ahead of their 2028 reports.
To review the questionnaires you receive, contact us.