ESRS 1 and ESRS 2 structure under CSRD

Use the standards that apply to the reporting period under the applicable EU act and national law. Commission Delegated Regulation (EU) 2023/2772 remains the binding Set 1 source for the structure described on this page.

The Commission adopted a revised ESRS delegated act on 3 July 2026 and sent it to the European Parliament and Council for a two-month scrutiny period that can be extended by two months. Adoption by the Commission is not the same as entry into application. Do not replace a 2023 ESRS disclosure index with the revised structure until the delegated act has cleared scrutiny and its application provisions have been checked for the reporting period.

ESRS 1 does not work like a topical checklist. Its role is to explain the architecture of ESRS, the drafting conventions and fundamental concepts, and the general requirements for preparing and presenting sustainability information under the Accounting Directive as amended by CSRD.

For a reporting team, ESRS 1 is the control framework for deciding how the sustainability statement is built. It sets the logic for double materiality, the reporting undertaking and value chain, time horizons, estimates and uncertainty, prior-period errors, structure of the sustainability statement, and incorporation by reference.

ESRS 2 is the general-disclosures standard in the 2023 Set 1. It is sector-agnostic and applies across sustainability topics. It covers the reporting areas defined by ESRS 1: governance, strategy, impact, risk and opportunity management, and metrics and targets.

ESRS 2 is where a reader should find the general information needed to understand the undertaking's sustainability statement: the basis for preparation, governance arrangements, strategy and business model context, stakeholder views, material impacts, risks and opportunities, the materiality-assessment process, and the list of ESRS disclosure requirements included in the statement.

Under the 2023 Set 1, most topical disclosures depend on the undertaking's assessment of material impacts, risks, and opportunities (IROs). ESRS 2 general disclosures and the IRO-1-related requirements listed in ESRS 2 paragraph 2 are disclosed irrespective of the outcome of that assessment, subject to the phase-in provisions in ESRS 1 Appendix C.

The Commission Q&A explains the practical distinction: ESRS 2 remains mandatory for an undertaking reporting under the 2023 Set 1, while other standards and individual disclosure requirements and datapoints are generally subject to materiality. Disclosure requirements subject to materiality are not voluntary. Material information must be reported, and the process used to identify reported information falls within the CSRD assurance opinion as implemented in the applicable national law.

Connect each ESRS 2 disclosure to the ESRS 1 rule that makes it understandable, verifiable, comparable, and complete. Apply those preparation rules within the ESRS 2 and topical disclosures instead of creating a separate ESRS 1 chapter in the final statement.

The report file should let a decision owner or assurance provider trace from materiality judgment to ESRS disclosure requirement, data source, owner, control, and final report location.

A common mistake is treating ESRS 1 and ESRS 2 as two introductory pages before the topical work starts. Under the 2023 Set 1, they determine what the sustainability statement contains and how that information is prepared and presented.

Using materiality as a deletion exercise is also wrong. ESRS materiality requires a documented judgment about material matters and material information; immature data collection does not support omitting difficult information.