---
title: "ESRS 1 and ESRS 2 structure under CSRD"
canonical_url: "https://www.sorena.io/artifacts/eu/corporate-sustainability-reporting-directive/esrs-1-and-esrs-2-structure"
source_url: "https://www.sorena.io/artifacts/eu/corporate-sustainability-reporting-directive/esrs-1-and-esrs-2-structure"
author: "Sorena AI"
description: "A grounded explanation of how ESRS 1 sets the reporting architecture and how ESRS 2 provides the mandatory general disclosures for CSRD sustainability statements."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "CSRD"
  - "ESRS"
  - "ESRS 1"
  - "ESRS 2"
  - "general requirements"
  - "general disclosures"
  - "double materiality"
  - "sustainability statement"
---
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---

# ESRS 1 and ESRS 2 structure under CSRD

A grounded explanation of how ESRS 1 sets the reporting architecture and how ESRS 2 provides the mandatory general disclosures for CSRD sustainability statements.

*CSRD* *ESRS structure* *EU*

## ESRS 1 and ESRS 2 structure under CSRD

ESRS 1 is the architecture for preparing the sustainability statement. ESRS 2 is the cross-cutting set of general disclosures that companies in CSRD scope must use across sustainability matters.

Use this page to separate general requirements, general disclosures, materiality-driven topical disclosures, and the evidence needed to make the statement readable and reviewable.

ESRS 1 and ESRS 2 are the two cross-cutting ESRS standards. ESRS 1 explains how the standards work: categories of standards, double materiality, value-chain coverage, time horizons, presentation of the sustainability statement, incorporation by reference, and qualitative characteristics of information. ESRS 2 contains the general disclosure requirements for governance, strategy, impact, risk and opportunity management, and metrics and targets.

## What ESRS 1 does

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.

- Use ESRS 1 to define how material impacts, risks and opportunities are identified and how material information is selected.
- Use ESRS 1 to decide whether disclosures belong in the dedicated sustainability statement, whether information can be incorporated by reference, and how the statement remains human-readable and machine-readable.
- Use ESRS 1 Appendix D as the structural anchor: general information, environmental information, social information, and governance information.
- Do not treat ESRS 1 as a data-point list; the Commission explains that ESRS 1 sets general principles and does not itself set specific disclosure requirements.

Sources for this answer:

- [European sustainability reporting standards (ESRS)](https://xbrl.efrag.org/e-esrs/esrs-set1-2023.html?ref=sorena.io) - Supports the description of ESRS 1 as the standard for ESRS architecture, drafting conventions, fundamental concepts, and general presentation requirements.
- [Questions and Answers on the Adoption of European Sustainability Reporting Standards](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_4043?ref=sorena.io) - Supports the distinction that ESRS 1 sets general principles and does not itself set specific disclosure requirements.

## What ESRS 2 does

ESRS 2 is the general-disclosures standard. It applies regardless of sector and 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.

- BP-1 and BP-2 explain the basis for preparation and specific circumstances, including value-chain coverage, estimates, changes, errors, and incorporation by reference.
- GOV disclosures explain the role of administrative, management and supervisory bodies, sustainability information flows, incentives, due diligence mapping, and reporting controls.
- SBM disclosures explain strategy, business model, value chain, stakeholder interests, and how material impacts, risks and opportunities interact with strategy and business model.
- IRO-1 and IRO-2 explain how material impacts, risks and opportunities are identified and which ESRS disclosure requirements are covered by the sustainability statement.
- Minimum Disclosure Requirements in ESRS 2 apply when the undertaking reports policies, actions, metrics, or targets for material sustainability matters.

Sources for this answer:

- [European sustainability reporting standards (ESRS)](https://xbrl.efrag.org/e-esrs/esrs-set1-2023.html?ref=sorena.io) - Supports the ESRS 2 scope across sector-agnostic, cross-cutting disclosure areas and the listed ESRS 2 disclosure families.
- [Questions and Answers on the Adoption of European Sustainability Reporting Standards](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_4043?ref=sorena.io) - Supports the point that ESRS 2 specifies essential general information and is mandatory for companies under CSRD scope.

## How materiality changes the rest of the statement

The relationship between ESRS 1 and ESRS 2 matters because most topical disclosures depend on the undertaking's materiality assessment, while ESRS 2 general disclosures and specified IRO-1-related topical requirements are disclosed irrespective of the outcome of that assessment.

The Commission Q&A explains the practical distinction: ESRS 2 remains mandatory, while the other standards and individual disclosure requirements and datapoints are generally subject to materiality. That does not make material disclosures optional. If the information is material, it must be reported, and the materiality assessment process is itself subject to external assurance under the Accounting Directive.

- Start with the ESRS 1 double-materiality criteria and document the impact-materiality and financial-materiality judgments.
- Use ESRS 2 IRO-1 to disclose the process, including methodologies, assumptions, scope, inputs, thresholds, controls, and changes from the prior period.
- Use ESRS 2 IRO-2 to show which disclosure requirements are included and where they appear in the sustainability statement.
- If a topic is not material, do not fill the report with boilerplate; explain omissions where ESRS requires or permits that explanation, including the specific climate-change explanation rule for ESRS E1.
- If a material impact, risk or opportunity is not covered, or is not sufficiently covered, by topical ESRS, prepare entity-specific disclosure rather than forcing it into an unrelated topical standard.

Sources for this answer:

- [European sustainability reporting standards (ESRS)](https://xbrl.efrag.org/e-esrs/esrs-set1-2023.html?ref=sorena.io) - Supports the rule that ESRS 2 general disclosures and IRO-1-linked topical requirements are reported irrespective of the materiality-assessment outcome.
- [Questions and Answers on the Adoption of European Sustainability Reporting Standards](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_4043?ref=sorena.io) - Supports the explanation that ESRS uses double materiality and that material disclosure requirements must be reported when relevant.

## How to use the ESRS 1 and ESRS 2 structure in a report file

A useful report file should connect each ESRS 2 disclosure to the ESRS 1 rule that makes the disclosure understandable, verifiable, comparable, and complete. The point is not to create a separate ESRS 1 chapter in the final statement; it is to make the ESRS 2 and topical disclosures follow the ESRS 1 preparation rules.

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.

- Create an ESRS 2 content index with each BP, GOV, SBM, IRO, and MDR disclosure, its report location, source system, evidence owner, and review status.
- Maintain a materiality register showing each sustainability matter considered, impact and financial materiality rationale, thresholds used, and the ESRS disclosure consequence.
- Keep a value-chain data log for metrics using upstream or downstream information, including whether estimates, sector-average data, or proxies were used and how accuracy will be improved.
- Keep a presentation checklist for the sustainability statement structure: dedicated management-report section, ESRS-required information distinguished from other information, and clear links when information is incorporated by reference.
- Keep a change-and-error log for revised metrics, changed preparation methods, prior-period errors, and comparative information that cannot practicably be restated.

Sources for this answer:

- [European sustainability reporting standards (ESRS)](https://xbrl.efrag.org/e-esrs/esrs-set1-2023.html?ref=sorena.io) - Supports the evidence guidance for content indexes, value-chain estimates, changes in presentation, prior-period errors, and incorporation by reference.

*Recommended next step*

*Placement: after evidence section*

## Build an ESRS 2 content index

Use the ESRS 1 rules to make each ESRS 2 disclosure traceable to materiality judgments, data sources, report locations, owners, and review evidence.

- [Open Research Copilot](/solutions/research-copilot.md): Check ESRS structure questions against cited source material.
- [Discuss CSRD implementation](/contact.md): Review ESRS 1 preparation rules, ESRS 2 disclosure structure, and evidence gaps with Sorena.

## Common structure mistakes

The most common mistake is treating ESRS 1 and ESRS 2 as two introductory pages before the real topical work starts. Under ESRS, they are the logic that determines what the whole sustainability statement contains and how a reader can trust it.

Another mistake is using materiality as a deletion exercise. ESRS materiality requires a documented judgment about material matters and material information; it does not support omitting difficult information simply because the data collection is immature.

- Do not publish generic ESRS 2 governance or strategy text that is not specific to the undertaking's bodies, business model, value chain, stakeholders, and material impacts, risks and opportunities.
- Do not report topical metrics without the ESRS 2 IRO-1 explanation of how the underlying impacts, risks and opportunities were identified and assessed.
- Do not mix ESRS-required information with extra framework or investor information without clearly identifying the external legislation, standard, or framework used.
- Do not use incorporation by reference if it makes the sustainability statement harder to read or breaks the link between a disclosure requirement and its supporting information.
- Do not treat ESRS 1 as optional background; its qualitative characteristics, structure rules, materiality logic, and value-chain provisions affect every ESRS 2 and topical disclosure.

Sources for this answer:

- [European sustainability reporting standards (ESRS)](https://xbrl.efrag.org/e-esrs/esrs-set1-2023.html?ref=sorena.io) - Supports the warnings about boilerplate, unclear incorporation by reference, and the need for coherent, understandable sustainability disclosures.
- [Questions and Answers on the Adoption of European Sustainability Reporting Standards](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_4043?ref=sorena.io) - Supports the point that common ESRS are intended to produce comparable and reliable sustainability information, not disconnected generic narrative.

## Primary sources

- [European sustainability reporting standards (ESRS)](https://xbrl.efrag.org/e-esrs/esrs-set1-2023.html?ref=sorena.io) - Primary source for ESRS 1 General Requirements, ESRS 2 General Disclosures, the sustainability-statement structure, and disclosure requirement mechanics.
  - Quote: "ESRS 1 General requirements and ESRS 2 General disclosures"
- [Questions and Answers on the Adoption of European Sustainability Reporting Standards](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_4043?ref=sorena.io) - Commission explanation of ESRS adoption, the double-materiality approach, ESRS 1 as general principles, and ESRS 2 as mandatory general disclosures for CSRD-scope companies.
  - Quote: "ESRS 2 is mandatory for all companies under the CSRD scope"

## Related Topic Guides

- [CSRD and ESRS Compliance Obligations](/artifacts/eu/corporate-sustainability-reporting-directive/compliance.md): Grounded CSRD and ESRS compliance guide covering scope checks, sustainability statements, double materiality, value-chain data, assurance, and digital tagging.
- [CSRD and ESRS FAQ: scope, materiality, assurance, tagging, and value chain](/artifacts/eu/corporate-sustainability-reporting-directive/faq.md): CSRD and ESRS FAQ hub covering company scope, reporting waves, ESRS structure, double materiality, assurance, digital tagging, Taxonomy Article 8, and value chain data.
- [CSRD and ESRS Reporting Checklist](/artifacts/eu/corporate-sustainability-reporting-directive/checklist.md): A practical CSRD and ESRS checklist for confirming reporting scope, sustainability statement content, double materiality, value-chain evidence, assurance readiness, and digital tagging.
- [CSRD and ESRS requirements: scope, reporting, assurance, and evidence](/artifacts/eu/corporate-sustainability-reporting-directive/requirements.md): Grounded guide to CSRD and ESRS requirements: who reports, what the sustainability statement must cover, double materiality, value-chain data, assurance, publication, digital tagging, and controls.
- [CSRD and ESRS value-chain data, estimates, proxies, and evidence](/artifacts/eu/corporate-sustainability-reporting-directive/value-chain-data-and-estimation.md): How to handle ESRS value-chain information when supplier or customer data is incomplete: reasonable efforts, estimates, limitations, controls, and assurance evidence.
- [CSRD Applicability Test for EU and Non-EU Company Groups](/artifacts/eu/corporate-sustainability-reporting-directive/applicability-test.md): Check whether CSRD and ESRS reporting may apply by testing undertaking size, listed status, group reporting, non-EU branches or subsidiaries, and phase-in evidence.
- [CSRD Article 40a third-country group reporting FAQ](/artifacts/eu/corporate-sustainability-reporting-directive/faq/third-country-groups.md): FAQ on when CSRD Article 40a applies to third-country groups, which EU subsidiary or branch publishes the report, and what happens with assurance and missing information.
- [CSRD assurance and ESRS digital tagging evidence](/artifacts/eu/corporate-sustainability-reporting-directive/assurance-and-digital-tagging-evidence.md): Evidence checklist for CSRD assurance readiness, ESRS datapoint traceability, and digital tagging preparation under the ESRS XBRL and ESEF reporting framework.
- [CSRD assurance evidence FAQ: what to keep for limited assurance](/artifacts/eu/corporate-sustainability-reporting-directive/faq/assurance-evidence.md): What CSRD and ESRS assurance evidence should support: management-report publication, the assurance report, national assurance procedures, and EU limited assurance milestones.
- [CSRD assurance evidence pack workflow for ESRS reporting](/artifacts/eu/corporate-sustainability-reporting-directive/assurance-evidence-pack-workflow.md): A CSRD and ESRS workflow for building an assurance-ready evidence pack covering scope, double materiality, ESRS datapoints, controls, estimates, and digital tagging.
- [CSRD assurance-ready controls and evidence for ESRS reporting](/artifacts/eu/corporate-sustainability-reporting-directive/assurance-ready-controls-and-evidence.md): Build CSRD and ESRS evidence around GOV-5 controls, double materiality, IROs, value-chain data, assurance files, and XBRL tagging checks.
- [CSRD data point inventory FAQ for ESRS disclosure readiness](/artifacts/eu/corporate-sustainability-reporting-directive/faq/data-point-inventory.md): How to build an ESRS data point inventory for CSRD reporting: disclosure requirements, materiality filters, evidence ownership, value-chain data, XBRL readiness, and assurance support.
- [CSRD deadlines and ESRS compliance calendar](/artifacts/eu/corporate-sustainability-reporting-directive/deadlines-and-compliance-calendar.md): A grounded CSRD and ESRS calendar covering the original reporting waves, enacted postponement caveats, publication duties, assurance, and digital reporting workstreams.
- [CSRD digital tagging and XBRL readiness FAQ](/artifacts/eu/corporate-sustainability-reporting-directive/faq/digital-tagging-xbrl.md): What CSRD teams should do now about XHTML, Inline XBRL, ESRS taxonomy materials, tagging controls, and limits before final digital taxonomy rules apply.
- [CSRD Double Materiality Interview Question Bank for ESRS](/artifacts/eu/corporate-sustainability-reporting-directive/double-materiality-interview-question-bank.md): Interview prompts for ESRS double materiality work: context, affected stakeholders, value chain IROs, impact materiality, financial materiality, thresholds, and evidence.
- [CSRD double materiality method under ESRS](/artifacts/eu/corporate-sustainability-reporting-directive/double-materiality-method.md): A grounded method for ESRS double materiality assessment: impact materiality, financial materiality, value-chain coverage, thresholds, evidence, and documentation.
- [CSRD double materiality scoring: IRO assessment and ESRS data points](/artifacts/eu/corporate-sustainability-reporting-directive/double-materiality-scoring.md): A grounded scoring guide for CSRD and ESRS double materiality: impact materiality, financial materiality, thresholds, evidence, governance, and disclosure mapping.
- [CSRD Double Materiality Workflow for ESRS Assessment](/artifacts/eu/corporate-sustainability-reporting-directive/double-materiality-workflow.md): A CSRD and ESRS workflow for running a double materiality assessment, from value-chain scoping and stakeholder inputs to IRO scoring, governance approval, and audit trail evidence.
- [CSRD omnibus stop-the-clock status: enacted delay vs proposed scope changes](/artifacts/eu/corporate-sustainability-reporting-directive/faq/omnibus-stop-the-clock-status.md): FAQ on the CSRD stop-the-clock directive, the separate Omnibus proposal, and how reporting teams should treat enacted and proposed changes.
- [CSRD penalties and fines: Member State enforcement, controls, and evidence](/artifacts/eu/corporate-sustainability-reporting-directive/penalties-and-fines.md): A conservative guide to CSRD penalty exposure: why fines depend on Member State implementation, which reporting failures create risk, and what evidence teams should keep.
- [CSRD reporting waves and Omnibus status](/artifacts/eu/corporate-sustainability-reporting-directive/reporting-waves-and-omnibus-status.md): Track what is enacted, postponed, final, or still in the Omnibus process for CSRD reporting waves, ESRS reporting, and Stop-the-Clock changes.
- [CSRD reporting waves FAQ: who reports first and what changed](/artifacts/eu/corporate-sustainability-reporting-directive/faq/reporting-waves.md): FAQ on original CSRD reporting waves, stop-the-clock caveats, listed SME opt-out, third-country reporting, and why local transposition law still matters.
- [CSRD scope and phasing by company type](/artifacts/eu/corporate-sustainability-reporting-directive/scope-and-phasing-by-company-type.md): Map CSRD reporting scope by company category, original Article 5 wave, listed SME opt-out, third-country group rules, and stop-the-clock caveats.
- [CSRD topical ESRS scoping: what must be reported?](/artifacts/eu/corporate-sustainability-reporting-directive/faq/topical-esrs-scoping.md): FAQ on CSRD topical ESRS scoping: ESRS 2, double materiality, topical disclosure requirements, omitted topics, climate, and Appendix B datapoints.
- [CSRD value chain data and estimation methodology under ESRS](/artifacts/eu/corporate-sustainability-reporting-directive/value-chain-estimates.md): How ESRS lets CSRD reporters use sector averages, proxies, and other estimates when direct value-chain data is not available after reasonable effort.
- [CSRD vs CSDDD: Reporting vs Due Diligence](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-csddd.md): Compare CSRD sustainability reporting with CSDDD human rights and environmental due diligence, including scope, evidence, assurance, penalties, and overlap.
- [CSRD vs EU Taxonomy Article 8](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-taxonomy-alignment.md): Compare CSRD and ESRS sustainability reporting with EU Taxonomy Article 8 KPI disclosures, including scope, evidence, tagging, and reuse limits.
- [CSRD vs GRI: ESRS Interoperability](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-gri.md): Compare CSRD/ESRS reporting with GRI-based reporting using grounded ESRS interoperability, materiality, value-chain, and disclosure-reuse rules.
- [CSRD vs IFRS S1 and S2 Comparison](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-ifrs-s1-and-s2.md): Compare CSRD and ESRS with IFRS S1 and S2 across scope, materiality, disclosures, value chain reporting, assurance, digital tagging, and interoperability.
- [CSRD vs SEC Climate Disclosure Rule](/artifacts/eu/corporate-sustainability-reporting-directive/csrd-vs-sec-climate-disclosure-rule.md): Grounded comparison notes for CSRD and the SEC climate disclosure rule, focused on CSRD and ESRS duties and conservative limits where SEC facts are not sourced.
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- [FAQ: CSRD double materiality scoring — thresholds, weighting, and evidence](/artifacts/eu/corporate-sustainability-reporting-directive/faq/double-materiality-scoring.md): How to score CSRD double materiality under ESRS without invented thresholds: impact materiality, financial materiality, evidence, and documentation.
- [FAQ: CSRD value chain estimates — methods and proportionality under ESRS](/artifacts/eu/corporate-sustainability-reporting-directive/faq/value-chain-estimates.md): When ESRS permits value chain estimates, what to disclose about assumptions, accuracy, limits, and improvement plans.
- [How do ESRS 1 and ESRS 2 structure CSRD reporting?](/artifacts/eu/corporate-sustainability-reporting-directive/faq/esrs-1-and-2-structure.md): FAQ explaining how ESRS 1 general requirements and ESRS 2 general disclosures fit into CSRD reporting, materiality, and topical ESRS disclosures.
- [LSME and VSME under EU CSRD: what SMEs should know](/artifacts/eu/corporate-sustainability-reporting-directive/faq/lsme-and-vsme.md): FAQ on LSME and VSME under the EU CSRD: listed SME reporting, the temporary opt-out, voluntary SME reporting, and value-chain requests.
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