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CSRDData modelEU

ESRS structure and data model

Build a reporting inventory that connects ESRS standards, disclosure requirements, datapoints, materiality conclusions, owners, evidence, and digital tags.

This page is for teams turning the ESRS legal text into a controlled data model for CSRD reporting, assurance, and later machine-readable filing.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
6 sections7 primary sources
Overview

Build the from the standards that legally apply to the reporting period, not from a spreadsheet template. Under 2023 ESRS Set 1, ESRS 1 sets general requirements, ESRS 2 sets general disclosures, and topical standards add environmental, social, and governance disclosures based on materiality. The Commission adopted revised ESRS on 3 July 2026, but they are not in force until Official Journal publication. Keep each standards version separate and link every reportable datapoint to its source paragraph, materiality status, owner, evidence, and digital-tagging readiness treatment.

Section 1

How the ESRS architecture drives the data model

The 2023 ESRS Set 1 architecture has 12 standards: two cross-cutting standards, five environmental standards, four social standards, and one governance standard. ESRS 1 contains general requirements and does not itself set disclosure requirements. ESRS 2 contains general disclosures and is reported irrespective of the outcome of the materiality assessment.

For the data model, treat ESRS 1 as the rulebook for concepts such as double materiality, reporting boundaries, value-chain information, time horizons, and presentation. Treat ESRS 2 and topical standards as disclosure modules that can produce reportable data points, narrative text, metrics, policies, actions, targets, and cross-references tied to material impacts, risks, and opportunities (IROs).

  • Create a versioned standards table with ESRS 1, ESRS 2, E1 to E5, S1 to S4, and G1 as separate 2023 Set 1 modules; do not overwrite them with the 3 July 2026 Commission-adopted text before that text applies.
  • Mark ESRS 2 as always applicable for companies in CSRD scope; do not run it through the topical materiality filter.
  • For each topical standard, store the materiality conclusion while keeping the IRO-1-linked requirements listed in ESRS 2 Appendix C outside the topical materiality filter, subject to applicable phase-ins.
  • Keep ESRS 1 concepts in reference tables, because they affect many disclosures but are not disclosure requirements in the same way as ESRS 2 or topical standards.
  • Model ESRS 2 cross-cutting disclosures separately from topical disclosures that extend ESRS 2 concepts such as impacts, risks, opportunities, strategy, governance, policies, actions, metrics, and targets.
Recommended next step

Turn the ESRS inventory into a controlled reporting workflow

This ESRS data-model guide helps connect disclosure requirements, owners, evidence, materiality decisions, and tagging metadata before CSRD report drafting starts.

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Open Research Copilot for CSRD and ESRS

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Section 2

Disclosure requirements, datapoints, and materiality

EFRAG IG 3 is useful for building a human-readable inventory for the 2023 ESRS, but it is neither the binding standard nor the digital XBRL taxonomy. EFRAG states that its current IG 1 to 3 relate to the ESRS adopted in 2023 and will not be updated for the simplified ESRS before their adoption. Version the inventory so guidance for one ESRS set is not applied silently to another.

Use the IG 3 structure as a control inventory: standard, disclosure requirement, paragraph, datapoint text, data type, phase-in field where relevant, materiality status, source system, owner, evidence, and report location. The inventory should distinguish mandatory ESRS 2 and IRO-1 datapoints from datapoints that become reportable only when the topic is material.

  • Store the exact ESRS reference for every datapoint, including standard, disclosure requirement, paragraph, and application requirement where applicable.
  • Classify each datapoint as narrative, semi-narrative, numeric, monetary, percentage, Boolean (yes/no), enumeration (a choice from predefined values), date, or other controlled type.
  • Record whether the datapoint is always reported, subject to materiality, voluntary, or subject to a phase-in provision identified in the ESRS inventory.
  • Keep the materiality decision and the datapoint response separate: a non-material topic should not silently erase a required explanation or table where ESRS requires one.
  • For EU-law-linked datapoints listed in ESRS 2 Appendix B, preserve a field for the report location or the explicit not-material statement.
Section 3

How to structure the internal ESRS data tables

A maintainable should separate requirement metadata, reporting judgments, source data, evidence, and publication output. Combining all of those into one collection spreadsheet makes assurance and digital tagging harder because the same field is asked to serve legal interpretation, workflow control, and report production at the same time.

Use stable identifiers that can survive report drafting changes. The paragraph reference and taxonomy concept are not the same thing: a paragraph reference anchors the legal requirement, while a taxonomy concept or dimension anchors machine-readable tagging. Keep both, and allow many-to-many relationships where one narrative disclosure maps to several tags or one tag is reused across related disclosures.

  • Requirement table: ESRS standard, disclosure requirement, paragraph, application requirement, datapoint text, source URL, and status.
  • Materiality table: sustainability matter, impact-risk-opportunity record, assessment conclusion, rationale, approver, and review date.
  • Response table: datapoint identifier, answer value, unit, period, boundary, assumptions, estimation method, and source system.
  • Evidence table: source document, calculation file, supplier input, control check, reviewer, version, and link to the datapoint response.
  • Report-location table: sustainability statement section, cross-reference, page or anchor, narrative owner, and publication status.
  • Digital-tag table: XBRL element, axis or dimension, member, period type, unit, scale, fact value, and tagging review status.
Section 4

XBRL taxonomy, ESEF, and tagging boundaries

Do not treat the IG 3 datapoint workbook as the machine-readable taxonomy. EFRAG developed an ESRS Set 1 XBRL taxonomy and a separate Article 8 taxonomy, while ESMA develops the regulatory technical standards for ESEF. ESMA states that undertakings are not required to mark up sustainability reporting until the relevant rules are adopted by delegated regulation.

Design the human-readable sustainability statement so it can be tagged later, but keep a separate readiness layer. It can capture XBRL concepts, dimensions, units, period type, scale, proposed hidden facts, and review status without forcing report writers to draft in taxonomy order or presenting proposed treatments as current filing law.

  • Use the ESRS XBRL taxonomy to prepare tagging metadata, not to rewrite the legal meaning of ESRS disclosures.
  • Keep narrative disclosures granular enough to avoid excessive Inline XBRL continuations, while preserving readable report flow.
  • Track instant versus duration period type, because XBRL context dates differ for end-of-period facts and reporting-period facts.
  • Store units and scale explicitly for numeric facts such as energy, water, GHG emissions, monetary values, and intensity metrics.
  • Do not use EFRAG illustrative XBRL reports as filing templates; treat them as technical illustrations unless an adopted rule says otherwise.
Section 5

Article 8 Taxonomy data belongs in the same report, but a separate model

Future CSRD sustainability markup is intended to cover sustainability reporting and Article 8 EU Taxonomy disclosures. EFRAG's Article 8 XBRL Taxonomy translates Article 8 disclosure requirements into a machine-readable technical model; it does not define their legal content or, by itself, create a current tagging duty.

Model Article 8 data as its own sub-ledger. It uses different concepts from ESRS topics: economic activities, eligibility, alignment, turnover, capital expenditure (CapEx), operating expenditure (OpEx), environmental objectives, do-no-significant-harm (DNSH) criteria, minimum safeguards, financial-undertaking templates, and nuclear or fossil gas templates where relevant. Then connect the Article 8 outputs to the sustainability statement and digital-tag review.

  • Separate ESRS materiality records from Article 8 eligibility and alignment calculations.
  • Store turnover, CapEx, and OpEx KPI denominators, numerators, accounting policies, and financial-statement line-item references.
  • Use controlled lists for environmental objectives, enabling or transitional categories, DNSH criteria, and minimum safeguards outcomes.
  • Keep row identifiers for repeated economic activities when the same activity appears with different values or objectives.
  • Review Article 8 tagging with the same controls as ESRS tagging, but do not merge the legal source tables.
Section 6

Implementation checks before report drafting

The data model is ready for report drafting when the company can trace each applicable disclosure from the correct ESRS version to the materiality conclusion, owner, evidence, and report location. Keep tagging readiness linked but non-blocking until a legal markup requirement applies; missing legal-source, ownership, evidence, or report-location fields should stop publication review.

Deciding what is material, collecting the data, and deciding how the disclosure will be tagged require separate review decisions. Keep those decisions linked but distinct so assurance reviewers and digital reporting specialists can test them independently.

  • Every ESRS 2 disclosure has an owner, evidence source, and draft report location.
  • Every topical datapoint has a materiality status and, if active, a response owner and source system.
  • Every value-chain estimate records the method, boundary, data source, and limitations.
  • Every numeric datapoint records unit, scale, period, consolidation boundary, and review status.
  • Every narrative datapoint records the source paragraph, drafting owner, evidence, and XBRL tagging granularity expectation.
  • Every Article 8 KPI records denominator, numerator, economic activity, objective, and financial-statement linkage.
  • Every public source used in the report can be traced without relying on private files, unpublished working notes, or unsupported interpretations.
Primary sources

References and citations

ESRS Set 1 XBRL Taxonomy - Explanatory Note and Basis for Conclusions
xbrl.efrag.org5 citations
Referenced sections
  • Technical source for ESRS Set 1 XBRL taxonomy design, dimensions, narrative tagging, Article 8 interaction, and ESMA tagging-rule boundaries.
  • Supports separating ESRS concepts, XBRL elements, dimensions, fact values, period type, units, scale, and narrative tagging considerations.
  • Supports the distinction between EFRAG taxonomy development and ESMA tagging rules, plus the need for a separate tagging layer.
Show 2 more
  • Supports that Article 8 disclosures are provided within the sustainability statement and tagged through the digital reporting process.
  • Supports retaining traceable tagging metadata for quantitative, qualitative, narrative, and dimensional ESRS disclosures.
"The taxonomy consists of a set of XBRL elements"
More quoted passages
"ESMA will define the tagging rules"
"The information disclosed under Article 8"
"identify, navigate and extract digital disclosures"
ESRS implementation guidance documents
efrag.org4 citations
Referenced sections
  • Identifies EFRAG IG 3 and related implementation guidance as non-authoritative support for preparing ESRS datapoint inventories.
  • Confirms EFRAG's IG 3 datapoints workbook and explanatory note as non-authoritative implementation support for ESRS.
  • Supports use of EFRAG implementation guidance as reporting preparation support rather than as a substitute for ESRS.
Show 1 more
  • Supports using IG 3 to prepare structured human-readable statements while not treating it as the digital taxonomy.
"IG 3 List of Datapoints as an Excel Workbook"
More quoted passages
"These documents are non-authoritative and support implementation."
"EFRAG IG3: Detailed ESRS Datapoints"
Commission Delegated Regulation (EU) 2023/2772
data.europa.eu3 citations
Referenced sections
  • Legal source for the adopted sector-agnostic ESRS used for CSRD sustainability reporting.
  • Adopts the sector-agnostic ESRS and sets the legal standards used for CSRD sustainability reporting.
  • Supports basing report requirements on the adopted ESRS legal text.
"sustainability reporting standards"
More quoted passages
"The sustainability reporting standards that undertakings are to use"
"This Regulation shall be binding in its entirety"
Questions and Answers on the Adoption of European Sustainability Reporting Standards
ec.europa.eu3 citations
Referenced sections
  • Explains ESRS architecture, double materiality, ESRS 2 mandatory status, and treatment of materiality-subject disclosures.
  • Supports the 12-standard ESRS architecture, ESRS 1 role, ESRS 2 mandatory status, and materiality approach for other standards.
  • Supports the distinction between materiality-subject disclosures, mandatory ESRS 2, and explicit treatment of SFDR, BMR, and CRR-linked datapoints.
"The ESRS take a double materiality perspective"
More quoted passages
"ESRS 2 is mandatory for all companies under the CSRD scope."
"Disclosure requirements subject to materiality are not voluntary."
Article 8 XBRL Taxonomy - Explanatory Note and Basis for Conclusions
xbrl.efrag.org2 citations
Referenced sections
  • Technical source for modelling Article 8 EU Taxonomy disclosures separately from ESRS disclosure requirements while preparing machine-readable reporting.
  • Supports treating Article 8 disclosures as a separate machine-readable taxonomy and data model inside the sustainability statement.
"Article 8 disclosure requirements into a machine-readable format"
More quoted passages
"transposing the Article 8 disclosure requirements into a machine-readable format"
CSRD implementing and delegated acts
finance.ec.europa.eu
Referenced sections
  • Confirms that the revised ESRS adopted by the Commission on 3 July 2026 are not in force until Official Journal publication.
ESMA electronic reporting overview
esma.europa.eu
Referenced sections
  • Confirms that sustainability reporting markup is not required until the relevant delegated regulation adopts the rules.

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