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FAQCSRDEU

ESRS 1 and ESRS 2 structure for CSRD reporting

explains the reporting architecture and materiality rules. sets the general disclosures that companies use across material sustainability matters.

This page helps understand how cross-cutting ESRS, topical ESRS, materiality, policies, actions, metrics, and targets fit together. uses shorthand labels such as BP (basis for preparation), GOV (governance), SBM (strategy, business model and value chain), IRO (impact, risk and opportunity management), and MDR (minimum disclosure requirements).

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
4 sections5 primary sources
Overview

is the cross-cutting standard that sets the concepts and general requirements for preparing an ESRS sustainability statement. is the cross-cutting standard containing general disclosures on preparation, governance, strategy, impacts, risks and opportunities, and metrics and targets. This page describes the 2023 ESRS adopted in Regulation (EU) 2023/2772. The Commission adopted revised ESRS on 3 July 2026, but they remain under Parliament and Council scrutiny, so preparers should confirm which version applies to their reporting year.

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4 of 4 questions
Question 1

What is the difference between ESRS 1 and ESRS 2?

In the 2023 ESRS, explains how to read and apply the standards. It covers the categories of standards, , value-chain reporting, time horizons, presentation of the sustainability statement, and concepts such as impacts, risks and opportunities.

In the 2023 ESRS, tells an undertaking what general information to provide, including governance, strategy, the process for identifying and assessing impacts, risks and opportunities, and minimum disclosure requirements for policies, actions, metrics, and targets.

  • Use to decide the reporting architecture, materiality approach, value-chain boundaries, disclosure structure, and whether entity-specific disclosures are needed.
  • Use to prepare the cross-cutting disclosures that sit across the sustainability statement, including basis for preparation (BP), governance (GOV), strategy, business model and value chain (SBM), impact, risk and opportunity management (IRO), and minimum disclosure requirements (MDR) disclosures.
  • Do not treat as a topic standard; it explains how the standards operate rather than listing climate, workforce, pollution, or business-conduct datapoints.
Question 2

How do cross-cutting and topical ESRS work together?

The 2023 ESRS text describes cross-cutting, topical and sector-specific categories. The adopted Set 1 contains cross-cutting and topical standards. Directive (EU) 2026/470 deleted the Commission empowerment to adopt sector-specific ESRS, so the historical category is not a separate current reporting checklist.

Topical ESRS cover environmental, social, and governance topics. They add topic-specific disclosure requirements and may also include requirements that are applied together with general disclosures. When a sustainability matter is material, the undertaking looks to the relevant topical ESRS and then applies the ESRS 2 minimum disclosure requirements for policies, actions, metrics, and targets where applicable.

  • Cross-cutting layer: supplies concepts and application rules; supplies general disclosures.
  • Topical layer: E1 to E5, S1 to S4, and G1 supply subject-specific disclosure requirements for material matters.
  • Entity-specific layer: if a material impact, risk, or opportunity is not covered, or is not covered with enough granularity, requires an .
Question 3

What does materiality change in the ESRS 1 and ESRS 2 structure?

Materiality is the starting point for ESRS reporting. ESRS uses : a sustainability matter is material if it meets the criteria for impact materiality, financial materiality, or both. The assessment covers impacts, risks, and opportunities in the undertaking's own operations and upstream and downstream value chain.

Under the 2023 ESRS, materiality does not make optional. paragraph 29 also requires the topical IRO-1 disclosures listed in ESRS 2 Appendix C irrespective of the materiality outcome, subject to applicable phase-ins. When a topical sustainability matter is material, the undertaking then applies the relevant topical disclosure requirements and the ESRS 2 minimum disclosure requirements connected to policies, actions, metrics, and targets.

  • IRO-1 explains the process used to identify and assess material impacts, risks, and opportunities.
  • SBM-3 explains the material impacts, risks, and opportunities resulting from the assessment and their interaction with strategy and business model.
  • IRO-2 identifies which ESRS disclosure requirements are covered by the sustainability statement.
  • For metrics, ESRS allows omission of information assessed as not material when the omission still meets the objective of the relevant disclosure requirement.
Recommended next step

Map ESRS 2 disclosures to material topics

Use the ESRS 1 and ESRS 2 structure to separate cross-cutting disclosures, topical requirements, materiality judgments, and evidence before drafting the CSRD sustainability statement.

Research workflow
Open Research Copilot

Answer CSRD and ESRS implementation questions with cited source material.

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Talk to Sorena
Discuss ESRS reporting structure

Review materiality, ESRS 2 disclosure mapping, and evidence gaps with Sorena.

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Question 4

What should a company map before drafting ESRS disclosures?

A useful and map starts with architecture, not with a list of copied datapoints. The reporting team should know which cross-cutting disclosures are always in scope, which topical matters are material, which value-chain impacts, risks, and opportunities are included, and where entity-specific disclosures are needed.

The map should also separate policies, actions, metrics, and targets. contains minimum disclosure requirements for those categories, and topical standards can add topic-specific detail. This prevents teams from treating a target, a policy, and a metric as interchangeable evidence.

  • List all general disclosures required by the ESRS version applicable to the reporting year.
  • Record the materiality conclusion for each relevant sustainability matter, including impact and financial materiality considerations.
  • For each material matter, connect the topical ESRS requirements to MDR-P, MDR-A, MDR-M, and MDR-T - the minimum disclosure requirements for policies, actions, metrics, and targets - where they apply.
  • Flag any material impact, risk, or opportunity that needs because the standards do not cover it with enough granularity.
  • Keep evidence for the criteria, thresholds, judgments, and source references used in the materiality assessment and disclosure map.
  • Assign an owner and review date to each conclusion. Reassess the map when the reporting perimeter, business model, sectors, geographies, value chain, material impacts, risks or opportunities, or applicable ESRS version changes.
Primary sources

References and citations

European sustainability reporting standards (ESRS)
xbrl.efrag.org5 citations
Referenced sections
  • Primary ESRS source for ESRS 1 general requirements, ESRS 2 general disclosures, reporting areas, materiality, topical standards, and datapoints.
  • Supports the distinction between ESRS 1 as the general requirements standard and ESRS 2 as the general disclosures standard.
  • Supports the three ESRS categories and the relationship between cross-cutting, topical, sector-specific, and entity-specific disclosures.
Show 2 more
  • Supports the double materiality rule, the always-disclosed ESRS 2 layer, and the link between material matters and topical standards.
  • Supports the disclosure map: reporting areas, datapoints, minimum disclosure requirements, and entity-specific disclosure logic.
"ESRS 2 General disclosures"
More quoted passages
"ESRS 1 General requirements"
"cross-cutting standards"
"Double materiality"
"policies, actions, metrics and targets"
ESRS implementation guidance documents
efrag.org3 citations
Referenced sections
  • EFRAG page for non-authoritative implementation guidance relating to the 2023 ESRS, including materiality assessment, value chain, and datapoint guidance.
  • Identifies EFRAG's non-authoritative implementation guidance, including IG 1 Materiality Assessment, as support for applying the ESRS materiality approach.
  • Supports use of EFRAG implementation guidance for materiality, value chain, and ESRS datapoint mapping.
"non-authoritative and support implementation"
More quoted passages
"IG 1 Materiality Assessment"
"Detailed ESRS Datapoints"
Questions and Answers on the Adoption of European Sustainability Reporting Standards
ec.europa.eu3 citations
Referenced sections
  • Commission Q&A explaining ESRS adoption, double materiality, mandatory ESRS 2 general disclosures, and materiality for other standards.
  • Explains that ESRS 1 sets general principles and ESRS 2 specifies essential information to be disclosed.
  • Supports the explanation that other standards and their datapoints are generally subject to materiality assessment, unlike ESRS 2.
"double materiality"
More quoted passages
"ESRS 2 is mandatory"
"subject to a materiality assessment"
Commission adopts revised sustainability reporting standards
finance.ec.europa.eu2 citations
Referenced sections
  • Confirms that revised ESRS were adopted on 3 July 2026 but remain subject to Parliament and Council scrutiny.
  • Confirms adoption of revised ESRS on 3 July 2026 and the remaining Parliament and Council scrutiny period.
"The revised ESRS and the voluntary reporting standard will now be submitted to the European Parliament and the Council for scrutiny."

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