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ESRS 1 and ESRS 2 structure for CSRD reporting

ESRS 1 explains the reporting architecture and materiality rules. ESRS 2 sets the general disclosures that companies use across material sustainability matters.

Use this page to understand how cross-cutting ESRS, topical ESRS, materiality, policies, actions, metrics, and targets fit together. ESRS 2 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
May 9, 2026
Questions
4

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

Under CSRD reporting, ESRS 1 and ESRS 2 are the cross-cutting layer of the European Sustainability Reporting Standards. ESRS 1 does not create topic-by-topic disclosure tables by itself; it explains the architecture, concepts, and general requirements. ESRS 2 contains the general disclosure requirements that structure governance, strategy, impact, risk and opportunity management, and metrics and targets.

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4 of 4 questions
Question 1

What is the difference between ESRS 1 and ESRS 2?

ESRS 1 is the rulebook for how to read and apply the ESRS set. It explains the categories of standards, double materiality, value-chain reporting, time horizons, presentation of the sustainability statement, and concepts such as impacts, risks and opportunities.

ESRS 2 is the general disclosure standard. It tells an undertaking what information to provide at a general level across material sustainability matters, including governance, strategy, the process for identifying and assessing impacts, risks and opportunities, and the minimum disclosure requirements for policies, actions, metrics, and targets.

  • Use ESRS 1 to decide the reporting architecture, materiality approach, value-chain boundaries, disclosure structure, and whether entity-specific disclosures are needed.
  • Use ESRS 2 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 ESRS 1 as a topic standard; it explains how the standards operate rather than listing climate, workforce, pollution, or business-conduct datapoints.
Citations
Question 2

How do cross-cutting and topical ESRS work together?

The ESRS architecture has three categories: cross-cutting standards, topical standards, and sector-specific standards. ESRS 1 and ESRS 2 are the cross-cutting standards and apply across the sustainability matters covered by topical and sector-specific standards.

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

  • Cross-cutting layer: ESRS 1 supplies concepts and application rules; ESRS 2 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, ESRS 1 requires additional entity-specific disclosure.
Citations
Question 3

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

Materiality is the starting point for ESRS reporting. ESRS uses double materiality: 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.

Materiality does not make ESRS 2 optional. ESRS 1 states that the undertaking always discloses the information required by ESRS 2 General Disclosures, regardless of the outcome of the materiality assessment. When a topical sustainability matter is material, the undertaking then applies the relevant topical or sector-specific disclosure requirements and the ESRS 2 minimum disclosure requirements connected to policies, actions, metrics, and targets.

  • ESRS 2 IRO-1 explains the process used to identify and assess material impacts, risks, and opportunities.
  • ESRS 2 SBM-3 explains the material impacts, risks, and opportunities resulting from the assessment and their interaction with strategy and business model.
  • ESRS 2 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.
Citations
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.

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Answer CSRD and ESRS implementation questions with cited source material.

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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 ESRS 1 and ESRS 2 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. ESRS 2 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 ESRS 2 general disclosures that must be addressed in the sustainability statement.
  • 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 ESRS 2 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 entity-specific disclosure 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.
Citations
Primary sources

References and citations

ESRS implementation guidance documents
efrag.org
Referenced sections
  • Supports use of EFRAG implementation guidance for materiality, value chain, and ESRS datapoint mapping.
"Detailed ESRS Datapoints"
European sustainability reporting standards (ESRS)
xbrl.efrag.org
Referenced sections
  • Supports the disclosure map: reporting areas, datapoints, minimum disclosure requirements, and entity-specific disclosure logic.
"policies, actions, metrics and targets"
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