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Across 12 modules • Updated May 9, 2026
Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
How do ESRS 1 and ESRS 2 structure CSRD reporting?

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
How do ESRS 1 and ESRS 2 structure CSRD reporting?

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
How do ESRS 1 and ESRS 2 structure CSRD reporting?

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
How do ESRS 1 and ESRS 2 structure CSRD reporting?

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
LSME and VSME under EU CSRD: what SMEs should know

What is the difference between LSME and VSME under the EU CSRD?

LSME is the listed-SME track. The CSRD amends the Accounting Directive so that small and medium-sized undertakings, except micro-undertakings, whose securities are admitted to trading on an EU regulated market are in scope for sustainability reporting. Those undertakings may limit reporting to specified SME information and report under sustainability reporting standards for small and medium-sized undertakings.

VSME is the voluntary SME track. It is aimed at SMEs that are not subject to mandatory CSRD sustainability reporting but still need a proportionate way to answer sustainability information requests from large companies, financial institutions, customers, banks, investors, or other stakeholders.

  • Use LSME analysis when the company is an SME issuer on an EU regulated market and is not a micro-undertaking.
  • Use VSME analysis when the company is outside mandatory CSRD reporting and wants a voluntary, proportionate response format for sustainability data requests.
  • Do not treat VSME as a substitute for mandatory CSRD reporting by a listed SME unless the applicable legal standard permits that result.
Citations
LSME and VSME under EU CSRD: what SMEs should know

When does the CSRD listed-SME opt-out matter?

The listed-SME opt-out matters only for SMEs in the CSRD listed-SME category. The CSRD text says that, for financial years starting before 1 January 2028, the relevant small and medium-sized public-interest undertakings may decide not to include the sustainability information in their management report.

That opt-out is not silent non-reporting. If used, the undertaking must briefly state in its management report why the sustainability reporting was not provided. A listed SME should therefore track whether it is relying on the opt-out, where the explanation appears, and when the opt-out window ends for its reporting calendar.

  • Confirm the company is a listed SME in scope and not a micro-undertaking before relying on the opt-out.
  • Record the financial year for which the opt-out is used and the management-report explanation.
  • Do not apply the listed-SME opt-out to non-listed SMEs; their issue is usually voluntary reporting or value-chain requests, not a CSRD reporting deferral.
Citations
LSME and VSME under EU CSRD: what SMEs should know

How should a non-listed SME use VSME in practice?

A non-listed SME should use VSME as a voluntary response framework, not as a new mandatory CSRD obligation. The Commission says the voluntary standard is intended to reduce administrative burden by helping SMEs respond to sustainability information requests from large companies and financial institutions that are themselves subject to mandatory CSRD reporting.

The practical use is to standardize the SME's answers, keep repeatable evidence behind them, and avoid bespoke questionnaires expanding beyond what is proportionate for an SME. The Commission also encourages large companies and financial institutions seeking sustainability information from SMEs to base requests on the voluntary standard as far as possible.

  • Map incoming sustainability questionnaires to VSME topics before creating custom answers.
  • Keep the source request, the VSME response, the evidence owner, and any unavailable-data explanation together.
  • Flag requests that appear to exceed the voluntary standard or the grounded value-chain cap context for commercial or legal review.
Citations
LSME and VSME under EU CSRD: what SMEs should know

What should teams avoid when deciding between LSME and VSME?

The main mistake is mixing the two tracks. A listed SME needs a CSRD scope and reporting analysis, including whether it can rely on the temporary opt-out and whether a proportionate listed-SME standard applies. A non-listed SME usually needs a voluntary reporting and customer-request strategy, not a statement that CSRD directly applies to it.

Teams should also avoid treating proposed or voluntary material as if it were already the same as binding CSRD reporting. The Commission's VSME Q&A says the future voluntary standard proposed under the Omnibus simplification package might differ from the current VSME Recommendation and depends on negotiations between co-legislators.

  • Do not cite VSME as mandatory CSRD reporting for every SME.
  • Do not rely on an opt-out without confirming listed-SME status and the required management-report explanation.
  • Do not promise a final LSME or future voluntary-standard position unless the current legal source supports it.
Citations
Taxonomy Article 8 KPIs under CSRD and ESRS

How do Article 8 KPIs relate to CSRD reporting?

Article 8 of the EU Taxonomy Regulation requires undertakings in the scope of the relevant Accounting Directive sustainability-reporting provisions to disclose how and to what extent their activities are associated with environmentally sustainable economic activities. For CSRD reporters, those disclosures are part of sustainability reporting rather than a separate marketing claim.

For a non-financial undertaking, the core Article 8 KPI work is to calculate and present the Taxonomy-aligned share of turnover, capital expenditure, and operating expenditure using the Taxonomy disclosure regulation and templates. The CSRD connection is that the sustainability report must include those Article 8 disclosures and, where digital reporting applies, mark them up in the required electronic format.

  • Do not treat Article 8 KPIs as ESRS materiality conclusions; they are Taxonomy disclosure outputs with prescribed KPI logic.
  • Connect the KPI file to the annual sustainability reporting process, financial statement line items, and management report review.
  • Keep the calculation basis, denominator, numerator, environmental objective breakdown, and contextual disclosures together so reviewers can trace the published percentages.
Citations
Taxonomy Article 8 KPIs under CSRD and ESRS

Are Article 8 KPIs part of ESRS?

They are related to ESRS reporting, but they are not ESRS datapoints calculated through ESRS double materiality. ESRS sets the sustainability-reporting baseline for CSRD reports, while Article 8 KPIs come from the EU Taxonomy disclosure framework and its delegated regulation.

The practical consequence is that the sustainability reporting owner should align presentation, controls, sign-off, and assurance readiness across ESRS and Article 8, but should not use ESRS materiality to omit or redesign required Article 8 KPI templates.

  • Use ESRS processes for report governance, consistency checks, and links to sustainability-statement disclosures.
  • Use the Article 8 disclosure regulation for the KPI mechanics, templates, and accompanying qualitative information.
  • Reconcile Article 8 KPI amounts to finance-owned source data before they enter the CSRD reporting package.
Citations
Taxonomy Article 8 KPIs under CSRD and ESRS

What does the Article 8 XBRL taxonomy add?

The Article 8 XBRL taxonomy is a digital representation of the Article 8 disclosure templates and related information requirements. EFRAG states that it transposes the Article 8 disclosure requirements into machine-readable format as technical support; it does not change the underlying EU Taxonomy KPI rules.

This matters for implementation because the report team needs two mappings: one from source finance and activity data into the Article 8 KPI templates, and one from the final disclosure tables and narrative context into the Article 8 XBRL taxonomy elements. The Article 8 taxonomy uses template structures, dimensions, text blocks, and KPI elements to support Inline XBRL tagging.

  • Map each reported Article 8 table or contextual disclosure to the relevant taxonomy table, text block, line item, and dimension.
  • Do not create entity-specific XBRL extensions for Article 8 disclosures where the Article 8 taxonomy is closed and provides the required elements.
  • Track corrected or revised figures separately from previously stated figures where the taxonomy structure supports reporting-scope distinctions.
Citations
Taxonomy Article 8 KPIs under CSRD and ESRS

What evidence should the reporting team keep?

Keep evidence that proves the published KPI values, not just evidence that the report was reviewed. Article 8 KPIs are percentage disclosures built from financial amounts, Taxonomy activity assessments, and template rules, so the retained file should let a decision owner or assurance provider retrace the calculation.

A useful evidence pack separates non-financial undertaking KPI material from any financial-undertaking templates. Unless the reporting entity is a financial undertaking in scope of the relevant Article 8 annexes, avoid importing green asset ratio, asset manager, investment firm, or insurance-specific detail into the page or disclosure file.

  • Entity scope conclusion showing why Article 8 disclosures are included in the CSRD sustainability reporting package.
  • Activity eligibility and alignment assessment, including environmental objective, substantial contribution, DNSH, and minimum safeguards evidence where applicable.
  • Turnover, CapEx, and OpEx numerator and denominator workpapers tied to finance source systems and financial statement references.
  • Completed Article 8 templates and contextual disclosures, with the source regulation or template version identified.
  • XBRL mapping sheet showing the Article 8 taxonomy element, table, axis or member, unit, period, and reporting-scope treatment for each tagged fact.
  • Review log for finance, sustainability, legal, and digital-reporting sign-off before publication.
Citations
Taxonomy Article 8 KPIs under CSRD and ESRS

What is the main implementation risk?

The main risk is mixing three different layers: the legal KPI obligation, the ESRS sustainability-statement process, and the XBRL tagging layer. When those layers are merged into one generic checklist, teams can publish a plausible-looking sustainability section without a traceable KPI calculation or a reliable digital-tagging map.

Keep the layers distinct: Article 8 determines the KPI content and templates, CSRD and ESRS determine the sustainability-reporting package and governance context, and the Article 8 XBRL taxonomy supports machine-readable tagging of the final disclosures.

  • Avoid unsupported claims that ESRS replaces the Article 8 KPI templates.
  • Avoid applying financial-undertaking KPI detail to non-financial undertakings unless the source rule and entity type support it.
  • Avoid treating the EFRAG Article 8 XBRL taxonomy as a new substantive rule; use it as the digital tagging map for the disclosure requirements.
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