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FAQCSRDESRS

CSRD topical ESRS scoping What must be reported after the materiality assessment

Choose the applicable ESRS version first. The 2023 standards remain in force until the revised standards adopted on 3 July 2026 complete scrutiny and enter into force.

This FAQ separates the current and revised scoping rules for , topical disclosures, omitted topics, climate, and EU-law datapoints.

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

Start by identifying the ESRS version that governs the financial year. Commission Delegated Regulation (EU) 2023/2772 remains the legally applicable Set 1 ESRS until the revised standards adopted on 3 July 2026 are published in the Official Journal and enter into force. Under the 2023 standards, applies irrespective of the topic and topical disclosures are filtered through . The adopted revision keeps double materiality but changes several scoping mechanics; it is intended to apply for financial years beginning on or after 1 January 2027, with an option for 2026 once the delegated act is in force.

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6 of 6 questions
Question 1

Does every CSRD reporter have to report every topical ESRS?

No. Under the 2023 ESRS, and the topical IRO-1 requirements listed in ESRS 2 Appendix C apply irrespective of the materiality outcome, subject to applicable phase-ins. The remaining topical disclosure requirements and datapoints are assessed for materiality. The undertaking reports material information and may omit non-material information subject to the specific IRO-2 rules.

Materiality does not make topical requirements voluntary. If a topical matter, disclosure requirement, or datapoint is material under , the undertaking must disclose the material information. The materiality assessment is also within the sustainability-statement assurance engagement.

  • Start with because its cross-cutting disclosures apply irrespective of which sustainability matter is considered.
  • Assess topical ESRS by impacts, risks, and opportunities, including both impact materiality and financial materiality.
  • When a topical matter is material, use the related ESRS disclosure requirements to identify the information to report.
  • If a material impact, risk, or opportunity is not covered or is insufficiently covered by ESRS, add an rather than leaving the matter unexplained.
Question 2

What changes under the revised ESRS adopted in July 2026?

The revised standards are not yet in force. Once applicable, they replace the 2023 ESRS 1 and scoping mechanics. They keep and require the undertaking to apply ESRS 2, then report the material information for topics or sub-topics connected to material impacts, risks, or opportunities.

The revised ESRS expressly use a two-step sequence: identify topics related to material impacts, risks, or opportunities, then determine the information to report for those topics. They allow a top-down approach from the business model, strategy, sectors, geographies, and value chain where materiality or non-materiality is evident; a more specific assessment is required where it is not evident.

  • Use the 2023 scoping rules until the revised delegated act enters into force.
  • For financial years beginning in 2026, use the revised standards only if the act is in force and the undertaking elects the option provided by the adopted act.
  • For financial years beginning on or after 1 January 2027, plan for the revised standards, subject to completion of scrutiny and entry into force.
  • Once the act is in force, Article 2 also permits the 2023 standards with the specific reliefs listed there for financial years beginning in 2026. Record the chosen option and state the version used in the sustainability statement as Article 2 requires.
Question 3

How should teams scope topical ESRS after finding a material matter?

Under the 2023 ESRS, move from the material sustainability matter to the related disclosure requirements, then to the specific datapoints needed to meet those requirements. EFRAG's implementation guidance describes this as determining material matters first and then determining material information at the more granular level of disclosure requirements or datapoints.

The assessment should cover the undertaking's own operations and upstream and downstream value chain. It should also apply objective criteria and thresholds that fit the undertaking's facts and circumstances, because ESRS does not mandate one fixed sequence of steps for the materiality assessment.

  • Identify actual and potential impacts, risks, and opportunities connected with the topic.
  • Decide whether the matter is material from the impact perspective, financial perspective, or both.
  • Map material matters to ESRS topical standards and disclosure requirements.
  • Apply materiality of information at disclosure-requirement and datapoint level so the sustainability statement includes relevant, faithful, decision-useful information.
  • Document thresholds or criteria used to determine which information is material, because IRO-2 requires an explanation of that determination.
  • Reassess the conclusion at each reporting date and sooner when acquisitions, disposals, new sectors or geographies, changed business relationships, incidents, stakeholder evidence, regulation, or other facts could change the impacts, risks or opportunities.
Question 4

What must still be disclosed when a topical ESRS is not material?

Under the 2023 ESRS, IRO-2 requires the sustainability statement to list the disclosure requirements complied with and to make understandable which topics were omitted as not material as a result of the materiality assessment.

If climate change is assessed as not material and the undertaking omits all ESRS E1 disclosure requirements, requires a detailed explanation of the materiality-assessment conclusions for climate change, including forward-looking analysis of conditions that could make climate change material in the future. For other non-material topics, the undertaking may provide a brief explanation of the materiality-assessment conclusions.

  • Provide the IRO-2 list of disclosure requirements included in the sustainability statement, with page or paragraph references.
  • Explain how material information was determined for the material impacts, risks, and opportunities that are reported.
  • For a fully omitted ESRS E1 Climate change standard, include the detailed non-materiality explanation and forward-looking analysis required by .
  • For other fully omitted topical ESRS, consider a brief explanation of the materiality-assessment conclusion so users can understand why the topic is absent.
Question 5

How do EU-law datapoints affect topical ESRS scoping?

Some ESRS datapoints correspond to information used under other EU sustainable-finance frameworks, including SFDR, benchmark, and Capital Requirements Regulation disclosures. Under the 2023 ESRS, IRO-2 requires a table of all listed in Appendix B, showing where they appear in the sustainability statement or marking them as Not material.

The revised standards adopted in July 2026 retain the table and the Not material marker but place the list in Appendix A of . In either version, silence is not enough for these listed datapoints; use the appendix that belongs to the version applied.

  • Build a content index for disclosure requirements included in the sustainability statement.
  • For the 2023 ESRS, maintain the Appendix B table for .
  • For the revised ESRS, use the replacement list in Appendix A of .
  • When a listed EU-law datapoint is not material, mark it as Not material in the table rather than omitting it.
  • Keep the basis for not-material conclusions aligned with the same materiality thresholds and criteria used for other ESRS information.
Question 6

Questions and answers

Which ESRS version should a company use for topical scoping?

Use the ESRS version legally applicable to the reporting period. Commission Delegated Regulation (EU) 2023/2772 remains in force until the revised delegated regulation adopted on 3 July 2026 is published in the Official Journal and enters into force. The adopted act provides for the revised standards to apply from financial years beginning on or after 1 January 2027 and permits their use for financial years beginning in 2026 once the act is in force. A company using the 2023 standards should follow the existing IRO-2, climate, and Appendix B rules; a company validly using the revised standards should follow the replacement ESRS 1 and instead.

Do companies in CSRD scope have to report every topical ESRS?

No. Under the 2023 ESRS, and the topical IRO-1 requirements listed in ESRS 2 Appendix C apply irrespective of the materiality outcome, subject to applicable phase-ins. The remaining topical disclosure requirements and datapoints are assessed for materiality. Material topical information must be reported, and non-material information may be omitted subject to IRO-2, the special climate explanation, and the Appendix B table. The revised standards adopted in July 2026 also apply ESRS 2 and a materiality filter, but they use replacement scoping and omitted-topic rules; do not carry the 2023 mechanics into a report using the revised version.

What happens if a topical ESRS is not material?

Under the 2023 ESRS, the undertaking may omit a non-material topical standard. If it omits all ESRS E1 climate disclosures, it must give a detailed explanation and a forward-looking analysis of conditions that could make climate material later. It may give a brief explanation for another fully omitted topical standard. Under the revised standards adopted in July 2026, IRO-2 instead requires the basis for a conclusion that climate change is not material; it does not carry forward the same detailed forward-looking explanation or the optional brief explanation for every other omitted topic.

How do Appendix B datapoints affect scoping?

Under the 2023 ESRS, IRO-2 requires a table for all listed in Appendix B, showing where each datapoint is reported or marking it as Not material. The revised standards adopted in July 2026 retain this table but move the list to Appendix A of ESRS 2. Use the appendix and paragraph numbering from the ESRS version applied to the reporting period.

Recommended next step

Review topical ESRS scoping before drafting disclosures

Use the materiality assessment, ESRS 2 IRO-2 content index, and the EU-law datapoint appendix for the applicable ESRS version to decide which disclosures belong in the sustainability statement.

Research workflow
Open Research Copilot

Check CSRD and ESRS scoping questions against cited source material.

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Talk to Sorena
Discuss CSRD and ESRS implementation

Review materiality outcomes, topical ESRS coverage, and sustainability-statement evidence with Sorena.

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Primary sources

References and citations

Commission Delegated Regulation (EU) 2023/2772
eur-lex.europa.eu5 citations
Referenced sections
  • Primary ESRS text used for ESRS 2 IRO-2, content indexes, omitted topics, climate non-materiality explanations, Appendix B datapoints, and materiality definitions.
  • Supports ESRS 2 IRO-2, the content-index requirement, omitted-topic treatment, and the definitions of materiality, impact materiality, and financial materiality.
  • Supports the requirement in ESRS 2 IRO-2 to explain how material information was determined, including thresholds and ESRS 1 materiality criteria.
Show 2 more
  • Provides the ESRS 2 IRO-2 rules for listing reported disclosure requirements, omitted topics, the special ESRS E1 climate explanation, and optional brief explanations for other omitted topical standards.
  • Supports the ESRS 2 IRO-2 Appendix B table requirement for EU-law-derived datapoints and the instruction to indicate Not material where applicable.
"Disclosure Requirements in ESRS covered by the undertaking's sustainability statement"
More quoted passages
"including the use of thresholds and/or how it has implemented the criteria"
"topics that have been omitted as not material"
"the undertaking shall indicate "Not material" in the table"
Questions and Answers on the Adoption of European Sustainability Reporting Standards
ec.europa.eu3 citations
Referenced sections
  • Commission Q&A used for the high-level rule that ESRS 2 is mandatory, other ESRS disclosures are materiality-assessed, and material disclosure requirements are not voluntary.
  • Explains that ESRS 2 is mandatory for CSRD-scope companies and that all other standards, disclosure requirements, and datapoints are subject to materiality assessment.
  • Confirms the Commission's policy explanation that a company omitting climate change as non-material has to provide a detailed explanation of its materiality-assessment conclusions.
"Disclosure requirements subject to materiality are not voluntary."
More quoted passages
"ESRS 2 is mandatory for all companies under the CSRD scope."
"climate change is not a material topic"
Revised ESRS annex adopted 3 July 2026
ec.europa.eu3 citations
Referenced sections
  • Adopted replacement standards used to explain the future materiality sequence, climate non-materiality disclosure, and the renamed EU-law datapoint appendix.
  • Adopted replacement ESRS 1 paragraphs 22 to 33 on the materiality filter, two-step scoping sequence, top-down option, and information to report.
  • Adopted replacement ESRS 2 IRO-2 and Appendix A for the EU-law datapoint table under the revised standards.
"apply ESRS 2 General Disclosures"
More quoted passages
"The undertaking determines the information to be reported in two steps"
"a table of all the datapoints that derive from other EU legislation"
ESRS implementation guidance documents
efrag.org2 citations
Referenced sections
  • EFRAG implementation-support page used for non-authoritative materiality, value-chain, and datapoint guidance that helps apply topical ESRS scoping.
  • Identifies EFRAG's non-authoritative IG 1 materiality guidance, IG 2 value-chain guidance, and IG 3 datapoint list as implementation support for ESRS scoping.
"implementation guidance documents"
More quoted passages
"non-authoritative implementation guidance"
European Commission implementing and delegated acts under CSRD
finance.ec.europa.eu2 citations
Referenced sections
  • Official status source for the revised ESRS adopted on 3 July 2026, including the fact that the act is not yet in force.
  • Official status page stating that the 3 July 2026 revised ESRS act is not in force until publication in the Official Journal.
"not in force until it is published in the Official Journal"

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