Client Alert: EU Finalizes Simplified ESRS for 2027

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Your 2027 data is your 2028 Report.

The EU has finalized its simplified sustainability reporting standards. Commission Delegated Regulation (EU) 2026/1563 was published on September 21, replacing the existing ESRS annexes, and enters into force on November 10, 2026. The revised standards cut mandatory datapoints by over 60%.  

Who is affected 

EU Companies

EU companies and non-EU issuers with more than 1,000 employees on average and over 450 million in net turnover remain in CSRD scope. The first CSRD reports are expected in 2028 and should cover FY 2027.  

Non-EU companies

Non-EU companies exceeding 450 million(euros) net turnover generated in the EU and having at least one EU subsidiary or branch with over 200 million(euros) net turnover will report under ESRS-40a (currently in draft, anticipated to be published January 2027), with first reports due in 2029, expected to cover FY 2028.   

Why 2027 matters 

The revised ESRS applies to financial years beginning with January 1, 2027. The first report comes in 2028, but the data behind it starts on January 1. First-time reporters don’t need prior-year comparatives in year one, but FY 2027 data become the baseline. Emissions, workforce, and value chain data need consistent methods, boundaries, and controls from the start of the year.  

Relief for first-time reporters: 

  • No comparative information is required in the first reporting year. 

  • Biodiversity (E5) and the value chain workers, affected communities, and consumers standards (S2 to S4) can be omitted for the first two years. 

  • Most anticipated financial effects are also phased in over two to four years. 

Value Chain Requests 

Starting in FY 2027, in-scope companies cannot require value chain partners with an average of 1,000 employees or fewer, including non-EU suppliers, to provide information beyond the short list of essential ESG data points in Annex II of the EU’s Voluntary Standard (Delegated Regulation (EU 2026/1560). Supplier data requests for 2027 should be designed around this limit. 

Companies already reporting (FY 2026) 

Companies already reporting under the existing ESRS may choose between: 

  1. The existing ESRS 

  2. The ESRS, supplemented by eight specific reliefs from the revised standards 

  3. The Revised ESRS in full 

Companies must state in their sustainability statement which version they applied.  

How KERAMIDA is helping companies with CSRD readiness 

  1. Confirming whether your organization is in scope under the new thresholds. 

  2. Performing and refreshing Double Materiality Assessments against the revised standards. 

  3. Collecting, managing, and mapping data against EFRAG’s revised list of data points with a Gap Assessment and Implementation Roadmap. 

  4. Supporting companies in closing gaps in the Roadmap with additional sustainability services such as GHG Inventories, ESG training, etc.