European Commission Launches Consultations on Draft Delegated Regulations for Revised ESRSs and Voluntary Sustainability Reporting Standard

On May 6, 2026, the European Commission (EC) published for public comment a draft delegated act that proposes changes to Delegated Regulation (EU) 2023/2772 to simplify the European Sustainability Reporting Standards (ESRSs). Concurrently, the EC launched a consultation on a draft voluntary reporting standard for smaller entities that are not within the scope of the Corporate Sustainability Reporting Directive (CSRD). Comments on both draft delegated acts are due by June 3, 2026.

In December 2025, in response to a March 2025 request, EFRAG submitted to the EC technical advice on the simplification of the ESRSs. (For additional details on the technical advice, see Deloitte’s January 14, 2026, Heads Up.) In the draft delegated act for revised ESRSs, the EC has made the following targeted modifications to EFRAG's technical advice to provide further clarity and flexibility related to certain provisions:

• Materiality and materiality assessment:
  • Entities would not be expected to meet individual users’ information needs.
  • The goal of the standards would be to ensure reporting of decision-useful information.
  • The term “informed assessment” would be clearly defined and entities would not be required to report immaterial information, “except in certain clearly defined circumstances.”
  • A provision would be added to emphasize that the “top-down” approach to assessing materiality allows entities “to avoid unnecessary work and in general to avoid assessing the materiality of each individual impact, risk or opportunity.”
• Fair presentation:
  • The principle of “fair presentation” would be clarified as applying to the sustainability statement as a whole rather than to each individual data point.
  • There would be clarification that “the application of ESRS results in fair presentation.”
• Level of aggregation and disaggregation:
  • Entities would be allowed to use greater discretion when considering “specific geographical contexts” as part of the materiality assessment.
  • The level of disaggregation related to the materiality assessment would not necessarily be the same as that required for reporting information.
• Omission of information: New provisions from the Omnibus I Directive have been incorporated to allow the omission of certain information in certain circumstances (e.g., information that could be “seriously prejuducial to the commercial position of the undertaking”).
• Anticipated financial effects:
  • Estimates will most likely be used to report anticipated financial effects, and a change in such estimates because of the availability of new information would not constitute a reporting “error.”
  • The provision to omit certain information because it could be “seriously prejudicial to the commercial position of the undertaking” also applies to reporting on anticipated financial effects.
• Reporting boundary for greenhouse gas (GHG) emissions: The proposal would be aligned with global sustainability reporting standards in that it would allow entities to use one of the approaches prescribed in the GHG Protocol “when defining the reporting boundary to be applied”: (1) the financial control approach or (2) the operational control approach.
• Climate transition plans: Entities would be required to provide transparent disclosures when they report transition plans involving targets that are not compatible with the 1.5°C target.
• Microplastics: The disclosure requirements related to microplastics would be limited to primary microplastics; metrics for secondary microplastics would not be required.
• Emission of pollutants: The determination of which pollutants are material for reporting purposes should be made on the basis of a managerial assessment.
• Substances of very high concern: Entities that use products containing “substances of very high concern” would be given a one-year phase-in period for reporting on such substances.
• Alignment with the Corporate Sustainability Due Diligence Directive (CSDDD): Technical revisions related to due diligence would be incorporated to better align with the CSDDD.
• Human rights incidents and incidents of discrimination: Only “substantiated” incidents would need to be reported.
• Asset management activities: New provisions would be introduced under which entities that perform asset management activities would not be required to report irrelevant information about the investments they manage.

The draft voluntary sustainability reporting standard is intended to support voluntary sustainability reporting for entities not within the scope of the CSRD. In addition, the voluntary standard establishes a “value-chain cap” that limits the information in‑scope CSRD reporting entities may request from value-chain entities that are not within the scope of the CSRD. That is, entities within the scope of the CSRD cannot require value-chain entities that are not within the CSRD’s scope to provide information beyond that described in the voluntary standard.

The delegated acts are expected to be adopted soon after the consultation closes. After adoption, the delegated acts will be subject to a two- to four-month period of scrutiny by the European Parliament and the Council of the EU before becoming effective. The revised ESRSs would apply to financial years beginning on or after January 1, 2027. Entities subject to sustainability reporting requirements for financial year 2026 would have the option of applying the revised ESRSs to reporting for financial year 2026. The voluntary standard would be effective beginning in financial year 2027 for the value-chain reporting of entities within the scope of the CSRD, irrespective of the option to apply the revised ESRSs for financial year 2026 on a voluntary basis. For entities not within the scope of the CSRD that wish to report on a voluntary basis, the new standard will be effective upon the date the directive is entered into force.

For more information, see the press release on the EC’s Web site.