Your company already generates much of the physical data ESRS needs: purchases, energy and water use, waste, fleet activity, workforce records, and supplier evidence. The cost appears when teams reconstruct those records for every reporting cycle, questionnaire, and audit, then repeat the work when the standard changes.
The European Commission has now locked in the timeline for the Delegated Act adopting simplified ESRS. The practical question is not only when to comply. It is whether your environmental data can serve operations, finance, auditors, and reporting teams without another rebuild.
What just happened
In December 2025, EFRAG delivered to the European Commission its technical advice on simplified ESRS. These standards reduce datapoints by 61% compared to the original ESRS, reorganize materiality assessment, and eliminate requirements that the market flagged as disproportionate.
The Commission confirmed it will adopt the Delegated Act before the fourth quarter of 2026. After adoption, a scrutiny period of two plus two months opens (European Parliament and Council). If nobody objects, the new standards take effect automatically, likely between late 2026 and early 2027.
Mandatory application will be for the 2027 financial year. But there is a relevant nuance: companies that want to can apply them voluntarily starting in 2026.
What this means for your company
It depends on which wave you are in and whether you remain in scope after Omnibus I.
If you are in Wave 1 (large public-interest entities, >500 employees, already reporting): You continue reporting under current ESRS for FY2025 and FY2026. The “quick fix” Delegated Act from July 2025 gives you transitional relief: you can omit E4 Biodiversity, S2 Workers in the value chain, S3 Affected communities, and S4 Consumers, even if material. But for FY2027, you will report under simplified ESRS.
If you are in Wave 2 (large companies >1,000 employees and >€450M revenue after Omnibus I): Your first mandatory reporting year is FY2027. And you will do it directly with simplified ESRS. The good news is you start with lighter standards. The bad news is you have just over a year to prepare.
If you fell out of scope (the majority Omnibus I reduced affected companies from roughly 50,000 to about 5,000): The regulation does not bind you, but your supply chain does. Your large customers who report under CSRD need scope 3 data from their suppliers. You are their supply chain. That the law does not force you to report does not mean your customers will not demand it. And if you do not provide it, your competition will.
Banks are in the same dynamic. Financial entities subject to the Taxonomy Regulation and Pillar III requirements need environmental data from the companies they finance. If you apply for financing and cannot demonstrate how you manage climate risks, the cost of credit can rise, or funding may not be available.
Then there are investment funds. ESG mandates remain active. Asset managers need comparable, reliable information to justify their investment decisions to their own regulators. That your company is not bound to report does not make it invisible to capital markets.
The timeline that matters
These are the dates you should mark:
June 2026: Formalization of the VSME standard as a reference for companies outside CSRD scope.
July 2026: ESMA registration for ESG ratings providers under the new European regulation. Italy has already delegated to its government the alignment with this regulation a signal this is serious.
Q3-Q4 2026: Commission adoption of the simplified ESRS Delegated Act plus start of the scrutiny period.
August 2026: Entry into force of the Packaging Regulation (PPWR).
Q4 2026 to Q1 2027: Entry into force of simplified ESRS.
FY2027: First year of mandatory application of the new standards.
What you cannot do: wait for the Delegated Act to organize your data
This is the error we see most often. Companies saying “when the final ESRS are published, then we will get organized.” The problem is that data collection does not happen by improvisation.
If your first mandatory reporting year is FY2027, you need your data from January through December 2027 to be consistent, comparable, and traceable. That means the collection system has to be working before the fiscal year starts, not when it ends.
The datapoints have been reduced, yes. But the double materiality structure is still there. The need for traceability is still there. And assurance which is already in the definition phase will require data to have an auditable origin.
In other words: having fewer questions does not mean the answers can be worse.
What to do now
If you are in scope (Wave 1 or Wave 2):
Review your double materiality assessment through the lens of proportionality that simplified ESRS brings. EFRAG has added flexibility to do the assessment top-down or bottom-up. Identify which datapoints disappear and which remain. Start collecting FY2026 data as if you were already applying the new standards. If you can, adopt voluntarily.
If you are out of scope but in the market:
Map what your customers and financiers are asking of you. Prepare a VSME+ package (baseline VSME expanded with the KPIs they ask for most). You do not need to do a complete CSRD report, but you need to have data ready when they ask for it. And they will ask.
Spain on its own timeline
A note on the Spanish context. The LEIS the transposition of CSRD into national law has been in Parliament since November 2024. The amendment period extended to February 2026. Since then, no visible movement. The European Commission has opened infringement procedures against Spain and seven other countries for failing to transpose on time.
Meanwhile, RD 214/2025 remains the operational obligation for Spanish companies: mandatory carbon footprint with 2025 data, five-year reduction plan, publication in 2026.
The legislative gap of the LEIS is not an excuse to do nothing. It is another reason to structure the data now. When the transposition arrives, companies with a shared environmental dataset will adjust the regulatory output. Those without one will rebuild the information from zero with the clock running.