Energy invoices, fuel records, purchases and supplier evidence already give your company environmental data. The FY2026 ESRS decision determines how that information feeds a revised statement, but it also affects preparation costs, internal controls and the ability to reuse records for operational decisions.
The Commission adopted the revised ESRS delegated act on 3 July 2026, followed by publication in the Official Journal on 21 September. For companies remaining within CSRD scope, the question is which version to use and how to document the transition. The general application date is for financial years beginning on or after 1 January 2027, with an option for eligible 2026 financial years subject to the transitional provisions and the act being applicable.
Choosing a framework is not a reason to discard useful data. In Spain, common sources can also support EINF, carbon inventories, reduction plans associated with RD 214/2025, MITECO procedures and customer requests. Other jurisdictions have their own requirements. Treat the decision as one about data architecture and internal control, alongside the applicable reporting rules.
What has changed with ESRS 2.0
The Commission opened consultation on the revised delegated act on 6 May 2026, with the consultation ending on 3 June. It adopted the final act on 3 July as part of Omnibus I. The final published text now provides the reference for finance, legal, reporting and review teams; the article should no longer be read as an account of a proposal awaiting adoption.
The Commission’s announcement describes reductions of more than 60% in mandatory datapoints and more than 70% overall. The revision introduces flexibility and simplifies presentation and the application of materiality. ESMA’s regulatory overview distinguishes publication from entry into force, scheduled for 10 November 2026.
Fewer required disclosures still need complete, consistent and explainable inputs. Energy, emissions, water, waste, workforce, governance, risk and value-chain information remain spread across departments and subsidiaries. The immediate task is to select a version, record the decision and preserve comparability with information already prepared.
Fewer datapoints, not less accountability
Reduced disclosure volume may ease drafting and review, but it does not produce an equivalent reduction in data-control work. Management, an assurance provider, a bank or a customer may still need to understand a figure and its boundaries.
For each metric, retain the source, owner, period, methodology, validation and changes against the preceding year. Connect the disclosure to the underlying record and supporting evidence rather than retaining documents in isolated folders. When a requirement disappears, consider whether the record remains useful for costs, operations or another output before removing its collection process.
Double materiality remains the filter
Double materiality continues to identify relevant matters. Assess impacts on people and the environment alongside sustainability-related effects on financial position, strategy, business model and risk. A matter can be material through either perspective or both.
A more proportionate, principles-based process is not a formality. Non-materiality conclusions still need a reasoned explanation supported by available evidence. Revisit the assessment where facts or requirements change, recording why a conclusion was retained or amended. The CSRD double materiality guide sets out the documentation approach.
Physical business data is still needed
The revision does not remove electricity invoices, production records, fleet consumption, water measurements, waste information or supplier responses. A manufacturer can use one electricity record for a climate disclosure, its carbon inventory, energy-cost analysis and a customer request.
If every team collects independently, changing the standard can create additional versions instead of reducing work. Keep the unit, period, entity, source and responsible owner attached to each record. Then map the validated information to each output, checking differences in definition, calculation and perimeter. Workforce and governance information also require appropriate ownership and controls; not every disclosure is environmental data.
The FY2026 choice: apply the revision or wait for FY2027
Companies already reporting under CSRD, particularly those in Wave 1 that remain within scope, need to assess the options for their next statement. The published act and its transitional provisions determine eligibility. Early use is not an unconditional option for every company, nor does it remove national requirements.
Evaluate these 4 considerations rather than choosing solely by datapoint count:
- Financial-year timetable. Earlier use can bring presentation changes forward and prepare teams for FY2027, but requires time to implement the new mapping.
- Data readiness. Continuing the earlier framework may preserve continuity where the reporting cycle is advanced or revised controls are not yet ready.
- Review and assurance. Management, finance, legal, reporting teams and the assurance provider need a shared interpretation and work plan.
- Comparability. Explain the version selected, transitional choices, changes in disclosures and treatment of prior-period information.
Keep a decision file with the applicable text, methodology, approvals, perimeter changes and reasons for differences. This supports review under either route and prevents the reporting choice from becoming an undocumented last-minute decision.
What this means for national and group requirements
A reporting group needs to consider domestic obligations, subsidiary requirements and requests from customers and financial institutions. The Spanish reference case illustrates how one underlying dataset can serve several purposes without equating their legal requirements.
CSRD, national disclosures and Taxonomy
EINF and CSRD are different regimes but can use common sources for energy, emissions, waste, workforce, policies and evidence. Similar reuse is possible for the relevant EU Taxonomy analysis. Keep each output’s criteria and financial or operational boundaries explicit; separate legal obligations do not require unrelated versions of the same source data.
Carbon inventories and reduction plans
Records prepared for climate disclosures can support corporate carbon calculations and reduction planning. In Spain, assess RD 214/2025 and relevant MITECO requirements separately. Include Scope 1, Scope 2 and the necessary Scope 3 categories according to the intended inventory, rather than assuming one statement covers every procedure.
Customers, tenders and the value chain
Businesses outside direct reporting scope may receive customer, lender or tender requests, subject to applicable proportionality and information limits. Identify the suppliers and activities relevant to the request, distinguish confirmed data from estimates and record missing evidence. An external request should not automatically restart data collection.
6 steps to prepare the decision without rebuilding the work
Start with sources and responsibilities before reconfiguring reporting templates. These steps create a record that management and reviewers can follow as the chosen framework is implemented.
1. Confirm the corporate perimeter
List entities, subsidiaries, sites and activities included in reporting. Document acquisitions, disposals, consolidation changes and exceptions. Confirm current CSRD scope before assuming the question is only which ESRS version to apply.
2. Compare the two ESRS mappings
Map the earlier and revised requirements to actual sources. Identify removed fields, changed definitions and disclosures still relying on the same operational information. Retain a versioned crosswalk so corrections can be traced to the output affected.
3. Review double materiality
Check the reasoning, owners, sources and evidence for each material matter. If the revision changes a conclusion or required detail, record its date and rationale. Do not replace documented assessment with an assumption that simplification removes a topic.
4. Close priority data gaps
Prioritise information used in several outputs: energy, emissions, purchases, water, waste, suppliers, workforce and governance. Structured data collection can bring together ERP, operational systems, spreadsheets and questionnaires. Confirm the available connection or import workflow for each source.
5. Prepare evidence and digital structure
Retain the source, method, formula, owner and approval. Prepare identifiable records for digital reporting without assuming that publication of a taxonomy makes tagging mandatory. EFRAG explains the separate ESEF rulemaking process; check the requirements applicable to the period.
6. Align management and assurance teams
Agree the version, timetable, comparatives and outstanding work with relevant decision-makers and the assurance provider. Record approvals and unresolved interpretation issues before closing. Preserve a shared plan across finance, legal, operations and reporting teams.
Tip: Test one energy record through both mappings. Check the source, period, conversion, approval and destination disclosure before extending the approach to the full dataset.
How Dcycle helps prepare for ESRS 2.0
Dcycle is an environmental data platform for information the business already generates. Rather than rebuilding it for isolated requests, teams can structure it once for finance, operations, reviewers and reporting outputs. The platform does not act as an auditor or replace legal scope and methodology decisions.
One foundation for multiple outputs
Energy, emissions, water, waste, purchases and supplier records can support several compatible uses. Multi-framework reporting makes the mapping relevant when a standard changes: review affected requirements and reuse validated inputs rather than automatically collecting them again. Social and governance disclosures need their own appropriate information alongside environmental records.
Owners, checks and evidence
Identify owners, incomplete periods, inconsistent units and supporting documents. Maintain the distinction between confirmed information, estimates and outstanding requests to a subsidiary or supplier. An evidence trail should explain the source, calculation, approval and later changes; a platform does not guarantee acceptance by an independent reviewer.
Physical data connected to operations
Organise relevant invoices, purchases, site, fleet, energy and supplier information, checking the supported input workflow. A carbon accounting foundation can reuse activity for different calculations. The same records can help investigate consumption, prioritise supplier follow-up and evaluate costs, with savings confirmed against actual results.
Conclusion
Revised ESRS reduce mandatory disclosure volume while retaining the need for reliable records, documented double materiality and traceable evidence. The FY2026 choice must consider eligibility, readiness, comparability and review, alongside national and other reporting requirements.
Build a shared environmental data foundation before changing mappings. That allows the company to adapt its outputs while preserving useful operational information. The same controlled sources can support carbon inventories, customer requests and cost decisions, with the boundaries of each use checked separately.
Need to review your perimeter, compare both mappings or structure reusable environmental data? Explore the workflow with Dcycle.
Request a demoFrequently asked questions (FAQs)
When do the revised ESRS apply?
They generally apply to financial years beginning on or after 1 January 2027. Eligible 2026 financial years may use the revised standards under the act's transitional provisions once it is applicable. Check the reporting entity, period and legal conditions.
Can I use ESRS 2.0 for FY2026?
The act provides an option for certain financial years beginning in 2026. Confirm eligibility, applicability and transitional conditions, then agree the implementation plan with management and the assurance provider. Do not assume the option applies automatically to every company.
Does the revision remove double materiality?
No. Double materiality remains the filter for impacts, risks and opportunities relevant to reporting. A proportionate approach still requires reasoned conclusions and supporting evidence.
How does ESRS 2.0 relate to Spain's EINF?
They are different regimes with common sources, such as energy, emissions, workforce, waste, policies and evidence. Reuse information with clear boundaries, owners and methods while assessing the requirements of each regime separately.
What should a company do now?
Confirm scope, compare mappings, review double materiality, close priority gaps and agree the timetable with management and assurance teams. Identify information also needed for domestic disclosures, carbon inventories, customers and tenders.
What data should companies have ready for FY2026 ESRS reporting?
Maintain an inventory of in-scope information, sources, owners, boundaries, methods, evidence and materiality decisions. Connect environmental records with operations, suppliers, energy, materials and emissions so the selected framework can be implemented and reviewed without unnecessary recollection.
