Sustainability
Revised ESRS: settle the reporting approach before rebuilding the data
Reporting scope, entry into force and the first applicable financial year are separate questions.
Adopted regulation · Entry into force on 10 November 2026
Source development: 21 September 2026
What changed
Commission Delegated Regulation (EU) 2026/1563 was published on 21 September 2026. Article 3 provides for entry into force on 10 November 2026 and application to financial years beginning on or after 1 January 2027. Article 2 provides transitional choices for financial years starting in 2026, including use of the revised standards or specified reliefs with the earlier standards. Undertakings must state which version they use. This is an October preparation note on an adopted September measure, not a new October obligation.
Why it matters
Our interpretation is that reporting teams should settle the applicable basis before altering questionnaires, data systems and assurance preparation. A change to reporting standards does not itself determine whether a particular company is within the statutory reporting population. The relevant company and group circumstances still need to be checked.
The management decision
Confirm the reporting entity, its financial year and the applicable legal scope. For a 2026 reporting exercise, assess the available transitional approach with the reporting and assurance teams. Then map existing data collection to that choice, retain clear ownership of material information and explain any changes to the people supplying it. Avoid rebuilding a system around a draft or a mixture of standard versions.
Our view
Treat simplification as an opportunity to improve the reporting process. Start with the information that supports a defensible statement and useful management decisions. For a business outside mandatory scope, establish the customer or lender need before commissioning a statutory-style reporting programme.