ESRS 2023 vs Revised ESRS 2026: Which Version Should Your Company Use?

Version selection affects more than wording. It determines materiality instructions, disclosure inventory, metric definitions, phase-ins, statement structure, comparative treatment, data systems, assurance evidence and how the basis of preparation is described. A route that appears easier for the current year may create a larger redesign one year later; a route that aligns early with FY2027 may require more system change and comparative analysis now.

Figure 1. FY2026 ESRS version decision matrix and FY2027 direction. London Reporting Academy learning visual.

Commission Delegated Regulation (EU) 2023/2772 contains the first set of ESRS. Commission Delegated Regulation (EU) 2025/1416, the Quick Fix, amended selected phase-in provisions for undertakings that had already begun reporting. Commission Delegated Regulation (EU) 2026/1563 of 3 July 2026, published in the Official Journal on 21 September 2026, replaces Annex I (the ESRS) and Annex II of Delegated Regulation (EU) 2023/2772. It enters into force on 10 November 2026 and applies to financial years beginning on or after 1 January 2027 (Article 3).

Article 2 covers all financial years starting between 1 January and 31 December 2026. It does not depend on whether the year began before or after entry into force, so a calendar-year FY2026 reporter can use any of the three routes. Because a FY2026 statement is normally authorised after 10 November 2026, it can cite Regulation (EU) 2026/1563 as its basis where Route B or C is used.

The eight Route C relief areas are: ESRS 1 paragraph 27 on top-down double materiality; paragraphs 32-33 on undue cost or effort and value-chain limitations in the assessment; paragraphs 74-75 on acquisitions and disposals; paragraph 90 on metrics for non-significant activities; paragraph 91 on partial value-chain reporting scope; paragraph 92 on joint operations; paragraph 106 on a separate EU Taxonomy appendix; and paragraph 110 on an executive summary. Other revised requirements and definitions do not become available under Route C merely because they appear helpful.

Article 2 requires an undertaking using either the current/revised choice or the current-plus-reliefs route to state clearly in the sustainability statement which version it applies for the FY2026 reporting period. This is a core comparability and assurance control. The statement should identify the delegated regulation, the 2025 Quick Fix, whether the full revised standards are used and, for Route C, the specific reliefs applied.

The Quick Fix was designed for undertakings already reporting from FY2024. It extends selected phase-in reliefs for FY2025 and FY2026 so that those undertakings do not have to add information that companies entering later waves would not yet have been required to report. It does not replace the 2023 ESRS, change the main double materiality model or authorise general use of the revised 2026 wording. Route A and Route C therefore need a controlled 2023-ESRS source set with the Quick Fix incorporated.

A practical mistake is to use a clean copy of Delegated Regulation (EU) 2023/2772 and overlook the Quick Fix, or to apply the Quick Fix to an undertaking that does not meet its conditions. The disclosure applicability matrix should identify every phase-in, the eligibility basis, the year used and the supporting source.

A Route B transition can change quantitative metrics, amounts, calculation methods or boundaries. Revised ESRS 1 generally requires prior-period comparatives for quantitative metrics and amounts and, where relevant, narrative disclosures. It also provides a transition relief: wave-one undertakings do not need comparative information in their first year under the revised regulation for metrics and amounts that are not the same as those required by the 2023 ESRS. Other undertakings are not required to provide comparatives in their first ESRS reporting year.

The relief is not a reason to erase trend information that remains comparable and useful. The reporting team should classify each metric as unchanged, changed but restatable, changed and impracticable to restate, new, or no longer required. Where a comparative is revised, the company should explain the reason and the difference. Where it is unavailable under a valid relief, the basis and effect should be clear.

The delegated regulation is directly applicable from 10 November 2026, but the duty to report and the reporting level arise through the Accounting Directive as transposed. The version memorandum should therefore include the national legal basis, the financial year start date, whether the undertaking is reporting under an individual or consolidated duty, and any regulator or filing guidance. A calendar-year group and an entity with a 1 July year start both fall under Article 2 for the year beginning in 2026, but their authorisation dates and first mandatory revised-ESRS year differ (financial years beginning 1 January 2027 and 1 July 2027 respectively).

Where a group operates across Member States, the parent’s consolidated statement version does not automatically resolve every subsidiary’s local obligation, exemption citation or filing requirement. Legal and company-secretariat teams should confirm that the version statement, management report and assurance opinion use compatible legal references.