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 remains the first set of ESRS in force. Commission Delegated Regulation (EU) 2025/1416, the Quick Fix, amended selected phase-in provisions for undertakings that had already begun reporting. The Commission adopted a replacement Annex I through C(2026) 5010 on 3 July 2026, but the Commission’s official page states that it is not in force until publication in the Official Journal. Therefore, a report authorised before entry into force cannot simply cite “revised ESRS 2026” as its legal basis.

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 once in force, 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 may reach different practical conclusions on availability, board approval and the first application period.

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.