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CSRD & ESRS sustainability reporting after the Omnibus

Covers the Corporate Sustainability Reporting Directive (CSRD) and European Sustainability Reporting Standards (ESRS) as reshaped by the stop-the-clock postponement (Directive 2025/794), Omnibus I (Directive 2026/470) and the 2026 simplified ESRS (Delegated Regulation 2026/1563, applying from financial years starting 1 January 2027), plus the related EU Taxonomy Article 8 disclosures and audit/assurance rules. Built for CFOs, CSR and sustainability managers, and statutory auditors who need precise answers on scope and timing, double materiality, mandatory disclosures, ESRS E1 climate requirements, value-chain cap phase-ins and assurance obligations for a given reporting period. Curated by Kopik from public sources: EUR-Lex / Publications Office of the European Union (reuse authorised, Decision 2011/833/EU).

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Answers are written by a language model solely from this base's documents, with numbered sources. They can be wrong and aren't legal, medical or financial advice: check the sources before any important decision.

This assistant answers precise questions on EU sustainability reporting under the CSRD and the ESRS, as reshaped by the stop-the-clock Directive (EU) 2025/794, Omnibus I (Directive (EU) 2026/470) and the simplified ESRS of Delegated Regulation (EU) 2026/1563. It is built for CFOs, sustainability managers and statutory auditors who need to know what applies to a given reporting period. Every answer is drawn from the official consolidated texts published on EUR-Lex.

Timing: stop-the-clock, the quick fix and the ESRS versions

The simplified ESRS adopted by Delegated Regulation (EU) 2026/1563 apply to financial years beginning on or after 1 January 2027. They reduce the number of datapoints, prioritise quantitative datapoints over narrative text, separate mandatory from voluntary datapoints more clearly and give clearer instructions on the materiality principle.

For financial years beginning between 1 January 2026 and 31 December 2026, undertakings already reporting may choose between the original standards (Delegated Regulation (EU) 2023/2772 as last amended by Delegated Regulation (EU) 2025/1416) and the new simplified version. Whichever they choose, they must state clearly in their sustainability statement which version they apply.

Directive (EU) 2025/794 postponed by two years the sustainability reporting requirements for undertakings and issuers that would otherwise have reported for the first time for financial years beginning in 2025 or 2026.

For undertakings already reporting for financial year 2024, Delegated Regulation (EU) 2025/1416 (the ESRS quick fix) adapted the phase-in timetable of Appendix C of ESRS 1. First-wave undertakings with more than 750 employees can now use phase-in provisions previously reserved for smaller reporters, notably for the complete topical standards ESRS E4 (biodiversity and ecosystems), S2 (workers in the value chain), S3 (affected communities) and S4 (consumers and end-users), which they may omit for the first 3 years of preparation of their sustainability statement.

An undertaking that uses these temporary exemptions for a complete topical standard must nevertheless report certain summarised information on that topic if it has concluded the topic is material (ESRS 2, paragraph 17).

The value-chain cap and the voluntary standard

Delegated Regulation (EU) 2026/1560 sets out a sustainability reporting standard for voluntary use. It serves two purposes: undertakings outside the mandatory scope can use it to report voluntarily, and it acts as a value-chain cap for reporting undertakings.

The cap protects undertakings in the value chain that do not exceed an average of 1 000 employees during the preceding financial year. A reporting undertaking may not require more information from them than the voluntary standard specifies, and those protected undertakings have a statutory right to decline anything beyond it. The cap provisions apply from financial years beginning on or after 1 January 2027.

A reporting undertaking may rely on a self-declaration of size from its suppliers or customers without verifying it, unless it knows, or can reasonably be expected to know, that the declaration is manifestly incorrect.

The cap only covers essential datapoints, listed in a dedicated annex that distinguishes between undertakings with more than 10 employees and those with 10 employees or fewer. It does not stop information being shared voluntarily, and it does not affect requests needed to comply with other Union or national law.

Value-chain information in the first reporting years

Where applicable, the sustainability reporting must contain information about the undertaking's own operations and about its value chain. For the first three years of being subject to the reporting requirements, if not all the necessary value-chain information is available, the undertaking must explain the efforts made to obtain it, the reasons why it could not be obtained and its plans to obtain it in the future.

After that three-year transition, value-chain information must come either from information obtained directly from undertakings in the value chain or from estimates, as appropriate. A reporting undertaking that reports the necessary value-chain information without asking protected undertakings for anything beyond the voluntary standard is deemed to have complied with this obligation.

Digital format and EU Taxonomy Article 8 disclosures

Undertakings in scope must prepare their management report in the single electronic reporting format of Delegated Regulation (EU) 2019/815 and, in principle, mark up their sustainability reporting, including their EU Taxonomy Article 8 disclosures. However, as amended by Omnibus I, the Accounting Directive provides that until the marking-up rules are adopted in that Delegated Regulation, undertakings are not required to mark up their sustainability reporting.

For the Taxonomy, non-financial undertakings report turnover, CapEx and OpEx KPIs under Delegated Regulation (EU) 2021/2178. They may omit assessing the eligibility or alignment of activities whose cumulative turnover or CapEx is below 10 % of the relevant KPI denominator, and they have a specific relief when OpEx is not material for their business model.

Frequently asked questions

Can we keep using the original ESRS for our 2026 report?

Yes. For financial years beginning in 2026, undertakings already subject to the standards may apply either Delegated Regulation (EU) 2023/2772 as amended by the 2025 quick fix, or the simplified 2026 ESRS. You must state in your sustainability statement which version you apply.

Do we have to XBRL-tag our sustainability statement now?

The management report must be prepared in the single electronic reporting format. The marking-up of the sustainability reporting is only required once the marking-up rules are adopted in Delegated Regulation (EU) 2019/815; until then, undertakings are not required to mark it up.

Can a supplier refuse our sustainability questionnaire?

If the supplier does not exceed an average of 1 000 employees in the preceding financial year, it is a protected undertaking. It may decline to provide information that goes beyond the voluntary standard, and you must inform it of that right when you ask for more.

Is OpEx always part of our Taxonomy assessment?

No. Where operational expenditure is not material for its business model, a non-financial undertaking may omit the eligibility and alignment assessment for OpEx, provided it discloses the total OpEx KPI denominator and explains why OpEx is not material.

Which sources does the assistant rely on?

Twelve official texts from EUR-Lex: the CSRD, the Accounting and Audit Directives in their consolidated versions, the stop-the-clock and Omnibus I Directives, the original and simplified ESRS, the quick fix, the voluntary standard and the Taxonomy Article 8 Delegated Act.

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MCP URL
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Claude Code, Cursor and other clients
Claude Code
claude mcp add --transport http kopik-eu-csrd-esrs-reporting "https://kopik.io/api/mcp?base=eu-csrd-esrs-reporting" --header "Authorization: Bearer kpk_…"
JSON config (mcpServers)
{
  "mcpServers": {
    "kopik-eu-csrd-esrs-reporting": {
      "url": "https://kopik.io/api/mcp?base=eu-csrd-esrs-reporting",
      "headers": {
        "Authorization": "Bearer kpk_…"
      }
    }
  }
}

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curl
curl -X POST https://kopik.io/api/v1/bases/eu-csrd-esrs-reporting/query \
  -H "Authorization: Bearer kpk_…" \
  -H "Content-Type: application/json" \
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