The ESRS are Final: The Time for Action Starts Now

From regulatory uncertainty to business action and value creation

22 September 2026

Mountain

For the last two years, organisations have been navigating uncertainty around the future of sustainability reporting in Europe. Reporting deadlines shifted, requirements were revised, and the focus often remained on what might change.

That period is now over. With the revised European Sustainability Reporting Standards (ESRS) final, organisations have 12 to 18 months to move from regulatory uncertainty to business action.

The final standards provide regulatory certainty and an important opportunity to view ESRS as more than a compliance exercise. The question is no longer what the rules will look like, but how organisations will use this time to identify and understand their most significant impacts, risks and opportunities, strengthen resilience, prioritise investment, improve decision-making and identify new opportunities for growth.

For many businesses, preparation will still be treated primarily as a reporting requirement. But the organisations getting the most from sustainability reporting are using the process to focus on the issues that matter most and connect disclosure with better business decisions.

The framework now confirmed gives organisations a structured way to understand the sustainability issues that could shape future business performance.

The opportunity now is to use that clarity to prepare with purpose.

Applying the standards: focus on what matters most

The ESRS remain grounded in the double materiality concept. This requires organisations to assess both their impacts on people and the environment and the sustainability-related risks and opportunities facing the business, through a Double Materiality Assessment (DMA) following the methodology set out in ESRS 1.

Applied well, this process can help answer critical business questions:

  • Where are the most significant risks and opportunities across the value chain?
  • Which issues could affect future growth and profitability?
  • Where is the business most exposed to disruption?
  • How resilient is the business model?
  • What information do leaders need to make better decisions?

This is where sustainability reporting connects directly to business performance: revealing opportunities to strengthen resilience, improve operational performance, prioritise investment and support innovation.

The revised ESRS may simplify reporting requirements, but they do not reduce the strategic importance of this work. If anything, they create a clearer pathway to focus effort where it can create the greatest value.

“Organisations that combine a robust double materiality assessment with rigorous alignment to the revised ESRS can turn compliance into competitive advantage, focusing resources on the initiatives that drive resilience, performance and long-term value“
Sandrine Le Biavant, Director

What has changed?

The good news is that the final standards reinforce this shift, reducing reporting complexity and sharpening focus onto the issues that matter most to business performance.

Key changes include:

  • A new top-down approach to determining topic materiality, with additional guidance on how existing prevention, mitigation and remediation actions influence the assessment
  • Greater reliance on professional judgement and qualitative assessment where materiality or immateriality is evident
  • No requirement for exhaustive value chain analysis, companies now focus on where impacts are most likely to occur
  • A significant reduction in datapoints, including mandatory datapoints cut by approximately 61% and all non-mandatory datapoints removed
  • Greater interoperability with IFRS Sustainability Disclosure Standards and the Greenhouse Gas Protocol
  • Greater emphasis on information materiality, allowing companies to focus on disclosures that are genuinely useful for investor and stakeholder decision-making rather than applying a complex datapoint-by-datapoint assessment
  • A clearer structure of reporting requirements
  • Greater flexibility in how information is presented, including appendices and cross-references to reduce duplication
  • Removal of expanded reporting on acquisitions, joint ventures and equity investments

The intent is clear: focus organisations on reporting what matters most.

Turning ESRS preparation into business value

Most large EU companies have already completed a double materiality assessment, assessed readiness against the original ESRS, and potentially begun mapping datapoints. But with the ESRS now finalised, including some significant changes, and with a year or more likely having passed since that work was done, this is a good point to revisit it, this time through a value creation lens.

To produce a meaningful and robust report, and get the most out of the process, organisations should begin implementing the following phases now:

  • Regulatory scoping – confirm applicability of the Corporate Sustainability Reporting Directive (CSRD) and the EU Taxonomy, and consider reporting strategy, including boundaries and consolidation options
  • Double materiality assessment – revisit existing materiality processes and results in light of the revised ESRS, ensuring alignment with current business impacts, risks and opportunities and identification of topics that are going to create measurable and lasting value
  • Gap and readiness assessment – check existing assessments against the revised ESRS to understand organisational maturity, identify priority gaps and determine where effort will have the greatest impact
  • Data governance – assess data availability, KPI calculation methodology, governance and reporting capability against the revised ESRS requirements, datapoints and assurance expectations, and use the opportunity to build efficient, repeatable processes that provide decision-useful insights beyond reporting
  • Implementation of policies and processes – address identified gaps, strengthen governance and embed sustainability considerations into business planning, decision-making and performance management
  • Reporting strategy – define what to report, when to report it and how to communicate information in a way that supports compliance while delivering meaningful insights to internal and external stakeholders

These steps should make full use of the available reliefs while ensuring robust and fair presentation. Practical actions include data collection, mock or dry-run reporting to test content development against the maturity of the data and processes, assurance preparation, and report copywriting and design.

“The biggest misconception we see is that simplification means preparation can wait. Most implementation challenges are not created by disclosure requirements. They’re created by governance, ownership and data availability. Those challenges remain “
Chris Shaw, Technical Director

Why this matters: beyond compliance. The opportunity now to unlock hidden value.

The next competitive divide will be between organisations that see ESRS purely as a compliance obligation and those that use it to improve how they identify risks, allocate capital, prioritise investment and build resilience.

Accessing that hidden value successfully requires more than reporting expertise. It requires connecting sustainability, finance, risk, operations and communications across the business.

Anthesis brings together:

  • End-to-end support from regulatory scoping, readiness assessment and double materiality through to reporting, action planning and activation
  • More than 1,300 sustainability experts across climate, decarbonisation, nature, human rights, supply chains and sustainable finance, bringing deep technical and sector expertise to inform practical recommendations tailored to each organisation’s specific risks and opportunities
  • A value-led approach that helps organisations identify where sustainability priorities can deliver the greatest benefit for both the business and wider stakeholders, strengthening the case for investment and action
  • Practical implementation experience that extends beyond disclosure into business transformation
  • Independence from audit-related constraints, enabling hands-on support throughout the process
  • In-house communications and reporting specialists who build stakeholder buy-in, articulate the business case for action and maximise the value of the reporting journey

Anthesis’s role is not simply to help clients publish compliant reports. It is to help them use sustainability reporting to make better decisions, strengthen resilience, uncover opportunity and create long-term business value.

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