The ESRS system of standards has three layers. The first is universal standards, used by all companies. The Commission will issue them in the form of delegated acts in the coming weeks. The second layer will be sector-specific standards, which are likely to start applying on January 1, 2026, and we will learn their content gradually over the coming years. The third layer will be company-specific disclosures.
Each reporting company, after conducting a materiality study, must apply the relevant disclosures from the common and sector standards appropriate to its industry. If, after applying all of these sectors, it were to turn out that there were any remaining impacts, risks or opportunities not included in the report, then the company must prepare industry-specific disclosures about them. These are not designed into the standards, but ESRS 1 provides instructions to consider when creating such disclosures.
The lack of sector standards and the delay in their implementation will therefore create a rather uncomfortable situation for companies. If we already had sector standards, then all or almost all impacts, risks and opportunities deemed material in any company would be included in them, and the use of company-specific disclosures would be sporadic. In the early years of the CSRD, however, it may be that reports consist largely of company-specific disclosures.
Applying company-specific disclosures is more labor-intensive. After all, you have to spend time not only gathering data and information to complete a particular disclosure, but you also have to design that disclosure beforehand. Auditors will scrutinize such disclosures extremely closely; after all, they do not have a template presented in the standards against which they can examine their content completed by the company.
In addition to being labor-intensive, each non-standardized reporting element also raises risks related to legal uncertainty. Reducing the number of disclosure requirements and delaying the application of sector standards may therefore not bring companies reporting ease at all, but more work, costs and stress. I hope, however, that these are temporary problems that will fade on their own when the entire ESRS system stabilizes in the second half of the decade.
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