CSRD delegated acts: what they are and the ESRS (Regulation 2023/2772)

In the European Union, when a law is adopted that later needs to be specified or updated, the legislator can delegate powers to the Commission to draw up delegated acts. This mechanism allows legislation to be adjusted without launching a full new legislative process, speeding up its adaptation to reality. In corporate sustainability, delegated acts have been the route used to adopt the ESRS, the technical standards of the CSRD.

What is the CSRD and why does it matter to companies?

The CSRD (Corporate Sustainability Reporting Directive) sets a common framework for companies to publish sustainability information. Its aim is to improve the transparency and comparability of non-financial information and to drive the transition to a more sustainable economy.

Compared with its predecessor, Directive 2014/95/EU (NFRD), the CSRD introduces significant changes:

• It raises the status of the sustainability report: non-financial information is now called the sustainability statement and is placed on a par with the financial report.
• It widens the scope: in its original design the directive was set to affect around 50,000 companies in the EU. However, the 2026 Omnibus Regulation raised the thresholds and substantially reduced that universe (see below).
• Double materiality: it is based on the principle of double materiality, which requires reporting both on how sustainability affects the company and on the company's impact on people and the environment.

Who does the CSRD apply to as of 2026?

The original timetable provided for a staggered entry (large public-interest entities with more than 500 employees from 2024, the rest of large companies from 2025 and listed SMEs from 2026). That timetable has changed. The Omnibus Regulation, in force since 18 March 2026, has raised the main threshold to 1,000 employees and 450 million euros in turnover and postponed waves 2 and 3 by two years, leaving most SMEs outside mandatory reporting. We explain this in our analysis of the Omnibus Regulation.

What are the CSRD delegated acts?

The central delegated act is Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 (published in the Official Journal on 22 December 2023), which adopted the first set of European Sustainability Reporting Standards (ESRS), mandatory for companies subject to the CSRD.

The first set of ESRS is structured as follows:

Cross-cutting standards

• ESRS 1: general requirements for preparing sustainability information.
• ESRS 2: general disclosures about the company and its strategy.

Environmental standards (E)

• ESRS E1: climate change.
• ESRS E2: pollution.
• ESRS E3: water and marine resources.
• ESRS E4: biodiversity and ecosystems.
• ESRS E5: resource use and circular economy.

Social standards (S)

• ESRS S1: own workforce.
• ESRS S2: workers in the value chain.
• ESRS S3: affected communities.
• ESRS S4: consumers and end-users.

Governance standard (G)

• ESRS G1: business conduct (ethics, anti-corruption and anti-bribery, and so on).

The revision of the ESRS in 2025-2026

Delegated acts are not static: that is precisely their purpose. Following the Omnibus simplification mandate, EFRAG and the European Commission have prepared a revision of Delegated Regulation (EU) 2023/2772 that cuts the mandatory datapoints by around 61%, redesigns the materiality framework and simplifies the structure of the standards. The draft revised delegated act went out to public consultation in 2026 and its application is expected for the 2027 financial year, with the option of early voluntary adoption. In other words, the ESRS that apply today and those that will apply from 2027 are not exactly the same.

Prepare and verify your sustainability reports with Manglai

At Manglai, specialists in calculating emissions under the GHG Protocol and ISO 14064, we offer solutions to comply with the CSRD and the ESRS:

• Measuring the carbon footprint accurately, including Scopes 1, 2 and 3.
• Identifying reduction measures from data analysis.
• Producing auditable sustainability reports compliant with the standards.
• Communicating the sustainability strategy to stakeholders.

If your company falls within the scope of the CSRD, discover how Manglai handles CSRD compliance from start to finish.

Frequently asked questions

What does CSRD stand for?

CSRD stands for Corporate Sustainability Reporting Directive. The form "CSDR" that appears in some URLs is a typo.

What is the main delegated act of the CSRD?

Delegated Regulation (EU) 2023/2772 of 31 July 2023, which adopted the first set of ESRS. In 2025-2026 it was revised to simplify and reduce the mandatory datapoints.

Who does the CSRD require to report as of 2026?

After the Omnibus Regulation, mainly companies with more than 1,000 employees and more than 450 million euros in turnover, with waves 2 and 3 postponed by two years.