Legislation and regulation
2026 03 04
•
6 MIN
Carolina Skarupa
Product Carbon Footprint Analyst

When the European Commission announced the Quick Fix, which introduced changes to the ESRS in 2025, many companies read it as a sign of relief. After months preparing for the rollout of the CSRD, any adjustment sounded like a truce.
But 2026 is making one thing clear: this is not a step backwards. It is, rather, a pace adjustment.
The Quick Fix does not reduce the ambition of the European ESG reporting framework. What it does is soften the landing so that the first cycle does not turn into an operational collapse.
It is a targeted amendment to the first package of ESRS standards designed for companies that were already required to report under the CSRD. It was adopted as a European Commission delegated regulation in July 2025 and applies to financial years starting on or after 1 January 2025. The Commission recognised that implementation was proving more complex than expected and chose to introduce technical adjustments so that it would not be abrupt.
It does not change the framework. It does not redefine ambition. It simply gives more room to organise.
The adjustments are concrete and, above all, temporary.
In the original ESRS design, the second and third years meant adding new layers of information: more metrics, more detail and fewer transitional exceptions. The Quick Fix pauses that progression.
During 2025 and 2026, companies can keep a reporting level similar to that of the first year, without automatically expanding the scope. In practice, it means gaining time to consolidate the measurement system before increasing complexity.
In the original approach, many of the transitional measures were designed mainly for smaller companies. The large companies of the first wave (Wave One), those that were already subject to the old Non-Financial Reporting Directive (NFRD) and have reported since the 2024 financial year, had less room.
The Quick Fix extends those temporary reliefs to Wave One companies. Specifically, during 2025 and 2026 large companies with more than 750 employees can take up almost the same exemptions that smaller companies already enjoyed.
Some standards were especially demanding from a technical standpoint, such as biodiversity (E4) or certain social aspects in the value chain (S2, S3 and S4). The reform lets Wave One companies omit that information in 2025 and 2026, even if the topic has been identified as material.
Flexibility is also kept for certain anticipated financial impacts and complex estimates, provided they are properly justified.
The first ESRS package included voluntary disclosures. In theory they were not mandatory, but in practice many companies included them out of caution. The Quick Fix suspends them in this initial phase. That reduces the workload and, above all, removes the "just in case" pressure. Companies report what is mandatory. Nothing more.
During the first year many companies reported more than necessary for fear of misreading the rule. The Quick Fix brings greater clarity about what exactly is expected at each phase. That does not lower the requirement, but it reduces uncertainty. And when there is less ambiguity, there is less tendency to over-report.
The Quick Fix was an emergency solution, not the end of the road. In parallel, the EU has reformed the framework in depth:
In other words: the Quick Fix gave breathing room in 2025-2026, and the structural simplification of the ESRS takes over from there.
Here is the important nuance.
The Quick Fix simplifies the start, but it does not reduce responsibility. Companies are still required to measure, structure and report ESG information rigorously. The only thing the regulator acknowledges is that this process needs a learning curve.
Put another way: the destination is the same. Only the speed changes.
In practice, this means that:
While Brussels adjusts the calendar, the market keeps looking at the numbers.
The Quick Fix may give room on the regulatory side, but investors, financial institutions and strategic partners have not lowered their expectations. They still need clear, solid information to assess risk, resilience and real transition capacity. In fact, most of the companies the Omnibus takes out of the CSRD plan to maintain or expand their reporting.
And what they ask for is not superficial.
They want to understand:
Technical compliance with the rule may be enough for the regulator, but not necessarily for capital. And that difference is what, in practice, is setting the real level of scrutiny.
The first cycle after the Quick Fix is making something very clear: the complexity of reporting does not lie in the rule, but in how data is managed inside the company.
Today the advantage is technological.
Automating data collection, having all sources connected and ensuring traceability is no longer about "optimising processes". It is the difference between firefighting before the audit and working with control from the start.
Manglai connects the company's internal sources, organises the information according to the ESRS, automates metrics and uses its AI Copilot to spot inconsistencies before they become a problem. That translates into something very practical: less manual work, fewer errors, less time chasing data. And more time to analyse, decide and improve.
It is not just about complying with the CSRD. It is about keeping your sustainability report under control.
If you want to see how to fit all this into your reporting, explore our solution for the CSRD.
In the end, the ESRS 2025 changes do not make reporting simple. They just make it clearer where the real challenge lies. And in an environment where the demands will keep rising, having data well managed is not a luxury. It is a clear advantage.
The so-called "Quick Fix" is the delegated regulation that the European Commission adopted in July 2025 to ease the first application of the ESRS under the CSRD. It does not remove obligations, but eases the initial pace and depth of reporting during 2025 and 2026.
No. They introduce gradualness, but keep the structural principles intact, such as double materiality and audit.
No. Double materiality remains the structural axis of the ESRS framework. Companies must assess both the impact of ESG factors on their business (financial materiality) and the impact of their activity on the environment (impact materiality). What changes is operational clarity and gradualness in some disclosures, not the methodological principle.
The group known as Wave One: the large companies that were already subject to the old NFRD and that report under the CSRD from the 2024 financial year. They were the first to start ESRS reporting and, therefore, the ones that most needed room to consolidate their measurement systems.
No. The obligation of external verification remains. The current level required is limited assurance, with a regulatory expectation of moving towards reasonable assurance in the future. The quality, traceability and consistency of the data remain essential.
In practice, the changes translate into greater flexibility in the first year, materiality-based prioritisation, gradualness in the depth of the data and lower risk of regulatory over-interpretation. However, the need for consistent, auditable and traceable data remains intact.
It is possible, but operationally complex. ESG reporting under the ESRS means integrating multiple internal sources, coordinating departments, consolidating environmental, social and governance metrics and preparing for external audit. Many companies turn to technological solutions to reduce manual errors, improve traceability and gain efficiency in reporting cycles.
Carolina Skarupa
Product Carbon Footprint Analyst
About the author
Graduated in Industrial Engineering and Management from the Karlsruhe Institute of Technology, with a master’s degree in Environmental Management and Conservation from the University of Cádiz. I'm a Product Carbon Footprint Analyst at Manglai, advising clients on measuring their carbon footprint. I specialize in developing programs aimed at the Sustainable Development Goals for companies. My commitment to environmental preservation is key to the implementation of action plans within the corporate sector.
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