ESRS 1 – General Requirements

ESRS 1 – General Requirements is the first of the two cross-cutting standards within the European Sustainability Reporting Standards (ESRS). It defines the architecture of the standards set, the fundamental concepts and the principles that every company must follow when preparing its sustainability report under the CSRD. One key idea to bear in mind: ESRS 1 does not contain specific disclosures — rather, it sets the ground rules that apply to all the other standards.

ESRS 1 vs ESRS 2: they are not the same

The two cross-cutting standards are often confused, but they serve different functions:

• ESRS 1 (general requirements): explains how information is prepared. Conceptual framework, conventions, definition of double materiality, report structure, value chain, time horizons, estimates. It does not require specific data.
• ESRS 2 (general disclosures): sets out the mandatory general disclosures (governance, strategy, management of impacts, risks and opportunities, and metrics and targets) that every company must publish regardless of materiality.

Simply put: ESRS 1 says how to report; ESRS 2 says what must always be reported.

Key concepts regulated by ESRS 1

Double materiality

ESRS 1 enshrines the principle of double materiality, which combines two perspectives:

• Impact materiality: the effects of the company on the environment and society.
• Financial materiality: how sustainability matters affect the company's financial position.

A matter is material if it is so from either perspective. This analysis determines which thematic standards the company must apply.

Structure of the ESRS

ESRS 1 describes how the 12 standards in the first set are organised: two cross-cutting (ESRS 1 and ESRS 2), five environmental (E1 to E5), four social (S1 to S4) and one governance (G1).

Qualitative characteristics of information

It establishes that information must be relevant, faithful, comparable, verifiable and understandable.

Other aspects

• Inclusion of the upstream and downstream value chain.
• Time horizons (short, medium and long term).
• Treatment of estimates, uncertainties and the principle of relative importance.
• Transitional provisions to facilitate first-time application.

Implications for the carbon footprint

Although ESRS 1 does not require specific figures, its framework shapes how the carbon footprint is measured: the scope of the analysis (including the value chain for Scope 3), the outcome of the double materiality assessment and the data quality characteristics determine how emissions are subsequently reported under ESRS E1.

Regulatory status in 2026

The 2023 ESRS (Commission Delegated Regulation (EU) 2023/2772) remain the legal reference in force. A revision process is underway to simplify them (European Commission public consultation between May and June 2026, with a delegated act planned for late 2026), which will also affect ESRS 1, with application targeted at financial years beginning from 2027. In addition, Directive (EU) 2026/470 (Omnibus I) raised the CSRD thresholds to more than 1,000 employees and EUR 450 million in turnover.

At Manglai we help companies measure their carbon footprint and prepare their sustainability information in compliance with the ESRS. Discover how Manglai can help you.