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. The 2026 revision keeps double materiality in place but allows companies to approach it through a top-down assessment that starts from the business model to identify obviously material topics.

Structure of the ESRS

ESRS 1 describes how the 12 standards are organised: two cross-cutting (ESRS 1 and ESRS 2), five environmental (E1 to E5), four social (S1 to S4) and one governance (G1). The revised 2026 standards keep this architecture and drop no topic.

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

On 3 July 2026 the European Commission adopted the delegated act containing the revised ESRS, which replace the 2023 first set (Commission Delegated Regulation (EU) 2023/2772). The revision cuts more than 60% of mandatory data points and more than 70% of all data points, removes voluntary disclosures and makes the materiality assessment more flexible. ESRS 1 is one of the most affected standards: it adds an explicit fair presentation requirement, restricts the disclosure of non-material information, allows a top-down materiality assessment and introduces an undue cost or effort relief, alongside greater latitude for estimates and proxies in value chain reporting.

The revised standards apply to financial years beginning on or after 1 January 2027, with early application possible for financial year 2026, and the delegated act is subject to the scrutiny period of the European Parliament and the Council. Separately, Directive (EU) 2026/470 (Omnibus I) raised the CSRD thresholds to more than 1,000 employees and more than EUR 450 million in net 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.