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ICSRG Bulletin
September 2026
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Latest news on sustainability reporting and governance in Europe and beyond |
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MESSAGE FROM ICSRG TEAM
CSRD, CSDDD and ESRS
In July 2026 the EC formally adopted the suite of revised European Sustainability Reporting Standards (ESRS) by way of a delegated act (DA). We welcome the revised ESRS and urge member states to adopt them as soon as possible. At the same time, we strongly support the EU’s resistance to any efforts from the US to water down CRSD, CSDDD and ESRS.
Reporting by Smaller EU Companies
In concert with the adoption of the revised ESRS, the EC also adopted a voluntary standard (VS) for smaller companies out of scope of the ESRS by way of a DA. Significantly the VS is also the ’value chain cap’: this limits the information that companies having to report under ESRS can require from value-chain partners with 1,000 or less employees to the VS.
We hope that voluntary sustainability reporting and assurance will become the norm for companies with 1,000 employees or fewer. These companies will have the option to use either the VS or revised ESRS. We suggest that smaller, simpler entities from lower risk sectors use the VS while larger, more complex entities from higher risk sectors use the revised ESRS.
ESRS-40a
In response to a request from the European Commission (EC), EFRAG developed the ESRS for certain non-EU Undertakings (ESRS-40a) Exposure Draft. ESRS-40a is now open for public consultation. We welcome this ED but urge the EC to require the global approach in the interests of establishing a level playing field between EU and non-EU companies.
Assurance
We welcome Europe’s decision to adopt a sustainability assurance standard by 1 July 2027 and support the global adoption and implementation of the ISSA 5000 and IESSA. Global standard setters should closely monitor the impact on value chain reporting and assurance and, where that impact is deemed disproportionate, modify the standards with timely limited scope amendments.
Global Reporting by SMEs
We believe the IFRS Foundation should develop an IFRS sustainability disclosure standard for non-listed SMEs (or non-publicly accountable entities) across the globe so they might efficiently respond to requests for sustainability information from larger companies and finance providers. This standard could be based on the EU’s VS and would be a sister standard to the IFRS for SMEs.
Paul Thompson and Nikola Stajic
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| EU Developments |
CSRD and CSDDD
On 26 February 2026 the EU published the final legal text in the Official Journal of the revised CSRD and CSDDD (or CS3D) known as Omnibus I. The key changes are summarized in the European Council’s press release. Transposition started in late March 2026. Member States have 12 months to implement the CSRD amendments, while changes to the CSDDD must be applied by 26 July 2028.
To help businesses implement the legislation see Frank Bold’s Business Knowledge and Implementation Centre which includes this legal briefing on the new restrictions on information requests to business suppliers following the Omnibus 1 revisions to the CSRD and CSDDD and explains the practical implications for companies.
A year after signing a trade framework agreement with the EU, the US government is threatening action against the EU since they say Omnibus I changes to CSRD and CSDDD do not go far enough. The US Ambassador to the EU said they “will take any actions necessary to address unreasonable burdens on U.S. commerce.” As Andreas Rasche argues in this LinkedIn post the EU is “within its rights to regulate non-EU companies with significant business on EU markets based on its own terms” and goes on to say that there is no reason why US companies should be treated any differently to other non-EU nations.
On 30 July 2026 a research study looking at the legitimacy of Omnibus I was published. Better Regulation in the Context of Omnibus I; How a Departure from Evidence-Based Policymaking May Affect the Legitimacy of Omnibus I, reveals how the EC went in less than three years from arguing the original CSRD and CSDDD were necessary to strengthen competitiveness to saying the same Directives were a threat to competitiveness, in so doing casting doubt on the integrity of the policy process.
EFRAG State of Play 2026
On 1 July 2026 EFRAG published the 2026 edition of the State of Play Report, providing an evidence-based assessment of sustainability reporting practice over 900 assured 2025 sustainability statements prepared under ESRS. In this podcast, Kerstin Lopatta, Chair of the EFRAG Sustainability Reporting Board (SRB) discusses the key findings, emerging reporting trends, and explains what they mean for stakeholders. One of the key findings is that the most declared material topics are the same as in the previous year- namely E1 Climate Change, S1 Own Workforce and G1 Business Conduct – and that identified material topics inched up from 6.3 to 6.6 per company.
Revised ESRS and Voluntary Sustainability Reporting Standard (VS)
On 3 July 2026, much sooner than expected, the EC published delegated acts (DA) on revised ESRS and Voluntary Sustainability Reporting Standard (VS). The revised standards simplify and streamline sustainability reporting requirements and will apply to financial years beginning on or after 1 January 2027, with early adoption for financial year 2026 permitted once the delegated act enters into force. EFRAG has hosted all the related documents here.
At the same time, the EC also adopted and published a DA establishing a VS. The VS will support companies outside mandatory CSRD reporting and establishes a ’value chain cap’, preventing CSRD in-scope companies from requiring more information from value-chain partners with 1,000 employees or fewer than what the voluntary standard covers. The VS is very similar to the VSME which it supersedes.
Both DAs have now been transmitted to the European Parliament and the Council of the European Union for scrutiny in accordance with the legislative process. They have an initial two-month scrutiny period during which either institution may object (this is rare!). If not rejected, the DAs will enter into force after publication in the Official Journal of the EU, likely in September 2026.
Read a full analysis of the publication of the revised ESRS and VS by Frank Bold here. Some, like Frank Bold, believe the VS is ill-suited to companies employing up to 1,000 since the VSME on which it is based was developed for much smaller companies. Accordingly, they recommend that large companies outside the scope of the revised CSRD should report using the revised ESRS rather than the VS.
While the ESRS are now final, questions are still being asked. As Head of Responsible Companies at Frank Bold wrote in this Encompass article, some have questioned the deviations from EFRAG’s technical advice.
Guidance on ESRS
Late last year EFRAG launched the ESRS Knowledge Hub to help users navigate the ESRS, including the VSME, and implementation materials developed by EFRAG - register here. The 2026 Revised ESRS text and Voluntary Standard (VS) are now available on the EFRAG ESRS Knowledge Hub as explained here. The new interactive document set includes all revised topical ESRS standards as well as the VS and features that enable comparisons with and between the extant 2023 ESRS, the 2025 Simplified ESRS delivered by EFRAG to the EC on 30 November 2025. Most recently, on 28 August 2026, EFRAG published the 2026 Draft List of Datapoints for Revised ESRS and an online survey here.
There’s a growing amount of guidance from other sources. For example, on 20 August 2026 Position Green hosted a webinar on the final ESRS. Watch the recording here and access the slides here.
Guidance on VS
EFRAG has developed a considerable amount of materials supporting implementation of its VSME and duly housed it in the SME Ecosystem of its Knowledge Hub as this educational video explains. As the VS supersedes the VSME the VSME material is expected to be tweaked to support the VS. The EC plans to launch a dedicated portal that will include new templates and guidance suited to larger entities that are eligible to use the VS.
European Sustainability Reporting Standards for Certain non-EU Undertakings (ESRS-40a)
The CSRD introduces sustainability reporting requirements for certain non-EU undertakings with significant activities in the EU. Under Article 40a of the Accounting Directive, the EC is required to adopt dedicated ESRS for these undertakings. Following a request from the EC, EFRAG developed the ESRS for certain non-EU Undertakings (ESRS-40a) Exposure Draft. ESRS-40a (previously referred to as Non-EU ESRS (N-ESRS) or ESRS for Third Countries (ESRS-TC)) is now open for public consultation until 31 October 2026. The feedback received will inform finalization of EFRAG's technical advice to the EC. Reporting in accordance with ESRS-40a will be mandatory for financial years starting on or after 1 January 2028.
The suite of ESRS-40a comprise 12 standards, 2 cross-cutting and 10 topical standards, mirroring the ESRS structure. The standards focus only on impacts and as such do not include anticipated financial effects (incidentally this German research study found AFE reporting to be patchy). Fair presentation remains the overall reporting objective, but the focus is only on material impacts and how they are managed. Definition of users, upstream and downstream value chain, incorporation by reference, and transitional provisions are the same as or aligned with ESRS. The ESRS-40a offers two reporting options, a global approach and a mixed approach. EFRAG's SRB prefers the global approach, citing concerns over the limited scope of the disclosure requirements under the mixed approach.
Following the Omnibus amendments, Article 40a applies to non-EU undertakings that: generate more than EUR 450 million net turnover in the EU during each of the last two consecutive financial years; and either have an EU branch generating more than EUR 200 million or are the ultimate parent of EU subsidiaries generating more than EUR 200 million. The largest share of the estimated 1,200 companies (down from around 10,000 pre-Omnibus) within scope of the ESRS-40a come from the US, followed by the UK, Switzerland and Japan and are some of the world’s largest multinational groups.
From the EU’s perspective, the ESRS-40a is about creating a level playing field. If large non-EU groups generate significant revenues in the EU, they should be subject to sustainability reporting expectations comparable to those applied to EU companies. But outside Europe many may see the ESRS-40a more as the EU extending its regulatory expectations beyond its borders.
To support stakeholders during the consultation, EFRAG has published the presentation, recording, and FAQs (see bottom of this webpage) from the webinar held to introduce the ESRS-40a. Interestingly the ED provides much flexibility in how to structure the sustainability report.
EFRAG Updates
The sustainability and financial reporting podcast episodes for July 2026 are available on the EFRAG Spotify and YouTube channels. The July 2026 EFRAG Update report – summarizing recent public technical discussions and decisions taken, open consultations, future events, etc. – is here.
Connectivity Discussion Paper
The comment period for EFRAG’s Discussion Paper on Connectivity of Financial and Sustainability Reporting closed in late June 2026. In this LinkedIn Pulse article an EFRAG staff member suggests the goal should be complementarity rather than connectivity. In their response to the discussion paper Accountancy Europe stress that while they are connected and share common principles, principles that can help reporting tell a coherent story with clear cross referencing, financial and sustainability reporting have different objectives, different users, and different approaches to materiality, timing and design. |
| Global Developments in Sustainability Finance, Governance and Reporting |
Global State of Play
Recently IFAC published a report showing that the global sustainability reporting ecosystem is becoming less fragmented as more of the world’s largest companies begin to adopt or form plans to use the ISSB standards and ESRSs. The report, The State of Play: Sustainability Disclosure and Assurance (Six-Year Trends and Analysis, 2019-2024), finds companies increasingly referencing the use or future use of ISSB Standards and ESRS. The LinkedIn Pulse article ”Sustainability Disclosure and Assurance in Europe: Six Years of Progress, One Inflection Point” looks at how European countries are doing compared with the rest of the world.
In late June 2026 the Global Reporting Initiative (GRI) published perhaps the largest-ever survey of sustainability reporting. The State of Sustainability Reporting: Global Trends in the GRI Standards 2025 finds GRI standards to be the most widely used sustainability disclosure standards. The report also finds that Asia and the Global South are closing the gap on Europe in terms of impact disclosure.
Despite enormous efforts to make the various frameworks and suites of standards interoperable, this Corporate Disclosures article reveals that there are still significant differences, such as on materiality.
ISSB Update
This ISSB Update summarises the July 2026 International Sustainability Standards Board (ISSB) meeting. You can also listen to ISSB Chair and Vice-Chair in the latest episode of the ISSB podcast discuss the use of both ISSB Standards and ESRS, the likely benefits of the ISSB's forthcoming nature-related disclosure proposals, and the next phase of enhancements to the SASB Standards.
ISSB Plan
On 18 August 2026, a week after senior leadership changes, the IFRS Foundation Trustees announced a series of strategic initiatives: a five-year operating and financing plan for both the IASB and the ISSB; the opening of a new ISSB office in Geneva, Switzerland in 2027; and publication of proposed targeted amendments to the IFRS Foundation’s Constitution (comment period ends 16 November 2026).
ISSB Adoption
The IFRS’s Jurisdictional Readiness Assessment Guide and associated tool supports jurisdictions in assessing how prepared their markets are for the adoption or other use of ISSB Standards. The guide provides practical examples drawn from the experiences of some of the 40 or so jurisdictions that have already taken steps to adopt or otherwise use ISSB Standards.
This webpage hosts a list of ongoing and completed jurisdictional consultations on sustainability-related disclosures. On 31 August 2026 there were three open sustainability disclosure consultations – Singapore, New Zealand, and the EU. This Corporate Disclosures article takes a closer look at Australia where the Treasury is undertaking a public consultation on potential measures to streamline sustainability reporting and assurance requirements including tightening guidance on proportionality and limit the data that reporting entities can request from their supply chains partners.
ISSB Implementation Support
All ISSB support materials for IFRS Sustainability Disclosure Standards are hosted here. In this latest Q2 2026 episode of the Implementation Insights podcast, ISSB Vice Chair Sue Lloyd leads a discussion on the latest resources available to support companies applying ISSB Standards.
SME Sustainability Reporting
In this ICAEW Insights article Accountancy Europe Senior Director Paul Gisby explains why sustainability reporting among SMEs is as critical as ever despite the recent easing of EU rules. Meantime on 25 August 2026 ACCA published a paper, Measure what matters, offers solutions to the practical challenges SMEs face in collecting and reporting on sustainability and climate metrics. One of the recommendations is that frameworks and collection methods need to be standardised across SMEs and, further, simplicity, certainty and stability are crucial in effective application of regulation and standards. The ICSRG believes the IFRS Foundation should develop an IFRS sustainability disclosure standard for non-listed SMEs (or non-publicly accountable entities) across the globe so they might efficiently respond to requests for sustainability information from larger companies and finance providers. This standard could be based on the EU’s VS and would be a sister standard to the IFRS for SMEs.
SASB Standards
The ISSB’s public consultation on proposed amendments to three SASB Standards closed in late July 2026. While EFRAG’s comment letter is quite supportive, as Corporate Disclosures reports many respondents are asking how the SASB Standards should interrelate with the ISSB Standards.
ISSB Nature-Related Disclosures
The ISSB is on track to publish an exposure draft (ED) of its Practice Statement (PS) for nature-related disclosures in time for the biodiversity COP in October 2026. The ISSB Vice-Chair shared insights on the project during her address to the IFRS Foundation Conference in late June 2026. Until such time as the PS is finalized the TNFD recommendations will remain in force.
IFRS Sustainability Disclosure Taxonomy
In late July 2026 the ISSB published IFRS Sustainability Disclosure Taxonomy—Proposed Update 1 Amendments to Greenhouse Gas Emissions Disclosures. This proposal considers updates to the IFRS Sustainability Disclosure Taxonomy (ISSB Taxonomy) in the wake of targeted amendments to IFRS S2 Climate-related Disclosures in December 2025. The deadline for comments is 28 September 2026.
Taskforce on Inequality and Social-Related Financial Disclosures (TISFD)
The TISFD is aiming to establish a standardised framework for reporting on companies' people-related impacts, dependencies, risks and opportunities just as the TCFD did for climate and the TNFD did for nature. The public consultation on the TISFD Framework (Beta Version 0.1) closed on 31 July 2026. The final framework is expected by the end of 2027. This Corporate Disclosures article explains that the core set of metrics that will anchor the framework is expected by the end of 2026.
Public Sector Standards
Since releasing IPSASB SRS 1, Climate-related Disclosures, the first-ever public sector sustainability reporting standard earlier this year, IPSASB has focused its attention to the development of a public sector equivalent to the ISSB’s IFRS S1, a general sustainability-related disclosure standard that sets out general principles for sustainability disclosures in the public sector. IPSASB is on track to issue a final standard in late 2026. The standard is the main agenda item at IPSASB’s September 2026 meeting.
Taskforce on Nature-related Financial Disclosures (TNFD)
On 31 July 2026 the comment period closed on the TNFD’s discussion paper outlining potential refinements to the TNFD risk assessment and scenario analysis guidance, aiming to support more effective, consistent and comparable nature-related risk assessments.
US Developments
Corporate Disclosures reports that on 27 July 2026 the California Air Resources Board (CARB) launched a fresh consultation on draft regulations for establishing mandatory direct GHG emissions disclosures under SB 253 and set out its proposals for implementing Scope 3 reporting requirements.
ACCA Publishes Integrated Report
ACCA Walks the talk. ACCA, strong advocates of sustainability reporting and using integrated reporting to help with its connectivity to financial reporting, recently published its own integrated report and, for the first time, climate-related disclosures as it works towards adopting the ISSB’s sustainability disclosure standards. Check out the three-minute story of ACCA's year here and read the full report here. |
| Global Developments in Sustainability Assurance |
ISSA 5000
The effective dates of the IAASB and IESBA standards aimed at building trust and transparency in sustainability reporting and assurance are now just around the corner. The International Standard on Sustainability Assurance (ISSA 5000) General Requirements for Sustainability Assurance Engagements becomes effective for periods starting on or after 15 December 2026. Early adoption is encouraged and translations are available here.
ISSA Adoption and Implementation Support
There is a growing momentum around the world as jurisdictions continue to adopt ISSA 5000. Some jurisdictions are making sustainability assurance mandatory while others are taking a voluntary approach. This IAASB webpage includes ‘ISSA 5000 Jurisdictional Adoption’ (see under ‘Additional Information’).
Access published adoption and implementation resources on the dedicated ISSA 5000 web page. Many others have issued guidance including the ICAEW and the World Business Council for Sustainability Development (WBCSD) that published this guide to assurance on sustainability information that takes organisations through their entire assurance journey, from understanding what assurance is, to preparing for it, selecting a practitioner and interpreting the results.
IESSA
In concert with the IAASB, the IESBA launched its new International Ethics Standards for Sustainability Assurance (IESSA) and other new sustainability-related provisions that will also become effective for sustainability assurance engagements on sustainability information for periods starting on or after 15 December 2026, with early adoption encouraged.
In this article an IESBA Board Member explains how the complementary trinity of standards of the ISSB, IAASB, and IESBA create a strong foundation for credible reporting and assurance. To help implement the IESSA the IESBA has a suite of IESSA Implementation Resources including a feedback mechanism to gather implementation insights.
European Union
The revised CSRD maintains the limited assurance requirement and the EC plans to adopt a sustainability assurance standard by 1 July 2027. To protect SMEs, it proposes requiring assurance providers to respect the obligation that companies should not request information from value chain companies with fewer than 1,000 employees beyond what is included in the VS. In January 2026 the EC sent an updated request to the Committee of European Auditing Oversight Bodies (CEAOB), asking it to develop EU-specific add-ons and possible carve-outs to ISSA 5000 for limited assurance on sustainability reporting by 30 September 2026. Meantime assurance providers can consult these CEAOB guidelines and illustrative examples of limited assurance reports - unmodified report and modified report – published by the ECG. |
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