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ESRS Reporting: Requirements, Timeline and How to Prepare

TL;DR

ESRS (European Sustainability Reporting Standards) are the mandatory sustainability reporting standards under the EU's Corporate Sustainability Reporting Directive (CSRD). Indian companies in scope — including EU subsidiaries and large Indian exporters — must report on environmental, social, and governance matters using ESRS, with phased applicability from 2024 to 2026.

EU trade & reportingEnterprise

Regulation Overview

Jurisdiction / regulator
European Union — European Commission (DG FISMA)
Who needs it
EU companies and certain non-EU companies with EU operations or listed securities
Frequency
Annual, included in the management report
Report type / template
ESRS Report (SustainableX template)
Key threshold
Large EU companies, listed SMEs, and non-EU companies with >€150M EU revenue and ≥1 EU branch/subsidiary
Official source
EU Corporate Sustainability Reporting Directive (CSRD); ESRS delegated acts

What is ESRS Reporting?

ESRS (European Sustainability Reporting Standards) are the sustainability reporting standards developed by EFRAG and adopted by the European Commission under the CSRD. Companies in scope must report on sustainability matters using double materiality — both how sustainability issues affect the company and how the company affects people and the environment. ESRS covers environmental (climate change, pollution, water, marine resources, biodiversity, circular economy), social (own workforce, workers in value chain, affected communities, consumers), and governance (business conduct) topics. Reporting is subject to limited assurance initially, moving to reasonable assurance.

Who needs it?

  • Large EU public-interest entities (from 2024)
  • Large EU companies not previously under NFRD (from 2025)
  • Listed SMEs (from 2026, with opt-out to 2028)
  • Non-EU companies with >€150 million net revenue in the EU and at least one EU branch or subsidiary (from 2028, Indian exporters with significant EU operations may fall in scope)

What does it cover?

ESRS comprises 12 standards organized into four areas:

  • ESRS 1: General requirements (double materiality, value chain, reporting boundary)
  • ESRS 2: General disclosures (governance, strategy, impact/risk/opportunity management, metrics and targets)
  • Environmental (E): Climate change (ESRS E1), pollution (E2), water and marine resources (E3), biodiversity and ecosystems (E4), resource use and circular economy (E5)
  • Social (S): Own workforce (S1), workers in value chain (S2), affected communities (S3), consumers and end-users (S4)
  • Governance (G): Business conduct (G1)

Why is it hard manually?

  • Double materiality assessment requires stakeholder engagement and complex judgment
  • Data must cover the full value chain, including suppliers outside the EU
  • ESRS has over 1,000 potential data points across 12 standards
  • Assurance requirements (limited, moving to reasonable) demand audit trails and evidence
  • Indian companies lack EU-aligned data collection processes and templates

How SustainableX helps

  • ESRS template library: Pre-built ESRS-aligned structure covering all 12 standards and double materiality
  • Cross-framework from one ingestion: Enter ESG data once; generate ESRS alongside CBAM, CSRD, BRSR, GRI, and IFRS
  • AI-assisted drafting: First draft of ESRS disclosures from uploaded policy, metric, and stakeholder data
  • Double materiality support: Documented materiality assessment process and stakeholder engagement records
  • Audit-ready output: Data lineage, version control, and evidence linking for limited/reasonable assurance

How to prepare — 5 steps

  1. Assess applicability: Determine whether your company or EU subsidiary is in scope under CSRD timelines
  2. Conduct double materiality: Identify which ESRS topics are material to your company and stakeholders
  3. Map data to ESRS: Collect metrics for each applicable ESRS standard (climate, pollution, water, biodiversity, social, governance)
  4. Draft disclosures: Use SustainableX's AI-assisted ESRS template to generate narrative and metric disclosures
  5. Review and assure: Complete internal review, arrange limited assurance, and include in your annual management report

Frequently asked questions

What is ESRS?

European Sustainability Reporting Standards — the mandatory sustainability reporting framework under the EU's CSRD.

Do Indian companies need ESRS?

Directly, if they are large EU subsidiaries or listed on EU markets. Indirectly, if they are suppliers to EU companies under CSRD scope or have >€150M EU revenue with EU operations.

What is double materiality?

Reporting on both how sustainability issues affect the company's value and how the company affects people and the environment.

Can SustainableX generate ESRS reports?

Yes — SustainableX includes ESRS-aligned templates with AI-assisted drafting and cross-framework output.

When does ESRS apply to Indian exporters?

Non-EU companies with significant EU revenue come in scope from 2028; many Indian exporters face ESRS pressure earlier through EU buyer requirements.

Sources

  • EU Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464)
  • ESRS delegated acts adopted by the European Commission

Next step

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