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EU ESG reporting requirements in 2026, mapped.

Between October 2025 and July 2026 the EU rewrote its sustainability rulebook: CBAM entered its definitive regime, the Omnibus package narrowed CSRD, the ESRS were simplified, VSME became the SME default and ETS2 settled on 2028. This page maps the EU ESG reporting requirements that actually apply in 2026 — each regime, its legal act, who it covers and the next date. We maintain it as the rules move; the change log below records every revision.

The 2026 map

One rulebook, five moving parts.

Five regimes shifted between autumn 2025 and mid-2026. Here is where each stands today — the legal detail follows below.

CBAM — definitive regime running

Since 1 January 2026, only authorised CBAM declarants may import covered goods above the 50-tonne threshold. The cost accrues through 2026; certificate sales open on 1 February 2027.

CSRD — scope cut by Omnibus I

Directive (EU) 2026/470, in force since 18 March 2026, limits mandatory reporting to undertakings with more than 1,000 employees and over EUR 450 million net turnover — both tests at once.

ESRS — simplified for FY2027

The Commission adopted the revised standards on 3 July 2026. They apply mandatorily from financial years beginning 1 January 2027, with voluntary early use for FY2026 if published in time.

VSME — the SME default

EFRAG's voluntary standard, annexed to Commission Recommendation (EU) 2025/1710, is now the EU's designated answer for SMEs — and the cap on what large buyers should ask suppliers for.

ETS2 — fully operational in 2028

The second trading system prices fuel for buildings, road transport and smaller industry. Fuel suppliers pay, not households — and their permit and reporting duties are already running.

→ The common thread

Fewer companies report because a law says so. More companies report because a customer, an importer or a bank cannot legally do without their data.

What applies

What EU ESG rules actually apply in 2026.

As of 2026, four EU instruments shape corporate sustainability obligations. The CBAM definitive regime applies since 1 January 2026 under Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083, in force since 20 October 2025. CSRD remains in force, rescoped by Directive (EU) 2026/470. VSME stands as the voluntary reporting route for SMEs under Recommendation (EU) 2025/1710. And ETS2, created by Directive (EU) 2023/959, is in its preparation phase ahead of full operation in 2028.

The legal duties sit in specific places. Under CBAM, the obligation — authorisation, the annual declaration, certificates — belongs to the EU importer, the authorised CBAM declarant. Non-EU producers carry no obligation under the Regulation, but their EU customers are legally required to declare embedded-emissions data that the Regulation defines in detail, which is why the data request still lands with exporters. Under CSRD, wave-1 companies have already reported for FY2024 and FY2025 under the existing ESRS, while undertakings above the new thresholds prepare for FY2027 reports due in 2028.

Just as important is what 2026 does not require. Listed SMEs no longer face mandatory CSRD reporting. Importers below the 50-tonne CBAM de-minimis — which covers iron and steel, aluminium, fertilisers and cement, but not electricity or hydrogen — have no authorisation, declaration or certificate duties for those goods. And the proposed CBAM extension to downstream, mainly steel- and aluminium-intensive products from 2028 is exactly that: a proposal, in trilogue as of autumn 2026, not law. Companies facing a first report can start from a CSRD readiness and gap analysis rather than from the regulation text.

Rule by rule

The post-Omnibus map, rule by rule.

RegimeLegal basisWho it coversWhere it stands in 2026Next date
CBAMReg. (EU) 2023/956, amended by Reg. (EU) 2025/2083EU importers of cement, iron and steel, aluminium, fertilisers, electricity and hydrogenDefinitive regime since 1 Jan 2026; 50 t per-importer de-minimis for the mass-based goods1 Feb 2027 — certificate sales open
CSRDDirective (EU) 2026/470 (Omnibus I), in force 18 Mar 2026Undertakings with more than 1,000 employees and over EUR 450m net turnover; non-EU groups via EUR 450m EU net turnoverWave 1 reports under the existing ESRS; Member-State transposition due by 19 Mar 20272028 — first wave-2 reports, on FY2027
ESRS (revised)Delegated act of 3 Jul 2026, amending Delegated Reg. (EU) 2023/2772Every company reporting under CSRDAdopted; in the Parliament and Council scrutiny period as of October 2026FYs from 1 Jan 2027 — mandatory application
VSMECommission Recommendation (EU) 2025/1710 of 30 Jul 2025Non-listed SMEs — and, as the value-chain cap, the large companies and banks requesting their dataVoluntary; the designated reporting language below the CSRD thresholds— (an eventual delegated act may follow)
ETS2Directive (EU) 2023/959Fuel suppliers for buildings, road transport and smaller industry; costs pass through fuel pricesPermits required since 1 Jan 2025; reporting running, with verified data from 20262028 — fully operational

Status as of 31 October 2026, per EUR-Lex and the European Commission's CBAM, finance and climate pages. The change log below records each revision of this page.

The dates to plan around

Between now and 2028 the calendar runs: 1 February 2027 — CBAM certificate sales open on the common central platform, covering 2026 imports retroactively. 19 March 2027 — deadline for Member States to transpose Directive (EU) 2026/470. 30 September 2027 — the first annual CBAM declaration, for 2026 imports, is due, with certificates surrendered by the same date. Financial years from 1 January 2027 — the revised ESRS apply mandatorily, making FY2027 the data year behind the 2028 CSRD reports. 2028 — ETS2 becomes fully operational. One budgeting note for importers: through 2026 the CBAM cost accrues but cannot yet be paid. The Q1 2026 certificate price — EUR 75.36, published 7 April 2026 — is the published reference, and provisioning against the quarterly averages is the only preparation possible before February 2027.

Data first

Different rules, same data.

Strip the acronyms away and every regime on this page asks for the same underlying asset: a greenhouse-gas inventory built on the GHG Protocol, with country-specific emission factors. CBAM wants installation-level embedded emissions per product. CSRD and VSME want the corporate footprint across scope 1, scope 2 and scope 3. Banks and large customers want the same numbers again, in questionnaire form.

Building that dataset once — and keeping it verifiable — beats answering each request from scratch. A corporate carbon footprint done properly in 2026 feeds the CBAM communication template, a VSME report and a CSRD gap analysis alike.

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Change log

What changed, and when.

  • 14 April 2025 — Directive (EU) 2025/794, the stop-the-clock directive, postpones wave-2 and wave-3 CSRD reporting by two years.
  • 30 July 2025 — the VSME standard is annexed to Commission Recommendation (EU) 2025/1710 as the voluntary standard for SMEs and the value-chain cap.
  • 20 October 2025 — Regulation (EU) 2025/2083 enters into force: a 50-tonne de-minimis replaces the EUR 150 consignment rule, default values become usable in the definitive period, and the first declaration moves to 30 September 2027.
  • December 2025 — Implementing Regulation (EU) 2025/2621 sets the definitive-period default values, with a 10% mark-up on defaults for 2026 imports, 20% for 2027 and 30% from 2028 (actual verified emissions carry no mark-up). The Commission also proposes extending CBAM to downstream products from 2028.
  • 1 January 2026 — the CBAM definitive regime applies; only authorised declarants may import covered goods above the threshold.
  • 26 February / 18 March 2026 — Omnibus I, Directive (EU) 2026/470, is published and enters into force: mandatory CSRD narrows to more than 1,000 employees and EUR 450 million net turnover, and listed SMEs leave the scope.
  • 7 April 2026 — the first quarterly CBAM certificate price is published: EUR 75.36 for Q1 2026.
  • 3 July 2026 — the delegated act on the revised, simplified ESRS is adopted, applying mandatorily from financial years beginning 1 January 2027.
  • Autumn 2026 — the proposed downstream CBAM extension sits in trilogue, after the Council's general approach of 12 June 2026 and Parliament's mandate of 15 September 2026. Still a proposal, not law.
FAQ

Frequently asked.

What are the EU ESG reporting requirements in 2026?
Four instruments matter. CBAM's definitive regime applies since 1 January 2026: EU importers of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen must hold authorised-declarant status and will file their first annual declaration by 30 September 2027. CSRD keeps wave-1 companies reporting, while Directive (EU) 2026/470 limits future mandatory scope to undertakings above 1,000 employees and EUR 450 million net turnover. VSME is the voluntary standard for everyone below those lines. And ETS2 already imposes permit and reporting duties on fuel suppliers ahead of full operation in 2028.
What are the CSRD requirements in 2026?
The companies actually publishing CSRD reports in 2026 are wave-1 undertakings, which have reported for FY2024 and FY2025 under the existing ESRS. Everyone else is preparing rather than publishing: undertakings above the new thresholds — more than 1,000 average employees and more than EUR 450 million net turnover, both tests cumulative — face their first report in 2028 on FY2027, written under the revised ESRS. Listed SMEs have no mandatory CSRD obligation, and Member States have until 19 March 2027 to transpose the new scope into national law.
What is ETS2?
ETS2 is a separate EU emissions trading system, created by Directive (EU) 2023/959, covering CO2 from fuel combustion in buildings, road transport and smaller industry outside the original ETS. The regulated entities are fuel suppliers, not households or drivers: suppliers have needed a permit since 1 January 2025, report their fuel-related emissions, and will surrender allowances once the system is fully operational in 2028, with costs passing through to fuel prices. A price-containment mechanism releases extra allowances if prices exceed EUR 45 (in 2020 prices) in the first two years, and revenue feeds the Social Climate Fund — at least EUR 86.7 billion over 2026–2032.
What changed in the revised ESRS for 2026?
On 3 July 2026 the Commission adopted the delegated act on revised, simplified ESRS, amending Delegated Regulation (EU) 2023/2772. As of October 2026 it sits in the Parliament and Council scrutiny period. It applies mandatorily from financial years beginning 1 January 2027 — FY2027 being the data year for the 2028 wave-2 reports — with voluntary early application for FY2026 contingent on timely publication in the Official Journal. The gateway exercise is unchanged: under ESRS 1, a topic is reported if it is material from the impact perspective, the financial perspective, or both.
ISSB vs ESRS — which applies to EU companies?
They answer different questions. The ESRS are the mandatory standards for companies in CSRD scope, built on double materiality: impacts on people and the environment count alongside financial risks and opportunities, and either test alone triggers disclosure. The ISSB's standards are investor-focused and apply where a jurisdiction adopts them or a company opts in. For an EU company in CSRD scope, ESRS is what the law requires; ISSB alignment is a choice, not a substitute.
Does CBAM already apply in 2026?
Yes. The transitional, reporting-only period ended on 31 December 2025, and the definitive regime has applied since 1 January 2026. Importing CBAM goods above the 50-tonne threshold without authorised-declarant status carries a penalty of three to five times the standard rate — the base penalty being EUR 100 per tonne of CO2e. What 2026 does not yet involve is payment: certificates go on sale on 1 February 2027 and cover 2026 imports retroactively, so this year's obligations are to be authorised, collect the data and provision the cost.
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