CSRD: timeline for amended ESRS (2025–2028) — what to plan for

The CSRD directive and ESRS are not frozen: the Commission can adopt revised delegated acts after EFRAG’s technical advice. Amended ESRS from the 2025 cycle (July draft, then finalisation) aim to simplify application while keeping climate ambition. For project teams, the key is knowing what to plan for without confusing a draft with binding law.

Indicative timeline (2025–2028)

Publicly documented steps typically look like:

• 2025 — EFRAG publishes draft amended ESRS for consultation (including climate E1); market comments collected.
• 2025–2026 — technical advice finalised; European Commission prepares a revised delegated act (exact calendar on official sites).
• Entry into force — often expressed for financial years starting on or after a given date (commentary often mentions around 2027 for application of amendments, depending on the final text). Check the exact date in the Official Journal when published.

What this means for your internal calendar

Even before amended standards apply, first CSRD reports already use the ESRS from the 2023 delegated regulation. Good practice is:

• Short term: comply with the framework currently applicable to your entity (reporting cohort, covered subsidiaries).
• Medium term: regulatory monitoring (EFRAG, Commission, national standard-setter) to adjust data models and internal controls when the amended text is published.
• Data: invest early in emissions traceability — including digital Scope 3 — to avoid “catching up” on three years of incomplete history at assurance time.

Omnibus and political changes

EU political debates (relief for some SMEs, threshold delays, etc.) can change the scope of companies subject to CSRD. These topics are distinct from the content of ESRS E1, but they affect your compliance planning. Legal should cross-check official sources.

In short

ESRS E1 updates in 2025 sit in a clarification and methodological strengthening of the climate pillar — not a rollback of reporting. To anticipate, focus on: reliable activity data, governance of emission factors, and alignment with the GHG Protocol for scopes.