Revised ESRS: what changes for HR teams from 2027

On 21 September 2026, the European Union published two texts on sustainability reporting. The first replaces the ESRS, the standards that set out what companies must disclose under the CSRD. The second creates a voluntary standard for companies that are not subject to the directive. The French Treasury (Direction générale du Trésor) summarised both texts on 21 October. Source: Direction générale du Trésor, 21 October 2026 (in French).

HR teams are directly affected. A large share of social data comes from the HR information system, payroll, training and health and safety records. This article explains what was published, what changes in the social standards and what an HR team can prepare now. To check whether your company is subject to the CSRD, and for the basics, start with our CSRD guide.

Revised ESRS: what was published

The European Commission adopted two delegated regulations on 3 July 2026. A delegated regulation is an implementing text: it adds detail to a directive without going back to the European Parliament for a full vote. Both were published in the Official Journal on 21 September 2026.

• Delegated Regulation (EU) 2026/1563 replaces the 2023 ESRS. It enters into force on 10 November 2026 and applies to financial years starting on or after 1 January 2027. Source: Delegated Regulation (EU) 2026/1563.
• Delegated Regulation (EU) 2026/1560 creates a voluntary sustainability reporting standard. It is meant for companies that are not subject to the CSRD. Source: Delegated Regulation (EU) 2026/1560.

These texts complete the Omnibus directive of 24 February 2026, which reduced the number of companies subject to the CSRD. The new thresholds are explained in our CSRD guide.

What about financial year 2026?

For financial years starting in 2026, the regulation leaves a choice. Companies already in scope can apply either the 2023 ESRS or the revised ESRS. Those that keep the old version can already use some of the reliefs in the new one. In both cases, the sustainability statement must state clearly which version was applied. Finance and the sustainability team usually make this choice. It also sets the list of data HR will have to provide for 2026, so it pays to be involved early.

What changes in the standards

Regulation 2026/1563 sets six objectives for the revision:

1. reduce the number of datapoints, meaning the individual pieces of information to disclose;
2. give priority to quantitative data over narrative text;
3. separate mandatory information more clearly from voluntary information;
4. give clear instructions on how to apply the materiality principle;
5. improve consistency with other EU legislation;
6. take account of international sustainability reporting standards.

The text states that the Commission amended the technical advice of EFRAG, the body that prepares the standards, on several points. Two of them concern HR directly: human rights incidents and cases of discrimination. Another one concerns consistency with the corporate sustainability due diligence directive.

According to the European Commission, the number of mandatory datapoints falls by more than 60% and the total number of datapoints by more than 70%. The Commission also estimates that reporting costs will fall by more than 30% per company. Source: European Commission, 3 July 2026.

The revised ESRS contain 12 standards: two general standards, five environmental standards, four social standards and one standard on business conduct. They still rest on double materiality. The company reports on its material impacts on people and the environment, and on the material risks and opportunities it faces. Only the topics found to be material through this analysis go into the report.

The social side of the revised ESRS: what concerns HR

Of the four social standards, the own workforce standard (S1) is the one that involves HR teams the most. In its revised version, it contains 16 disclosure requirements. We group them below into four families, with the most common data sources.

Not every requirement applies to every company: only the topics retained by the materiality analysis are disclosed. When workforce topics come out as material, the priority given to quantitative data puts HR systems at the centre of the work. Our page on employee engagement for CSR shows how United Heroes approaches this area.

SMEs and mid-sized companies: the voluntary standard and the value chain cap

According to the French Treasury, the vast majority of SMEs and mid-sized companies are no longer subject to the CSRD. They can still receive information requests from their customers or their funders. The voluntary standard gives them a common format to answer.

It follows the structure of the European standard for SMEs published in 2025 under the name VSME. It has a basic module and a comprehensive module. The basic module contains three workforce blocks:

• B8: general characteristics of the workforce;
• B9: health and safety;
• B10: remuneration, collective bargaining and training.

This standard also works as a cap. The value chain means a company's suppliers and partners. A company subject to the CSRD cannot require a partner that had an average of 1,000 employees or fewer over the previous financial year to provide information beyond this standard. The cap applies to requests made for CSRD purposes. The French Treasury notes that it does not cover requests made for other purposes.

For the HR team of an SME or mid-sized company, requests from large customers made for CSRD purposes cannot go beyond these blocks. Preparing reliable data on headcount, health and safety, pay and training once lets you answer each tender quickly.

What HR can prepare now

The sustainability statement is still assured by a statutory auditor or an independent assurance provider, in the form of limited assurance. This is a consistency check, less thorough than a financial audit, and it requires traceable data. Six workstreams can start now.

Part of standard S1 covers policies, actions and targets, in addition to indicators. To meet it, the company describes what it actually does for its teams and with them.

At United Heroes, our solution gets employees involved in collective actions across four use cases: well-being, cohesion and social connection, solidarity and CSR engagement, and change enablement. Challenges and short events create measurable participation that HR can track over time. To learn more, discover our approach to employee CSR engagement and our guide to CSR in companies.

This article explains the texts for information purposes. It does not replace legal advice tailored to your company.

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