ESRS Disclosure Checklist Template
Five-page landscape tracking sheet for the disclosure requirements of four European Sustainability Reporting Standards: ESRS 2 General disclosures, E1 Climate change, S1 Own workforce and G1 Business conduct. It prints the references and short names of two texts, both copied on 20 October 2026 from EUR-Lex: Annex I of Delegated Regulation (EU) 2023/2772 (55 rows) and the replacement Annex I of Delegated Regulation (EU) 2026/1563 (48 rows), because the numbers and titles differ between them. Each row has a place for whether your own materiality assessment found the requirement material, the data point owner, an evidence reference, a status, gaps and notes and a review sign-off. Page 1 records which text you follow, the date you read the current text and what the Commission, EUR-Lex and EFRAG pages said that day. E2 to E5, S2 to S4 and entity-specific topics are not listed. The sheet decides nothing: materiality is your assessment, and a completed sheet does not show that a sustainability statement meets the Directive or the standards.
What's inside
Page 1: details and the state of the texts, completed before any row
- Sheet details: reporting entity (and group), financial year, sheet version and date, who prepared it; which text of the standards the sheet follows (text A, text B or other); the date you read the current text and where; the materiality assessment reference; and any phase-in or relief used
- What the texts said on 20 October 2026: what EUR-Lex showed for Delegated Regulation (EU) 2023/2772 and for Delegated Regulation (EU) 2026/1563, what the European Commission page and the EFRAG page said, and a prompt to check the current text and write the date
- How to fill in: the Y, N or ? choice, six example status codes, the evidence reference and the standards that are not listed
Pages 1 to 4: the tracking rows, one table per text
- Text A, 55 rows: Annex I of Delegated Regulation (EU) 2023/2772 as amended by (EU) 2025/1416. ESRS 2 (BP-1 to IRO-2 and the four minimum disclosure requirements), E1 (including the headings that relate to ESRS 2), S1 (S1-1 to S1-17) and G1
- Text B, 48 rows: the Annex I set out in Delegated Regulation (EU) 2026/1563. ESRS 2 (with the four general disclosure requirements), E1-1 to E1-11, S1-1 to S1-16 and G1-1 to G1-6
- Each row: reference, short name as in the text, material (circle Y, N or ?), data point owner, evidence reference, status, gaps and notes, review sign-off
Page 5
- Other requirements you track: five blank rows for anything not printed
- Review and sign-off: three roles with name, signature and date
The status codes and section titles are ours, to change. The references and short names are copied from the headings of the texts named on page 1, not from memory; check the current text before you use the sheet.
What requires or shapes this record
No source opened for this page says that a sustainability statement needs a tracking sheet like this one, and this form does not say that any law requires one. In the European Union, recital 1 of Delegated Regulation (EU) 2023/2772 says that Directive 2013/34/EU, as amended by Directive (EU) 2022/2464, requires certain undertakings to include in a dedicated section of the management report the information needed to understand their impacts on sustainability matters and how those matters affect them, prepared in accordance with sustainability reporting standards, and the Regulation sets out those standards (the ESRS) in its Annexes. Which undertakings are in scope, and from which financial year, is set by the Directive and changes: recital 2 of Delegated Regulation (EU) 2026/1563 says that Directive (EU) 2026/470 has reduced the number of undertakings in scope and simplified the reporting from financial years beginning on or after 1 January 2027. On 20 October 2026 the EUR-Lex page of Regulation 2023/2772 showed that it had been changed, and Regulation 2026/1563, published on 21 September 2026, replaces its Annex I; Article 3 of that act says it enters into force on 10 November 2026 and applies to financial years beginning on or after 1 January 2027, and Article 2 lets an undertaking apply either text for years beginning in 2026 if it says which. Because the numbers and titles of the requirements differ between the two texts, this form prints both and asks you to tick the one you follow. This page is general information, not legal advice: check the current text and your own obligations before you rely on it.
- Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023, Annex I (ESRS 1 paragraphs 29 and 32 and Appendix C, ESRS 2, ESRS E1, S1 and G1; OJ L, 22.12.2023; EUR-Lex page opened in a browser on 20 October 2026, consolidated version of 01/01/2025)
The EUR-Lex page shows the act as "In force: This act has been changed. Current consolidated version: 01/01/2025" and lists the changes: Delegated Regulation (EU) 2025/1416 (replacement Annex I, from 01/01/2025) and Delegated Regulation (EU) 2026/1563 (replacement Annex I and Annex II, from 01/01/2027). The headings of ESRS 2, E1, S1 and G1 in Annex I give the references and titles printed in text A, 55 rows in all: ESRS 2 BP-1 to IRO-2 and the four minimum disclosure requirements MDR-P, MDR-A, MDR-M and MDR-T; E1-1 to E1-9 with three headings that relate to ESRS 2; S1-1 to S1-17 with two such headings; G1-1 to G1-6 with two. Where the contents list and the heading of one standard differ in a few words (S1-16, G1-1 and G1-4), the heading is used. ESRS 1 paragraph 29 says that, whatever the outcome of its materiality assessment, the undertaking always discloses the information required by ESRS 2 and the topical requirements that relate to IRO-1. ESRS 1 paragraph 32 and ESRS 2 IRO-2 (paragraphs 55 to 58) say what to disclose if climate change is concluded not to be material, ask for a list of the disclosure requirements complied with, with page numbers or paragraphs, and allow it as a content index. I also opened Regulation 2025/1416 of 11 July 2025: its Annex replaces only Appendix C of ESRS 1, the list of phased-in disclosure requirements, and the introductory wording of section 17 of ESRS 2, so the references and titles are unchanged. The form copies headings only and does not summarise the content of any requirement.
- Commission Delegated Regulation (EU) 2026/1563 of 3 July 2026 amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standards, Articles 1 to 3 and Annex I (OJ L, 2026/1563, 21.9.2026; EUR-Lex page opened in a browser on 20 October 2026)
Article 1 replaces Annex I and Annex II of Regulation 2023/2772. Article 3 says the act enters into force on 10 November 2026, a date after the day this page was read, and applies to financial years beginning on or after 1 January 2027. Article 2 says that for financial years starting between 1 January and 31 December 2026 an undertaking may apply either the 2023/2772 standards as last amended by 2025/1416 or the new Annex I, or the old standards with certain reliefs, and must state in its sustainability statement which version it applies. Recital 2 refers to Directive (EU) 2026/470 of 24 February 2026, which it says reduced the number of undertakings in scope and simplified the reporting from financial years beginning on or after 1 January 2027, and lists the aims of the new standards (fewer datapoints, more distinction between mandatory and voluntary datapoints). The headings of ESRS 2, E1, S1 and G1 in the new Annex I give the 48 rows of text B. Their numbering differs from text A: for example Health and safety metrics is S1-14 in text A and S1-13 in text B, and Gross Scopes 1, 2, 3 and Total GHG emissions is E1-6 in text A while Gross scope 1, 2, 3 GHG emissions is E1-8 in text B. In ESRS 1 of text B, paragraph 29(a) says the undertaking applies ESRS 2, and IRO-2 asks for a list of the disclosure requirements complied with, which AR 29 allows as a content index.
- European Commission, Corporate sustainability reporting (finance.ec.europa.eu; page "last updated on 3 July 2026"; opened 20 October 2026)
The page's policy-making timeline lists, under 3 July 2026, the "Adoption - ESRS" of two delegated acts: one amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standards, and one for standards for voluntary use by undertakings protected by the value chain cap. It lists a political agreement between the European Parliament and the Council on the Omnibus I simplification package on 9 December 2025, a delegated act of 11 July 2025 giving wave one companies more flexibility for financial years 2025 and 2026, and the "stop-the-clock" Directive. The page does not give scope thresholds and does not name Directive (EU) 2026/470, so the sheet leaves scope to you. The page is an overview, not the legal text.
- EFRAG, Draft Simplified ESRS (efrag.org/en/draft-simplified-esrs, reached from efrag.org/en/amended-esrs; opened 20 October 2026)
EFRAG's page says it was asked in 2025 by the European Commissioner for Financial Services to give technical advice on simplifying the ESRS delegated act, and that it published its draft amended ESRS on 3 December 2025 after a 60-day public consultation in the summer. The page lists the draft standards (ESRS 1, ESRS 2, E1 to E5, S1 to S4 and G1) and supporting documents, including a log of amendments and a comparative table of texts. It shows no adoption date and does not say that the drafts are in force. The sheet's rows are copied from the adopted EUR-Lex texts, not from these drafts; EFRAG's comparison documents are a place to look at how the drafts differ from the 2023 standards.
Each source checked on 20 October 2026. Not legal advice; check the text in force for your site.
Field by field
Fill in the sheet details and the state of the texts on page 1 first, then use only the table of the text you follow and strike the other. Add a row for each further requirement you decide to track in section C. The status codes, the section titles and the wording of the guidance are ours and can be changed; the references and short names are copied from the texts, so change them only by copying again from the current text. The fields of the table are the same in both texts.
- Reporting entity
- Why: The sheet is for one reporting entity and one period, with a version and a date so that an earlier version can be told from a later one. The boxes also hold the financial year, who prepared the sheet and the sheet version. For a group, say whether the rows are tracked for the consolidated sustainability statement.
- Common mistake: Keeping one sheet for several entities or years, so that a status or an owner cannot be tied to a statement.
- Text of the standards this sheet follows
- Why: The 2023 text (Annex I of Delegated Regulation (EU) 2023/2772, as amended by (EU) 2025/1416) and the replacement Annex I of Delegated Regulation (EU) 2026/1563 number and title the requirements differently. For years beginning in 2026 Article 2 of the 2026 act lets an undertaking apply either and requires it to say which in the sustainability statement. Ticking one here keeps the rows, the owners and the evidence on a single numbering.
- Common mistake: Mixing the two numberings in one sheet, for example using S1-14 for health and safety metrics from the 2023 text and S1-13 from the 2026 text, so that an owner is given the wrong requirement.
- Date you read the current text, and where
- Why: Legal status and dates move: on 20 October 2026 the 2026 act had been published but was due to enter into force on 10 November 2026. Write the date you opened the texts and the address or file, so that a reader can tell how old the check is and whether the current text has changed since.
- Common mistake: Copying the table of status from this page and not checking the current text, so that a change after 20 October 2026 is missed.
- Materiality assessment reference
- Why: Whether a topical requirement is reported depends on your own assessment of material impacts, risks and opportunities, and the texts ask for the outcome to be disclosed (ESRS 2 IRO-2). Name the document, its date and its version so that each Y or N in the sheet can be traced to it. The materiality assessment matrix template is a place to record that assessment.
- Common mistake: Writing Y or N in the sheet with no assessment behind it, so that the content index and the assessment cannot be reconciled.
- Phase-in or relief used
- Why: Text A has a list of phased-in disclosure requirements in Appendix C of ESRS 1 (replaced by Regulation 2025/1416), and text B has a requirement named "Specific information if the undertaking uses phasing-in options" (BP-2). Name any phase-in or relief you rely on and its paragraph, so that a row with no data is not read as a gap or as a finding of not material.
- Common mistake: Leaving a row empty because a phase-in applies, without saying which, so that the omission looks like a mistake or hides one.
- Check the current text
- Why: A prompt, not a finding: the sheet records what the pages said on 20 October 2026 (EUR-Lex, the Commission page and the EFRAG page), and the law, the scope and the dates may have changed since. Check the current text and your own obligations, and note any change in section 1.
- Common mistake: Using a printed sheet for a later reporting year without reading the text that applies to that year.
- Ref
- Why: The requirement's reference as printed in the heading of the text, for example E1-6 or GOV-4. Some headings in text A are topical requirements that relate to an ESRS 2 requirement, shown as, for example, SBM-3 (S1). The same reference can mean a different requirement in the other text.
- Common mistake: Reading a reference without the text, so that G1-4 (Incidents of corruption or bribery in text A, Metrics related to corruption or bribery in text B) is treated as one requirement with one scope.
- Short name (as in the text)
- Why: The title copied from the heading of the text, so that the person who owns the data point sees the same words as the standard. Where a text's contents list and its heading differ in a few words, the heading is used. The short name is a label, not a summary of what the requirement asks.
- Common mistake: Rewriting the title in your own words and then tracking a requirement the standard does not contain.
- Material?
- Why: Circle Y, N or ? from your own materiality assessment. ESRS 1 of each text says how ESRS 2 and the topical standards relate to the outcome of that assessment (paragraph 29), and it says what to disclose if climate change is concluded not to be material, so read it before you write N on an ESRS 2 row or on E1. The form does not decide the answer.
- Common mistake: Writing N on a row to save work, with no assessment or explanation, or leaving the question mark in place when the statement goes for review.
- Data point owner
- Why: A named role that supplies and can explain the data points for the row. The texts do not name owners, so this is a control you add. Name a role and a person, not a department, so that a question about a figure has one place to go.
- Common mistake: Naming a team or the sustainability lead for every row, so that nobody who holds the data is asked.
- Evidence reference
- Why: Where the disclosure is found in the sustainability statement (page or paragraph) and the source file behind it. The 2023 and 2026 texts both ask in IRO-2 for a list of the disclosure requirements complied with, and both allow it as a content index, so this column can be the working draft of that index.
- Common mistake: Writing "see file" with no location, so that the content index and the evidence cannot be rebuilt by someone else.
- Status (example codes, replace them)
- Why: A short code for how far the work has got: NS not started, IP in progress, DR drafted, RV reviewed, AS assured, NA not material or omitted. The codes are ours; write your own meaning of each, in particular what assured means in your set-up and who gave it. NA needs a basis, which goes in the notes.
- Common mistake: Marking DR or RV when the data is a placeholder, or using AS for a row that an assurance provider has not looked at.
- Gaps and notes
- Why: What is missing, why, and who will close it by when: an unfinished calculation, a boundary question, a phase-in used, a source not yet received. A short note beside the code lets a reviewer see the state without opening the file.
- Common mistake: Leaving the note empty on rows marked IP, so that the reader cannot tell a nearly finished row from a stalled one.
- Review sign-off
- Why: The person who checked the row against the text and the evidence, with initials and date. Both texts have a requirement titled Risk management and internal controls over sustainability reporting (GOV-5 in text A, GOV-4 in text B); the sheet does not summarise it, but a reviewer other than the preparer is a control you can show there.
- Common mistake: Signing off a row the same person prepared, or signing off before the evidence is in place.
- Other requirements you track
- Why: Five blank rows for requirements not printed here. The sheet lists only ESRS 2, E1, S1 and G1: E2 to E5, S2 to S4, sector-specific and entity-specific topics are not listed. Both texts allow entity-specific disclosures where a material topic is not covered by a standard. Copy the reference and title from the text you read.
- Common mistake: Assuming that a topic that is not printed in this sheet is not required.
- Review and sign-off
- Why: Three roles with name, signature and date for the whole sheet, for example the sustainability lead, the finance lead and the audit committee chair or equivalent. The roles are examples: write the roles your governance gives the review.
- Common mistake: Having the sheet signed at the end of the process only, so that reviewers see a finished table and not the gaps.
Worked example
IllustrativeEight requirements tracked against text A for an invented manufacturer (invented names, dates and references; the codes are the example codes of the form)
| Ref (text A) | Short name | Material? | Data point owner | Evidence reference | Status | Gaps and notes |
|---|---|---|---|---|---|---|
| BP-1 | General basis for preparation of the sustainability statement | ESRS 2 row | Group reporting lead | Draft statement, section 1.1, page 3 | DR | The note on the consolidation boundary is not written yet. ESRS 2 rows follow ESRS 1 paragraph 29, read on the day the sheet was started. |
| IRO-2 | Disclosure Requirements in ESRS covered by the undertaking's sustainability statement | ESRS 2 row | Sustainability lead | Content index, draft, tab Index | IP | The index lists the rows of this sheet that have an evidence reference. It still needs the table of datapoints that derive from other EU legislation. |
| GOV-4 | Statement on due diligence | ESRS 2 row | Legal counsel | Mapping table, appendix 2, draft | RV | Reviewed by the sustainability lead on 14 October 2026 (invented date). The mapping points to the policy sections. |
| E1-5 | Energy consumption and mix | Y | Facilities manager | Meter export, January to September 2026, file ENG-26 | DR | Vehicle fuel split missing for one site: due 15 December 2026 (invented date). |
| E1-6 | Gross Scopes 1, 2, 3 and Total GHG emissions | Y | Environmental manager | GHG inventory workbook v3, tabs 2 to 4 | IP | Scope 3 categories not yet screened. Method and source of every factor to be written beside each figure. |
| S1-6 | Characteristics of the undertaking's employees | Y | HR manager | HR system report, to be run after the year end | NS | Definition of headcount at the end of the period not yet agreed. |
| S1-14 | Health and safety metrics | Y | EHS manager | Incident register export, sheet 4 | RV | Reviewed by the EHS director on 12 October 2026 (invented date). Contractor hours are shown separately, as written in the KPI definition sheet. |
| G1-6 | Payment practices | N | Finance manager | Assessment record MA-07, 3 September 2026 | NA | Assessed as not material for this entity (invented). The basis is recorded for the IRO-2 disclosure and is revisited at the next assessment. |
Every name, date, reference and status is invented to show the method. Tally of the eight rows: NS 1 (S1-6), IP 2 (IRO-2, E1-6), DR 2 (BP-1, E1-5), RV 2 (GOV-4, S1-14), NA 1 (G1-6), AS 0, which makes 8. The Y and N come from the invented company's own assessment, not from the form, and the example does not say that a real undertaking may omit payment practices or any other requirement: that depends on the current text and on its own assessment.
When a spreadsheet stops being enough
A printed sheet or a spreadsheet is enough for a first reading of the standards with one preparer and a handful of owners. It stops being enough when several people supply data points from different systems, when the same row has to hold a changing status through drafts and reviews, when an auditor or reviewer asks who changed what and when, or when the numbering of the standards changes and the owners and evidence have to be moved from one text to the other.
A software record keeps each requirement as a record with an owner, a status history, links to the evidence and the review, and can carry the same row across two versions of the standards without losing the earlier answer. Ask to see it with your own sheet: change an owner, move a row to a new reference, remove a piece of evidence and show what the content index then says.
The list on the page below applies the CSRD comparison used by the site. Nothing in it shows that a product produces a statement that meets the Directive or the standards.
Same rule for every product: tagged “ESG Reporting”, “ESG Frameworks Reporting”, “Sustainability Reporting”, “Materiality Assessment”, “ESG & Sustainability” or “Sustainability & ESG”, with a sourced CSRD, ESRS or materiality capability in its record, or one the vendor stated to us, labelled as vendor-stated. Documented and conditional capabilities qualify; check the linked scope before treating a module as included.
Tekmon pays for a sponsored placement (above); its place in this list follows the same rule as every entry. How lists are ordered
Dunya Analytics · ESRS E4, GRI, CDP and SBTN aligned reports · Conditional
Vendor source · Profile checked
osapiens HUB · Reporting and disclosure preparation · Conditional
Vendor source · Profile checked
Datamaran · Materiality thresholds and borderline review · Documented
Vendor source · Profile checked
NatureMetrics · TNFD, ESRS E4 and GRI reporting support · Conditional
Vendor source · Profile checked
Normative · ESG disclosure collection · Conditional
Vendor source · Profile checked
Novisto · Double-materiality assessment · Conditional
Vendor source · Profile checked
Persefoni · Disclosure review record · Documented
Vendor source · Profile checked
Plan A · CSRD Manager · Conditional
Vendor source · Profile checked
Position Green · Double materiality assessment · Documented
Vendor source · Profile checked
Sweep · Multi-framework sustainability reporting · Documented
Vendor source · Profile checked
XNatura · ESRS E4, TNFD and GRI disclosure packs · Conditional
Vendor source · Profile checked
Tekmon · Stakeholder materiality questionnaires and matrix · Documented
Vendor source · Profile checked
Enablon · ESG data, reporting and double materiality · Conditional
Vendor source · Profile checked
VelocityEHS · GHG and materiality · Documented
Vendor source · Profile checked
All 14 matching profiles are shown. Documentation review, not hands-on testing or a claim of compliance.