ESRS and Other Sustainability Reporting Frameworks: ISSB, GRI, SFDR and UK SRS Compared

The CSRD is Directive (EU) 2022/2464 of 14 December 2022, in force since 5 January 2023. It binds the Member States, and a company is bound by the national law that transposes it. Directive (EU) 2026/470 (Omnibus I), in force since 18 March 2026, replaced the size test in Articles 19a(1) and 29a(1) of Directive 2013/34/EU, and Member States must transpose it by 19 March 2027 (Article 5(1)). The ESRS are delegated regulations and apply directly. How the reporting duty itself works is set out where the Corporate Sustainability Reporting Directive (CSRD) is explained.

This page compares five frameworks in one table, then gives the EU legal anchors that tie the ESRS to global standards, the materiality concept of each framework, the joint interoperability texts and the effective dates as of 29 October 2026.

What Counts as a Sustainability Reporting Framework under EU Law?

Under the CSRD, sustainability reporting standards are the ESRS, which the Commission adopts by delegated act under Article 29b of Directive 2013/34/EU, taking into consideration technical advice from EFRAG (Article 49(3b)); the ISSB, GRI and UK standards are issued outside EU law, and the SFDR is a separate EU regulation for financial market participants. Article 2(18) of Directive 2013/34/EU, inserted by Directive (EU) 2022/2464, defines sustainability reporting as reporting information related to sustainability matters "in accordance with" Articles 19a, 29a and 29d. Which framework fulfils that duty? Article 29b(1) empowers the Commission to adopt delegated acts specifying the information to report under Articles 19a and 29a, and those delegated acts are the ESRS. A GRI, ISSB or UK report can inform the sustainability statement, but the duty itself is met with the ESRS.

Article 2(17) of the same directive defines sustainability matters as environmental, social and human rights, and governance factors, including sustainability factors as defined in Article 2(24) of Regulation (EU) 2019/2088, the SFDR. That cross-reference is written into the Accounting Directive itself. The revised (simplified) ESRS, Delegated Regulation (EU) 2026/1563, define materiality with the term "sustainability topic", and the Directive uses "sustainability matters".

The Frameworks Side by Side: Issuer, Legal Status, Users and Materiality

The frameworks compared here come from five different issuers: the European Commission for the ESRS, the ISSB of the IFRS Foundation, the Global Sustainability Standards Board of GRI, the EU legislature for the SFDR and the UK Department for Business and Trade for the UK SRS. Only two of the five are EU law. The ESRS are Delegated Regulation (EU) 2023/2772 as amended by Delegated Regulation (EU) 2025/1416, and Delegated Regulation (EU) 2026/1563, which replaces Annexes I and II of 2023/2772 without repealing it. The SFDR is Regulation (EU) 2019/2088, which has applied since 10 March 2021 (Article 20(2)).

The other three frameworks apply by choice or through a jurisdiction's own rules. IFRS S1 and IFRS S2 apply to entities in jurisdictions that adopt them and to entities that use them voluntarily. The UK SRS S1 and S2 are available for voluntary use by any entity; their use becomes required only where the Companies Act 2006, FCA rules or another UK regulator applies them, as FCA PS26/19 does for in-scope listed issuers on a comply-or-explain basis. Table 1 gives the status of each framework as of 29 October 2026; each row has its own comparison page, where the disclosures are compared one by one.

How the Directive Ties the European Standards to Global Ones

The CSRD ties the ESRS to global standards first in recital 43 of Directive (EU) 2022/2464, which says the standards should take account of GRI, SASB, IIRC, IASB, TCFD, CDSB and CDP and integrate the ISSB baseline content to the extent consistent with the Union legal framework and the Green Deal. The operative text sits in Article 29b(5) of Directive 2013/34/EU. When the Commission adopts the standards, it takes account of global standard-setting initiatives for sustainability reporting (point (a)) and of the information that financial market participants need to comply with their disclosure obligations under Regulation (EU) 2019/2088 (point (b)).

Did the Omnibus change these links? Directive (EU) 2026/470 amended Article 29b(2): the standards must avoid disproportionate administrative or financial burden on undertakings, including by taking account of global standard-setting initiatives and ensuring coherence with other Union acts, and they prioritise quantitative information. Article 29b(5) was not amended, because the Omnibus amended only paragraphs 1, 2 and 4 of Article 29b.

Where the Revised Standards Let Companies Draw on Other Frameworks

Delegated Regulation (EU) 2026/1563 names interoperability with global sustainability reporting standards, "to the greatest extent possible", among its objectives (recital 2, point (vi)). Two provisions of ESRS 1 in the 2026 set put that objective into practice, listed below.

• ESRS 1 AR 5: for entity-specific disclosures, an undertaking may use the IFRS industry-based guidance and the GRI Standards, including GRI topic and sector standards.
• ESRS 1 paragraph 107: supplementary information may come from other legislation or from "generally accepted standards or frameworks such as" those of the Global Reporting Initiative, and it must be clearly identified.

Both paragraphs belong to the 2026 set in Delegated Regulation (EU) 2026/1563, which enters into force on 10 November 2026 and is mandatory for financial years beginning on or after 1 January 2027, with optional use for financial year 2026. The set keeps 12 standards and replaces Annexes I and II of Delegated Regulation (EU) 2023/2772; the full list of changes is set out under the revised (simplified) ESRS.

Where TCFD and SASB Content Lives Now

IFRS S1 and IFRS S2 fully incorporate the TCFD recommendations, and the IFRS Foundation monitors climate-related disclosure progress from 2024, a task it took over from the TCFD at the request of the Financial Stability Board. In the UK, FCA PS26/19 replaces the 2021 TCFD-aligned climate rules for listed issuers.

SASB content reaches companies through IFRS S1. Paragraph 55(a) of IFRS S1 says an entity "shall refer to and consider the applicability of" the disclosure topics in the SASB Standards. UK SRS S1 turns that duty into an option: the entity "may" refer to and consider them.

How Each Framework Defines What Is Material

The ESRS apply double materiality, a topic being material from the impact perspective, the financial perspective or both, while IFRS S1 treats information as material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that primary users of general purpose financial reports make (paragraph 18 of IFRS S1). In the 2026 set, double materiality has two dimensions, impact materiality and financial materiality (ESRS 1 chapter 3 and Annex II Table 2 of Delegated Regulation (EU) 2026/1563). A topic is material from a financial perspective if it generates risks or opportunities that affect, or could reasonably be expected to affect, the undertaking's financial position, financial performance, cash flows, access to finance or cost of capital. The 2023 set applies the same principle in ESRS 1 paragraph 28: impact or financial or both.

GRI uses impact materiality, and the ESRS adopted the same definition of impact materiality as GRI, according to the EFRAG-GRI joint statement in the EFRAG SRB paper of 23 August 2023. Under the 2026 set, a topic is material from an impact perspective when it pertains to the undertaking's material actual or potential, positive or negative impacts on people or the environment over the short, medium and long term. How a company runs the test is explained under double materiality assessment under the ESRS.

The SFDR asks a different question. Article 4 of Regulation (EU) 2019/2088 concerns the principal adverse impacts of investment decisions on sustainability factors, which Article 2(24) defines as environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. Article 2(17) of Directive 2013/34/EU draws those factors into "sustainability matters". The UK SRS follow the ISSB approach: the advisory committee (TAC) behind the UK SRS recommended in December 2024 that IFRS S1 and S2 be endorsed with minor amendments.

Equivalence and Interoperability: Can One Report Serve Two Regimes?

For climate, the ESRS-ISSB interoperability guidance of 2 May 2024 (IFRS Foundation and EFRAG) says that one report can serve both sets of standards: "Regardless of whether it starts with ESRS or ISSB Standards, an entity can comply with the climate requirements of both sets of standards by following the content of this interoperability guidance". The guidance adds that it cannot be relied on in isolation. It states that the two standard setters worked "to achieve a high degree of alignment of the respective standards, with a specific focus on climate-related reporting", and that "almost all the disclosures in ISSB Standards related to climate are included in ESRS". Where ESRS E1 paragraph 50 and IFRS S2 split greenhouse gas emissions differently, "two different disaggregations would need to be provided". These statements belong to the joint guidance and are not a Commission decision.

For a group based outside the EU, the EU report follows its own test. A third-country group reports under Article 40a of Directive 2013/34/EU, as amended by Article 2(13) of Directive (EU) 2026/470, when its net turnover in the Union exceeds EUR 450 million in each of the last two consecutive financial years and it has an EU subsidiary or EU branch with a net turnover exceeding EUR 200 million in the preceding financial year, first for financial years starting on or after 1 January 2028. Who files and how is set out under the CSRD report of non-EU companies under Article 40a.

Mapping Guidance and the Set It Refers To

EFRAG and the IFRS Foundation published joint ESRS-ISSB interoperability guidance that refers to the paragraph numbers of the 2023 set (Delegated Regulation (EU) 2023/2772) and says it is educational material, not a formal statement of equivalence. Its section 1.1 aligns financial materiality in ESRS 1 paragraph 48 of the 2023 set with materiality in IFRS S1 paragraph 18. The guidance also states that future amendments to the standards may change its analysis.

GRI publishes its own mapping material on its global alignment page. The two documents are the GRI-ESRS Interoperability Index of November 2024, dated 22 November 2024, and the ESRS-GRI datapoint mapping, dated 28 April 2025. As of 29 October 2026, GRI lists no update of either document for the revised ESRS.

Effective Dates of Each Framework as of 2026-10-29

Four dates fall in 2027: the revised ESRS become mandatory for financial years beginning on or after 1 January 2027, the IFRS S2 amendments apply to annual reporting periods beginning on or after 1 January 2027, GRI 102 and GRI 103 take effect for reporting from January 2027, and the FCA rules on UK SRS apply to accounting periods starting on or after 1 January 2027. The SFDR has applied since 10 March 2021 and its regulatory technical standards in Delegated Regulation (EU) 2022/1288 since 1 January 2023. The SFDR 2.0 proposal, COM(2025) 841 of 20 November 2025, is pending as of 29 October 2026 under procedure 2025/0361(COD): the ECON committee voted on 10 September 2026, and the Parliament plenary confirmed entry into interinstitutional negotiations on 7 October 2026 (Rule 72). The proposal would repeal Delegated Regulation (EU) 2022/1288 (Article 3) and would apply 18 months after its entry into force (Article 4).

The UK SRS S1 and S2, published on 25 February 2026, carry no effective date of their own. Their application depends on the Companies Act 2006, FCA rules or another UK regulator (UK SRS S1 paragraphs E5 and 73B), and the FCA rules lead to first reports in 2028.

One Reporting Process for Several Frameworks

A company that reports under the ESRS can reuse that work for other frameworks only as far as the texts of those frameworks allow, and three texts set that limit. They are listed below in the order of Table 1.

• IFRS S1 and UK SRS S1: IFRS S1 paragraph C2 lets an entity refer to and consider the GRI Standards and the ESRS to the extent they assist it and do not conflict with IFRS S1; UK SRS S1 allows the same.
• GRI: an undertaking reporting under the ESRS is considered to report "with reference to" the GRI Standards, as GRI 1 defines that claim (EFRAG-GRI joint statement); it does not thereby report "in accordance with" GRI.
• SFDR: the revised ESRS 2 Appendix A lists the datapoints that derive from other EU legislation, including the SFDR. In the 2026 set, principal adverse impact indicators 1 and 2 map to E1-8 (gross Scope 1, 2 and 3 greenhouse gas emissions) and indicator 12 to S1-15 (unadjusted gender pay gap).

Appendix A is a non-binding illustration and an integral part of ESRS 2 in the 2026 set; the 2023 set used ESRS 2 Appendix B for the same purpose. Which datapoints a company reuses still depends on its own ESRS work: the materiality assessment, the sustainability statement and its assurance come first, and the steps are laid out in the step-by-step CSRD reporting plan.

ESG Reporting and EU Sustainability Reporting: Where the Terms Differ

ESG is not a defined term of the CSRD: Directive 2013/34/EU speaks of "sustainability matters" in Article 2(17) and "sustainability reporting" in Article 2(18). Those two defined terms, not the label ESG, decide what an undertaking in scope reports.

Is ESG a Framework of Its Own?

No: EU law sets no framework called ESG, and for an undertaking in scope of the CSRD the framework is the ESRS. Its environmental, social and human rights, and governance factors are the sustainability matters that ESRS reporting covers, from climate change under ESRS E1 to business conduct under ESRS G1.

An "ESG report" prepared without the ESRS does not meet the CSRD for an undertaking in scope. Article 2(18) ties sustainability reporting to Articles 19a, 29a and 29d, so the title of a document does not change the duty: the content must follow the ESRS, whatever other frameworks the undertaking also uses.

Which Standard Can Smaller Undertakings Use Voluntarily?

Undertakings that, on their balance sheet dates, do not exceed an average of 1,000 employees during the preceding financial year may report under the voluntary standard (VS, formerly VSME), Annex I of Delegated Regulation (EU) 2026/1560 (Annex I paragraph 2). The standard serves undertakings outside Articles 19a and 29a; its modules are described under the voluntary standard (VS, formerly VSME).