The European Sustainability Reporting Standards (ESRS) — the mandatory reporting framework for CSRD filings — are undergoing major simplification in 2026. EFRAG published its revised ESRS Set 1 for public consultation in 2025, with a significant reduction in datapoints proposed, more voluntary disclosures, and a clearer value-chain cap. The revised Delegated Act is expected to be adopted mid-2026 and applied to FY2027 reports. Sector-specific ESRS and listed-SME ESRS have been indefinitely postponed, but the VSME voluntary standard (published December 2024) is gaining traction as the de-facto SME response to upstream customer sustainability questionnaires. Whether your company reports directly under CSRD or receives VSME requests from large customers, Deply Digital Product Passport provides authoritative product-level data that directly feeds ESRS E5 (Circular Economy) and E1 (Climate) disclosures — turning weeks of spreadsheet reconciliation into a single exportable data package.
What is this regulation?
ESRS defines what and how companies must disclose under CSRD. The original Set 1, adopted as Delegated Regulation (EU) 2023/2772, includes 12 standards: 2 cross-cutting (ESRS 1 general requirements, ESRS 2 general disclosures), 5 Environmental (E1 Climate, E2 Pollution, E3 Water, E4 Biodiversity, E5 Circular Economy), 4 Social (S1–S4), and 1 Governance (G1). The simplified 2026 version proposes a significant reduction in the number of required datapoints.
Who must comply?
Mandatory ESRS users: companies within the revised CSRD scope under the Omnibus I amending Directive — more than 1,000 employees and net turnover exceeding €450 million, applicable to financial years starting on or after 1 January 2027. Voluntary ESRS users: non-listed SMEs adopting VSME to respond to customer questionnaires proactively. The VSME standard has two modules — Basic (B) and Comprehensive (C) — both voluntary and designed to be filled in weeks rather than months.
How this impacts your business
For in-scope companies, the simplified ESRS dramatically reduces audit burden and makes first-time reporting tractable. For SMEs outside CSRD but in large supply chains, VSME is becoming non-negotiable: major European brands are integrating VSME requirements into supplier onboarding. Many VSME data requests overlap with DPP data — material composition, supplier origin, energy use, circularity — meaning your DPP work directly accelerates your ESG reporting.
How Deply helps
Deply exports VSME-ready data packages directly from your product records: material origin, supplier tiers, environmental claims, end-of-life information. For CSRD-scope companies, the same data feeds ESRS E5 (resource flows, waste metrics) and E1 (product carbon footprint, Scope 3 category 1 upstream). Build the DPP once; answer every sustainability request — from customer questionnaires to statutory reports — from the same source of truth.
Frequently asked questions
Will the simplified ESRS reduce our audit fees?
As an SME, should we adopt VSME proactively before customers ask?
How does ESPR product data map to ESRS E5 disclosures?
Official sources
- Delegated Regulation (EU) 2023/2772 — ESRS Set 1
- EFRAG — European Sustainability Reporting Standards portal
- EFRAG — VSME Voluntary Standard
This page provides general information and does not constitute legal advice. Regulatory obligations depend on sector, product category, and jurisdiction.
Last updated: April 2026
