ESRS Sustainability Topics: The New List for the Double Materiality Analysis
As part of the double materiality analysis, companies determine which sustainability issues are material to them. These issues are the thematic categories for which impacts, risks, and opportunities are assessed. The revised ESRS changes the composition of this list. In this article, you’ll find the new list, an explanation of how it was derived from the previous version, and a recommendation for how to use it.
As of August 2026. The information refers to the delegated act dated July 3, 2026, in its German-language version. For the scope and timeline of the Corporate Sustainability Reporting Directive (CSRD) as a whole, please see our article on the CSRD Implementation Act.
The revised ESRS have been adopted but have not yet entered into force
The European Commission adopted the revised ESRS as a delegated regulation on July 3, 2026. It amends Delegated Regulation (EU) 2023/2772 and completely replaces its Annex I. According to the Commission, the number of mandatory data points will decrease by more than 60%, and the total number of data points by more than 70%.
The act is not yet legally in effect. Parliament and the Council have a two-month review period, which may be extended by two additional months. Only then will it be published in the Official Journal and take effect three days later. The revised standards are to be applied to fiscal years beginning on or after January 1, 2027. For the 2026 fiscal year, there is an option: You may report in accordance with ESRS (2023) or voluntarily adopt ESRS (2026) early.
For your planning purposes, this means: If you are reporting for 2026 according to the current version, continue to use the old list of topics. If you are already using the new ESRS for 2026 or planning your reporting for 2027, you should base your materiality analysis on the new list.
Five changes to the list of topics that affect your analysis
AR 16 becomes Appendix A. The list is no longer included in the application requirements of ESRS 1 but is now contained in a separate appendix. According to ESRS 1, paragraph 18, the application requirements are binding; the appendix is expressly not.
The sub-subtopic level has been omitted. The table now has only two columns: Topics and Subtopics. What was previously listed as a sub-subtopic is now either included in parentheses within the subtopic, has been moved to the subtopic level, or is no longer listed.
ESRS S1 and ESRS S2 share a row. Both standards have identical subtopics in the list. They remain two separate standards with separate disclosure requirements. A footnote clarifies that the depth and granularity of the assessment for workers in the value chain depend on the type and quality of available data. The subtopic “Water and Sanitation” applies only to ESRS S2.
ESRS E3 is now called “Water.” Marine resources have been removed from the standard. ESRS E5 now addresses the nature and recyclability of resource inflows, including marine resources.
Sustainability aspects become sustainability issues. ESRS 1, paragraph 14, clarifies that the terms “sustainability-related topic” and “sustainability-related subtopic” are to be understood as synonymous with the terms “sustainability aspects” and “sustainability factors” in the Accounting Directive. From a technical standpoint, this does not change anything; however, the terminology used in your internal documents and templates will change.
The ESRS (2026) list of topics and its origins in the previous version
The following table reproduces Appendix A of ESRS 1. The right-hand column shows the origin of each subtopic in the previous AR-16 list.
| ESRS | Topic | Subtopic | Origin in the ESRS (2023) |
|---|---|---|---|
| ESRS E1 | Climate Change | Climate Protection | unchanged |
| Adaptation to Climate Change | unchanged | ||
| Energy | unchanged | ||
| ESRS E2 | Environmental pollution | Air Pollution | unchanged |
| Water pollution | unchanged | ||
| Soil Contamination | unchanged | ||
| Substances of Concern and Substances of Very High Concern | Two previous subtopics have been combined | ||
| Microplastics | unchanged | ||
| – | Contamination of living organisms and food resources is no longer specifically mentioned | ||
| ESRS E3 | Water | Water use, including abstraction, consumption, discharge, and storage | summarizes the previous subtopics on water; storage is a new topic, and discharge into the oceans is no longer mentioned separately |
| – | Marine resources have been moved to ESRS E5; the standard title is now “Water” | ||
| ESRS E4 | Biodiversity and Ecosystems | Factors influencing changes in biodiversity and ecosystems (including changes in terrestrial and marine habitats, invasive species) | From “Direct Causes of Biodiversity Loss”; of the seven causes listed, two are explicitly identified |
| Status of Species | from “Impacts on Species Status” | ||
| Extent and Condition of Terrestrial and Marine Ecosystems | from “Effects on the Extent and Condition of Ecosystems” | ||
| Ecosystem Services | From “Impacts and Interdependencies of Ecosystem Services” | ||
| ESRS E5 | Circular Economy and Resource Use | Inflows of resources | From “Resource inflows, including resource use”; now also includes marine resources |
| Resource Outflows Related to Products and Services | unchanged | ||
| Resource Outflows (Waste) | from “Waste” | ||
| ESRS S1/S2 | The company’s workforce and workers in the value chain | Working conditions (including fair pay, work-life balance, working hours, and job security) and social protection | from the previous subtopic “Working Conditions”; “Social Security” is a new entry on the list |
| Social dialogue and collective bargaining, freedom of association, workers’ rights to information and consultation, including through works councils | Previously, there were three sub-subtopics on working conditions; now there is a separate subtopic | ||
| Health and Safety | Previously a subtopic under “Working Conditions”; now a separate subtopic | ||
| Continuing Education and Skills Development | Previously a subtopic under “Equal Treatment,” now a separate subtopic | ||
| Diversity and Equal Treatment (including gender equality, equal pay for equal work, employment and inclusion of people with disabilities, non-discrimination, and measures to combat violence and harassment) | from “Equal Treatment and Equal Opportunity”; non-discrimination has been explicitly added | ||
| Other work-related human rights (including child labor, forced labor, privacy, and adequate housing, water, and sanitation) | From “Other Work-Related Rights”; Water and Sanitation applies only to ESRS S2 | ||
| ESRS S3 | Affected Communities | Economic, social, and cultural rights of communities (including territorial and security-related impacts, adequate housing, and adequate food, water, and sanitation) | The content remains unchanged; the previous sub-subtopics are now listed in parentheses. |
| Civil and Political Rights of Communities (including freedom of expression, freedom of assembly, and implications for human rights defenders) | unchanged in content | ||
| Rights of Indigenous Peoples (including free, prior, and informed consent; self-determination; and cultural rights) | unchanged in content | ||
| ESRS S4 | Consumers and end users | Information-related impacts on consumers or users (including privacy, access to information, and freedom of expression) | Previously “Access to high-quality information,” now “Access to information” |
| Personal safety of consumers or end users (including health and safety, protection of children, and personal safety) | unchanged in content | ||
| Social inclusion of consumers or end users (including access to products and services, responsible marketing practices, and non-discrimination) | unchanged in content | ||
| ESRS G1 | Corporate Governance | Corporate culture, including the fight against corruption and bribery, the protection of whistleblowers, and animal welfare | summarizes four previous points in a subtopic |
| Political influence, including lobbying | From “Political Engagement and Lobbying Activities” | ||
| Management of supplier relationships, including payment practices, particularly with regard to late payments to small and medium-sized enterprises (SMEs) | Provisions regarding late payments to small and medium-sized enterprises (SMEs) have been explicitly added |
Source: Delegated Regulation amending Delegated Regulation (EU) 2023/2772, C(2026) 5010 final dated July 3, 2026, Annex I, ESRS 1, Appendix A. The German version of the legal act uses the term “Abteilung” instead of “Ableitung” in one instance; we assume this is a translation error that will be corrected in the Official Journal.
Download the ESRS Topic Comparison: Old vs. New 2026
To facilitate the transition of your materiality analysis, we have compared the two lists. The file contains the mapping in both directions—from the previous AR-16 list to Appendix A and back—with the type of change specified for each entry. This allows you to see, for each row, whether a topic remains unchanged, has been consolidated, has been moved, or is no longer included.
The list is a starting point, not a checklist
The preamble to Appendix A explicitly specifies the order of the list:
“This appendix is an integral part of ESRS 1 General Requirements and provides non-binding guidance on the application of the provisions set forth in this standard. The following table lists the topics and subtopics covered by topic-specific standards that are included in the dual materiality assessment. The entity must consider its own specific circumstances when determining the topics or subtopics to be reported.” (ESRS 1, Appendix A)
Important: The list of topics does not definitively limit the materiality analysis. On the contrary, ESRS 1, paragraph 11, requires that if a topic with material impacts, risks, or opportunities is not covered by the ESRS—or is covered with insufficient granularity—the company must provide company-specific disclosures. This may be due to sector-specific characteristics or to circumstances that are relevant only to that company.
Non-essential issues don’t require justification, but climate change does
Two rules are interrelated here. ESRS 1, paragraph 24, prohibits the disclosure of non-material information: A company may not report information required by a disclosure requirement or a data point if that information is not material. Non-material information is therefore not merely omitted—it has no place in the report.
The ESRS do not require a separate justification for this. The only exception is climate change: If a company omits all disclosure requirements under ESRS E1, it must disclose the basis for this conclusion in accordance with ESRS 2 IRO-2, paragraph 37(b). This exception already applied under the ESRS (2023) and remains in effect.
For documentation purposes, however, this means that the reasoning behind your decision must be clearly included in your records, even if it isn’t included in the report. Reviewers will examine how you arrived at your selection.
Dual materiality remains the guiding principle for reporting
Materiality has two dimensions: impact materiality and financial materiality. The first examines how the company affects people and the environment. The second examines how sustainability issues affect earnings, financial position, cash flows, access to financing, and cost of capital. One dimension is sufficient for classification as material.
According to ESRS 1, paragraph 36, the starting point is generally the assessment of impacts. In addition, the company evaluates whether there are significant risks or opportunities unrelated to its own impacts, such as physical risks. The revised version also clarifies that not every request for information from individual stakeholders needs to be included in the analysis.
Your Materiality Analysis with CONSUST
The dual materiality analysis determines which standards you apply and which data points you collect. A clearly documented, logically derived analysis reduces the effort required for data collection and supports the audit. Our FramesCube software maps the topics in Appendix A and assigns the corresponding ESRS data points to them. The substantive decision regarding what is material for your company remains yours; the system handles the documentation of this decision.
If you report according to GRI, IFRS S1/S2, or EMAS in addition to ESRS, there is no need to collect the list of topics twice. Our article on the interoperability of sustainability standards explains how these frameworks relate to one another and where a single data collection is sufficient for all of them.
Do you need assistance with preparing and conducting your materiality analysis? Contact us for a no-obligation consultation.
This article presents a professional assessment based on the sources cited, as of August 2026, and is not a substitute for a legal review of a specific case.
