EFRAG Proposes 2026 Sustainability Reporting Work Program – What’s Ahead for CSRD Reporters

EFRAG recently submitted its proposed 2026 sustainability reporting work program to the European Commission. The work program outlines EFRAG’s strategic priorities and planned activities relating to the EU’s Corporate Sustainability Reporting Directive. This post discusses aspects of the work program and their timing that will be of interest to CSRD reporters.  

EFRAG’s mission is to serve the European public interest in financial and sustainability reporting by developing and promoting European views in the field of corporate reporting. As part of the sustainability reporting pillar, EFRAG has been mandated to provide technical advice to the European Commission on CSRD reporting standards and related implementation support. 

EFRAG’s proposed 2026 sustainability reporting work program includes the activities discussed below. Timing is dependent on, among other things, adoption of the “simplified” ESRS and Voluntary Standard delegated acts by the Commission.

N‑ESRS for Third‑country Undertakings

EFRAG’s 2026 work program includes preparing technical advice on N-ESRS for non-EU undertakings that come within the scope of Article 40a of the CSRD. 

EFRAG’s development of the N-ESRS draft standard is expected to include a public consultation and preparation of an exposure draft. The draft will reflect the content of the simplified ESRS adopted by the Commission. 

EFRAG intends to commence a 100-day public consultation on an N-ESRS exposure draft in mid‑July. EFRAG has indicated that outreach will target jurisdictions of affected groups, with workshops across time zones. Delivery of N-ESRS technical advice to the European Commission is targeted for the end of January 2027.

EFRAG’s November 2024 N-ESRS working papers are discussed in this Ropes & Gray post.

The SME Ecosystem

Omnibus I contemplates adoption by the European Commission of a new Voluntary Standard based on the Voluntary Standard for SMEs previously issued by EFRAG and endorsed by the Commission. The new Voluntary Standard will be available for use by companies not required to report under the CSRD as amended by Omnibus I. The work program plans for the Voluntary Standard delegated act to be issued in June.

According to the work program, EFRAG will continue building the ecosystem to support the Voluntary Standard. In the second half of 2026, EFRAG plans to develop supporting guides for the Voluntary Standard that provide practical assistance. It also plans to launch a second acceptance survey on the use of the Voluntary Standard and its Digital Template. EFRAG also may consider developing a Q&A to address recurring implementation questions if the agenda consultation (discussed below) and stakeholder feedback confirm there is a need. In March, EFRAG issued a call for expressions of interest inviting out‑of‑scope non‑SMEs and other stakeholders to participate in engagement and research activities to inform application of the Voluntary Standard.

In addition, EFRAG plans to develop educational materials and training modules on the Voluntary Standard within the ESRS Knowledge Hub and to make technical enhancements to the XBRL taxonomy and Digital Template to support usability, interoperability and digital readiness. 

Interoperability with International Frameworks

The work program indicates that interoperability with international standards remains a central strategic consideration, to limit reporting fragmentation and avoid unnecessary duplication for EU undertakings.

In furtherance of this goal, EFRAG intends to participate in international standard-setter consultations. To the extent consultation timelines do not permit a public consultation on EFRAG draft responses, it will employ alternative outreach mechanisms such as targeted stakeholder workshops..

EFRAG also plans to update its interoperability mappings after the ESRS delegated act is adopted. 

Digitalization

The work program indicates that digitalization is recognized as a key enabler for the effective application of ESRS and the Voluntary Standard.

EFRAG plans to prepare an XLS‑based list of ESRS requirements that updates EFRAG Implementation Guide 3 (IG 3). It also intends to develop an updated ESRS XBRL taxonomy to support machine readability and integration into the European Single Electronic Format by December. EFRAG anticipates beginning consultations on XLS-based list requirements and the updated ESRS XBRL taxonomy in mid-July, with 60‑ to 90‑day comment periods. 

EFRAG also plans to enhance its ESRS Knowledge Hub to include interactive ESRS text and user support tools. Additional Knowledge Hub features such as multilingual content, educational modules and AI‑assisted navigation are contemplated but depend on funding and governance decisions. 

Education

This part of the work program contemplates the development of educational materials, including explanatory videos and guidance, and training content. These activities are expected to be closely coordinated with the ESRS Knowledge Hub to ensure accessibility across EU member states.

Implementation Support

This portion of the work program involves two sequential steps: first, collecting preliminary stakeholder input on future guidance needs and designing an effective mechanism for delivering these materials, leveraging lessons from EFRAG’s prior support activities; and second, based on the preliminary input collected, consulting on proposals and agreeing on the approach and process for future implementation support. EFRAG intends to consult by the end of June/mid-July on the priority topics that should be addressed in future EFRAG implementation activities. Depending on the outcomes of the consultation, EFRAG may begin preparing implementation support materials in the second half of 2026 for both ESRS and the Voluntary Standard.

In addition, the work program indicates that, during the first half of the year, the EFRAG Secretariat will conduct a market study, involving companies and other stakeholders that have an interest in voluntary reporting by non-SME-companies outside the scope of the CSRD. This is intended as an input for the discussion on the future approach and content of implementation guidance for the Voluntary Standard.

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