ESRS Topics List 2026: Revised Sustainability Matters (Appendix A)

Every double materiality assessment (DMA) starts with the same question: which sustainability matters do we look at? The answer used to be ESRS 1 AR 16, a long list of topics, sub-topics and sub-sub-topics that many companies worked through line by line. With the revised ESRS, that list has moved, shrunk and changed its legal status. This article shows the ESRS topics list 2026 as it now stands in ESRS 1 Appendix A, what changed compared to AR 16, how many datapoints sit behind each topical standard and how to use the list efficiently in your DMA.

In short: The list of sustainability matters moved from ESRS 1 AR 16 (2023) to ESRS 1 Appendix A in the revised ESRS (Delegated Regulation (EU) 2026/1563). It is now non-binding guidance and "one of the inputs" to the DMA. Sub-sub-topics are gone, E3 is now called "Water" with marine resources moved to E5, and you no longer have to document a conclusion for every line. The list covers 10 topical standards (E1 to E5, S1 to S4, G1), which together contain 265 of the 359 datapoints in EFRAG's 2026 draft datapoint list. Use it as a checklist for a top-down screening, go bottom-up only where the outcome is not evident, and add entity-specific topics where needed.

For the full picture of how the revised standards change the DMA, read our article on the double materiality assessment under the revised ESRS. If you are new to the topic, start with our CSRD double materiality assessment guide.

What is the ESRS list of sustainability matters?

The list of sustainability matters (often simply called the ESRS topics list) is the overview of the topics and sub-topics covered by the ten topical standards. Each topic corresponds to one topical standard, for example E1 Climate change or S1 Own workforce. The sub-topics break each topic down into the areas where impacts, risks and opportunities (IROs) typically arise.

A material topic is a topic or sub-topic that meets the criteria for impact materiality, financial materiality or both. Material topics are the output of your DMA, and they determine which topical disclosure requirements, and therefore which datapoints, you report.

The revised ESRS were adopted by the European Commission on 3 July 2026, published in the Official Journal on 21 September 2026, enter into force on 10 November 2026 and are mandatory for financial years starting on or after 1 January 2027. For financial year 2026, companies can still choose between the 2023 and the revised standards.

From ESRS 1 AR 16 to Appendix A: what changed

Aspect	2023 ESRS	Revised ESRS (2026)
Location	ESRS 1, application requirement AR 16	ESRS 1, Appendix A "List of topics"
Status	Part of the application requirements; to be considered in the DMA	Non-binding guidance, "one of the inputs" to the DMA
Levels	Topics, sub-topics, sub-sub-topics	Topics and sub-topics only; former details appear as examples in brackets
E3	Water and marine resources	Water; marine resources moved to E5
Documentation in practice	Many companies documented a conclusion for every line	No need to document a conclusion for every line
Entity-specific topics	Required where necessary	Still required where necessary (ESRS 1 §11)

The introduction to Appendix A sums up its new role. It states that the appendix "provides non-binding guidance" and that the table lists the topics and sub-topics "as one of the inputs to the double materiality assessment. The undertaking needs to consider its own specific circumstances when determining the topics or sub-topics to be reported." Where necessary, the company "shall consider topics or sub-topics not covered by ESRS to develop entity-specific disclosures".

EFRAG describes the list as "no longer mandatory to consider". It remains a very useful checklist, but it is no longer a form that has to be filled in line by line.

The 10 topical ESRS at a glance, with 2026 datapoints

The table below shows the ten topical standards, the number of datapoints per standard in EFRAG's 2026 draft list of datapoints (published on 28 August 2026) and the disclosure requirement codes. The figures come from the dataset behind our free ESRS Datapoint Explorer.

Standard	Topic	Datapoints (2026 draft)	Disclosure requirements
E1	Climate change	87	E1-1 to E1-11
E2	Pollution	20	E2-1 to E2-5
E3	Water	11	E3-1 to E3-4
E4	Biodiversity and ecosystems	12	E4-1 to E4-5
E5	Resource use and circular economy	18	E5-1 to E5-5
S1	Own workforce	52	S1-1 to S1-16
S2	Workers in the value chain	15	S2-1 to S2-4
S3	Affected communities	15	S3-1 to S3-4
S4	Consumers and end-users	12	S4-1 to S4-4
G1	Business conduct	23	G1-1 to G1-6
Total topical standards		265

The remaining 94 datapoints sit in ESRS 2: 63 in the general disclosures (BP, GOV, SBM and IRO) and 31 in the new general disclosure requirements for policies, actions, metrics and targets (GDR, which replace the former MDR). ESRS 1 contains no datapoints. In total, the 2026 draft list has 359 datapoints, compared with 1,144 in the 2024 list (EFRAG IG 3). We explain the cut in our article on EFRAG's 2026 draft list of ESRS datapoints.

The revised sub-topics (ESRS 1 Appendix A)

The sub-topics below are taken from ESRS 1 Appendix A as adopted in Delegated Regulation (EU) 2026/1563, as published in the EFRAG Knowledge Hub. The legally binding version is the text in the Official Journal (EUR-Lex).

Topic (Appendix A)	Sub-topics
Climate change (E1)	Climate change mitigation; climate change adaptation; energy
Pollution (E2)	Pollution of air; pollution of water; pollution of soil; substances of concern, including substances of very high concern; microplastics
Water (E3)	Water use, which includes withdrawal, consumption, discharges and storage
Biodiversity and ecosystems (E4)	Drivers of biodiversity and ecosystem change (including terrestrial and marine habitat change, invasive species); state of species; the extent and condition of terrestrial and marine ecosystems; ecosystem services
Circular economy and resource use (E5)	Resource inflows; resource outflows related to products and services; resource outflows (waste)
Own workforce and workers in the value chain (S1/S2)	Working conditions (including adequate wages, work-life balance, working time, secure employment) and social protection; social dialogue and collective bargaining, freedom of association, information and consultation rights of workers, including through works councils; health and safety; training and skills development; diversity and equal treatment (including gender equality, equal pay for work of equal value, employment and inclusion of people with disabilities, non-discrimination, anti-harassment, measures against violence); other labour-related human rights (including child labour, forced labour, privacy and adequate housing, water and sanitation)
Affected communities (S3)	Communities' economic, social and cultural rights (including land-related impacts, security-related impacts, adequate housing and food, water and sanitation); communities' civil and political rights (including freedom of expression, freedom of assembly, impacts on human rights defenders); rights of indigenous peoples (including free, prior and informed consent, self-determination, cultural rights)
Consumers and end-users (S4)	Information-related impacts for consumers or users (including privacy, access to information, freedom of expression); personal safety of consumers or end-users (including health and safety, protection of children, security of a person); social inclusion of consumers or end-users (including access to products and services, responsible marketing practices, non-discrimination)
Business conduct (G1)	Corporate culture, including anti-corruption and bribery, the protection of whistle-blowers and animal welfare; political influence, including lobbying activities; management of relationships with suppliers, including payment practices, especially late payment to SMEs

Four details are worth noting:

• S1 and S2 share one set of sub-topics. Appendix A adds a note that the depth of the assessment for workers in the value chain depends on the data available, so the way you assess impacts and risks may differ between S1 and S2. "Water and sanitation" applies to S2 only.
• E3 has a single sub-topic. Water use now covers withdrawal, consumption, discharges and storage. Marine resources are addressed under E5 as part of resource inflows.
• G1 is consolidated into three sub-topics. Corporate culture now bundles anti-corruption, whistle-blower protection and animal welfare.
• The former sub-sub-topic level is gone. What used to be a separate line now appears, where it survived, as an example in brackets within a sub-topic.

How to use the topics list in your DMA

The revised ESRS 1 turns the list from a form into a checklist. A proportionate approach looks like this:

1. Start with your business, not the list. Analyse your strategy, business model, sectors, geographies and value chain first. The DMA document checklist shows which inputs to collect.
2. Screen each topic top-down (ESRS 1 §27). For each of the ten topics, decide whether it is clearly material, clearly not material or not evident. A software company can conclude without detailed scoring that biodiversity is not material; a steel producer that climate change is material. Document the reasoning in one or two sentences.
3. Go bottom-up where the outcome is not evident (§28). Identify and assess specific IROs at sub-topic level. You are not required to assess every possible IRO (§32), only the areas where material IROs are likely to arise. Our explainer on IROs under the CSRD explains how to describe them.
4. Add entity-specific topics. If a material matter is not covered by Appendix A, for example cybersecurity for a digital infrastructure provider, add it and develop entity-specific disclosures (§11).
5. Map material topics to disclosure requirements and datapoints. Material topics and sub-topics determine which topical disclosure requirements apply. Our guide to identifying your ESRS datapoints explains the logic, and the ESRS Datapoints Mapping Tool does it for you.

If you visualise the result, our article on the materiality matrix under the revised ESRS shows how to build one on the new topic structure.

What this means for an existing DMA based on AR 16

If your last DMA used the 2023 list, you do not have to start from scratch. The revised ESRS 1 (§34) only requires an update when significant changes occur. When you move to the revised standards, check four things:

• Re-map IROs from sub-sub-topics to the new sub-topics. In most cases this is a relabelling exercise, not a new assessment.
• Move marine resource IROs from E3 to E5. And rename E3 to "Water" in your templates and reports.
• Remove "not material" documentation you no longer need. A top-down rationale at topic level replaces line-by-line conclusions for clearly irrelevant matters.
• Update your datapoint mapping. The revised standards come with a much shorter datapoint list, so the reporting scope for your material topics changes even if the topics themselves do not.

Key takeaways

• The ESRS topics list moved from ESRS 1 AR 16 to ESRS 1 Appendix A and is now non-binding guidance, "one of the inputs" to the DMA.
• Sub-sub-topics are gone, E3 is now "Water" and marine resources sit in E5.
• The 10 topical standards contain 265 of the 359 datapoints in EFRAG's 2026 draft list; E1 (87) and S1 (52) are the largest.
• Use the list for a top-down screening, assess bottom-up only where the outcome is not evident, and add entity-specific topics where needed.
• Existing DMAs do not need to be redone, but IROs should be re-mapped to the new structure.

Materiality Master already uses the revised topic structure. Once your material topics are set, the ESRS Datapoints Mapping Tool turns them into the exact list of 2026 datapoints you need to report. Compare the options on our pricing page.