How to Identify Your ESRS Data Points (Revised ESRS 2026)

"Which ESRS data points do we actually have to report?" is the question that follows every double materiality assessment. Under the revised ESRS, adopted by the European Commission on 3 July 2026, the answer has become much shorter, but the method for getting there has not changed: your material topics decide your datapoints. This guide walks you through that method step by step, using EFRAG's 2026 draft list of datapoints.

In short: EFRAG's 2026 draft list for the revised ESRS contains 359 datapoints, compared with 1,144 in the 2024 IG 3 list. You do not report all of them. ESRS 2 (63 datapoints) is likely material for every company, the GDR (31 datapoints) apply to the policies, actions, metrics and targets of your material topics, and the topical standards E1 to G1 only apply where your double materiality assessment found a material topic. To build your list: (1) take your DMA result, (2) map material topics and sub-topics to disclosure requirements, (3) pull their datapoints from the EFRAG list, (4) filter out conditional datapoints and apply phase-ins, (5) assign data owners and close the gaps. Reporting immaterial information is no longer a safe default: the revised ESRS 1 §24 says you shall not disclose it.

What is an ESRS datapoint?

An ESRS datapoint (often searched as "CSRD data point") is the smallest unit of information a disclosure requirement asks for. Each ESRS standard is split into disclosure requirements (for example E1-6), and each disclosure requirement is split into datapoints: a single number, a short statement or a narrative description.

EFRAG's list classifies every datapoint by data type. In the 2026 draft list, 129 datapoints are narrative and 50 semi-narrative; the rest are quantitative or mixed (percentages, monetary amounts, GHG emissions, energy, mass, volume, dates). The quantitative ones are what many people call ESRS metrics.

Datapoints matter because they are the level at which work actually happens: someone has to own each one, find the data, and be able to show the auditor where it came from.

How many ESRS datapoints are there in 2026?

The 2024 EFRAG IG 3 List of ESRS Datapoints catalogued 1,144 datapoints for the original ESRS. EFRAG's 2026 draft list, released on 28 August 2026 for the revised ESRS, contains 359. According to EFRAG, mandatory datapoints fell by around 61%, and total datapoints by around 71%, because all voluntary ("may disclose") datapoints were removed. We cover the full background in our article on EFRAG's 2026 draft list of ESRS datapoints.

ESRS 1 contains no datapoints; it sets the general rules. The 359 datapoints are spread across twelve sets:

Two more numbers from the list are useful for planning: 122 datapoints are flagged as conditional (they only apply if a condition is met) and 10 as alternative presentations (you choose one way of presenting the information). In other words, even the 359 overstate what a single company reports.

Note that the 2026 list is a draft. EFRAG collected feedback until 23 October 2026, and the XBRL taxonomy and guidance are still being finalised. Use it to scope your reporting, and check efrag.org for the final version.

What always applies and what depends on your material topics

The revised ESRS split your datapoints into three groups.

1. ESRS 2: likely material for everyone. In the 2023 ESRS, ESRS 2 applied irrespective of the materiality assessment. The revised text is more nuanced: the ESRS 2 disclosure requirements are "likely to result in material information for all undertakings". In practice, plan to report the 63 ESRS 2 datapoints (basis for preparation, governance, strategy and business model, and the IRO disclosures that describe your DMA), and document your reasoning if you consider an individual ESRS 2 item not material.

2. GDR: the minimum content for each material topic. The general disclosure requirements (GDR) for policies, actions, metrics and targets replace the Minimum Disclosure Requirements (MDR) of the 2023 ESRS. They define what you disclose about the policies, actions, metrics and targets for each material topic. Because they apply per topic, the same 31 GDR datapoints can appear several times in your sustainability statement.

3. Topical standards: only where a topic is material. E1 to G1 apply only to the topics your double materiality assessment identified as material. If climate change is material, E1 applies; if water is not, E3 does not. One relief worth knowing: if you conclude that climate change is not material, ESRS 2 IRO-2 §37(b) now only requires the basis for that conclusion, no longer the detailed forward-looking analysis demanded in 2023.

How to identify your ESRS datapoints in 7 steps

Step 1: Start from your double materiality assessment result

Your datapoint list can only be as good as your DMA. You need a documented list of material topics and sub-topics, ideally with the material impacts, risks and opportunities (IROs) behind each one.

The revised ESRS make this step more proportionate: you may reach topic-level conclusions top-down (ESRS 1 §27), you are not required to assess every possible IRO (§32), and you only need to update the DMA when significant changes occur (§34). All changes are explained in our article on the double materiality assessment under the revised ESRS, and our double materiality assessment example shows a complete result for a mid-sized manufacturer.

Step 2: Translate material topics and sub-topics into topical standards

The list of sustainability matters (formerly ESRS 1 AR 16) now sits in Appendix A of ESRS 1. It is non-binding guidance, sub-sub-topics are gone, E3 is now simply "Water" and marine resources moved to E5. Use it to make sure your material topics are expressed in ESRS language, so you can match each one to its topical standard. Our ESRS topics list for 2026 gives you the full structure.

If one of your material topics is not covered by any topical standard, you will need to report it with your own company-specific information. The EFRAG list does not cover it, so plan it separately.

Step 3: Select the disclosure requirements

For each material topic, open the topical standard and identify the disclosure requirements that relate to your material IROs. Then add the ESRS 2 disclosure requirements and the GDR for the policies, actions, metrics and targets of each material topic.

Keep a record of why each disclosure requirement is in or out. Your auditor will review the DMA and its link to the sustainability statement under limited assurance, and this record is the bridge between the two.

Step 4: Pull the datapoints from the EFRAG list

Now go down one level: filter the EFRAG workbook (or the ESRS Datapoint Explorer) by the selected disclosure requirements and copy out their datapoints. For each datapoint, keep the paragraph reference, the data type and the flags. This is your gross datapoint list.

Step 5: Filter conditional and alternative datapoints

Go through the 122 conditional datapoints in your gross list and check whether the condition applies to you. Typical conditions depend on whether you have a relevant policy, target or activity in the first place. Where a datapoint is marked as an alternative presentation, decide which presentation you use and drop the other.

Then apply the information filter: within a material topic, check whether each remaining piece of information is actually material for your situation (see the section on §24 below). The result is your net datapoint list.

Step 6: Check phase-ins and your FY2026 option

Some datapoints can be omitted in your first reporting years. EFRAG's workbook marks phase-ins in three columns, labelled "prior to FY 2027", "prior to FY 2030" and "first two FY of reporting". One example: for wave-one companies, the anticipated financial effects in SBM-3 can be omitted in qualitative form before FY2028 and in quantitative form before FY2030.

Also confirm which rulebook you apply. For financial year 2026, companies can choose between the 2023 ESRS, the revised ESRS in full, or the 2023 ESRS with a set of reliefs, and must state the choice in the sustainability statement. If you stay on the 2023 ESRS for FY2026, the 1,144-datapoint IG 3 list is still your reference for that year. From FY2027, the revised ESRS are mandatory.

Step 7: Assign data owners and run a gap analysis

Finally, turn the list into a work plan. For each datapoint, name an owner (finance, HR, procurement, operations, legal), note the source system, and mark whether the data exists today, exists partly or does not exist at all. The data type helps: quantitative datapoints usually need a system and a calculation method, narrative ones need a policy or process description and a responsible author.

When the gap sits in your value chain, remember the value chain cap: from financial years starting on or after 1 January 2027, you may not require more from value chain partners with up to 1,000 employees than the Voluntary Standard contains. The revised ESRS allow you to use sector or regional data instead (ESRS 1 §33).

Over-reporting is now a problem too: the "shall not disclose" rule

Under the 2023 ESRS, many companies reported datapoints "just in case". The revised ESRS 1 §24 closes that door: a company shall not disclose information that is not material. The Commission deliberately tightened EFRAG's softer "is not required to" wording. Clearly labelled supplementary information remains possible (§§107–108), and the new fair presentation chapter (§§19–21) judges the sustainability statement as a whole.

For your datapoint list this means two things. First, the filtering in Steps 3 to 5 is no longer optional housekeeping; it is part of compliance. Second, a datapoint list copied from a peer or a consultant template is risky in both directions: it can miss material datapoints and include immaterial ones. Your list has to follow from your DMA.

Excel list, explorer or mapping tool: which route fits?

There are three practical ways to get from material topics to datapoints.

The Excel route is free and authoritative, but the mapping work is yours: matching each material sub-topic to disclosure requirements, checking conditions and documenting the reasoning. For a first report this typically takes days, not hours.

The mapping tool automates exactly that step. You enter the material topics from your DMA, preview the result before you buy, and download your datapoint list in Excel and PDF. It now uses the revised ESRS datapoints (EFRAG 2026 draft list) instead of the legacy 1,144-datapoint list. Our guide to the ESRS Data Points Mapping Tool shows every step.

Common mistakes when identifying ESRS datapoints

• Using the wrong list. The 1,144-datapoint IG 3 list belongs to the 2023 ESRS. If you report under the revised ESRS, work with the 2026 list, and say clearly in your sustainability statement which option you applied for FY2026.
• Reporting everything "to be safe". Under §24 this is no longer neutral. Immaterial information has to be left out or clearly marked as supplementary.
• Forgetting ESRS 2 and the GDR. They account for 94 of the 359 datapoints and apply regardless of which topical standards are material.
• Treating the topic list as a mandatory checklist. Appendix A is non-binding guidance. You do not need a documented conclusion for every line, but you do need a defensible rationale for your material topics.
• Ignoring conditional datapoints. A third of the list is conditional. Not checking the conditions inflates your workload and your report.
• Overlooking phase-ins. Some datapoints can be omitted in your first years. Check the phase-in columns before you start collecting data.
• Assigning owners too late. Data that nobody owns is a common reason first reports run late. Do Step 7 straight after the mapping.

Who needs to identify ESRS datapoints after Omnibus I?

Under the Omnibus I Directive (EU) 2026/470, the CSRD applies to EU companies with more than 1,000 employees and more than €450 million net turnover. Former wave-two companies that meet these thresholds report for the first time for FY2027. Non-EU groups follow from FY2028 if they generate more than €450 million in the EU and have an EU subsidiary or branch with more than €200 million turnover. Listed SMEs are no longer in scope.

Companies below the thresholds can report voluntarily under the Voluntary Standard (VS), which has no materiality assessment and a fixed set of disclosures, so the method in this guide does not apply to them. Our comparison of VSME vs ESRS after Omnibus explains who reports under which standard.

Next step: from material topics to your datapoint list

Identifying your ESRS datapoints is a mapping exercise with a clear sequence: DMA result, topics, disclosure requirements, datapoints, filters, owners. With 359 datapoints instead of 1,144 it is far more manageable than in 2024, but the stricter rules on immaterial information make it more important to get it right.

Materiality Master covers the full chain: run your double materiality assessment in the app, then map the material topics to the revised ESRS datapoints with one click. You can buy a single mapping for €997 or get unlimited mappings with the annual plan. Compare all options on our pricing page.