Sector-specific ESRS

What is Sector-specific ESRS?

The original CSRD architecture envisaged two tiers of sustainability reporting standards. Set 1, adopted in July 2023 via Delegated Regulation (EU) 2023/2772, contains 12 sector-agnostic standards that apply to all in-scope undertakings. Article 29b of the amended Accounting Directive then empowered the Commission to adopt supplementary standards addressing sustainability matters specific to particular sectors.

Sector-agnostic ESRS cover topics like climate change and own workforce at a level of generality that cannot capture industry-specific risks. A food producer's water consumption profile differs from a mining company's biodiversity exposure. Sector-specific standards were meant to close that gap by prescribing additional disclosure requirements and datapoints relevant to each industry's material sustainability matters, layered on top of whatever the double materiality assessment already required under ESRS 1 paragraphs 37–58.

EFRAG prioritised eight sectors for the first wave, including oil and gas; mining, quarrying, and coal mining; road transport; agriculture, farming, and fisheries; motor vehicles; energy production and utilities; food and beverages; and textiles, accessories, footwear, and jewellery. Exposure drafts for oil and gas and for mining were published in September 2024. The remaining six were at earlier drafting stages when the Omnibus I process overtook the timeline.

The Omnibus I directive, published in the Official Journal on 26 February 2026, removed the Commission's empowerment entirely. The rationale was to avoid increasing required datapoints at a time when the simplified ESRS (submitted by EFRAG in December 2025) were cutting mandatory datapoints by over 60%. In place of binding standards, the Commission retained the ability to issue non-binding sector-specific guidance on identifying sustainability matters likely to be material for a typical undertaking in a given sector.

Worked example: Rossi Alimentari S.p.A.

Client: Italian food production company, FY 2026, revenue EUR 67M, IFRS reporter. Rossi is a Wave 1 entity (large public-interest entity) preparing its third CSRD-compliant sustainability statement.

Step 1 — Confirm regulatory status

Rossi's sustainability team confirms that no sector-specific ESRS have been adopted. The Omnibus I directive removed the Commission's empowerment, and the EFRAG exposure drafts for food and beverages never reached final adoption.

Step 2 — Use sector-agnostic ESRS to capture industry-specific matters

Rossi's double materiality assessment under ESRS 1.37–58 identifies water and marine resources (E3) and biodiversity and ecosystems (E4) as material alongside climate change (E1) and own workforce (S1). These topics would have been addressed by the planned food-sector standard with industry-specific datapoints (water withdrawal per tonne of output, agricultural land use, seasonal workforce conditions, and food waste volumes). Without the sector standard, Rossi applies the general disclosure requirements under ESRS E3, E4, and S1.

Step 3 — Consider available guidance

The Commission has not yet published sector-specific guidance for the food industry as of March 2026. Rossi's team reviews EFRAG's September 2024 exposure draft for food and beverages as an informal reference, adapting relevant disclosure concepts (supply chain traceability for raw materials, food waste metrics) without treating them as mandatory.

Step 4 — Brief the assurance provider

Rossi's auditor scopes the limited assurance engagement to cover the sector-agnostic ESRS disclosures only. The voluntary industry-specific metrics fall outside the mandated scope. Rossi and the auditor agree that those metrics will be covered by a separate agreed-upon procedures engagement.

Conclusion: Rossi's sustainability statement is defensible because the regulatory status of sector-specific ESRS is documented and mandatory disclosures follow the sector-agnostic standards, while voluntary industry metrics are clearly separated from the assured scope.

Why it matters in practice

• Teams at companies in high-impact sectors (mining, oil and gas, food production) sometimes treat EFRAG's unpublished or unadopted exposure drafts as quasi-mandatory, incorporating draft sector datapoints into the sustainability statement without disclosing that these are voluntary additions. ESRS 1.14 limits mandatory disclosure requirements to adopted standards. Mixing unadopted draft requirements into the mandatory reporting scope confuses the assurance provider and creates a risk that the sustainability statement implies compliance with standards that do not exist.
• Practitioners overlook the distinction between the removal of mandatory sector-specific ESRS and the Commission's retained power to issue non-binding guidance. When that guidance eventually appears, it will inform the double materiality assessment but will not create new disclosure requirements. Auditors who treat future guidance as though it carries the same weight as an adopted standard misrepresent the regulatory framework to the entity.

Sector-specific ESRS vs. sector-agnostic ESRS (Set 1)

The distinction matters for scoping the sustainability assurance engagement. With sector-specific ESRS cancelled, the assurance provider evaluates completeness of disclosures against the sector-agnostic standards only. Any industry-specific metrics the entity reports voluntarily sit outside the mandatory assurance scope unless explicitly included by agreement.

Related terms

Frequently asked questions