Revised ESRS in force 10 November: what Indian groups need

The revised European Sustainability Reporting Standards (ESRS) enter into force today, 10 November 2026. Published in the EU's Official Journal on 21 September as Delegated Regulation (EU) 2026/1563, they replace the first set of ESRS adopted in 2023 for financial years beginning on or after 1 January 2027.^{1 2}

What it means for Indian groups

EU subsidiaries in scope of the CSRD — those with more than 1,000 employees and more than €450 million turnover — report on FY 2027 under the revised standards, in 2028.³ For FY 2026, companies already reporting may choose the original ESRS, the original ESRS with the new reliefs, or the revised ESRS in full, and must say which they used.¹

Indian groups with more than €450 million of EU turnover and a qualifying EU subsidiary or branch report on FY 2028, in 2029.^{3 4}

The main reliefs

• A top-down approach to the double materiality assessment, starting from strategy and known issues.¹
• Value-chain limitations, and reliefs for acquisitions and disposals.¹
• A cap on data requests to smaller suppliers: a separate voluntary standard, Delegated Regulation (EU) 2026/1560, limits what in-scope companies may ask of value-chain companies with 1,000 or fewer employees, from financial years beginning on or after 1 January 2027.¹

What Indian suppliers should do

Suppliers with 1,000 employees or fewer can expect EU customers' requests to follow the voluntary standard's datapoints. Preparing one standard answer — energy, emissions, water, waste and workforce figures, with evidence — makes each request quicker.

Our guides CSRD for Indian companies and Double materiality assessment under the revised ESRS go into detail. ESGTrack holds the double materiality assessment and the ESRS disclosures on the standards adopted in 2023 — which companies may still use for FY 2026 — with the revised ESRS shown as a regulatory update; see CSRD and ESRS.