EFRAG Publishes Draft ESRS Datapoint List, Opens Consultation Ahead of November Handover

The European Financial Reporting Advisory Group has published its 2026 Draft List of Datapoints and accompanying draft XBRL taxonomy for the revised European Sustainability Reporting Standards, based on the Delegated Act the European Commission published on 3 July 2026. The draft has been issued for a "fatal flaw" consultation, with comments accepted via public survey until 23 October 2026, ahead of a planned handover of the finalised taxonomy to ESMA and the European Commission in November 2026.

 

Why Removing "Whether and How" Phrasing Reduces the Boolean Datapoint Count

 

One of the more consequential structural changes in the 2026 draft is the near-total removal of the "whether and how" phrasing that characterised many datapoints under the original 2023 ESRS Set 1. Under the earlier standard, a disclosure requirement using this phrasing typically had to be modelled as a Boolean, a simple yes/no confirmation, paired with a separate narrative explanation, effectively splitting a single disclosure into two distinct trackable data points.

By removing that phrasing from the revised standard text itself, EFRAG's draft substantially reduces the number of Boolean datapoints companies and their reporting systems need to track and tag separately. That change connects directly to the broader simplification objective underlying this revision cycle: fewer split datapoints means a less fragmented reporting structure overall, even where the substantive information being disclosed remains largely unchanged. The few remaining "whether and how" cases are instead modelled as a single combined datapoint carrying both a semi-narrative and narrative data type simultaneously, a technical adjustment intended to better reflect that these disclosures inherently combine a confirmation with an explanation rather than functioning as two independent facts.

 

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Why Separating Disaggregations From the Core Datapoint Count Changes How Simplification Is Measured

 

A methodological shift with real consequences for how the reform's overall scale should be interpreted involves how disaggregations, breakdowns of a datapoint by category, country, gas type or similar dimension, are now treated. Rather than counting each possible disaggregation as its own separate datapoint, as the 2024 Implementation Guidance effectively did through "Table" virtual datapoints, the 2026 draft moves all disaggregation information into a dedicated column alongside the core datapoint, distinguishing mandatory disaggregations (marked with an asterisk) from optional ones.

That accounting change means the headline datapoint count reduction achieved through this revision is not purely a reflection of substantive requirements being cut; part of the reduction reflects a different counting methodology applied to information that, in practice, companies may still need to report in a comparable form. EFRAG's own explanatory note acknowledges this dynamic directly, noting that datapoints merged into a single paragraph as part of the simplification effort were not counted as "deleted" in official reduction statistics, one of the stated reasons the final datapoint count is lower than earlier estimated in the standard's Basis for Conclusions.

 

Why Several Technical Elements Remain Deliberately Unfinished at This Stage

 

The explanatory note is explicit that a number of technical aspects of the draft taxonomy remain incomplete and are described as "work in progress." The list of Substances of Very High Concern, relevant to pollution and chemical safety disclosures under ESRS E2, has not yet been implemented because EFRAG has not yet decided which official list to reference, with the corresponding XBRL element temporarily set to a generic string data type as a placeholder. Validation rules confirming that required disclosures are actually present in a submitted report have similarly not yet been built, apart from a narrower existence check applied specifically to EU-mandated datapoints.

That combination of an open public consultation running alongside acknowledged, unresolved technical gaps signals this is a genuinely interim working draft rather than a near-final specification awaiting only cosmetic adjustment. EFRAG specifically recommends that broader validation rules be added only after an initial wave of companies has already digitised reports under the new taxonomy, suggesting the agency anticipates refining the technical specification based on real-world implementation experience rather than attempting to anticipate every edge case before the standard goes live.

 

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Why the New "Alternative Presentation" Classification Reflects a Deliberate Anti-Duplication Choice

 

The draft introduces a renamed and refined "Alternative presentation" classification, replacing the "Alternative" label used in the 2024 guidance, applied where a single underlying disclosure can legitimately be presented using more than one data type. The explanatory note gives the example of a company's total permanent employee count, which the standard allows to be reported either as a plain headcount (an integer) or as a full-time equivalent figure (a decimal), without prescribing which method a company must use.

Rather than creating two separate datapoints to cover each possible presentation format, a structure that would have required counting and potentially double-reporting the same underlying fact, the draft models this as a single datapoint capable of accepting either data type. EFRAG explicitly frames this design choice as intended to avoid double counting and duplication within the overall datapoint list, while still accurately capturing the genuine flexibility the standard itself grants to reporting companies.

 

Why Interoperability With Other Frameworks Shaped Specific Modelling Decisions

 

The explanatory note notes that alignment with other major sustainability reporting frameworks, particularly the International Sustainability Standards Board's IFRS S1 and S2 standards, directly influenced how certain datapoints were structured. One cited example involves ESRS 2 paragraphs on qualitative and quantitative financial effects disclosures, where the wording was specifically aligned to match equivalent IFRS S1 and S2 disclosure requirements, and modelled with a combined "narrative, monetary" data type intended to capture both the qualitative and quantitative dimensions of the required disclosure simultaneously.

That interoperability consideration reflects a broader pattern also visible in the ISSB's own 2026 adoption trajectory covered elsewhere in recent reporting, where regulators and standard-setters across different jurisdictions have increasingly sought to reduce the compliance burden on companies reporting under multiple overlapping frameworks by deliberately aligning specific disclosure requirements and terminology where the underlying substance is comparable, rather than requiring companies to produce entirely separate, differently structured disclosures to satisfy each framework independently.

 

Source: EFRAG