The topical standards: report only what your assessment flags as material

Once ESRS 1's double materiality process has been run and ESRS 2 is underway, the topical standards come into play — but only the ones your own assessment identifies as material. They fall into three groups.

Environment

• E1 — Climate change: greenhouse gas emissions, energy consumption and climate transition planning. For most manufacturers, this is the environmental standard most likely to come out as material, given process emissions, energy-intensive equipment and supply-chain exposure.
• E2 — Pollution: air, water and soil pollution, and substances of concern.
• E3 — Water and marine resources: water withdrawal, consumption and discharge.
• E4 — Biodiversity and ecosystems: impacts on biodiversity and ecosystem services.
• E5 — Resource use and circular economy: resource inflows, outflows, waste and circularity. This is the other environmental standard that tends to be highly relevant for manufacturers, given the materials-intensive nature of production, packaging and end-of-life product handling.

Of these five, E1 and E5 are typically the ones manufacturers find most relevant in practice — though this is a generalisation, not a guarantee, and your own double materiality assessment is what actually decides it. We go into E1 and E5 specifically for manufacturing operations in a dedicated deep-dive.

Social

• S1 — Own workforce: working conditions, equal treatment and other workforce-related matters for the company's own employees.
• S2 — Workers in the value chain: the equivalent concerns extended to workers at suppliers and other value chain partners — relevant for manufacturers with extended, multi-tier supply chains.
• S3 — Affected communities: impacts on communities near operations or facilities.
• S4 — Consumers and end-users: impacts on the people who use the company's products.

Governance

• G1 — Business conduct: corporate culture, anti-corruption, political engagement and supplier relationship management.

Sector-specific standards: in principle, but currently deprioritised

The ESRS framework was designed to eventually include sector-specific standards — additional, more detailed disclosure requirements tailored to particular industries, including manufacturing sub-sectors. In principle these standards exist as a planned part of the architecture. In practice, their development has been delayed and deprioritised as part of the EU's Omnibus simplification package, and there is no confirmed standard set of sector-specific requirements currently in force for manufacturers to apply. Do not build a compliance programme around sector-specific ESRS content until the European Commission has actually adopted and published it — check current status before assuming any particular sector standard applies to you.

Scope, thresholds and timing: actively being renegotiated — verify before you rely on any figure

This is the area where we are most deliberately cautious, and where you should be too. As of 2026, the thresholds that determine which companies fall into CSRD scope, and the timing of the reporting waves, are under active revision through the EU's Omnibus I simplification package. Figures and wave-by-fiscal-year tables that circulated when CSRD was first adopted are no longer a safe basis for planning, because the negotiation is ongoing and has already moved the goalposts once. We are not going to assert a specific employee count, turnover threshold or fiscal-year table here as final, because doing so risks giving you a number that is wrong by the time you read it.

What can be said with confidence is the general shape of the framework, which has remained consistent even as exact figures move:

• Large companies report first. The largest in-scope companies — broadly, those already subject to non-financial reporting obligations or meeting the largest size criteria — are first into the reporting obligation.
• Smaller and listed SMEs get delayed or relaxed entry. Smaller companies and listed SMEs are generally positioned for later entry into scope, and the Omnibus process has been moving toward relaxing or delaying their obligations further, though the exact mechanism and dates are still being settled.
• Non-EU companies are pushed further out. Non-EU parent companies with significant EU activity are in scope in principle, but on a later timeline than EU-headquartered large companies.

If your organisation needs to know precisely when it enters scope, or under what threshold, confirm the current position directly — with the official EU legislative texts, your auditor, or a qualified compliance consultant — rather than relying on any article, including this one, for a fixed date. The direction of travel under Omnibus has generally been toward simplification and later, narrower scope, but "generally" is not the same as "confirmed," and the process is not finished.

Where CSRD reporting causes the most practical friction for manufacturers

In our experience working with industrial organisations and their compliance documentation, the hardest part of CSRD is rarely understanding what ESRS 1 or ESRS 2 ask for in the abstract. It is pulling together the evidence: the emissions data buried in an energy audit from two years ago, the waste and resource-flow figures scattered across plant-level spreadsheets, the supplier questionnaires needed to assess value-chain workforce exposure under S2. When a sustainability team needs to substantiate a specific disclosure — which policy covers a given E1 target, which document evidences the double materiality assessment's reasoning for a given topic — the document often exists somewhere, but finding the exact, current version quickly is the actual bottleneck.

This is the gap IgeraIndustria is built to close. It is AI that answers directly from a company's own compliance and quality documents — policies, assessments, audit records, supplier evidence — and cites the exact source for every answer, rather than generating a plausible-sounding summary. For a framework where every material disclosure needs to be traceable back to real evidence, having a tool that can instantly surface "which document supports this ESRS 2 governance disclosure" turns assurance preparation from a search exercise into a lookup.

Common mistakes manufacturers make

• Starting with a topical standard instead of the materiality assessment. Jumping to E1 or S1 before ESRS 1's double materiality process is complete means building disclosures on an unconfirmed foundation — you may report on topics that aren't actually material, or miss ones that are.
• Treating ESRS 2 as optional. Because it isn't a "topic" in the way E1 or S1 are, some teams underweight ESRS 2. It is mandatory for every in-scope reporter regardless of the materiality outcome.
• Assuming financial materiality alone, or impact materiality alone, is enough. Double materiality requires assessing both angles; a topic material from only one direction is still material overall.
• Planning around a threshold or date that hasn't been confirmed recently. Given the ongoing Omnibus I renegotiation, a scope threshold or wave date that was accurate a year ago may no longer hold. Re-verify before committing resources to a specific deadline.
• Assuming a sector-specific standard exists and applies. Sector-specific ESRS content has been delayed under Omnibus; don't build reporting processes around requirements that haven't actually been adopted.
• Underestimating value-chain data collection for E5 and S2. Circular economy metrics and value-chain worker data typically require supplier cooperation that takes far longer to arrange than the internal reporting work itself — start early.

Frequently asked questions