EFRAG published the draft ESRS XBRL Taxonomy for the revised ESRS on September 17, 2026 and opened a public consultation. Comments close on November 11, 2026. EFRAG intends to submit the final taxonomy to ESMA, the European Securities and Markets Authority, and the European Commission by the end of 2026.
This is an implementation-side document, a step removed from the question of how to write the sustainability report itself. But the deadline is close and the effects are hard to read, which makes it worth registering.
It replaces the August 2024 version
The first thing to establish is that this draft is not an update to the existing version but a replacement.
The revised ESRS were adopted in July 2026, a revision that included consolidating and simplifying datapoints. The taxonomy has been rebuilt to match.
What this means in practice is straightforward. Work advanced on the assumption of the August 2024 taxonomy cannot simply be carried forward. If reporting tool selection or mapping design was progressing against the old version, a step is needed to check what has changed.
The taxonomy was developed in parallel with the draft datapoint list for the revised ESRS that EFRAG published earlier, in August 2026, and the two contain the same datapoints. The difference is that the XBRL Taxonomy carries the additional technical attributes needed for digital representation; datapoints are expressed as XBRL elements, or concepts.
Required, but not yet mandatory
This is the part most easily misread.
CSRD — the Corporate Sustainability Reporting Directive — requires that ESRS disclosures be digitised. But the concrete implementing framework rests on ESEF, the European Single Electronic Format, which ESMA proposes and the European Commission adopts, and that regulatory framework is not yet established.
Accordingly, digital tagging of ESRS datapoints is not mandatory at this point.
Position under CSRD
Digitisation of ESRS disclosures is a CSRD requirement. The direction is settled.
Basis for implementation
The concrete framework rests on ESEF, following a process in which ESMA proposes and the European Commission adopts.
Current status
Because that regulatory framework is not yet established, the timing for mandatory digital tagging is undetermined.
EFRAG's role
Developing the taxonomy and submitting the final version to ESMA and the European Commission by the end of 2026.
Read that way, companies bracing for tagging as an imminent obligation and companies judging it irrelevant for now are both misreading the situation. It is mandated but undated. The specification is heading toward being settled at year-end, while when it applies rests on a separate process.
Who should be commenting
EFRAG frames this consultation as particularly relevant to software vendors, XBRL specialists and practitioners of digital sustainability reporting, while welcoming feedback from other stakeholders.
That naming indicates the sequence. The people who need to act now are those building or selecting the reporting tooling, not those drafting the narrative disclosures.
Nor is it irrelevant to companies planning to build their reporting capability from 2027 onward. The specification the tool they choose will comply with is being settled over roughly the next eight weeks. You cannot place requirements on a specification at the point of tool selection; you can at the point the specification is drafted.
The relationship to mid-sized and smaller reporters
EFRAG has been running a consultation on ESRS for SMEs in parallel. The burden of digitisation tends to fall relatively harder the smaller the reporting operation.
Given the sequence — the taxonomy is settled first, and the ESEF-based implementing framework follows — how much preparation time will be available cannot be read at this point. If the interval between specification and application is short, tool procurement and internal data preparation will run concurrently.
For anyone positioned as a supply chain partner asked to provide reporting data, working out now what the requested granularity corresponds to as XBRL elements will make things easier later. Through the chain of simplification running from the ESRS 2.0 public consultation, the number of datapoints has been pared back. On top of that, what the remaining datapoints demand in machine-readable form has now been made concrete in this document.