ESRS 2 general disclosures

Whatever a company's material topics, its sustainability statement opens with ESRS 2. These disclosures tell readers how the report was prepared, who oversees sustainability, how the business model and value chain work, and how material impacts, risks and opportunities were found, and they set the pattern for every topical disclosure that follows. This guide lists each requirement in the revised ESRS 2, works through a manufacturer's main disclosures, and covers the general requirements for policies, actions, metrics and targets and what changed in 2026.

By Hamza Fida, Chartered Accountant. Reviewed by Mirza Fahad Baig, Chartered Accountant. 4 minute read.

Short answer

ESRS 2 sets out the general disclosures every company reporting under the ESRS must make, whatever its material topics. In the revised standards, adopted in 2026 and applying from financial year 2027, it has eleven disclosure requirements in four groups: basis for preparation (BP-1 and BP-2); governance (GOV-1 to GOV-4), covering the role of the board and management, sustainability in incentive schemes, the statement on due diligence, and risk management and internal controls over sustainability reporting; strategy (SBM-1 to SBM-3), covering the business model and value chain, stakeholders' views, and how material impacts, risks and opportunities interact with strategy, including financial effects; and impact, risk and opportunity management (IRO-1 and IRO-2), covering the materiality process and the list of material items and disclosures. It also sets the general disclosure requirements for policies, actions and resources, metrics and targets that every topical standard applies.

At a glance

Applies to
Every ESRS reporter
Requirements
Eleven, in four groups
Governance
Four, GOV-1 to GOV-4
Strategy
Three, SBM-1 to SBM-3
Materiality process
IRO-1 and IRO-2
Pattern for topics
Policies and targets
ESRS 2 general disclosuresApplies to: Every ESRS reporter; Requirements: Eleven, in four groups; Governance: Four, GOV-1 to GOV-4; Strategy: Three, SBM-1 to SBM-3; Materiality process: IRO-1 and IRO-2; Pattern for topics: Policies and targets.KEY FACTS AT A GLANCEESRS 2 general disclosuresApplies toEvery ESRS reporterRequirementsEleven, in four groupsGovernanceFour, GOV-1 to GOV-4StrategyThree, SBM-1 to SBM-3Materiality processIRO-1 and IRO-2Pattern for topicsPolicies and targetsTax BakersESRS 2 general disclosuresApplies to: Every ESRS reporter; Requirements: Eleven, in four groups; Governance: Four, GOV-1 to GOV-4; Strategy: Three, SBM-1 to SBM-3; Materiality process: IRO-1 and IRO-2; Pattern for topics: Policies and targets.KEY FACTS AT A GLANCEESRS 2 general disclosuresApplies toEvery ESRS reporterRequirementsEleven, in four groupsGovernanceFour, GOV-1 to GOV-4StrategyThree, SBM-1 to SBM-3Materiality processIRO-1 and IRO-2Pattern for topicsPolicies and targetsTax Bakers
Key facts at a glance, as set out in this guide.

What does ESRS 2 require?

RequirementTitle
BP-1Basis for preparation of the sustainability statement
BP-2Specific information if the undertaking uses phasing-in options
GOV-1The role of the administrative, management and supervisory bodies in relation to sustainability
GOV-2Integration of sustainability-related performance in incentive schemes
GOV-3Statement on due diligence
GOV-4Risk management and internal controls over sustainability reporting
SBM-1Strategy, business model and value chain
SBM-2Interests and views of stakeholders
SBM-3Interaction of material impacts, risks and opportunities with strategy and business model, and financial effects
IRO-1Process to identify and assess material impacts, risks and opportunities and material information
IRO-2Material impacts, risks and opportunities and disclosure requirements included in the statement

ESRS 2 always applies; it is not subject to the materiality assessment. See ESRS 1 general requirements.

What are the general disclosure requirements for policies and targets?

ESRS 2 also sets four general disclosure requirements, applied whenever a topical standard asks about a material matter: GDR-P for policies, GDR-A for actions and resources, GDR-M for metrics and GDR-T for targets. They require, for example, the scope of each policy and who is accountable for it; key actions, their expected results and the significant financial resources allocated, with an indicative range for future resources; how each metric is measured and whether it is validated by an external body; and each target's level, base year, timeframe and progress. In the 2023 standards these were called minimum disclosure requirements. See ESG KPIs explained and setting and reporting net zero targets.

ESRS 2 general disclosures: a manufacturer's main points

An industrial manufacturer drafts its ESRS 2 section for its 2027 report.

Key ESRS 2 disclosures for a manufacturerKey ESRS 2 disclosures for a manufacturerWhat it asksThe manufacturer's answerBP-1Basis forpreparationSame group as theaccounts; estimates usedGOV-1Board andmanagement rolesBoard sustainabilitycommittee, four meetingsGOV-2Sustainabilityin pay10% of bonus tiedto emissions cutsSBM-3Material items andfinancial effectsEight items, effectsphased inIRO-1MaterialityprocessTop-down, withstated thresholds
ESRS 2 frames the report before any topical disclosure.

Under BP-1 it explains that the statement covers the same group as its accounts and that scope 3 and value chain worker data rely partly on estimates. Under GOV-2, it discloses that 10% of executives' annual bonus depends on cutting scope 1 and 2 emissions. Under SBM-3, it describes its eight material items and their current and anticipated financial effects, using the phase-in for the anticipated effects. Under IRO-1, it explains its top-down materiality process and the thresholds used, and IRO-2 lists the disclosure requirements it reports. See impacts, risks and opportunities.

What do the governance disclosures cover?

GOV-1 covers the composition of the board and management, their sustainability expertise, and how they oversee material impacts, risks and opportunities. GOV-2 covers how sustainability performance feeds into pay. GOV-3 maps where the statement describes the main steps of due diligence on people and the environment. GOV-4 describes risk management and internal controls over sustainability reporting, which assurance providers rely on. Companies can incorporate governance information by reference from the corporate governance statement. Business conduct itself is covered by ESRS G1. See sustainability assurance.

What do the strategy disclosures cover?

SBM-1 describes the company's strategy, business model, main products, markets and value chain, including revenue by significant sector. SBM-2 explains how stakeholders' interests and views are taken into account (see stakeholder engagement for materiality). SBM-3 is the centre of the report: it describes each material impact, risk and opportunity, where it arises, its time horizon, how the strategy responds, and the current and anticipated financial effects, which must be consistent with the financial statements. See current and anticipated financial effects, connected information and climate risk in the financial statements.

What changed in the 2026 revision of ESRS 2?

The revision cut datapoints, renamed the minimum disclosure requirements as general disclosure requirements, allowed ranges for future financial resources and anticipated financial effects, and clarified that current financial effects with a significant risk of material adjustment in the next year are reported. Anticipated financial effects remain subject to phase-ins. The topical standards were revised at the same time; see, for example, ESRS S1 own workforce. See also the revised ESRS and double materiality.

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Questions people ask

What is ESRS 2?

The ESRS standard setting general disclosures every reporter makes, on basis for preparation, governance, strategy and the management of impacts, risks and opportunities.

Is ESRS 2 subject to materiality?

No. ESRS 2 always applies, whatever the outcome of the materiality assessment.

What are GDR-P, GDR-A, GDR-M and GDR-T?

The general disclosure requirements in ESRS 2 for policies, actions and resources, metrics and targets, applied to every material topic.

Where are financial effects disclosed under ESRS 2?

In SBM-3, which covers how material impacts, risks and opportunities interact with strategy and their current and anticipated financial effects.

Sources

Every fee, date and rule on this page was taken from these official and primary sources.

  1. EFRAG Knowledge Hub: revised ESRS 1 General requirements, delegated act version
  2. EFRAG Knowledge Hub: revised ESRS 2 General disclosures, delegated act version
  3. Commission Delegated Regulation (EU) 2026/1563 revising the ESRS, published 21 September 2026
  4. EFRAG: Commission publishes delegated act on revised ESRS and voluntary standard

Rules and fees change. If you are reading this long after October 11, 2026, confirm the figures with the source before you rely on them.

SustainabilityESRS 1 general requirementsSustainabilityThe revised ESRS: what changed in 2026SustainabilityImpacts, risks and opportunities (IROs)

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This guide is general information. It is not tax or legal advice for your situation.