Brussels has moved the date again. And this time, the delay is not a technical detail: it directly affects how you plan your reporting for the next two financial years.
What just happened
The timeline the European Commission had been signalling until recently, with adoption of the Delegated Act revising the ESRS around mid-2026, no longer holds. With the two-month scrutiny period (extendable by two more) that the Parliament and the Council must complete after formal adoption, actual entry into force is now expected in the fourth quarter of 2026.
Firms like Cleary Gottlieb, EY and Position Green confirm this reading in their latest April regulatory briefings. It is not a rumour: it is the view already held by the law firms advising the companies that have to report.
Application of the revised standard is still expected for FY2027, with a voluntary early-adoption option for FY2026 that now takes on a different dimension.
Why this delay changes your planning
If your company is in Wave 1, meaning you are already reporting under the original ESRS, this move affects you in three concrete ways.
First: the “quick fix” will remain your operating framework for longer than expected. Delegated Regulation (EU) 2025/1416, in force since November 2025, lets Wave 1 reporters skip datapoints in ESRS E4, S2, S3 and S4 for FY2025 and FY2026. With the new Delegated Act delayed, this transitional regime effectively extends until the end of 2026.
Second: you now have a real window to voluntarily apply the simplified standard in FY2026. The draft published by EFRAG in December 2025 cuts mandatory datapoints by 61% and removes all voluntary ones. Adopting it early, once published in the Official Journal, is not just a compliance decision: it is a way to arrive at FY2027 with the process already running.
Third: the “wait and see” message stops working. Many ESG teams had been in a holding pattern, postponing decisions until the new Delegated Act was adopted. With adoption in Q4 2026, waiting means reaching FY2027 with no time to adapt.
What stays the same (and is worth remembering)
The delay does not affect the other dates in the Omnibus I package. Directive 2025/7942 (“stop-the-clock”) still postpones entry into force of Wave 2 and Wave 3 to 2027 and 2028 respectively. The Omnibus I Directive entered into force on 18 March 2026, and Member States have until 19 March 2027 to transpose it. The CSDDD keeps its schedule: transposition in July 2028, application in July 2029.
In Spain, Royal Decree 214/2025 remains in force. It makes carbon footprint accounting and a five-year reduction plan mandatory for companies covered by Law 11/2018, and requires 2026 reporting of FY2025 data. That is the ground you stand on now, regardless of the European calendar.
What to do this week
The plan is not to redo your reporting roadmap. The plan is to revisit three things.
- Review the data map you already have. If the simplified draft cuts mandatory datapoints by 61%, some of the work you were doing can be redirected. Identify which data will remain mandatory, which shifts to optional and which disappears.
- Decide whether to voluntarily apply the revised standard in FY2026. This is a strategic decision, not merely a technical one. It depends on your investors, your value chain and your appetite for getting ahead of the curve.
- Make sure your data system supports both regimes. Through 2026, the original ESRS (for those staying on the quick fix) and the revised ESRS (for those moving early) will coexist. Your data infrastructure has to handle both.
If you want to go deeper into how CSRD transposition is playing out across Member States, we have covered it. And if your focus is how the ESRS change in practice, the ESRS quick fix 2026 remains the operating framework during this year.
Where Dcycle fits
When the regulatory framework moves, the one thing that does not move is the data. The companies that arrive first at the new standard are not the ones with more time: they are the ones with their data in order.
At Dcycle we have spent months tuning the product to run both regimes in parallel, precisely so you do not depend on the date that finally lands in the Official Journal. Our carbon footprint module and the CSRD resource hub are ready for both the current ESRS and the simplified draft. If your ESG team is revisiting the plan because of this delay, let’s talk.