30 September 2026

At the end of 2023, following the adoption of the Corporate Sustainability Reporting Directive (CSRD), the European Sustainability Reporting Standards (ESRS) were adopted. They constituted the first European framework to harmonise how companies report on their environmental, social and governance (ESG) performance.

Both the CSRD and the 2023 ESRS succeeded in placing disability firmly on the sustainability agenda, with several references included throughout the Standards.

However, this and other pieces of European legislation underwent a review and simplification process in the context of the Omnibus initiatives proposed in 2025. In addition to amending the scope of the CSRD by reducing the number of companies concerned, the European Commission asked EFRAG, the technical body responsible for developing the standards, to substantially simplify the ESRS. 

EFRAG’s proposals and the final approved ESRS, published on 21 September 2026, represent a reduction of more than 60% in content compared to the original ESRS.

 

Disability Inclusion in the ESRS

Although not all the original disability-related content was retained in the 2026 ESRS, a key indicator tracking the percentage of persons with disabilities in a company has been preserved, alongside other important elements.

Across the 2026 ESRS, disability is referenced in all four existing social standards (S1 Own workforce, S2 Workers in the value chain, S3 Affected communities and S4 Consumers and end-users), with a total of 23 references. 

More specifically, the retained provisions include: 

  • Explicit recognition of the employment and inclusion of persons with disabilities among the matters that companies must consider when conducting their double materiality assessments
  • Inclusion of the UN Convention on the Rights of Persons with Disabilities among the relevant human rights instruments
  • Consideration of disability in consultation and grievance mechanisms for the workforce and its representatives (S1-2), as well as in the value chain (S2-2)
  • Protection in cases of acquired disability (S1-10)
  • Reporting of incidents of discrimination on the grounds of disability (S1-16)
  • Inclusion of persons with disabilities in engagement with affected communities or stakeholders (S3-2)
  • Explicit references to disability in the definitions of equal treatment, harassment and social protection in the glossary. (1)

 

The revised ESRS enter into force on 10 November 2026 and apply to financial years beginning on or after 1 January 2027 for companies in scope of the CSRD. 

 

Disability in Additional Voluntary ESRS 

Following the reduced scope of the Corporate Sustainability Reporting Directive (CSRD) under the Omnibus initiatives, the European Commission developed simplified voluntary standards for companies originally covered by the 2023 CSRD framework but excluded from its scope following the 2026 revision. (2)

These voluntary standards, also published on 21 September 2026, expressly identify the employment and inclusion of persons with disabilities as sustainability matters to be considered by companies.

 

(1) Compared with the 2023 ESRS, the 2026 version removed numerous guidelines and specific examples on various topics. In relation to disability, this resulted in the absence of specific references to accessibility, although the perspective of the inclusion of persons with disabilities remains present across all the social ESRS, including those concerning consumers and end-users.

(2) Delegated Regulation 2026/1560, aimed at companies with fewer than 1,000 employees.