A German FY2026 sustainability report draft landed on my desk this month quoting disclosure requirements that, since September 21, 2026, exist in two official versions. The correct English vocabulary for that file no longer depends on my glossary. It depends on a decision the client has to make first.
What actually changed on September 21, 2026
Two delegated acts went into the Official Journal that day: the Simplified ESRS as Commission Delegated Regulation (EU) 2026/1563, and the Voluntary Sustainability Reporting Standard as (EU) 2026/1560. Both had been adopted by the Commission on July 3, 2026, as one of the closing moves of the Omnibus simplification package, and both sat through the Parliament and Council scrutiny period before publication.
The headline numbers are the ones every ESG newsletter ran: mandatory datapoints cut by 61%, all voluntary disclosures eliminated, total datapoint reduction of more than 70%. Less widely reported, and more important for anyone who translates this material: the Commission kept most of EFRAG’s technical advice but added what it called targeted modifications, primarily aimed at clarifying certain provisions. Clarified provisions mean rewritten sentences. Rewritten sentences mean that a German paragraph paraphrasing the standard may now paraphrase a wording that the current official English no longer uses.
Annex II is where this gets operational for terminology work. It is built as two tables: Table 1 lists the acronyms used across the standards, Table 2 defines the terms to be used as reference for preparing sustainability statements. That annex is, functionally, the EU’s own termbase for the ESRS. If yours and theirs disagree, yours loses.
The dates that matter for scheduling: the Simplified ESRS enters into force on November 10, 2026, the voluntary standard entered into force earlier, on September 24, 2026. The revised standards apply to financial years beginning on or after January 1, 2027. Wave-one companies may elect to apply them early, to financial years beginning on or after January 1, 2026. That early-adoption window is the whole problem.
The one question that decides your English vocabulary
For financial years running January 1 to December 31, 2026, an in-scope entity can report under the original ESRS with phase-in reliefs, under the original ESRS plus eight additional reliefs, or under the simplified ESRS. The report has to specify which version was used.
Read that last sentence as a translator and you have your brief field. If the report itself must state its version, the translation order must state it too. I have received exactly one ESRS brief this autumn that did. The rest said some variant of “CSRD-compliant, please follow last year’s terminology,” which in September 2026 is not a brief at all. It is two instructions that can now contradict each other: last year’s terminology is 2023-standard terminology, and if the client early-adopts, following it will produce an English report that describes the wrong regime.
So the fiscal year is no longer enough. FY2026 plus early adoption and FY2026 without early adoption are two different source texts wearing the same cover page, and the German search term I keep seeing in inquiries this month, vereinfachte ESRS Übersetzung Englisch, is really a question about which of those two a company is in.
The EN/DE gap is in the EU’s own text, not just in your files
This is the part I would want every IR and sustainability manager to know, because it sounds like a translator’s excuse until you read it from the German standard-setter itself. The DRSC noted on publication day:
Due to the short period between the adoption of the Delegated Acts on July 3, 2026 and their publication today, the comments on the translations could not yet be taken into account. However, a corrigendum is already envisaged for October/November 2026, which is intended to incorporate amendments to the German-language versions of the Simplified ESRS and the VS.
The DRSC had submitted translation proposals to the Commission on individual technical terms and passages, developed jointly with the Austrian standard-setter AFRAC. In plain terms: the German terminology of the revised standard was still being negotiated after the English text was already published, and a German corrigendum is expected within weeks of this article going live.
That has one hard practical consequence. In this gap, the English is the text that exists in its intended final form, and the German is the text that may move. The single most expensive habit I see in this season is back-formation: a translator meets a German term in a client’s report, renders it into plausible English, and ships it, without checking whether an official English term for that concept already exists in the standard. You do not translate a German paraphrase of an EU standard into English. You identify which provision it refers to and use the official English of the applicable version. Everything else is a house-style decision, and house style does not outrank a delegated regulation.
Category terminology that moved: the end of the voluntary disclosure
The elimination of voluntary datapoints is not a deletion of content. It is the deletion of a category. Under the 2023 standards, a disclosure could be flagged as voluntary and still sit inside the standard’s architecture. Under the simplified standards it cannot, because the architecture no longer has that slot.
German reporting prose is full of formulations that lean on that slot: the material and the additional, the required and the offered-on-top. When such a phrase points at the removed ESRS category and the report is prepared under the simplified standards, rendering it as “voluntary disclosure” in English silently asserts a classification the standard no longer provides. Where the German instead means “we are telling you something beyond what is required,” English options that do not name a defunct ESRS category work better: additional information, entity-specific information, information provided beyond the requirements of the standard. Which one is right is a client decision, not a translator’s reflex, and it should be recorded as a term entry rather than solved sentence by sentence.
The mirror-image error is just as costly. If the report is prepared under the 2023 standards with phase-in reliefs, the voluntary category still exists, and scrubbing the word out of the English because you read about the simplification in a newsletter misrepresents the report in the opposite direction. Same German phrase, two defensible English renderings, decided entirely upstream of the translator.
Rewritten-for-clarity text is a false friend
When a standard is shortened by deletion, the translation problem is visible: the passage is gone, and everyone notices. When a standard is rewritten for clarity, the problem hides. The German boilerplate a company has carried since its first CSRD cycle often paraphrases a provision closely enough to read like a quotation, and the current official English of that provision now reads differently. Run it through a memory built on the prior year and you get a clean 100% match that quietly quotes a superseded wording.
My handling is boring and it holds up in review:
- Identify the provision the German sentence is pointing at, by standard and disclosure requirement, not by keyword.
- Pull the official English of that provision in the version the report is prepared under, and check whether the German is quoting, paraphrasing or summarizing.
- Quote exactly where the German quotes. Where the German paraphrases, translate the paraphrase but align its terminology to the official English. Where the German paraphrases a wording that no longer exists in the applicable version, it goes in the query sheet—I do not silently modernize a client’s source text, and I do not silently preserve an error either.
That third line is the one clients thank me for in February and resent in November. A query sheet entry costs ten minutes. An English report that describes requirements under the wrong version costs an assurance conversation.
Fewer datapoints, more prose—and what that does to MTPE
A 61% cut in mandatory datapoints does not shrink a sustainability report by 61%. It shifts its center of gravity. Tabular, highly repetitive, terminology-bound content goes down. Narrative explaining materiality judgments, transition planning and governance goes up, because that is what remains when the checklist shrinks and the reader still wants to understand the company.
This changes the economics of the file in a way worth saying out loud. Datapoint-heavy content is where machine translation plus post-editing genuinely earns its keep: high repetition, tight terminology, low rhetorical load. I price MTPE at €0.51 per standard line, against €0.85 for specialist translation from scratch—a standard line in the German market being 55 characters including spaces, the unit your pricing grid is almost certainly built on. On repetitive tables, the faster route and the better route are the same route.
Double-materiality narrative is the opposite case. It is argued prose, written by people who chose their hedges carefully, and machine output tends to flatten exactly the hedges that carry the legal weight. Post-editing that back into a defensible English text is not post-editing anymore; it is translation with an unhelpful first draft in the way. As the simplified standards push reports toward narrative, the share of an ESRS file that MTPE can carry honestly goes down. Split the file by content type before you price it, not after.
The termbase audit, step by step
This is the sequence I run before an ESRS file goes into production. It takes half a day to a day on an established termbase, and it prevents the most expensive kind of rework this season.
- Tag every ESRS entry with a version and a source. Two values at minimum: the 2023 delegated act, or the 2026 simplified act, Commission Delegated Regulation (EU) 2026/1563. An entry that cannot be traced to one of them is legacy house style and must be labeled as such.
- Flag entries whose underlying datapoint was deleted rather than renamed. A deleted concept needs a do-not-use note with a reason, not a quiet removal—otherwise it reappears from someone’s old export next year.
- Separate official EU terminology from client house style, in separate fields. Official terminology is not negotiable within a version. House style is negotiable and should be visibly marked as the thing that can bend.
- Mark every German entry awaiting the official language version as provisional, with the date you checked. Given the corrigendum expected for October/November 2026, provisional is an honest status this autumn, not a cop-out.
- Lock approved entries before the first file goes out, and record who approved them. A termbase that is still being edited while translation runs guarantees two vocabularies in one report.
What this looks like in Trados or Across
Do not build two termbases. I have watched that go wrong on multi-entity groups: someone attaches the wrong one, nobody notices until proofreading, and the fix is a full terminology pass. Add a version attribute to the existing term entries instead, with a picklist rather than free text. One termbase, filtered by version, means a translator who selects the wrong filter still sees that a conflicting entry exists.
On the memory side, this is a season for penalties. Segments inherited from a 2023-based prior-year report should not come back as clean 100% matches when the client has early-adopted. Apply a penalty to the prior-year TM so those segments surface as fuzzies and get looked at, or at minimum set a review flag on full matches in the ESRS chapters. Yes, that raises the effective word count, and on the CAT scale a segment that drops from a repetition at €0.17 into the 95–99% band at €0.51 costs more. It costs less than an English text that confidently describes the wrong regime.
The context-match logic deserves one specific warning. Context matches are free on my scale, €0.00 per line, precisely because their surroundings vouch for them. When the standard text around a segment has been rewritten, that guarantee is weaker than the tool believes. This year, sample them.
Multi-vendor projects: one report, two vocabularies
Large groups rarely have one translator. They have a lead vendor for the main report, someone else for the subsidiaries, and an agency that handles the web version. Each of them holds a glossary snapshot, and the snapshots were taken on different days of a season in which the official German text is still moving. That is how a single company ends up publishing two ESRS vocabularies in one reporting package, and it is not caught by any linguist working alone, because each of them is internally consistent.
The governance step is unglamorous: one bilingual glossary, one named owner, one date in the filename, one sign-off, distributed to everyone who touches the report, with a freeze date after which changes are logged and communicated instead of silently applied. If you take a single thing from this article into your process, take that one. It is worth more than any individual term decision in it.
Seven lines for the ESRS translation brief
Paste these into the order this autumn. If a line cannot be answered, that is the finding—answer it before the file moves, not after.
ESRS TRANSLATION BRIEF — required fields
1. Fiscal year covered by the report:
2. Standard version applied: 2023 ESRS / 2023 ESRS + additional reliefs / Simplified ESRS 2026
3. Early-adoption decision for FY2026: taken / pending / not applicable — and date taken
4. Assurance provider's working language, and language of the assurance report:
5. Prior-year TM status: reusable as-is / penalized / review flag on 100% matches
6. Glossary owner (name) and glossary version date:
7. Terminology freeze date, before first delivery:Line 4 surprises people. If the assurance work runs in German and the English is a translation, the English has to be traceable back to the German the provider read. If the group works in English and the German is the translation, the direction of authority flips and so does the way I handle discrepancies. Nobody puts this in a brief unprompted, and it changes how I query.
Honest limits, as of late September 2026
Three things are unsettled while I write this, and I would rather say so than write around them.
- The German language version. A corrigendum is envisaged for October/November 2026 to incorporate amendments to the German-language texts of the Simplified ESRS and the VS. Until it lands, any German term entry sourced from the September 21 publication is provisional by definition.
- National implementation. How German transposition and national guidance settle around the revised standards is not something I can responsibly predict, and it may affect reporting language in the notes.
- Assurance practice. How providers handle a translated sustainability statement under the new regime is, as far as I can verify, not yet standardized. I hear differing approaches from different clients and I am not going to dress anecdote up as market data.
I will update this article when the German corrigendum publishes, because the termbase advice in it changes the day the official German terminology is fixed—in the direction of less improvisation, which is the good direction.
Send me the brief before you send the file
I have been translating German financial and sustainability reporting full time since 2008, through enough annual-report seasons to have watched three regulatory vocabularies arrive and one leave. The pattern is always the same: the expensive errors are not mistranslations, they are correct translations of the wrong version. That is why I version-tag terminology in the termbase rather than trusting a glossary file that someone emailed in August. A glossary file tells you what a word means. A version tag tells you when it was true.
If you are scoping an FY2026 sustainability report for translation, send me the seven lines above before the file. Rates, match scale and turnaround are on the services page, and you can start a scoping conversation through contact. For the record, and because it comes up in this field: I do not offer sworn or certified translation—court-sworn colleagues handle those. Specialist reporting translation is what I do.