Can you explain more? When do i have to account for headroom?
Sure.
So most ESS / AKM / BB Delta Sigma DACs have an 8x digital interpolation filter followed by (generally) 2nd order IIR which is 8x ~ 32x. And finally the DS modulator (HyperStream in case of ESS).
ESS anyways attenuates the IIR output before it is fed to HyperStream modulator by 3 dB so that it does not overload. So this part we don't have to be concerned about.
It's the 8x interpolation part which needs some special handling in terms of digital clipping prevention.
If you are passing 44K to 192 K and using ESS built in filter, you don't have to worry about (for so long the DAC designer has not enabled the optional 18 dB gain register to the DAC chip).
However if you are passing 352.8 K and upwards PCM, this 8x interpolation is now disabled. So say you decide to do software based oversampling (using HQ Player, SoX, etc), you need to make sure the signal is attenuated enough to not cause inter sample peaks before it is sent to ALSA / WDM endpoint.
Also, if you are a DAC designer, you could have your own custom FIR coefficients to override the ESS built in ones for the 8x digital filter. May be you want a steeper roll off using longer filter lengths. Regardless, here again, care has to be taken to prevent clipping while oversampling.