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Phased-in disclosures

Exemption of Disclosure Requirements from the ESRS

Vita Marquenie avatar
Written by Vita Marquenie
Updated over a week ago

For the first year(s) of preparing the sustainability statement under the ESRS, certain disclosure requirements are phased in and not immediately mandatory. We will highlight these in the questions, but also provide you a comprehensive list of all exemptions applicable during the first year(s).

Learn here what this means for your company:

Does you company has less than 750 employees?

  • ESRS E1-6: You may omit the datapoints on scope 3 emissions and total GHG emissions for the first year of preparation of your sustainability statement.

  • ESRS E4: For the first 2 years of reporting, your company can omit the information required by this topical disclosure.

  • ESRS S1: For the first year of reporting, your company can omit the information required by this topical disclosure.

  • ESRS S2, S3 and S4: For the first two years of reporting, your company can omit the information required by these topical disclosures.


Is this the first year of your sustainability statement?

  • ESRS 2 SBM3: The material impacts, risks and opportunities and their interaction with strategy and business model are allowed to be ommitted

  • ESRS E1-6: You may omit the datapoints on scope 3 emissions and total GHG emissions for the first year of preparation of their sustainability statement.

  • ESRS E1-9: You may omit the information prescribed by ESRS E1-9 for the first year of preparation of its sustainability statement.

  • ESRS E2-6: You may omit the information prescribed by ESRS E2-6 for the first year of preparation of the sustainability statement. Except for the information prescribed by paragraph 40 (b) on the operating and capital expenditures occurred in the reporting period in conjunction with major incidents and deposits.

  • ESRS E3-5: You are allowed to omit all datapoints for this disclosure requirement.

  • ESRS E4-6: You are allowed to omit all datapoints for this disclosure requirement.

  • ESRS E5-6: You are allowed to omit all datapoints for this disclosure requirement.

  • ESRS S1-7: You are allowed to omit all datapoints for this disclosure requirement.

  • ESRS S1-8: This information can be omitted in the first year for your companies' employees in non-EEA countries. The EEA includes EU countries and also Iceland, Liechtenstein and Norway.

  • ESRS S1-11: You are allowed to omit all datapoints for this disclosure requirement.

  • ESRS S1-12: You are allowed to omit all datapoints for this disclosure requirement.

  • ESRS S1-13: You are allowed to omit all datapoints for this disclosure requirement.

  • ESRS S1-14: Your company may omit the data points on cases of work-related ill-health and on number of days lost to injuries, accidents, fatalities and work-related ill health for the first year of preparation of the sustainability statement.

  • ESRS S1-14: You may omit reporting on non- employees for the first year of preparation of its sustainability statement.

  • ESRS S1-15: You are allowed to omit all datapoints for this disclosure requirement.


Is this your first, second or third year of the preparing the sustainability statement?

  • ESRS E1-9: You may report only on qualitative disclosures for the first 3 years of preparation of your sustainability statement, if it is impracticable to prepare quantitative disclosures.

  • ESRS E3-5: You can be compliant by just disclosing qualitative information.

  • ESRS E4-6: You can be compliant by just disclosing qualitative information.

  • ESRS E5-6: You can be compliant by just disclosing qualitative information.


For more details consult Appendix C: List of phased-in Disclosure Requirements of ESRS 1.

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