The ESRS has a total of 1,052 datapoints, spread out over the 10 topic-specific ESRS categories as well as ESRS 2: General disclosures. Based on the double materiality assessment, companies have to report the datapoints that are material. This is assessed on three levels:
1. ESRS topic level:
A ESRS topic is material if one of it's sub-topics is deemed material. If an ESRS topic is material, (e.g. ESRS S1 Own Workforce), the corresponding datapoints will have to be reported on, unless specified otherwise.
Example: If ESRS S1 (Own Workforce) is material, most corresponding datapoints will have to be reported on. The Coolset platform mentions which ones are optional.
2. ESRS sub(-sub)-topic level:
Some datapoints are only material at sub(-sub)-topic level, which means that the materiality of one sub-(sub)-topic, doesn't lead to reporting requirements of another non-material sub-(sub)-topic belonging to the same overarching ESRS topic.
Example: When the sub-topic Pollution of air (of ESRS E2: Pollution) is material, but the sub-topic Substances of concern is not, companies can omit the datapoints E2-3 Targets related to pollution.
3. ESRS impact and/or financial materiality level:
A sustainability matter may be material from both an impact and financial materiality perspective, or from only one perspective. Some datapoints may be omitted when the (sub-)topic is only material from one perspective.
Example: E1-9 (Anticipated financial effects from material physical and transition risks and potential climate-related opportunities) doesn't need to be reported on when sub-topic Climate change mitigation of ESRS E1 is only material from an impact perspective.
Overview of ESRS datapoints
See the table below for an overview of the datapoints per ESRS topic.
ESRS | Irrespective of DMA | Subject to DMA | Total | Voluntary DPs |
ESRS 2 | 127 |
| 127 | 12 |
E1 | 16 | 171 | 187 | 15 |
E2 | 3 | 41 | 44 | 20 |
E3 | 2 | 25 | 27 | 18 |
E4 | 11 | 43 | 54 | 65 |
E5 | 2 | 40 | 42 | 19 |
S1 |
| 127 | 127 | 55 |
S2 |
| 47 | 47 | 18 |
S3 |
| 45 | 45 | 18 |
S4 |
| 44 | 44 | 19 |
G1 |
| 39 | 39 | 10 |
Total | 161 | 622 | 783 | 269 |
On top of that, there are minimum disclosure requirements (MDRs) to be reported on for material sustainability matters. The table below illustrates the datapoints in relation to MDRs on Policies, Actions, Targets and Metrics (PAT&M) according to ESRS 2 Chapter 4.2. These are considered for the disclosures when the undertaking has adopted PAT related to material sustainability matters. If not, the reporting company shall disclose why it doesn't have this and when it plans om implementing PATs.
DPs | |
MDR-P | 6 |
MDR-A | 12 |
MDR-T | 13 |
MDR-M | 3 |
Steps to determine which datapoints need to be reported on:
Double materiality assessment to determine material sub-topics and sub-sub-topics:
For each sub-topic (and thus sub-sub-topic) conduct a double materiality assessment, to establish which impacts, risks and opportunities are important to your company.
Disclose mandatory requirements per topical standard:
Some datapoints should always be reported on for material ESRS topics. This includes:
Policies, actions, and targets:
Disclose Policies, actions, and targets (PATs), and optionally the timeframe for their implementation. If you don't have PATs yet, you are asked to disclose this fact and the reason for this, along with a timeline on when you'll develop these.
Transition plans:
Reporting on transition plans them means that you lay out a plan for achieving the targets you have set. If you don't have a transition plan yet, you need to disclose that this is the case, and state when you will develop one.
For example, if climate change mitigation is material, disclose the transition plan (or its absence) and the implementation timeframe.
Processes:
For sub-topics S1 to S4, disclose processes for engaging with workers, affected communities, consumers, and end-users. If these processes are absent, disclose this fact and optionally the timeframe for their implementation.
Determine which metrics to report on:
Judgment for relevant Disclosures Requirements:
Use judgment to determine the relevant DRs related to metrics in topical standards. The Coolset platform highlights which metrics only need to be reported on when a certain sub-(sub-)topic is material.
Material metrics:
If a metric is material, it must be disclosed. If not, it can be omitted.
Reference to ID177 Appendix:
Refer to the appendix of EFRAG document ID177 for tables linking each AR16 matter with DRs directly related to those matters.
Mandatory disclosures:
Regardless of the materiality assessment outcome, your organization must always disclose on the 127 datapoints required by ESRS 2 General Disclosures and the Disclosure Requirements in the environmental ESRS related to DR IRO-1.