2025 Draft Simplified ESRS ESRS 1 ESRS 2 ESRS E1 ESRS E2 ESRS E3 ESRS E4 ESRS E5 ESRS S1 ESRS S2 ESRS S3 ESRS S4 ESRS G1 ESRS 2

AR 9 for para. 16

(AR 8) The undertaking may present the information required in paragraph 16 in the form of a table, cross-referencing the main steps of its due diligence process to the relevant disclosures in its sustainability statement.

AR 10 for para. 18

(AR 11) The undertaking shall consider the completeness and integrity of the data, and the accuracy of estimation results, as aspects that are relevant in the context of the risk management associated with the reporting process.

AR 11 for para. 20(c)

(new) Disclosing the significant sectors is relevant for users, as it supports the understanding of material impacts, risks and opportunities to which the undertaking is connected, notably when these are common in a given sector. In addition, this supports the understanding of possible entity-specific information included in the sustainability statement to cover aspects that are either specific to the undertaking or common in a given sector.

AR 12 for para. 20(c)

The sectors in which the undertaking is active are those of its own operations.

AR 13 for para. 20 (b)(c)

(AR 13 amended) A sector, a market, and a group of products, services or consumers shall be considered significant if:

(a) it accounts for more than 10 per cent of the undertaking’s revenue; or

(b) it is connected with the undertaking’s actual or potential material impacts.

For significant sectors arising from activities that are internal to the group only the criterion in letter (b) applies.

ESRS 2 General Disclosures does not mandate a specific classification system of business activities. When disclosing its significant sectors, the undertaking may apply one of the following approaches:

(a) the NACE classification system (Nomenclature générale des Activités Economiques dans les Communautés Européennes NACE Rev.2.1);

(b) the reportable segments disclosed in the financial statements in accordance with IFRS 8 Operating segments or local generally accepted accounting principles; or

(c) available classification best practices or frameworks, such as the IFRS industry-based guidance and GRI Standards defined in ESRS 1 General Requirements, AR 5.

AR 14 for para. 20(d)(i)

(40 (d)(i)) The calculation of revenues derived from the fossil fuel sector shall be based on revenues from the exploration, mining, extraction, production, processing, storage, refining or distribution of fossil fuels, including their transportation, storage and trade, as defined in Article 2, point (62), of Regulation (EU) 2018/1999 of the European Parliament and the Council). The undertaking may present a disaggregation of revenues derived from coal, oil and gas.

AR 15 for para. 24

The undertaking may consider the linkages that exist between paragraph 24 and IRO‑2, paragraph 37(a) to present the content in a way that avoids duplications and facilitates an understanding of the information reported in accordance with these paragraphs. Paragraph 24 focuses on reporting the interaction of the undertaking’s material impacts, risks and opportunities with its strategy and business model. IRO-2, paragraph 37(a) focuses on a description of those impacts, risks and opportunities and how they are likely to affect people and the environment.

A description of the undertaking’s material impacts, risks and opportunities is required in accordance with IRO-2, paragraph 37(a). The undertaking may present the descriptions of its material impacts, risks and opportunities in the same location as its disclosures on the related policies, actions, metrics and targets through which it manages them, in order to avoid duplication and support a coherent narrative.

AR 16 for paras. 25 and 26

If the information is included in the financial statements, it may be incorporated by reference (see ESRS 1 General Requirements, Chapter 9.3).

AR 17 for para. 27

(48(d) amended) In preparing the disclosure on anticipated financial effects, the undertaking shall consider how it expects its financial position, financial performance and cash flows to change over the short, medium and long term, given its strategy to manage risks and opportunities, taking into consideration:

(a) its announced investment and disposal plans (e.g. capital expenditure, major acquisitions and divestments, joint ventures, business transformation, innovation, new business areas and asset retirements), including plans to which the undertaking is not contractually committed; and

(b) its planned sources of funding to implement its strategy.

AR 18 for paras. 25 and 27

Quantitative information may consist of non-monetary information such as volumes, number of products, or number of employees.

AR 19 for paras. 25 and 27

In presenting information reported in accordance with paragraphs 25 and 27 about current financial effects and anticipated financial effects, the undertaking may consider the linkage with the information reported in accordance with GDR-A, paragraphs 46(b)(c) about financial resources allocated to the key actions.

AR 20 for paras. 25 and 27

The DR related to current financial effects and anticipated financial effects are designed to produce information that complements information provided in the financial statements. See Chapter 9 of ESRS 1 General Requirements for the requirements on how to support the understandability of connections between risks and opportunities and the information reported in the financial statements.

AR 21 for paras. 28 and 29

(new) If the undertaking cannot provide quantitative information in accordance with paragraphs 28 and 29, it is expected to provide qualitative information that is decision useful according to paragraph 23 of ESRS 1 General Requirements. In such instance, paragraph 24 of ESRS 1 General Requirements also applies.

AR 22 for para. 35(a)

(new) Input may include, where relevant and beyond generic information, due diligence processes that informed the assessment, specific data sources, sector benchmark analysis, and risk management processes; engagement with affected stakeholders; industry and peer group experience; reports, statistics and scientific data; and experts’ engagement.

AR 23 for para. 35(a)

(new) The description of the process to identity and assess material risks and opportunities is expected to cover dependencies when relevant.

AR 24. for para. 35(a)–(d)

(new) The undertaking shall focus on information that is specific to its own materiality assessment process. It shall avoid standardised, generic disclosures, sometimes referred to as ‘boilerplate’, such as information describing in detail that it has applied the criteria outlined in ESRS 1 General Requirements or followed the recommended process.

AR 25. for para. 35(b)

(new) Information concerning engagement with affected stakeholders is addressed in ESRS 2 IRO-1 and SBM-2 and ESRS S1-S4. To avoid duplication and support a coherent narrative:

(a) relevant disclosures under ESRS 2 IRO-1, paragraph 35(c), include how the materiality process includes consultation with affected stakeholders and external experts;

(b) information on ongoing engagement with affected stakeholders (as defined in ESRS 1 General Requirements, AR 21) is addressed in the respective social standards (ESRS S1-2, S2-2, S3-2 and S4-2);

(c) disclosures related to how key affected stakeholders’ (including workers’ representatives’) interests and views are brought to the attention of the undertakings’s administrative, management and supervisory bodies and inform its strategy and business model, with regard to its material impacts, risks and opportunities, are covered under ESRS 2 SBM-2, paragraph 22(c).

AR 26 for para. 35(b)

In disclosing how the undertaking considered areas of heightened risks of negative impacts related to specific activities, business relationships, or geographies, guidance is provided in ESRS 1 General Requirements, paragraphs 32 (b) and 33.

AR 27 for para. 35(d)

Disclosing changes from the previous period allows users to understand the last reporting period in which a full double materiality assessment was conducted and the aspects of it that have been updated in the reporting period in accordance with ESRS 1 General Requirements, paragraph 35.

AR 28 for para. 37(a)

(new) The description of material risks and opportunities also covers the related dependencies to the extent that is necessary for an understanding of those risks and opportunities.

Paragraph 50 of ESRS 1 General Requirements applies in presenting the disclosure prescribed by this DR.

AR 29 for para. 37(a)

The undertaking may present the description of its material impacts, risks or opportunities in the same location as its disclosures on the related policies, actions, metrics and targets through which it manages them, in order to avoid duplication and support a coherent narrative. If the undertaking exercises this option, it shall still present a concise description of its material impacts, risks and opportunities alongside its disclosures prepared in accordance with IRO-2.

AR 30 for para. 37(d)

(AR 19) The undertaking may present the disclosure as a content index, i.e. a tabular list of the DRs included in the sustainability statement, to support the identification of where they are located (page/paragraphs). It may present the list of information incorporated by reference in an appendix within its sustainability statement, or by including the necessary information in the list of reported DRs as required in paragraph 37(d).

The undertaking may directly reference the DR numbers within its sustainability statement (e.g. in section headings or paragraph titles).

The undertaking may present the ‘supplementary’ information provided under paragraph 37(e) by highlighting it in the section headings, paragraph titles, or the aforementioned content index, so that it is clearly distinguished as supplementary.

AR 35 for para. 43

When disclosing information about its human rights policy to implement the UN Guiding Principles on Business and Human Rights, the undertaking shall consider the International Bill of Human Rights, which consists of the Universal Declaration of Human Rights and the two Covenants that implement them, and the ILO principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.

AR 36 for para. 45

(AR 22) Key actions in the context of this DR are those actions that play a significant role in managing the undertaking’s material impacts risks and opportunities including actions taken to support the provision of remedy.

Key actions include actions that are part of the undertaking’s business practices, sustainability due diligence and overall business and risk management .

Key actions may have been initiated in prior reporting periods and continue to be implemented or produce effects in the current reporting period. For the sake of understandability, key actions may be aggregated if applicable. Conversely, if key actions cover more than one material impact, risk or opportunity, this can be indicated and cross-referenced if necessary.

AR 37 for para. 45

(new) Actions may be undertaken individually or in collaboration with other undertakings, especially if actual impacts or potential impacts are systemic or widespread in nature and cannot be addressed by the undertaking alone.

Users may find it useful to know whether a key action is collaborative.

AR 38 for para. 45

(new) In the description of environmental actions, these may be classified in accordance with the mitigation hierarchy (i.e. avoidance, minimisation, restoration and compensation).

AR 39 for para. 45(a)

(68(a)(b) amended) The scope of key actions refers to their coverage in terms of activities within its own operations, its upstream and downstream value chain, subsidiaries, geographies, and if defined, the affected stakeholder groups in scope. The timeframe refers to the time horizons over which the undertaking intends to complete each action.

AR 40 for para. 46

The undertaking may present the information on resource allocation in the form of a table broken down between (i) capital expenditure and operating expenditure, and between (ii) resources applied in the current reporting year and the planned allocation of resources over specific time horizons.

AR 41 for para. 46(b) and (c)

(new). If the undertaking has allocated significant non-financial resources (e.g. full-time equivalent resources), the information about those resources may be presented as non-monetary quantities.

AR 42 for para. 46(b) and (c)

(new) When preparing disclosures on significant financial resources that have been or are expected to be allocated to the implementation of key actions, the undertaking may limit the disclosure to:

(a) its approved and announced key actions and action plans; and

(b) its planned sources of funding for implementing these key actions.

AR 43 for para. 48

(76 amended) Metrics include those defined in ESRS, as well as metrics identified on an entity-specific basis, whether taken from other sources or developed by the undertaking itself, such as for ESRS S2-S4 topical standards that do not contain metrics.

AR 44 for para. 49(a)

(new) The European system of units of measurement stems from the International System of Units (SI). The units of measurement shall be expressed using the names and symbols set down in Directive 80/181/EEC, as amended by Directive 2009/3/EC. Metrics shall be disclosed using the units specified in the topical standards, which are aligned with this Directive. SI prefixes and their corresponding symbols may be used to designate certain decimal multiples or submultiples where appropriate, in order to present values at the level the undertaking considers most appropriate. For example, instead of reporting 1 200 000 tCO2e, the undertaking may report 1.2 MtCO2e.

AR 45 for para. 49(c)

(new) Contextual information about a metric may include:

(a) the reasons why the undertaking has chosen a particular measurement approach, as well as the reasons for the inputs and assumptions it uses; and

(b) for environmental metrics, the specific environmental conditions and characteristics of the area where the impact is occurring that are necessary to understand the metric in question.

AR 46 for para. 50

Information about progress and effectiveness towards the adopted targets over time is disclosed under GDR-M, paragraph 49(d).

AR 47 for para. 51

Outcome-oriented targets regarding material impacts are defined in terms of expected results for people and the environment.

AR 48 for para. 51 (g)

‘Based on conclusive scientific evidence’ shall be understood as the use of robust, peer-reviewed or otherwise authoritative biophysical information that identifies relevant ecological thresholds or that quantifies conditions, trajectories, and constraints using empirical data, modelling, or recognised scientific frameworks. Such evidence shall enable the undertaking to set ecologically grounded, context-specific and measurable targets.