Questions & Answers

ESRS E4-5 paragraph 37 mentions that ‘For datapoints specified in paragraphs 38 to 41, the undertaking shall consider its own operations’. Does that mean that ESRS E4 paragraph 33 where it says ‘The undertaking shall report metrics related to its material impacts on biodiversity and ecosystems’ also refers to the undertaking’s own operations only?

ID 1033: In the context of ESRS E1 paragraph 34 (a) and in a situation where a credit institution has set GHG emissions intensity targets, are credit institutions expected to provide associated absolute values in relation to their emissions intensity targets even if such metric is not used to steer the portfolio and due to the fact that it can be neither predictive or of confirmatory value due to the business model of the credit institutions?

ID 1076: Would it be possible for a financial institution to disclose GHG emissions targets set on Scope 3 category 15 (i.e. ‘financed emissions’) without reporting the corresponding targets in absolute emissions?’

ID 1122: Regarding absolute values for financial institutions – why not show exposure and exposure percentages instead of GHG emissions?’

Is the ESRS 1 Disclosure Requirement SBM-3 metric to be reported for ESRS E4 if biodiversity was assessed as not material for the company’s own operations but material only for the upstream value chain? The SBM-3 metric specifically refers to the company’s own sites, i.e. own operations. Additionally, no sites were found located in or near biodiversity-sensitive areas that have negative impacts on these areas.

How can preparers take ‘the changes over time’ into account when disclosing the amounts of pollutants?

May estimates or secondary data also be used for social topics if they concern social protection on own workforce?

What are the CSRD requirements regarding heating values (Lower Heating Value (LHV) versus Higher Heating value (HHV)), and do they differ based on the location of the preparer?

What is the level of disaggregation in the sustainability statement of a group with multiple legal entities per country in the EU and outside EU?

Shall the amount of microplastic that is generated due to tires wear be reported?

Is MDR-Policy a prerequisite for MDR-Target?

Is a company obliged to disclose a discrimination/harassment case that, upon investigation, was found to lack conclusive evidence supporting the allegations (and hence was considered closed without any supporting evidence)?

ID 271: What is the difference between work-related accident and work-related injury?

ID 287: What is the difference between an ‘accident’ and an ‘injury’, and how should I count a ‘case’?

Which indicators are to be used to convert fossil fuels to kWh (gasoline, diesel, natural gas)?

(1) Should individuals on parental leave, long-term sick leave or long-term special leave who receive less than their regular total annual remuneration be excluded from the annual total remuneration calculation considering long-term leave as a consecutive period of at least three months?

(2) When computing the annual total remuneration, do we consider the same salary components for both the highest paid individual and the employees (e.g. benefits in cash / benefits in kind)?

Is it necessary to report radioactive waste from analytical devices and tracer applications?

We think that disclosing ESRS S1 paragraph 88 (e) ‘the number of days lost to work-related injuries and fatalities from work-related accidents, work-related ill health and fatalities from ill health’ of non-employees would be non-compliant and against the law in Japan. Is it not against the law under European law? How should we deal with such disclosure?

Can undertakings report different metrics related to the same sustainability matter in different parts of the value chain depending on the nature of the impact, for example water withdrawal for own operations and water consumption for upstream value chain?

What is the meaning of water treatment ‘as a step towards more sustainable sourcing of water’?

For a material matter, if the undertaking assesses that a Disclosure Requirement is not material, is it possible to conclude that a datapoint of such Disclosure Requirement is material and therefore included?

How can one document ESG knowledge and the competences of the management board and supervisory board? Should it be one person from the Management Board or the Supervisory Board who has these features or else the entire Management Board and the entire Supervisory Board? Can it be an attorney? Should it be a course, training or, for example, studies?

What does ‘type of employee’ mean for the purposes of Disclosure Requirement ESRS S1-11 Social Protection?