Questions & Answers
Is the ‘bolded paragraph’ following each ESRS Disclosure Requirement a disclosure that the undertaking has to respond to? Or is it simply a ‘headline’ that prescribes what the paragraph will contain once all the individual datapoints are completed? See also ESRS E1 Disclosure Requirement E1-6.
- ‘Bolded paragraph’
- ESRS E1 Disclosure Requirement E1-6
Background
In ESRS 2 and in the topical ESRS, Disclosure Requirements are generally followed by a ‘bold paragraph’ stating ‘The undertaking shall disclose . . .’ with a general statement of the information that needs to be disclosed under the respective Disclosure Requirement.
The ‘bold paragraph’ is followed by an objective paragraph, which is followed by more detailed paragraphs containing the datapoints that must be disclosed under the respective Disclosure Requirement and further specifications of the information being requested.
In the case of ESRS E1 Disclosure Requirement E1-6, this is as follows:
ESRS E1 paragraph 44 provides a ‘bold paragraph’ with the general statement of the requirement that needs to be satisfied under ESRS E1 Disclosure Requirement E1-6.;
ESRS E1 paragraph 45 outlines the objective of the disclosure requirement; and
ESRS E1 paragraphs 46-52 further specify information to be included when disclosing on ESRS E1 paragraph 44.
This is illustrated as follows:
Answer
The ‘bold paragraph’ that introduces each Disclosure Requirement is not simply a headline. It is a general statement of what needs to be disclosed under the respective Disclosure Requirement.
The information provided under a Disclosure Requirement should satisfy the overall objective of it, as stated in the paragraph following the bold paragraph (‘the objective of this Disclosure Requirement is . . .’).
The subsequent paragraphs include a list of datapoints (‘the disclosure provided under paragraph XXX shall include . . .’). This list is generally sufficient to meet the disclosure requirements; however, such a list cannot be assumed to be exhaustive, as meeting the disclosure requirement takes precedent over the list of datapoints.
In providing the disclosure that corresponds to the list of individual datapoints (if applicable per the related Application Requirements), it is assumed that both the following are met:
(c)requirements of the ‘bold paragraph’; and
(d) objective as stated in the subsequent paragraph.
The ‘bold paragraph’ of ESRS E1 Disclosure Requirement E1-6 (i.e., ESRS E1 paragraph 44) covers Scope 1, 2 and 3 and total GHG emissions. The objective of the Disclosure Requirements also covers Scope 1, 2 and 3 and total GHG emissions. ESRS E1 paragraph 52 mentions the total GHG emissions. The total GHG emissions shall be reported as it is included in both the bold paragraph and the objective.
Relations
Paragraph | Content |
|---|---|
Metrics and targets | |
Disclosure Requirement E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions | |
Metrics and targets |