Questions & Answers

Question-ID: 180

Release Date: Jan 31, 2024


Questions & Answers

Is there a difference between the time horizon as defined in ESRS 1 for impact materiality and for financial materiality?

Key Terms
  • Financial materiality
  • impact materiality
  • time horizon

Background

ESRS 1 paragraph 77 states: ‘When preparing its sustainability statement, the undertaking shall adopt the following time intervals as of the end of the reporting period:

(a) for the short-term time horizon: the period adopted by the undertaking as the reporting period in its financial statements;

(b) for the medium-term time horizon: from the end of the short-term reporting period defined in (a) up to five years; and

(c) for the long-term time horizon: more than five years.’

ESRS 1 paragraph 80 states: ‘There may be circumstances where the use of the medium- or long-term time horizons defined in paragraph 77 results in non-relevant information, as the undertaking uses a different definition for (i) its processes of identification and management of material impacts, risks and opportunities or (ii) the definition of its actions and setting targets. These circumstances may be due to industry-specific characteristics, such as cash flow and business cycles, the expected duration of capital investments, the time horizons over which the users of sustainability statements conduct their assessments or the planning horizons typically used in the undertaking’s industry for decision-making. In these circumstances, the undertaking may adopt a different definition of medium- and/or long-term time horizons (see ESRS 2 BP-2, paragraph 9).’

ESRS 1 Basis of Conclusions paragraph 124 states: ‘The SRB discussed whether to prescribe mandatory time horizons for short-, medium- and long-term for reporting purposes or whether they should be entity-specific based on its business model, industry-characteristics, and its planning horizon. Feedback from public consultation in that respect was ambiguous. Preparers generally preferred an entity-specific approach to be able to use already existing data consistent with their managerial processes, whereas users a more standardized approach for better comparability across undertakings. Noticing that many of the forthcoming first-time sustainability reporters need guidance, to increase comparability the SRB decided to prescribe conventional time periods but to allow deviations from the medium- and long- term time horizons based on entity-specific circumstances, acknowledging also that – depending on the sustainability matter and sector concerned – other time horizons within the long-term horizon might be useful and therefore prevail at topical level.’

Answer

Time horizons are defined in ESRS 1 chapter 6.4, setting fixed time horizons for the short-, medium- and long-term with no distinction being made between impact and financial materiality.

However, ESRS 1 paragraph 80 acknowledges that there may be circumstances in which the undertaking uses a different definition of its time horizons compared to the fixed time horizons set in ESRS 1 paragraph 77. This exception to the general rule has been granted to take into account entity-specific circumstances to manage sustainability-related impacts, risks and opportunities.

When applying either the predefined time horizons or when the exception is used and as a result another entity-specific time horizon is used instead of the predefined time horizon, potential or actual impacts may have a different time horizon than risks or opportunities arising from the same sustainability matter (and their related financial effects). Similarly, actions put in place to address impacts may have a different time horizon than actions put in place to address risks or opportunities. Transparency about time horizons is required in connection with impacts and anticipated financial effects, as stated in ESRS 2 SBM-3 paragraph 48 (c) and (e).


Relations

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2023 ESRSESRS 1 - GENERAL REQUIREMENTS6. Time horizons6.4 Definition of short-, medium- and long-term for reporting purposes

6.4 Definition of short-, medium- and long-term for reporting purposes

2023 ESRSESRS 1 - GENERAL REQUIREMENTS6. Time horizons6.4 Definition of short-, medium- and long-term for reporting purposes

6.4 Definition of short-, medium- and long-term for reporting purposes

2023 ESRSESRS 1 - GENERAL REQUIREMENTS6. Time horizons6.4 Definition of short-, medium- and long-term for reporting purposes

6.4 Definition of short-, medium- and long-term for reporting purposes