Questions & Answers
Is it possible to report some metrics on a (deviating) financial year and other metrics on a calendar year basis? For example, if the financial year is from 1 July to 30 June, can the reporting of the energy consumption in metrics be based on the energy bill on a calendar year basis (i.e. from 1 January to 31 December) rather than the financial year?
- Financial year
- calendar year
- metrics
Background
ESRS 1 paragraph 73 states: ‘The reporting period for the undertaking’s sustainability statement shall be consistent with that of its financial statements.’
ESRS 1 paragraph 90 states: ‘Data and assumptions used in preparing the sustainability statement shall be consistent to the extent possible with the corresponding financial data and assumptions used in the undertaking’s financial statements.’
When making estimates, the qualitative characteristics of information shall be considered (see ESRS 1 chapter 2 and Appendix B). Faithful representation requires information to be (i) complete, (ii) neutral and (iii) accurate. Information can be accurate without being perfectly precise in all respects. Accurate information implies that the undertaking has implemented adequate processes and internal controls to avoid material errors or material misstatements. As such, estimates shall be presented with a clear emphasis on their possible limitations and associated uncertainty.
ESRS 1 paragraph 88 states: ‘An undertaking shall disclose information to enable users to understand the most significant uncertainties affecting the quantitative metrics and monetary amounts reported in its sustainability statement.’
ESRS 1 paragraph 69 states: ‘There are circumstances where the undertaking cannot collect the information about its upstream and downstream value chain as required by paragraph 63 after making reasonable efforts to do so. In these circumstances, the undertaking shall estimate the information to be reported about its upstream and downstream value chain by using all reasonable and supportable information, such as sector-average data and other proxies.’
ESRS E1 paragraph AR 42 states with respect to Disclosure Requirements E1-6 - Gross Scopes 1, 2, 3, and Total GHG emissions: ‘An undertaking might have a different reporting period from some or all of the entities in its value chain. In such circumstances, the undertaking is permitted to measure its GHG emissions in accordance with paragraph 44 using information for reporting periods that are different from its own reporting period if that information is obtained from entities in its value chain with reporting periods that are different from the undertaking’s reporting period, on the condition that:
(a) the undertaking uses the most recent data available from those entities in its value chain to measure and disclose its greenhouse gas emissions;
(b) the length of the reporting periods is the same; and
(c) the undertaking discloses the effects of significant events and changes in circumstances (relevant to its GHG emissions) that occur between the reporting dates of the entities in its value chain and the date of the undertaking’s general purpose financial statements.’
Answer
No, it is not possible to report metrics for a period which deviates from the financial year.
The reporting period for the undertaking’s sustainability statement shall be consistent with that of its financial statements. Accordingly, the undertaking shall use consistent assumptions adopted in the preparation of the financial statements for all metrics.
When reporting for a financial year from 1 July to 30 June, an undertaking starting for example from the calendar year energy bill as a basis to calculate the energy consumption, shall make appropriate adjustments to the data when this is necessary to properly depict the effective usage during the period running from 1 July to 30 June.
There are special provisions for ESRS E1 Disclosure Requirement E1-6 dealing with situations where an undertaking has a different reporting period from some or all of the entities in its value chain.
Relations
Paragraph | Content |
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The reporting period for the undertaking’s sustainability statement shall be consistent with that of its financial statements. | |
The reporting period for the undertaking’s sustainability statement shall be consistent with that of its financial statements. | |
The reporting period for the undertaking’s sustainability statement shall be consistent with that of its financial statements. |