Questions & Answers
Does the company need to report data from previous years?
- Comparative information
- base year
Background
ESRS 1 paragraph 83 states: ‘The undertaking shall disclose comparative information in respect of the previous period for all quantitative metrics and monetary amounts disclosed in the current period. When relevant to an understanding of the current period’s sustainability statement, the undertaking shall also disclose comparative information for narrative disclosures.’
ESRS 1 paragraph 85 states: ‘Sometimes it is impracticable to adjust comparative information for one or more prior periods to achieve comparability with the current period. For example, data might not have been collected in the prior period(s) in a way that allows for either retrospective application of a new definition of a metric or target or retrospective restatement to correct a prior period error and it may be impracticable to recreate the information (see ESRS 2 BP-2). When it is impracticable to adjust comparative information for one or more prior periods, the undertaking shall disclose this fact.’
ESRS 1 paragraph 86 states: ‘When an ESRS requires the undertaking to present more than one comparative period for a metric or datapoint, the requirements of that ESRS shall prevail.’
Some requirements (i.e., targets) provide the disclosure of the base year (see chapter 6.3 of ESRS 1), defined as the historical reference date or period for which information is available and against which subsequent information can be compared over time. In this context, comparative information is required in respect of the base year for amounts reported in the current period when reporting the developments and progress towards a target unless the relevant Disclosure Requirement already defines how to report on progress.
ESRS 1 paragraph 136 states: ‘To ease the first-time application of this Standard, the undertaking is not required to disclose the comparative information required by section 7.1 Presenting comparative information in the first year of preparation of the sustainability statement under the ESRS.’
Answer
Yes, the undertaking shall always report comparative information in respect of the previous period for all quantitative metrics and monetary amounts disclosed in the current period. Narrative disclosures shall only be disclosed for previous periods when relevant to an understanding of the current period’s sustainability statement.
Special provisions apply when it is impracticable to disclose comparative information (ESRS 1 paragraph 85).
Some requirements (e.g., targets) request the disclosure of the base year when reporting on progress towards a target. Comparative information is required in respect of the base year for amounts reported in the current period when reporting the developments and progress towards a target (ESRS 1 chapter 6.3).
A phase-in provision exists exempting undertakings for the first year of preparation of the sustainability statement to provide comparative information (ESRS 1 paragraph 136).