Question-ID: 762

The question received, ‘In relation to MDR on policies, actions and targets, should the undertaking report in each topical standard one or multiple policies, actions and targets? If so, should the undertaking report topical datapoints related to each policy, action or target in one block or for each policy?’ was modified to be able to address it more precisely and to add more nuance to the question.

ESRS 1 paragraph 13 states: ‘The undertaking shall apply the minimum disclosure requirements regarding policies, actions, metrics and targets together with the corresponding Disclosure Requirements in topical and sector-specific ESRS.’

ESRS 1 paragraph 115 states: ‘The undertaking shall structure its sustainability statement in four parts in the following order: general information, environmental information (including disclosures pursuant to Article 8 of Regulation (EU) 2020/852), social information and governance information. Respecting the provision in Section 3.6 Material impacts or risks arising from actions to address sustainability matters of this Standard, when information provided in one part contains information to be reported in another part, the undertaking may refer in one part to information presented in another part, avoiding duplications. The undertaking may apply the detailed structure illustrated in Appendix F of this Standard.’

ESRS 1 paragraph AR 18 states: ‘As an illustration for paragraph 115 in section 8.2 Content and structure of the sustainability statement of this Standard, the undertaking that covers environmental and social matters in the same policy may cross-refer. That means that the undertaking may report on the policy in its environmental disclosures and cross-refer to it from the relevant social disclosures and vice versa. Consolidated presentation of policies across topics is allowed.’

ESRS 2 paragraph 61 on MDR on policies and actions states: ‘The corresponding disclosures shall be located alongside disclosures prescribed by the relevant ESRS. When a single policy or the same actions address several interconnected sustainability matters, the undertaking may disclose the required information in its reporting under one topical ESRS and cross-reference to it in its reporting under other topical ESRS.’

ESRS 2 paragraph 71 on metrics and targets states: ‘The corresponding disclosures shall be located alongside disclosures prescribed by the topical ESRS.’

ESRS 1 chapter 3.6 paragraphs 52 and 53 state:

‘52. The undertaking’s materiality assessment may lead to the identification of situations in which its actions to address certain impacts or risks, or to benefit from certain opportunities in relation to a sustainability matter, might have material negative impacts or cause material risks in relation to one or more other sustainability matters. For example:

(a) an action plan to decarbonise production that involves abandoning certain products might have material negative impacts on the undertaking’s own workforce and result in material risks due to redundancy payments; or

(b) an action plan of an automotive supplier to focus on the supply of e-vehicles might lead to stranded assets for the production of supply parts for conventional vehicles.

53. In such situations, the undertaking shall:

(a) disclose the existence of material negative impacts or material risks together with the actions that generate them, with a cross-reference to the topic to which the impacts or risks relate; and

(b) provide a description of how the material negative impacts or material risks are addressed under the topic to which they relate.’