Questions & Answers

Question-ID: 906

Release Date: Jun 30, 2024


Questions & Answers

Is there the possibility to implement an ‘Appendix’ as another part of the sustainability statement (mainly for the content index, EU datapoint table, etc.)?

Key Terms
  • Structure of the sustainability statement
  • content index
  • EU-datapoint table
  • potential appendix

Background

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 2 paragraph 56 states: ‘The undertaking shall include a list of the Disclosure Requirements complied with in preparing the sustainability statement, following the outcome of the materiality assessment (see ESRS 1 Chapter 3), including the page numbers and/or paragraphs where the related disclosures are located in the sustainability statement. This may be presented as a content index. The undertaking shall also include a table of all the datapoints that derive from other EU legislation as listed in Appendix B of this standard, indicating where they can be found in the sustainability statement and including those that the undertaking has assessed as not material, in which case the undertaking shall indicate “Not material” in the table in accordance with ESRS1 paragraph 35.’

ESRS 1 paragraph 119 states: ‘Provided that the conditions in paragraph 120 are met, information prescribed by a Disclosure Requirement of an ESRS, including a specific datapoint prescribed by a Disclosure Requirement, may be incorporated in the sustainability statement by reference to:

(a) another section of the management report;

(b) the financial statements;

(c) the corporate governance statement (if not part of the management report) …’

ESRS 1 paragraph 120 states: ‘The undertaking may incorporate information by reference to the documents, or part of the documents, listed in paragraph 119, provided that the disclosures incorporated by reference:

(a) constitute a separate element of information and are clearly identified in the document concerned as addressing the relevant Disclosure Requirement, or the relevant specific datapoint prescribed by a Disclosure Requirement;

(b) are published before or at the same time as the management report;

(c) are in the same language as the sustainability statement;

(d) are subject to at least the same level of assurance as the sustainability statement; and

(e) meet the same technical digitalisation requirements as the sustainability statement.

Answer

It is possible to have the content index and the EU datapoint table as another section of the management report.

The sustainability statement shall consist of four parts (ESRS 1 paragraph 56). The first part is related to general information. As the content index and the datapoints that derive from other EU legislation are part of the ESRS 2 Disclosure Requirement IRO-2 – Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement, they need to be included in the part related to general information. However, information can, subject to the incorporation by reference requirements of ESRS 1 paragraph 120, also be placed in ‘another section of the management report’ (ESRS 1 paragraph 119 (a)).

See also Question ID 628 Content index.


Relations

Paragraph
Content
2023 ESRSESRS 1 - GENERAL REQUIREMENTS8. Structure of the sustainability statement8.2 Content and structure of the sustainability statement

8.2 Content and structure of the sustainability statement

2023 ESRSESRS 1 - GENERAL REQUIREMENTS8. Structure of the sustainability statement8.2 Content and structure of the sustainability statement

8.2 Content and structure of the sustainability statement

2023 ESRSESRS 1 - GENERAL REQUIREMENTS8. Structure of the sustainability statement8.2 Content and structure of the sustainability statement

8.2 Content and structure of the sustainability statement

2023 ESRSESRS 1 - GENERAL REQUIREMENTS...9.1 Incorporation by reference119.

Provided that the conditions in paragraph 120 are met, information prescribed by a Disclosure Requirement of an ESRS, including a specific datapoint prescribed by a Disclosure Requirement, may be incorporated in the sustainability statement by reference to:

2023 ESRSESRS 2 - GENERAL DISCLOSURES...4.1 Disclosures on the materiality assessment process56.

The undertaking shall include a list of the Disclosure Requirements complied with in preparing the sustainability statement, following the outcome of the materiality assessment (see ESRS 1 chapter 3), including the page numbers and/or paragraphs where the related disclosures are located in the sustainability statement. This may be presented as a content index. The undertaking shall also include a table of all the datapoints that derive from other EU legislation as listed in Appendix B of this standard, indicating where they can be found in the sustainability statement and including those that the undertaking has assessed as not material, in which case the undertaking shall indicate “Not material” in the table in accordance with ESRS 1 paragraph 35.

2023 ESRSESRS 1 - GENERAL REQUIREMENTS...9.1 Incorporation by reference119.

Provided that the conditions in paragraph 120 are met, information prescribed by a Disclosure Requirement of an ESRS, including a specific datapoint prescribed by a Disclosure Requirement, may be incorporated in the sustainability statement by reference to:

2023 ESRSESRS 2 - GENERAL DISCLOSURES...Disclosure Requirement IRO-2 – Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement56.

The undertaking shall include a list of the Disclosure Requirements complied with in preparing the sustainability statement, following the outcome of the materiality assessment (see ESRS 1 chapter 3), including the page numbers and/or paragraphs where the related disclosures are located in the sustainability statement. This may be presented as a content index. The undertaking shall also include a table of all the datapoints that derive from other EU legislation as listed in Appendix B of this standard, indicating where they can be found in the sustainability statement and including those that the undertaking has assessed as not material, in which case the undertaking shall indicate “Not material” in the table in accordance with ESRS 1 paragraph 35.

2023 ESRSESRS 2 - GENERAL DISCLOSURES4.1 Disclosures on the materiality assessment process56.

The undertaking shall include a list of the Disclosure Requirements complied with in preparing the sustainability statement, following the outcome of the materiality assessment (see ESRS 1 chapter 3), including the page numbers and/or paragraphs where the related disclosures are located in the sustainability statement. This may be presented as a content index. The undertaking shall also include a table of all the datapoints that derive from other EU legislation as listed in Appendix B of this standard, indicating where they can be found in the sustainability statement and including those that the undertaking has assessed as not material, in which case the undertaking shall indicate “Not material” in the table in accordance with ESRS 1 paragraph 35.

2023 ESRSESRS 1 - GENERAL REQUIREMENTS...9. Linkages with other parts of corporate reporting and connected information119.

Provided that the conditions in paragraph 120 are met, information prescribed by a Disclosure Requirement of an ESRS, including a specific datapoint prescribed by a Disclosure Requirement, may be incorporated in the sustainability statement by reference to:

2023 ESRSESRS 2 - GENERAL DISCLOSURESDisclosure Requirement IRO-2 – Disclosure Requirements in ESRS covered by the undertaking’s sustainability statement56.

The undertaking shall include a list of the Disclosure Requirements complied with in preparing the sustainability statement, following the outcome of the materiality assessment (see ESRS 1 chapter 3), including the page numbers and/or paragraphs where the related disclosures are located in the sustainability statement. This may be presented as a content index. The undertaking shall also include a table of all the datapoints that derive from other EU legislation as listed in Appendix B of this standard, indicating where they can be found in the sustainability statement and including those that the undertaking has assessed as not material, in which case the undertaking shall indicate “Not material” in the table in accordance with ESRS 1 paragraph 35.