Questions & Answers
Can the transitional provision in ESRS 1 paragraphs 132 to 135 be applied to the reporting of Scope 3 emissions in ESRS E1 paragraph 44 (c)?
- Value chain
- transitional provisions
- Scope 3 GHG emissions
Background
ESRS E1 paragraph 44 states: ‘The undertaking shall disclose in metric tonnes of CO2eq its:
(a) gross Scope 1 GHG emissions;
(b) gross Scope 2 GHG emissions;
(c) gross Scope 3 GHG emissions; and
(d) total GHG emissions.’
ESRS 1 paragraph 133 states: ‘For the first three years of its sustainability reporting under the ESRS, in order to take account of the difficulties that undertakings may encounter in gathering information from actors throughout their value chain and in order to limit the burden for SMEs in the value chain:
(a) when disclosing information on policies, actions and targets in accordance with ESRS 2 and other ESRS, the undertaking may limit upstream and downstream value chain information to information available in-house, such as data already available to the undertaking and publicly available information; and
(b) when disclosing metrics, the undertaking is not required to include upstream and downstream value chain information except for datapoints derived from other EU legislation, as listed in ESRS 2 Appendix B.’
Answer
No, the transitional provisions outlined in ESRS 1 paragraphs 132 to 135 cannot be applied to reporting Scope 3 emissions as required by ESRS E1 paragraph 44 (c). A phase-in exception applies to undertakings or groups not exceeding on their balance sheet dates the average number of 750 employees during the financial year.
The disclosure of Scope 3 emissions is a datapoint derived from EU legislation, as indicated in ESRS 2 Appendix B (Disclosure Requirement and related datapoint: ESRS E1-6 Gross Scope 1, 2, 3 and Total GHG emissions paragraph 44). Despite the transitional provisions of ESRS 1 paragraph 133 (b), datapoints derived from EU legislation, such as Scope 3 emissions, shall be reported.
It is, however, noteworthy that ‘undertakings or groups not exceeding on their balance sheet dates the average number of 750 employees during the financial year (on a consolidated basis where applicable) may omit the datapoints on Scope 3 emissions and total GHG emissions for the first year of preparation of their sustainability statement’ (see ESRS 1 Appendix C: List of phased-in Disclosure Requirements).
Relations
Paragraph | Content |
|---|---|
Appendix C - List of phased-in Disclosure Requirements | |
Appendix B - List of datapoints in cross-cutting and topical standards that derive from other EU legislation | |
Appendix C - List of phased-in Disclosure Requirements | |
Appendix B - List of datapoints in cross-cutting and topical standards that derive from other EU legislation | |
Appendix B - List of datapoints in cross-cutting and topical standards that derive from other EU legislation | |
Appendix C - List of phased-in Disclosure Requirements | |
Starting from the fourth year of its reporting under the ESRS, the undertaking shall include upstream and/or downstream value chain information according to paragraph 63. In this context, the information required by ESRS to be obtained from SME undertakings in the undertaking’s upstream and/or downstream value chain will not exceed the content of the future ESRS for listed SMEs. | |
For the first 3 years of the undertaking’s sustainability reporting under the ESRS, in the event that not all the necessary information regarding its upstream and downstream value chain is available, the undertaking shall explain the efforts made to obtain the necessary information about its upstream and downstream value chain, the reasons why not all of the necessary information could be obtained, and its plans to obtain the necessary information in the future. | |
Paragraphs 132 and 133 apply irrespective of whether or not the relevant actor in the value chain is an SME. | |
For the first 3 years of its sustainability reporting under the ESRS, in order to take account of the difficulties that undertakings may encounter in gathering information from actors throughout their value chain and in order to limit the burden for SMEs in the value chain: |