Questions & Answers
Can the ESRS 2 datapoints be overlapping with those in topical standards? What would be the scope of information the preparer is expected to provide within ESRS 2 (that is distinctive of topical standards datapoints)?
- ESRS 2-related disclosures in topical standards
- structure of the sustainability statement
Background
ESRS 1 paragraph 115 states: ‘The undertaking shall structure its sustainability statement in four parts in the following order: general information, environmental information … 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.’
ESRS 2 paragraph 2 states: ‘In the preparation of disclosures under this Standard, the undertaking shall apply the Disclosure Requirements (including their datapoints) set in topical ESRS, as listed in Appendix C of this Standard Disclosure/Application Requirements in topical ESRS that are applicable in conjunction with ESRS 2 General Disclosures. The undertaking shall apply the requirements listed in Appendix C:
(a) in all instances for the requirements in topical standards related to Disclosure Requirement IRO-1 Description of the processes to identify and assess material impacts, risks and opportunities; and
(b) for all other requirements listed in Appendix C, only if the sustainability topic is material based on the undertaking’s materiality assessment (see ESRS 1 Chapter 3 Double materiality as the basis for sustainability disclosures).’
Answer
No, the ESRS 2 Disclosure Requirements do not overlap with the Disclosure Requirements in topical ESRS with the exception of the Minimum Disclosure Requirements (MDRs) in ESRS 2 Chapter 4.2 Minimum disclosure requirement on policies and actions and chapter 5 Metrics and targets.
The MDR may overlap by definition with those in the topical standards as they are a checklist to be used for completeness: i.e. when a datapoint in MDR is already covered by a topical standard, undertakings are not supposed to report twice the same information.
Some Disclosure Requirements in the topical ESRS (labelled ‘Disclosure Requirement related to ESRS 2 GOV-1, GOV-3, SBM-2, SBM-3 or IRO-1 …’ in the respective topical ESRS; see Appendix C of ERSR 2) further specify the ESRS 2 disclosures in relation to the respective topical matter (see ESRS 2 paragraph 2).
The ESRS 2 disclosures, together with their specifications in topical ESRS, are expected to be disclosed as part of the general information of the sustainability statement. To avoid duplications, an undertaking may refer in one part of the sustainability statement to information presented in another part as stated in ESRS 1 paragraph 115.
See also Question ID 296 – Location of ESRS 2-related Disclosure Requirement of topical standards.
Relations
Paragraph | Content |
|---|---|
Appendix C - Disclosure and Application Requirements in Topical ESRS that are applicable in conjunction with ESRS 2 General disclosures | |
Appendix C - Disclosure and Application Requirements in Topical ESRS that are applicable in conjunction with ESRS 2 General disclosures | |
Appendix C - Disclosure and Application Requirements in Topical ESRS that are applicable in conjunction with ESRS 2 General disclosures | |
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. | |
In the preparation of disclosures under this Standard, the undertaking shall apply the Disclosure Requirements (including their datapoints) set in topical ESRS, as listed in Appendix C of this Standard Disclosure/Application Requirements in topical ESRS that are applicable jointly with ESRS 2 General Disclosures. The undertaking shall apply the requirements listed in Appendix C: | |
This ESRS sets out the disclosure requirements that apply to all undertakings regardless of their sector of activity (i.e., sector agnostic) and apply across sustainability topics (i.e., cross-cutting). This ESRS covers the reporting areas defined in ESRS 1 General requirements section 1.2 Reporting areas and minimum content disclosure requirements on policies, actions, targets, and metrics. | |
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. | |
This ESRS sets out the disclosure requirements that apply to all undertakings regardless of their sector of activity (i.e., sector agnostic) and apply across sustainability topics (i.e., cross-cutting). This ESRS covers the reporting areas defined in ESRS 1 General requirements section 1.2 Reporting areas and minimum content disclosure requirements on policies, actions, targets, and metrics. | |
In the preparation of disclosures under this Standard, the undertaking shall apply the Disclosure Requirements (including their datapoints) set in topical ESRS, as listed in Appendix C of this Standard Disclosure/Application Requirements in topical ESRS that are applicable jointly with ESRS 2 General Disclosures. The undertaking shall apply the requirements listed in Appendix C: | |
This ESRS sets out the disclosure requirements that apply to all undertakings regardless of their sector of activity (i.e., sector agnostic) and apply across sustainability topics (i.e., cross-cutting). This ESRS covers the reporting areas defined in ESRS 1 General requirements section 1.2 Cross-Cutting Standards and reporting areas. |