Questions & Answers
In the first years of the phase-in 750 employees, where should the disclosures required by ESRS 2 Disclosure Requirement BP-2 (paragraph 17) be reported?
- Minimum disclosure requirements
- phase-in less than 750 employees
- transitional provisions
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 . . . 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 ESRS 1.
ESRS 2 paragraph 61 states in respect of policies and targets: ‘The minimum disclosure requirements on policies and actions shall be located alongside disclosures prescribed by the relevant ESRS. When a single policy or 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 states in respect of metrics and targets: ‘The corresponding disclosures shall be located alongside disclosures prescribed by the topical ESRS.’
Answer
The undertaking shall structure its sustainability statement in four parts (ESRS 1 paragraph 115).
ESRS 2 Disclosure Requirement BP-2 (including its paragraph 17) is part of the general information required by ESRS 2 and as such, on a literal reading of ESRS 1 paragraph 115, could be disclosed as part of the general information, for example, together with the Disclosure Requirement SBM-3 Material impacts, risks and opportunities and their interaction with strategy and business model.
However, based on ESRS 1 paragraph 115, environmental, social and governance related information can – appropriately cross-referenced - also be disclosed with the respective environmental, social and governance related parts of the sustainability statement. This is in line with ESRS 2 paragraph 61 on the minimum disclosure requirement for policies and actions and with ESRS 2 paragraph 71 on metrics and targets, both allowing information to be located alongside disclosures prescribed by the relevant topical ESRS.
Relations
Paragraph | Content |
|---|---|
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. | |
The corresponding disclosures shall be located alongside disclosures prescribed by the topical ESRS. | |
The corresponding disclosures shall be located alongside disclosures prescribed by the relevant ESRS. When a single policy or 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. | |
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. | |
The corresponding disclosures shall be located alongside disclosures prescribed by the topical ESRS. | |
The corresponding disclosures shall be located alongside disclosures prescribed by the relevant ESRS. When a single policy or 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. | |
The corresponding disclosures shall be located alongside disclosures prescribed by the relevant ESRS. When a single policy or 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. | |
The corresponding disclosures shall be located alongside disclosures prescribed by the topical ESRS. | |
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. |