Questions & Answers
If the undertaking cannot disclose information regarding policies, actions or targets, it shall then disclose this to be the case and may report on a timeframe to have these in place. Is this also the case for metrics?
- Unavailability of information on material metrics
Background
According to ESRS 1 paragraph 33, if the undertaking has not established policies, taken actions or set targets for the topic, then it shall disclose this to be the case and may report a timeframe in which it aims to have these in place (see also ESRS 1 Appendix E: Flowchart for determining disclosures under ESRS).
According to ESRS 1 paragraph 34, the undertaking shall disclose information on metrics if the Disclosure Requirement or the individual datapoints are assessed to be material.
Clarification is needed in the case where the information of a Disclosure Requirement or datapoint on metrics is assessed as material but the undertaking does not have the information available.
ESRS 2 paragraph 11 requires disclosures on sources of estimation and outcome uncertainty.
Answer
No, this is not the case for metrics. The treatment of paragraph 33 of ESRS 1 is limited to policies, actions and targets and cannot be applied by analogy to metrics – to which paragraph 34 applies instead. Material metrics are to be reported. If the metric cannot be determined through direct data collection, it shall be estimated.
The level of measurement uncertainty of metrics is not a reason for omitting them. According to ESRS 2 BP-2, if a metric is subject to a high level of measurement uncertainty, the undertaking shall disclose information about the sources of measurement uncertainty (for example, availability and quality of data) and disclose the assumptions, approximations and judgments that the entity has made in measuring it.