Questions & Answers

Question-ID: 953

Release Date: Oct 31, 2024


Questions & Answers

Is it mandatory to report a metric for each material impact on biodiversity and ecosystems?

Key Terms
  • Metrics
  • mandatory

Background

ESRS 1 paragraph 11 states: ‘In addition to the disclosure requirements laid down in the three categories of ESRS, when an undertaking concludes that an impact, risk or opportunity is not covered or not covered with sufficient granularity by an ESRS but is material due to its specific facts and circumstances, it shall provide additional entity-specific disclosures to enable users to understand the undertaking’s sustainability-related impacts, risks or opportunities . Application requirements AR 1 to AR 5 provide further guidance regarding entity-specific disclosures.’

ESRS 1 paragraph 34 states: ‘When disclosing information on metrics for a material sustainability matter according to the Metrics and Targets section of the relevant topical ESRS, the undertaking:

(a) shall include the information prescribed by a Disclosure Requirement if it assesses such information to be material; and

(b) may omit the information prescribed by a datapoint of a Disclosure Requirement if it assesses such information to be not material and concludes that such information is not needed to meet the objective of the Disclosure Requirement.’

ESRS 1 paragraph AR 3 states ‘When determining the usefulness of metrics for inclusion in its entity-specific disclosures, the undertaking shall consider whether:

(a) its chosen performance metrics provide insight into:

i. how effective its practices are in reducing negative outcomes and/or increasing positive outcomes for people and the environment (for impacts); and/or

ii. the likelihood that its practices result in financial effects on the undertaking (for risks and opportunities);

(b) the measured outcomes are sufficiently reliable, meaning that they do not involve an excessive number of assumptions and unknowns that would render the metrics too arbitrary to provide a faithful representation; and

(c) it has provided sufficient contextual information to interpret performance metrics appropriately, and whether variations in such contextual information may impact the comparability of the metrics over time.’

ESRS E4 paragraph 33 states: ‘The undertaking shall report metrics related to its material impacts on biodiversity and ecosystems.’

ESRS E4 paragraph 35 states: ‘If the undertaking identified sites located in or near biodiversity-sensitive areas that it is negatively affecting (see paragraph 19(a)), the undertaking shall disclose the number and area (in hectares) of sites owned, leased or managed in or near these protected areas or key biodiversity areas.

ESRS E4 paragraph 38 states: ‘If the undertaking has concluded that it directly contributes to the impact drivers of land-use change, freshwater-use change and/or sea-use change, it shall report relevant metrics. The undertaking may disclose metrics that measure:

(a) the conversion over time (e.g. 1 or 5 years) of land cover (e.g. deforestation or mining);

(b) changes over time (e.g. 1 or 5 years) in the management of the ecosystem (e.g. through the intensification of agricultural management, or the application of better management practices or forestry harvesting);

(c) changes in the spatial configuration of the landscape (e.g. fragmentation of habitats, changes in ecosystem connectivity);

(d) changes in ecosystem structural connectivity (e.g. habitat permeability based on physical features and arrangements of habitat patches); and

(e) the functional connectivity (e.g. how well genes or individuals move through land, freshwater and seascape).’

ESRS E4 paragraph 39 states: ‘If the undertaking concluded that it directly contributes to the accidental or voluntary introduction of invasive alien species, the undertaking may disclose the metrics it uses to manage pathways of introduction and spread of invasive alien species and the risks posed by invasive alien species.’

ESRS E4 paragraph 40 states: ‘If the undertaking identified material imp

cts related to the state of species, the undertaking may report metrics it considers relevant. The undertaking may:

(a) refer to relevant disclosure requirements in ESRS E1, ESRS E2, ESRS E3, and ESRS E5;

(b) consider population size, range within specific ecosystems as well as extinction risk. These aspects provide insight on the health of a single species’ population and its relative resilience to human induced and naturally occurring change;

(c) disclose metrics that measure changes in the number of individuals of a species within a specific area;

(d) disclose metrics on species at extinction risk (80) that measure:

i. the threat status of species and how activities/pressures may affect the threat status; or

ii. changes in the relevant habitat for a threatened species as a proxy for the undertaking’s impact on the local population’s extinction risk.’

ESRS E4 paragraph 41 states: ‘If the undertaking identified material impacts related to ecosystems, it may disclose:

(a) with regard to ecosystems extent, metrics that measure area coverage of a particular ecosystem without necessarily considering the quality of the area being assessed, such as habitat cover. For example, forest cover is a measure of the extent of a particular ecosystem type, without factoring in the condition of the ecosystem (e.g. provides the area without describing the species diversity w

(b) thin the forest);

(c) with regard to the ecosystem’s condition:

i. metrics that measure the quality of ecosystems relative to a pre-determined reference state;

ii. metrics that measure multiple species within an ecosystem rather than the number of individuals within a single species within an ecosystem (for example: scientifically established species richness and abundance indicators that measure the development of (native) species composition within an ecosystem against the reference state at the beginning of the first reporting period as well as the targeted state outlined in the Kunming-Montreal Global Biodiversity Framework, or an aggregation of species’ conservation status if relevant); or

iii. metrics that reflect structural components of condition such as habitat connectivity (i.e. how linked habitats are to each other).’

Answer

No, ESRS E4 does not require reporting metrics for each material impact. For ESRS E4, it is only mandatory for the undertaking to report metrics for ESRS E4 paragraph 35 (if the undertaking identified sites located in or near biodiversity-sensitive areas that it is negatively affecting) and for paragraph 38. In applying paragraphs 35 and 38, the conditions of ESRS 1 paragraph 34 apply (see background). The disclosure of metrics related to ESRS E4 paragraphs 39, 40 and 41 is voluntary even if the undertaking has identified material impacts in connection with the subtopics mentioned in those paragraphs (the undertaking would still be required to disclose on the other provisions listed in ESRS E4 for those material subtopics).

With regard to ESRS E4 paragraph 38, the undertaking can choose to disclose metrics that measure other or only a few of the aspects listed in that paragraph. The undertaking shall refer to ESRS 1 paragraph 11 when identifying relevant entity-specific metrics.

Impact metrics in ESRS E4 are rarely standardized. For disclosure requirements where they are not, it is the responsibility of the undertaking to identify the metrics that are relevant to be disclosed (see ESRS 1 paragraph 31 and Appendix B of ESRS 1 for the definition of ‘relevance’). To assist the undertakings in this process, ESRS E4-5 indicates metrics or indicators that measure relevant aspects related to ecosystems and biodiversity and that may be material for undertakings to disclose.

In relation to paragraphs 39, 40 and 41, reporting on metrics is optional. However, if the undertaking concludes that the inclusion of entity specific metric(s) is necessary (ESRS 1 paragraph 11), the provisions in these paragraphs support the identification of relevant metrics to be reported.

See also Question ID 526 and ID 1021 – Disclosure of a non-material datapoint (water-consumption in own operations) related to a (a) material and (b) non-material topic.


Relations

Paragraph
Content
2023 ESRSESRS E4 - BIODIVERSITY AND ECOSYSTEMS...Disclosure Requirement E4-5 – Impact metrics related to biodiversity and ecosystems change41.

If the undertaking identified material impacts related to ecosystems, it may disclose:

2023 ESRSESRS E4 - BIODIVERSITY AND ECOSYSTEMS...Disclosure Requirement E4-5 – Impact metrics related to biodiversity and ecosystems change40.

If the undertaking identified material impacts related to the state of species, the undertaking may report metrics it considers relevant. The undertaking may:

2023 ESRSESRS E4 - BIODIVERSITY AND ECOSYSTEMS...Metrics and targets39.

If the undertaking concluded that it directly contributes to the accidental or voluntary introduction of invasive alien species, the undertaking may disclose the metrics it uses to manage pathways of introduction and spread of invasive alien species and the risks posed by invasive alien species.

2023 ESRSESRS E4 - BIODIVERSITY AND ECOSYSTEMS...Metrics and targets38.

If the undertaking has concluded that it directly contributes to the impact drivers of land-use change, freshwater -use change and/or sea-use change, it shall report relevant metrics. The undertaking may disclose metrics that measure:

2023 ESRSESRS E4 - BIODIVERSITY AND ECOSYSTEMS...Disclosure Requirement E4-5 – Impact metrics related to biodiversity and ecosystems change33.

The undertaking shall report metrics related to its material impacts on biodiversity and ecosystems.

2023 ESRSESRS E4 - BIODIVERSITY AND ECOSYSTEMS...Metrics and targets41.

If the undertaking identified material impacts related to ecosystems, it may disclose:

2023 ESRSESRS E4 - BIODIVERSITY AND ECOSYSTEMS...Metrics and targets40.

If the undertaking identified material impacts related to the state of species, the undertaking may report metrics it considers relevant. The undertaking may:

2023 ESRSESRS E4 - BIODIVERSITY AND ECOSYSTEMS...Disclosure Requirements39.

If the undertaking concluded that it directly contributes to the accidental or voluntary introduction of invasive alien species, the undertaking may disclose the metrics it uses to manage pathways of introduction and spread of invasive alien species and the risks posed by invasive alien species.

2023 ESRSESRS E4 - BIODIVERSITY AND ECOSYSTEMS...Disclosure Requirement E4-5 – Impact metrics related to biodiversity and ecosystems change38.

If the undertaking has concluded that it directly contributes to the impact drivers of land-use change, freshwater -use change and/or sea-use change, it shall report relevant metrics. The undertaking may disclose metrics that measure:

2023 ESRSESRS E4 - BIODIVERSITY AND ECOSYSTEMS...Metrics and targets33.

The undertaking shall report metrics related to its material impacts on biodiversity and ecosystems.