Questions & Answers
Why are some ESRS paragraphs and Application Requirements (AR) implemented as separate datapoints in IG 3 List of ESRS Datapoints and some are not?
- List of datapoints
Background
ESRS 1 paragraph 16 states: ‘ESRS structure the information to be disclosed under Disclosure Requirements. Each Disclosure Requirement consists of one or more distinct datapoints. The term “datapoint” can also refer to a narrative sub-element of a Disclosure Requirement.’
ESRS 1 paragraph 18 states: ‘ESRS use the following terms to distinguish between different degrees of obligation on the undertaking to disclose information:
(a) “shall disclose” – indicates that the provision is prescribed by a Disclosure Requirement or datapoint;
(b) “may disclose” – indicates voluntary disclosure to encourage good practice.
In addition, ESRS use the term “shall consider” when referring to issues resources or methodologies that the undertaking is expected to take into account or to use in the preparation of a given disclosure if applicable.’
IG 3 List of ESRS Data Points – Explanatory note and the ESRS XBRL Taxonomy provide non-authoritative implementation guidance on the datapoints required by ESRS. It supports the application of sector-agnostic ESRS adopted as delegated act on 31 July 2023 (see EFRAG IG 3 List of ESRS data points – Explanatory note chapter Content and objective of this Implementation Guidance).
ESRS E1 paragraph 36 states: ‘The objective of this Disclosure Requirement is to provide an understanding of the undertaking’s total energy consumption in absolute value, improvement in energy efficiency, exposure to coal, oil and gas-related activities, and the share of renewable energy in its overall energy mix.’
ESRS E1 paragraph AR36 states: ‘When preparing the information on energy intensity required under paragraph 40, the undertaking shall:
(a) calculate the energy intensity ratio using the following formula: …‘
ESRS E1 paragraph AR38 states: ‘The reconciliation of net revenue from activities in high climate impact sectors to the relevant financial statements line item or disclosure (as required by paragraph 43) may be presented either:
(a) by a cross-reference to the related line item or disclosure in the financial statements; or
(b) if the net revenue cannot be directly cross-referenced to a line item or disclosure in the financial statements, by a quantitative reconciliation using the below tabular format. …‘
Answer
IG 3 List of Data Points – Explanatory note (as well as the ESRS XBRL Taxonomy) have dedicated and separate items only for the individual datapoints of ESRS Disclosure Requirements. The datapoints are often indicated by terms equal or similar to ‘shall disclose’, ‘shall describe’ or ‘may disclose’. All paragraphs of ESRS 1, and some paragraphs and Application Requirements of the other topical ESRS, provide objectives, methodological guidance or other guidance that are to be considered when preparing or disclosing sustainability statements according to ESRS. Those paragraphs are not implemented as separate datapoints.
The following examples illustrate when paragraphs in ESRS are considered separate datapoints or not:
(a) ESRS E1 paragraph 36: Not a datapoint because it describes the objective of the disclosure requirement E1-5 on Energy Consumption.
(b) ESRS E1 paragraph AR 36: Not a data point because it provides calculation guidance on the energy consumption.
(c) ESRS E1 paragraph AR 38, implemented as separate data point, due to the character of the Application Requirement which defines how the reconciliation of net revenue from activities in high climate impact sectors to the relevant financial statements line item or disclosure may be presented.
(d) Application Requirements that are part of the narrative disclosure of their associated Disclosure Requirements or datapoint are not designated as separate datapoints. An example would be ESRS E1 paragraph 20 (a) and the related AR 9, detailing the information to be provided under ESRS E1 paragraph 20 (a).
(e) Application Requirements marked with ‘shall consider’ have not been included as separate datapoints, e.g., ESRS 2 paragraph AR 14 relating to ESRS 2 paragraph 42.
Relations
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