Annex I

1.

ESRS Standards and drafting conventions

1.1.

ESRS standards and entity-specific disclosures

1.2.

Drafting conventions

2.

Fair presentation and qualitative characteristics of information

3.

Double materiality as the basis for sustainability reporting

3.1.

Assessing information to be reported

3.1.1.

Information materiality

3.1.2.

Steps in determining the information to be reported

3.1.3.

Bases for assessing materiality

3.1.4.

Periodicity of the double materiality assessment

3.2.

Double materiality assessment: impact materiality and financial materiality

3.2.1.

Impact materiality assessment

3.2.2.

Financial materiality assessment

3.3.

Specific circumstances

3.3.1.

Material impacts or risks arising from actions to address impacts or risks related to other topics

3.3.2.

Level of aggregation and disaggregation

4.

Due diligence

5.

Reporting undertaking and upstream and downstream value chain

5.1.

Reporting undertaking and own operations

5.2.

Inclusion of upstream and downstream value chain information

5.3.

Provisions and exceptions for determining the respective reporting boundaries of own operations and value chain

5.4.

Relief for acquisitions and disposals

6.

Reporting period, base year and time horizons

6.1.

Reporting period and base year

6.2.

Time horizon: definition of short, medium and long term for reporting purposes

7.

Preparation of sustainability information

7.1.

Comparative information

7.2.

Judgement, measurement uncertainty and outcome uncertainty

7.3.

Reliefs for preparing the ESRS sustainability statement

7.4.

Reasonable and supportable information that is available without undue cost or effort

7.5.

Updating disclosures about events after the end of the reporting period

7.6.

Reporting errors in prior periods

7.7.

Omission of information

7.8.

Reporting on material opportunities

8.

Presentation requirements and structure of the sustainability statement

8.1.

General presentation requirement, structure and content of the sustainability statement

8.2.

Presentation of supplementary information included in the sustainability statement

8.3.

Options for presenting information across parts of the sustainability statement

9.

Connected information and linkages with other parts of corporate reporting

9.1.

Connected information

9.2.

Direct and indirect connectivity with financial statements, including consistency of assumptions

9.3.

Incorporation by reference

10.

Transitional provisions

10.1.

Transitional provision related to Chapter 5 Reporting undertaking and upstream and downstream value chain

10.2.

Transitional provision related to Chapter 7.1 Comparative information

10.3.

Transitional provision: List of DRs that are phased in

Appendix A –

List of topics

Appendix B –

Qualitative characteristics of information

1.

The European Sustainability Reporting Standards (ESRS) specify the sustainability information that undertakings are required to disclose in accordance with Directive 2013/34/EU (Accounting Directive) as amended by Directive (EU) 2022/2464 (Corporate Sustainability Reporting Directive – CSRD) and by Directive (EU) 2026/470 (Omnibus I Directive).

2.

ESRS require the undertaking to disclose information about its material impacts on people and the environment and about its material sustainability-related risks and opportunities (collectively ‘impacts, risks and opportunities’). Reporting under these two perspectives constitutes the double materiality principle (see Chapter 3).

3.

The objective of the sustainability statement, taken as whole, is to present fairly (see Chapter 2) all the undertaking’s material sustainability-related impacts, risks and opportunities and how the undertaking manages them. The reported information shall be decision-useful for the users of general-purpose sustainability statements.

4.

Users of general-purpose sustainability statements are:

5.

In its sustainability statement, the undertaking shall disclose information about the material impacts, risks and opportunities organised under topics to which they relate. This information shall cover the following reporting areas: (a) governance; (b) strategy including financial effects; (c) the management of impacts, risks and opportunities, including related policies and actions; and (d) metrics and targets.

6.

ESRS do not mandate behaviour except for behaviour specifically related to the reporting of sustainability information. Reporting in accordance with ESRS does not exempt the undertaking from other obligations, including due diligence obligations, laid down in Union law.

AR 1 for para. 4 (General-purpose)

The terms ‘general-purpose financial reports’ and ‘general-purpose sustainability statements’ refer to reports that:

7.

ESRS 1 General Requirements explains drafting conventions and sets out general requirements for identifying the undertaking’s material impacts, risks and opportunities, and for preparing and presenting information to be reported. It also sets out general requirements for the basis of preparation of the sustainability statement.

8.

The undertaking shall apply this Standard in conjunction with ESRS 2 General Disclosures (both referred to as ‘cross-cutting standards’) and with the topical standards.

9.

ESRS 2 General Disclosures establishes Disclosure Requirements (DRs) on the information that the undertaking shall provide at a general level across all the topics to which its material impacts, risks and opportunities relate, covering the reporting areas listed in paragraph 5.

10.

Topical standards address topics and sub-topics, complementing the requirements provided in ESRS 2 General Disclosures, and encompass the reporting areas listed in paragraph 5. The table in Appendix A List of topics provides an overview of the topics and sub-topics covered by topical standards.

11.

If the undertaking concludes that a topic related to a material impact, risk or opportunity, is not covered, or not covered with sufficient granularity, by an ESRS, it shall provide entity-specific disclosures taking account of the provisions on fair presentation in Chapter 2. This may be the case due to sectorial specificities or other facts and circumstances relevant to the undertaking itself.

12.

When developing its entity-specific disclosures, the undertaking shall consider comparability over time and with other undertakings that operate in the same sector(s).

13.

Throughout ESRS, the terms that are defined in the Glossary of terms defined in ESRS (Annex II, Table 2, of Delegated Regulation (EU) 2026/1563 (European Sustainability Reporting Standards – ESRS)) are denoted in bold italic, except when a defined term is used more than once in the same paragraph.

14.

The terms ‘sustainability topic’ and ‘sustainability sub-topic’ in ESRS are understood to be synonymous with the terms ‘sustainability matters’ or ‘sustainability factors’ as used in Directive 2013/34/EU (Accounting Directive). Disclosures in ESRS are structured into topics. A topic is further disaggregated into sub-topics. In ESRS, the term topic (in bold italic) is used to indicate either a topic or a sub-topic depending on the most appropriate level of granularity needed to meet the respective disclosure objectives.

15.

In all ESRS:

16.

Material impacts, risks and opportunities reported in the sustainability statement are understood to be the same as the undertaking’s principal impacts, risks and opportunities referred to in the Directive 2013/34/EU (Accounting Directive).

17.

The structure of information in ESRS is based on ‘Disclosure Requirements’ (DRs). Each DR consists of one or more distinct datapoints. DRs are signalled by the terms ‘shall disclose’, ‘shall report’, ‘shall describe’ and ‘shall explain’ to indicate that the information in question is prescribed, subject to materiality of information (see paragraphs 23 and 24).

18.

ESRS contain mandatory ‘Application Requirements’ (ARs) that support the application of, and have the same authority as, the requirements prescribed in the main body of the standards. ARs in ESRS 2 General Disclosures and in topical standards support the preparation of disclosures that meet the qualitative characteristics of information (see Appendix B). ARs use the term ‘shall consider’ to indicate issues, resources or methodologies that the undertaking is expected to take into account or to use in the preparation of a given disclosure. ARs also include presentation options, indicating that a given piece of information may be provided in tabular form, as narrative text or using other types of presentation options.

19.

Fair presentation requires disclosure of relevant information about the undertaking’s material impacts, risks and opportunities in accordance with Chapter 3 and their faithful representation in accordance with the requirements set out in this Standard (for relevance and faithful representation see Appendix B). To achieve faithful representation, the undertaking shall provide a complete, neutral and accurate depiction of its material impacts, risks and opportunities.

20.

Fair presentation also requires that the undertaking discloses:

21.

Applying ESRS, including the materiality filter as set out in paragraph 24, and with entity-specific disclosures when necessary (see paragraph 11), results in a sustainability statement that achieves fair presentation.

22.

The undertaking determines the information to be disclosed based on its double materiality assessment (see paragraph 2) and based on the provisions for determining the information to be reported, as explained in this Chapter.

23.

Information is material when omitting, misstating or obscuring that information could reasonably be expected to influence:

24.

Except for information that it may decide to disclose in accordance with section 8.2. Presentation of supplementary information included in the sustainability statement, the undertaking shall not disclose information prescribed by an ESRS DR or datapoint if that information is not material and shall not disclose information that is not material when disclosing entity-specific information in accordance with paragraph 11.

AR 8 for para. 23 (Decisions)

When considering the decision-usefulness of information, the undertaking shall take into account the information that groups of such users need, without aiming to meet all the specific information needs of each individual user.

25.

The undertaking determines the information to be reported in two steps:

26.

With respect to the identification of topics, the undertaking shall report material information for a topic or sub-topic when it relates to one or more material impacts, risks or opportunities identified based on the criteria in Chapters 3.2.1. and 3.2.2.

27.

Without prejudice to the criteria in Chapters 3.2.1 and 3.2.2, the undertaking may derive a conclusion, without further assessment, on the materiality or non-materiality of its impacts, risks or opportunities for a topic or sub-topic, on the basis of an analysis of its strategy and business model including its sector(s) of operations, its geographies, and the features of its upstream and downstream value chain (‘top-down’ approach to materiality assessment). In this approach, if the materiality or non-materiality of one or more impacts, risks or opportunities is not evident on the basis of the above analysis, the undertaking shall perform a specific assessment of the impacts, risks or opportunities in question.

28.

Without prejudice to the criteria in Chapters 3.2.1 and 3.2.2, the undertaking may rely on a materiality assessment conducted only at the level of impacts, risks and opportunities (‘bottom-up’ approach to materiality assessment).

29.

With respect to the information to be reported, the undertaking shall:

30.

When a material impact, risk or opportunity concerns a sub- topic, the undertaking shall report only the material information for that sub-topic.

31.

When using ESRS reliefs, the undertaking shall disclose the information prescribed in Sub-Chapters 5.4, 7.3, 7.4, and 7.7.

32.

In its double materiality assessment, the undertaking:

33.

The undertaking may be able to conduct the materiality assessment regarding upstream and downstream value chain without direct input from value chain actors, using instead average regional data, sector data or generally available information about the existence of impacts, risks and opportunities in the context in question.

34.

At each reporting date, the undertaking shall consider whether significant changes have occurred that could affect the conclusions of the materiality assessment conducted in previous reporting periods. If such changes are identified, the undertaking shall review and update the assessment. Changes may relate to the undertaking’s activities, structure, business relationships, understanding of impacts, risks or opportunities, assessment methodologies, or the external environment.

35.

Double materiality has two dimensions: impact materiality and financial materiality and the undertaking shall consider how they interact. An impact can be financially material from the start or become financially material, when it is reasonably expected to affect the undertaking’s financial performance, financial position, cash flows, its access to finance or the cost of capital over the short, medium or long term. Impacts can be material exclusively from an impact perspective, irrespective of whether they are financially material.

36.

In general, the starting point is the assessment of impacts. The undertaking shall as well evaluate whether there are material risks or opportunities that are not related to the undertaking’s impacts, such as physical risks.

37.

The undertaking shall determine which impacts, risks or opportunities are material, based on the criteria in Chapters 3.2.1 and 3.2.2, and supported by appropriate qualitative considerations and quantitative thresholds.

AR 17 for para. 37 (Materiality assessment for undertakings managing investments at certain conditions)

Where the undertaking manages investments subject to a fiduciary duty on behalf of its clients pursuant to a mandate agreed with those clients without retaining risks or rewards of ownership, that undertaking is not expected to assess the impacts, risks and opportunities related to those investments.

38.

The impact materiality assessment identifies the undertaking's material impacts.

39.

The undertaking shall report information about a given topic from an impact perspective if that topic relates to the undertaking’s material actual or potential, positive or negative impacts on people or the environment over the short, medium or long term. Impacts include those connected with the undertaking’s own operations and its upstream and downstream value chain, including through its products and services, as well as through its business relationships in its upstream and downstream value chain. Business relationships are not limited to direct contractual relationships.

40.

For actual negative impacts, materiality shall be assessed based on the severity of the impact. For potential negative impacts, it shall be assessed based on a combination of severity and likelihood. Severity shall be assessed based on the following factors: scale, scope and irremediable character of the impact. In the case of a potential negative human rights impact, the severity of the impact takes precedence over its likelihood.

41.

For actual positive impacts, materiality shall be assessed based on the scale and scope of the impact. For potential positive impacts, materiality shall be assessed based on the scale, scope and likelihood of the impact.

42.

The results of engagement with affected stakeholders carried out in the context of ongoing sustainability due diligence activities is a key input to the impact materiality assessment. Affected stakeholders are individuals or groups whose interests are affected or could be affected by the undertaking’s activities and its direct and indirect business relationships in its upstream and downstream value chain. Civil society, non-governmental organisations and trade unions as users can be proxies for affected stakeholders.

43.

The following applies in determining how to consider, in the materiality assessment, policies and actions to prevent, mitigate, bring to an end, minimise and remediate negative impacts:

44.

Positive impacts shall be assessed on their own, without netting against negative impacts. The results of actions to prevent, mitigate, bring to an end, minimise or remediate negative impacts the undertaking is connected to, or compliance with law and regulation, are not positive impacts. Positive impacts include effects of the undertaking’s business activities, products or services that mitigate, bring to an end, minimise or remediate another party’s negative impacts, when the undertaking is not connected to those impacts.

45.

The financial materiality assessment corresponds to the identification of information that is considered material for primary users of general-purpose financial reports in making decisions relating to providing resources to the undertaking (see paragraph 23(a)).

46.

The scope of financial materiality for sustainability reporting is an expansion of the scope of materiality used in the process of determining which information shall be included in the undertaking’s financial statements on the basis of the applicable recognition and measurement rules. The financial materiality of a topic is not limited to material risks or opportunities affecting entities that are within the control of the undertaking, but includes information on material risks and opportunities attributable to business relationships in the upstream and downstream value chain (see paragraph 62).

47.

The undertaking shall report information on a topic from a financial materiality perspective if it triggers, or could reasonably be expected to trigger, material financial effects. This is the case when the risks or opportunities related to a topic have, or could reasonably be expected to have, a material influence on the undertaking’s development, financial position, financial performance, cash flows, access to finance or cost of capital over the short, medium or long term.

48.

Risks and opportunities may arise from past or future events. Material risks and opportunities arise from the undertaking’s:

49.

When identifying risks and opportunities, the undertaking shall consider dependencies as sources of financial effects, either in terms of cash flows or in terms of resources not recognised in financial statements. Dependencies may be sources of risks or opportunities regardless of potential impacts on the natural, human and social resources relied on.

50.

The materiality of risks and opportunities is assessed based on a combination of the likelihood of occurrence and the potential magnitude of the financial effects.

51.

The materiality assessment may identify situations where the undertaking’s actions taken to address certain impacts, risks, or opportunities related to one topic may create material negative impacts or material risks related to one or more other topics. In such situations, the undertaking shall present its disclosure in a way that facilitates the understanding of the connections between different topics.

AR 32 for para. 51 (Impacts or risks arising from actions)

The following is an illustration of such situations. The climate-mitigation transition plan results in material negative impacts or risks related to own workforce. To promote connected information (see Chapter 9.1), the undertaking:

52.

The undertaking shall aggregate or disaggregate the information in a way that reflects the level at which significant variations of material impacts, risks or opportunities arise, such as by topic, sector, subsidiary, geography, asset. The undertaking shall consider relevant facts and circumstances to determine the level of aggregation that supports faithful representation of its impacts, risks or opportunities.

53.

The undertaking shall ensure that the level of aggregation and disaggregation does not obscure material information.

54.

The disaggregation used to present a given disclosure shall reflect the level that provides the most relevant information to users, i.e. topic, group of impacts, risks or opportunities, individual impact, risk or opportunity. This should reflect factors such as the nature of the impacts, risks or opportunities in question or the way the undertaking manages them.

55.

When reporting at a consolidated level, the undertaking shall carry out the assessment of material impacts, risks and opportunities for the consolidated group regardless of the group’s legal structure. It shall ensure that the activities of its subsidiaries are covered in a way that allows for the unbiased identification of material impacts, risks and opportunities at group level. If the undertaking identifies significant differences between material impacts, risks or opportunities at group level and material impacts, risks or opportunities of one or more of its subsidiaries, it shall disaggregate and present information in a way that allows an adequate understanding of the material impacts, risks and opportunities of the subsidiary or subsidiaries concerned. If a material impact, risk or opportunity determined at group level is not relevant for all subsidiaries or activities in the group, the information may be provided at a disaggregated level, covering only the subsidiaries or activities for which the impact, risk or opportunity is relevant (see also the reliefs for metrics in paragraph 93).

56.

Due diligence is the process by which the undertaking identifies, prevents, mitigates, brings to an end, minimises and remediates actual and potential negative impacts on people and the environment connected with its business. Directive (EU) 2024/1760 (Corporate Sustainability Due Diligence Directive – CSDDD) establishes due diligence requirements for undertakings subject to its provisions. The international instruments of the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises also provide relevant guidance on the due diligence process. Due diligence is an ongoing practice that responds to and may trigger changes in the undertaking’s strategy, business model, activities, business relationships, and operating context and practices, including design, purchasing, and selling and distribution.

57.

ESRS do not impose any conduct requirements in relation to due diligence, nor do they extend or modify the role of the administrative, management and supervisory bodies of the undertaking with regard to the conduct of due diligence. The provisions of ESRS are without prejudice to the provisions of the Corporate Sustainability Due Diligence Directive for undertakings in the scope of that directive.

58.

The outcome of the undertaking’s sustainability due diligence process informs the assessment of its material negative impacts.

59.

One of the steps of the due diligence process is the identification and assessment of negative impacts connected with the undertaking’s own operations, products or services, including through business relationships in the undertaking’s upstream and downstream value chain. The impact identification and assessment steps in the due diligence process inform the assessment of material impacts for reporting purposes (see Chapter 3.2.1). The identification of material negative impacts also supports the identification of material sustainability risks and opportunities, which are often a result of such impacts. Where the undertaking cannot address all impacts at once, the due diligence process allows for action to be prioritised based on the severity and likelihood of impacts.

60.

The sustainability statement shall be for the same reporting undertaking as for the financial statements. If the parent undertaking prepares consolidated financial statements, the sustainability statement shall be for the parent and its subsidiaries in accordance with the applicable accounting requirements. This does not apply if the undertaking is not required to prepare financial statements or if its consolidated sustainability reporting is prepared in accordance with Article 48i of Directive 2013/34/EU (Accounting Directive).

61.

In the case of group reporting, the reporting undertaking usually – except for specific circumstances, such as leasing and assets that are held by the undertaking’s long-term employee benefit schemes – considers as part of own operations: the assets, liabilities, revenues and expenses of the parent undertaking and its subsidiaries, located in or outside the EU, as determined in accordance with the applicable accounting requirements. Paragraphs 62 to 75 provide further provisions and exceptions for determining the reporting boundaries of own operations and upstream and downstream value chain. In addition, the undertaking may exclude from the sustainability reporting boundary a subsidiary that has been excluded from the scope of the consolidated financial statements due to its non-materiality from a financial perspective, unless there are specific facts and circumstances that expose the group to impacts arising from the subsidiary in question that meet the group’s materiality thresholds.

62.

To the extent necessary for an understanding of the undertaking’s material impacts, risks and opportunities and to meet the qualitative characteristics of information (see Appendix B), the reported information shall be extended beyond own operations to cover material impacts, risks and opportunities connected with the undertaking through its direct and indirect business relationships in the upstream and downstream value chain (value chain information), without prejudice to the relief for acquisitions and disposals in Chapter 5.4.

63.

The undertaking shall include material upstream and downstream value chain information in accordance with the outcome of its double materiality assessment as described in this standard and any specific requirements related to the upstream and downstream value chain in other ESRS.

64.

Applying paragraph 63 does not require information on each and every actor in the upstream and downstream value chain but only the inclusion of material information.

65.

To identify material impacts, risks or opportunities that are connected with the undertaking through its business relationships in the upstream and downstream value chain, and to report on them, the undertaking may use information collected directly from counterparties in the upstream and downstream value chain, or it may use estimates, depending on practicability and reliability considerations related to the necessary input. When developing estimates, the undertaking may use internal and external information, such as data from indirect sources, sector-average data, sample analyses, market and peer groups data, spend-based data or other proxies.

66.

When applying Article 19a(3), first to sixth subparagraph, and Article 29a(3), first to sixth subparagraph, of Directive 2013/34/EU (Accounting Directive), the undertaking shall take account of the fact that the upper limit (value-chain cap) of sustainability information which may be required from the protected undertakings in its value chain only comprises the datapoints specified in Annex II to Commission Delegated Regulation (EU) 2026/1560 (¹). This limitation also applies to non-EU undertakings in the upstream and downstream value chain of the reporting undertaking.

67.

Different impacts, risks or opportunities can be material in relation to different parts of the undertaking’s upstream and downstream value chain.

68.

The information reported about policies, actions and targets shall include upstream and downstream value chain information only to the extent that the value chain is within the scope of the undertaking’s policies, actions and targets.

69.

Investments, including shareholding positions in associates and joint ventures, are treated as business relationships.

70.

Without prejudice to the relief in paragraph 92, in some cases, associates or joint ventures that are accounted for under the equity method are also part of the undertaking’s upstream and downstream value chain beyond the shareholding relationship, such as when they are also suppliers or customers. In these cases, the undertaking shall disclose information related to these supply or customer relationships, in accordance with paragraph 62, consistent with the approach adopted for similar business relationships. In these cases, when determining metrics, the data of the associate or joint venture is not limited to the share of equity held, but it shall reflect the impacts, risks and opportunities that are connected with the undertaking through the supply or customer relationship. This means that the undertaking considers both its relationship as investor in the associate or joint venture and its supply or customer relationship.

71.

Impacts, risks and opportunities relating to a leased asset might have different sources, depending on whether they result from the use of the asset or from its ownership. The lessee is using the leased asset, and shall report the impacts connected with the use of the asset in its own operations during the lease period. The lessor provides the right to use the asset to the lessee and shall report the impacts connected with the use of the asset as part of its downstream value chain. Whether risks and opportunities relating to a leased asset, as well as impacts other than those connected with the use of the leased asset, accrue to the lessor or the lessee depends on the provisions of the lease contract, which should be reflected in the reported information.

72.

The impacts, risks or opportunities arising from assets that are held by the undertaking’s long-term employee benefit schemes are connected with the undertaking through its business relationships in the value chain.

73.

The provisions of paragraph 71 and 72 take precedence over topical standards including over the provisions in ESRS E1-8.

AR 39 for para. 71 (Leased assets)

For example, the lessee and not the lessor is the one causing pollution, using energy or consuming water in a leased factory. The lessee therefore assesses the material impacts connected with the use of the leased assets in its own operations.

74.

If the undertaking acquires a subsidiary undertaking during the reporting period, it may defer the inclusion of that subsidiary undertaking in the materiality assessment and in the sustainability statement to the following reporting period. If a subsidiary undertaking leaves the group during the reporting period, it may adjust the scope of the materiality assessment and the reporting boundary as from the beginning of the current reporting period.

75.

If the undertaking uses the relief of paragraph 74, it shall use available information to disclose any significant event that affected the subsidiary undertaking during the reporting period since the acquisition or until disposal and that has an effect on the group’s impacts on, or risks or opportunities related to sustainability matters.

76.

The reporting period for the undertaking’s sustainability statement – including for the calculation of metrics – shall be consistent with that of its financial statements.

77.

A base year is the historical reference date or period for which information is available and against which subsequent information can be compared over time.

78.

The undertaking shall present comparative information in respect of the base year for metrics reported in the current period when reporting progress towards a target unless the relevant DR specifically requires otherwise. If milestones between the base year and the reporting period have been reached, reporting about these achievements is useful contextual information.

79.

When preparing its sustainability statement, the undertaking shall adopt the following time intervals as of the end of the reporting period:

80.

The undertaking shall use additional breakdowns for a long-term time horizon if impacts or actions are expected over a period longer than five years as adding such a breakdown provides relevant information.

81.

The undertaking may adopt a different definition for medium- or long-term time horizons if the use of medium- or long-term horizons defined in paragraph 79 results in non-relevant information. This may happen if the undertaking uses a different definition for (a) its processes of identification and management of material impacts, risks and opportunities; or (b) its actions and targets. These circumstances may be due to industry-specific characteristics, such as cash flow and business cycles or planning horizons typically used in the sector for decision-making, the expected duration of capital investments, or the time horizons over which users conduct their assessments.

82.

References to ‘short term’, ‘medium term’ and ‘long term’ in ESRS refer to time horizons as determined by the undertaking in accordance with the provisions in paragraphs 79-81.

83.

The undertaking shall disclose comparative information in respect of the previous period for all quantitative metrics and amounts. If relevant to an understanding of the current period’s sustainability statement, it is also required to disclose comparative information for narrative disclosures.

84.

The definition and calculation of metrics, including metrics used to set targets and monitor progress towards those targets, shall be consistent over time. The undertaking shall provide contextual information and revised comparative figures unless it is impracticable to do so if it has:

85.

If it is impracticable to revise comparative information for metrics for one or more prior periods, the undertaking shall disclose this fact.

86.

When an ESRS requires the undertaking to present more than one comparative period for a metric or datapoint, the requirements of that ESRS shall prevail.

87.

For metrics and monetary amounts:

AR 40 for para. 84(b) (Revise comparatives)

The undertaking is not required to revise the comparative figure for new information received if the revised comparatives do not provide useful information, such as when the estimation methodology for the relevant metric relies systematically at the reporting date on an input from the previous period.

88.

The undertaking shall disclose information to enable users to understand:

89.

Some ESRS require the disclosure of information that have uncertain outcomes, such as explanations about possible future events. In judging whether information about such possible future events is material, the undertaking shall refer to the criteria in Chapter 3.2.2 and consider:

90.

The undertaking may exclude activities from metric calculations if, due to their nature, they are not a significant driver of the impacts, risks or opportunities that the metric purports to represent, and if their exclusion from the calculation is not expected to impair the relevance and faithful representation of the reported information. The undertaking shall disclose if this relief is used and include any relevant information to enable users to understand the scope limitations resulting from it.

91.

Except when reporting ESRS E1-8 metrics Gross scope 1, 2, 3 GHG emissions, if the undertaking can provide without incurring undue cost or effort reliable direct or estimated data only for an objectively defined part of its own operations or its upstream or downstream value chain, it shall disclose that it has identified material impacts, risks or opportunities but that the corresponding metric can currently only be reported on a partial reporting scope or for a subset of the value chain. In this circumstance, the undertaking shall disclose the actions it has taken to increase the coverage and quality of reported information in future periods and the progress made compared to the previous period. The coverage of reported information is expected to increase over time, particularly for metrics in own operations. This paragraph applies without prejudice to the applicability of the provisions in Sub-Chapter 7.4.

92.

The undertaking may exclude joint operations over which it does not have operational control from the scope of the calculation for environmental metrics reported in accordance with ESRS E2 Pollution, ESRS E3 Water, ESRS E4 Biodiversity and Ecosystems and ESRS E5 Resource Use and Circular Economy. The undertaking shall disclose if this relief is being used and include any relevant information to allow an understanding of the scope limitations resulting from it. In this circumstance, and without prejudice to the undertaking’s assessment to whether or not it exercises operational control, it shall disclose the actions it has taken to increase the coverage of the reported information and its quality in future periods and the progress made compared to the previous period.

AR 44 for para. 92 (Relief and scope 3 GHG emissions)

When preparing the information on gross scope 3 GHG emissions, within the boundaries defined in this standard and in AR 19 of ESRS E1 Climate Change, paragraph AR 24 of ESRS E1 Climate Change applies.

93.

The undertaking shall use all reasonable and supportable information that is available to the undertaking at the reporting date without undue cost or effort:

94.

The assessment of what constitutes undue cost or effort depends on the undertaking’s specific circumstances and requires a balanced consideration of the costs for the undertaking and the benefits of the resulting information for users.

95.

Reasonable and supportable information that is available to the undertaking without undue cost or effort is subject to reassessment for each reporting period. It reflects the results of the undertaking’s past actions to improve data availability or the higher availability of external information. As a result, availability of information is expected to improve over time.

AR 45 for para. 94 (Reasonable and supportable information available without undue cost or effort)

Reasonable and supportable information covers factors that are specific to the undertaking, as well as general conditions in the external environment. Reasonable and supportable information includes information about past events, current conditions and forecasts of future conditions. The undertaking is not required to carry out an exhaustive search for such information. When assessing whether the preparation of a disclosure would involve undue cost or effort at the reporting date, the undertaking shall consider, individually or jointly, criteria such as: In assessing the availability of information, the undertaking:

96.

If, after the reporting period but before the management report is authorised for issue, the undertaking receives information providing evidence or insights about conditions that existed at the end of the reporting period, the undertaking shall update its disclosures in light of the new information.

97.

The undertaking shall disclose information about material transactions, other events and conditions that occur after the end of the reporting period but before the date on which the management report is authorised for issue and provide narrative information indicating the existence, nature and potential consequences of these post-year events.

98.

The undertaking shall correct material prior period errors by restating the comparative amounts for the prior period(s) disclosed unless it is impracticable to do so. This requirement does not extend to reporting periods before the first year of application of ESRS by the undertaking.

99.

Potential reporting period errors discovered in the same reporting period are corrected before the sustainability statement is authorised for issue. However, material errors are sometimes not discovered until a subsequent period. In case of material errors discovered in a subsequent period, if it is impracticable to determine the effect of an error on all prior periods presented, the undertaking shall restate the comparative information to correct the error from the earliest date practicable.

AR 46 for para. 99 (Prior period errors)

Prior period errors are omissions from, and misstatements in, the undertaking’s sustainability statement for one or more prior periods. Such errors arise from a failure to use, or the misuse of, reliable information that: Such errors include: the effects of mathematical mistakes, mistakes in applying the definitions for metrics or targets, oversights or misinterpretations of facts, and fraud. Corrections of errors are distinguished from changes in estimates. Estimates may need to be revised as additional information becomes known.

100.

When disclosing information required by an ESRS, the undertaking may omit the following information:

101.

The undertaking shall make every reasonable effort to ensure that, beyond the omissions referred to in paragraph 100, the overall relevance of the disclosure in question is not impaired.

AR 47 for para. 101 (Information that can be omitted)

The fact that undertakings not established in the Union are not required to report the same information may not be used to justify the omission of information under paragraph 101 point (a).

102.

When reporting on material opportunities, the disclosure shall consist of descriptive information allowing users to understand the opportunities. The undertaking shall not report general opportunities for the sector but only opportunities that are currently being pursued or incorporated in its general strategy. The provisions on financial effects in ESRS 2 General Disclosures apply when reporting on material opportunities.

103.

The undertaking shall present all the disclosures required by ESRS within a dedicated section of the management report identified as the undertaking’s sustainability statement which also includes those disclosures incorporated by reference in accordance with Chapter 9.3.

104.

Sustainability information shall be presented:

105.

The undertaking shall structure its sustainability statement in four parts in the following order: general information, environmental information, social information and governance information. It may use appendices or separate sub-parts in accordance with paragraphs 107-111. The undertaking may structure its sustainability statement in a different manner to that defined in the first sentence of this paragraph, provided that it presents a reasoned explanation for using an alternative structure and that it complies with all other provisions of this chapter.

106.

If the undertaking prepares disclosures pursuant to Article 8 of Regulation (EU) 2020/852 and to the Commission Delegated Regulations, it is required to include them in its sustainability statement, and may do so in a separate appendix within the management report. These disclosures are not subject to the provisions of ESRS, with the exception of this paragraph.

107.

The undertaking may include in its sustainability statement supplementary information stemming from (i) other legislation which requires it to disclose sustainability information; or (ii) generally accepted reporting standards or frameworks, including non-mandatory guidance and sector-specific guidance, published by other standard setting bodies (such as by the Global Reporting Initiative), even if that information is not material. Such information shall be clearly identified with an appropriate reference to the related legislation, standard or framework.

108.

If needed to meet the data demands of a specific user, the undertaking may include in its sustainability statement supplementary disclosures that are not material.

109.

Disclosures made in accordance with paragraphs 107 and 108 shall:

110.

The undertaking may provide an executive summary in the sustainability statement which includes the key messages about its material environmental, social and governance impacts, risks or opportunities and their management. The content and presentation of this executive summary shall meet the qualitative characteristics of information and is an integral part of the sustainability statement prepared in accordance with the provisions of ESRS. Alternatively, the undertaking may incorporate information by reference to an executive summary placed outside its sustainability statement, such as in another section of the management report, provided that it meets the conditions for incorporation by reference (see Sub-Chapter 9.3).

111.

The undertaking may use appendices or separate sub-parts in its sustainability statement:

AR 48 for para. 111 (Presentation of more detailed information)

The undertaking may use internal references across different parts or subparts (including appendices) in the sustainability statement to facilitate the understanding of linkages that exist between different items of information. These internal references are not incorporation by reference.

112.

The undertaking shall provide information that enables users of its sustainability statement to understand the connections:

113.

Repeating the same information within the sustainability statement may obscure material information and impair the provision of concise and understandable information. If the same information is relevant to more than one DR, the undertaking may present the information where it considers it to be most relevant and cross-refer to that location as appropriate.

AR 49 for para. 113(a) (Connections within the sustainability statement)

Connections within the sustainability statement include:

114.

If the sustainability statement includes monetary amounts or other quantitative information also presented in the undertaking’s financial statements, the undertaking shall cross-reference to its financial statements (‘direct connectivity’).

115.

If the sustainability statement includes amounts that are an aggregation or part of amounts presented in the undertaking’s financial statements (‘indirect connectivity’), the undertaking shall 24explain how these amounts relate to the most relevant ones presented in the financial statements.

116.

Data and assumptions used in preparing the sustainability statement shall, to the extent possible, be consistent with the corresponding data and assumptions used in preparing the financial statements. To support the understanding of significant data and assumptions, the undertaking shall explain any significant differences in assumptions between those used in preparing the sustainability statements and those used in preparing the financial statements.

AR 50 for para. 115 (Currency to be used)

For monetary amounts the undertaking shall use the same currency as in the financial statements.

117.

Provided that the conditions in paragraph 118 are met, information or a specific datapoint prescribed by a DR may be incorporated in the sustainability statement by cross-reference to:

118.

The undertaking may incorporate information by reference to the documents, or part of the documents, listed in paragraph 117, provided that the information incorporated by reference:

119.

Provided that the conditions established in paragraph 118 are met, information prescribed by an DR or datapoint may be incorporated in the sustainability statement by reference to the undertaking’s report prepared in accordance with the EU Eco-Management and Audit Scheme Regulation (EU) No 1221/2009 of the European Parliament and of the Council (⁷). In this case, the undertaking shall ensure that the information incorporated by reference is produced using the same basis for preparation of ESRS information, including scope of consolidation and treatment of upstream and downstream value chain information.

120.

The undertaking shall consider the overall cohesiveness of the reported information and ensure that the incorporation by reference does not impair the readability of the sustainability statement.

121.

Unless otherwise stated, the transitional provisions in this Chapter apply from the first financial year the undertaking is subject to the sustainability reporting requirements under Articles 19a and 29a of Directive 2013/34/EU (Accounting Directive), in accordance with Article 5(2) first and third subparagraphs of Directive (EU) 2022/2464 (CSRD), as amended by Directive (EU) 2025/794 of the European Parliament and of the Council (Stop the Clock Directive) (⁸) and by Directive (EU) 2026/470 (Omnibus I Directive). Accordingly, earlier voluntary application of ESRS does not limit the use of the reliefs in this chapter and does not trigger the start of the phase-in provisions. In this chapter, financial year refers to the reporting period of an undertaking’s sustainability statement starting on or after January 1 of the respective year.

122.

‘Wave-one undertakings’ are those that are required to report on sustainability for financial years starting between 1 January 2024 and 31 December 2026, irrespective of when the relevant Member State transposes Directive (EU) 2022/2464 (CSRD) as amended by Directive (EU) 2025/794 (Stop the Clock Directive) and by Directive (EU) 2026/470 (Omnibus I Directive). They are defined in Article 5(2), first subparagraph, point (a), and third subparagraph, point (a), of the CSRD. ‘Other undertakings’ are those that are required to report on sustainability for financial years starting on or after 1 January 2027, irrespective of when the relevant Member State transposes the CSRD as amended by the Stop the Clock and by the Omnibus I Directives. They are defined in Article 5(2), first subparagraph, point (b), and third subparagraph, point (b), of the CSRD.

123.

For the first three financial years that the undertaking is subject to sustainability reporting requirements under Articles 19a and 29a of the Directive 2013/34/EU (Accounting Directive), in accordance with Article 5(2) first and third subparagraphs of the Directive (EU) 2022/2464 (CSRD), as amended by Directive (EU) 2025/794 (Stop the Clock Directive) and Directive (EU) 2026/470 (Omnibus I Directive), and in the event that not all the necessary information regarding its value chain is available, the undertaking shall explain the efforts made to obtain the necessary information about its value chain, the reasons why not all of the necessary information could be obtained, and its plans to obtain the necessary information in the future.

124.

‘Wave one’ undertakings, as defined in paragraph 122, are not required to disclose for their first year of reporting in accordance with Delegated Regulation (EU) 2026/1563 comparative information regarding quantitative metrics and amounts as required by Chapter 7.1 where those metrics and amounts are not the same as the metrics and amounts required by Delegated Regulation (EU) 2023/2772 as regards sustainability reporting standards (first set of ESRS). ‘Other undertakings’ as defined in paragraph 122, are not required to disclose comparative information as required by Chapter 7.1 for their first financial year of reporting.

125.

‘Wave-one’ undertakings, as defined in paragraph 122, that on their balance sheet dates exceed a net turnover of EUR 450 000 000 and an average number of 1 000 employees during the financial year, may omit in their sustainability statement:

126.

‘Wave-one’ undertakings, as defined in paragraph 122, that on their balance sheet dates do not exceed a net turnover of EUR 450 000 000 or an average number of 1 000 employees during the financial year may omit in their sustainability statement:

127.

‘Other undertakings’ as defined in paragraph 122 may omit in their sustainability statement:

QC1.

Sustainability information is relevant when it may make a difference in the decisions of users under a double materiality approach (see Chapter 3).

QC2.

Information may make a difference in a decision even if some users choose not to take advantage of it or are already aware of it from other sources. Sustainability information may impact decisions of users if it has predictive value, confirmatory value or both. Information has predictive value if it can be used as an input to processes employed by users to predict future outcomes. Sustainability information need not be a prediction or forecast to have predictive value but rather has predictive value when employed by users in making their own predictions.

QC3.

Information has confirmatory value when it provides feedback about (confirms or changes) previous evaluations.

QC4.

Materiality is an entity-specific aspect of relevance based on the nature or magnitude or both of the items to which the information relates, as assessed in the context of the undertaking’s sustainability reporting (see Chapter 3).

QC5.

To be useful, the information must not only represent relevant phenomena; it must also faithfully represent the substance of the phenomena that it purports to represent. Faithful representation requires information to be (a) complete; (b) neutral; and (c) accurate.

QC6.

A complete depiction of an impact, a risk or an opportunity includes all material information necessary for the users to understand that impact, risk or opportunity. This includes how the undertaking has adapted its strategy, risk management and governance in response to that impact, risk or opportunity, as well as the policies and actions in place to manage it, and metrics identified to set targets and measure performance.

QC7.

A neutral depiction is without bias in its selection or disclosure of information. Information is neutral if it is not slanted, weighted, emphasised, de-emphasised or otherwise manipulated to make it more likely that the users will receive that information favourably or unfavourably. It shall be balanced so as to cover favourable/positive and unfavourable/negative aspects. Both negative and positive material impacts from an impact materiality perspective as well as material risks and opportunities from a financial materiality perspective shall receive equal attention. Any aspirational sustainability information, for example, targets or plans, shall cover both aspirations and factors that could prevent the undertaking from achieving these aspirations in order to have a neutral depiction.

QC8.

Neutrality is supported by the exercise of prudence, i.e. caution when making judgements under conditions of uncertainty. Information shall not be netted or compensated to be neutral. The exercise of prudence means that opportunities are not overstated and risks are not understated. Equally, the exercise of prudence does not allow for the understatement of opportunities or the overstatement of risks. The undertaking may present net information, in addition to gross values, if such presentation does not obscure relevant information and includes a clear explanation about the effects of the netting and the reasons for the netting.

QC9.

Information can be accurate without being perfectly precise in all respects. Accurate information implies that the undertaking has implemented adequate processes and internal controls to avoid material errors or material misstatements. As such, estimates shall be presented with a clear emphasis on their possible limitations and associated uncertainty (see Chapter 7.2). The amount of precision needed and attainable, and the factors that make information accurate, depend on the nature of the information and the nature of the topics it addresses. For example, accuracy requires that:

QC10.

Sustainability information is comparable when it can be compared with information provided by the undertaking in previous periods and can be compared with information provided by other undertakings, in particular those with similar activities or operating within the same sector. A point of reference for comparison can be a target, a baseline, a sector benchmark, comparable information from either other undertakings or from an internationally recognised organisation, etc.

QC11.

Consistency is related to, but is not the same as, comparability. Consistency refers to the use of the same approaches or methods for the same topic from period to period by the undertaking and other undertakings. Consistency helps to achieve the goal of comparability.

QC12.

Comparability is not uniformity. For information to be comparable, like components shall look alike and different components shall look different. Comparability of sustainability information is not enhanced by making unlike things look alike any more than it is enhanced by making like things look different.

QC13.

Verifiability helps to give users confidence that information is complete, neutral and accurate. Sustainability information is verifiable if it is possible to corroborate the information itself or the inputs used to derive it.

QC14.

Verifiability means that various knowledgeable and independent observers could reach consensus, although not necessarily complete agreement, that a particular depiction is a faithful representation. Sustainability information shall be provided in a way that enhances its verifiability, for example, by:

QC15.

Some sustainability information will be in the form of explanations or forward-looking information. Those disclosures can be supportable by faithfully representing on a factual basis, for example, the strategies, plans and risk analyses of the undertaking. To help users decide whether to use such information, the undertaking shall describe the underlying assumptions and methods of producing the information as well as other factors that provide evidence reflecting the actual plans or decisions made by the undertaking.

QC16.

Sustainability information is understandable when it is clear and concise. Understandable information enables any reasonably knowledgeable user to readily comprehend the information being communicated.

QC17.

For sustainability disclosures to be concise, they need to (a) avoid generic ‘boilerplate’ information, which is not specific to the undertaking; (b) avoid unnecessary duplication of information, including information also provided in financial statements; and (c) use clear language and well-structured sentences and paragraphs. Disclosures are concise if they include only material information. Supplementary information presented pursuant to Sub-Chapter 8.2 shall be provided in a way that avoids obscuring material information.

QC18.

Clarity might be enhanced by distinguishing information about developments in the reporting period from ‘standing’ information that remains relatively unchanged from one period to the next. This can be done, for example, by separately describing features of the undertaking’s sustainability-related governance and risk management processes that have changed since the previous reporting period compared to those that remain unchanged.

QC19.

The completeness, clarity and comparability of sustainability disclosures all rely on information being presented as a coherent whole. For sustainability disclosures to be coherent, they shall be presented in a way that explains the context and the connections between the related information. Coherence also requires the undertaking to provide information in a way that allows users to relate information about its impacts, risks and opportunities to information in the undertaking’s financial statements.

QC20.

If risks and opportunities discussed in the financial statements have implications for sustainability reporting, the undertaking shall include in the sustainability statement the information necessary for users to assess those implications and present appropriate links to the financial statements (see Chapter 9). The level of information, granularity and technicality shall be aligned with the needs and expectations of users. Abbreviations shall be avoided and the units of measure need to be defined and disclosed.

1.

ESRS 2 General Disclosures sets out the Disclosure Requirements (DRs) that apply across sustainability topics (i.e. cross-cutting). It covers the reporting areas defined in ESRS 1 General Requirements, paragraph 5.

2.

The undertaking shall apply the DRs defined in this Standard when providing information on material impacts, risks and opportunities and the topics related to them and shall present such information in accordance with ESRS 1 General Requirements, paragraphs 52 and 53 on aggregation and disaggregation.

3.

The objective of this DR is to enable an understanding of the basis for preparation of the sustainability statement, including the disclosures required by ESRS 1 General Requirements in specific circumstances.

4.

The undertaking shall disclose:

5.

The undertaking shall state that its sustainability statement has been prepared in accordance with ESRS as applicable at the end of the reporting period.

6.

The undertaking shall disclose any relief, option or other specific provision prescribed in ESRS 1 General Requirements that it applies, together with the related required information.

7.

The objective of this DR is to enable an understanding of the phasing-in provisions that the undertaking has used.

8.

If, by applying the phase-in provisions provided by ESRS 1 General Requirements paragraphs 125(a), 126(a) and 127(a), the undertaking omits the information required by one or more of the standards listed in that paragraph, it shall nevertheless disclose whether the impacts, risks and opportunities related to the topics covered in those standards have been assessed to be material as a result of the undertaking’s materiality assessment.

9.

In addition to paragraph 8, if one or more of these topics have been assessed to be material, the undertaking shall:

10.

If, by applying the other phase-in provisions provided by ESRS 1 General Requirements in paragraphs 125(b)-(e), 126(b)-(e) and 127(b)-(e), the undertaking omits the information required by other DRs listed in those paragraphs, it shall disclose this fact.

11.

The objective of this DR is to enable an understanding of the roles and responsibilities of the administrative, management and supervisory bodies, as well as the associated processes, controls and procedures in monitoring, managing and overseeing material impacts, risks and opportunities.

12.

The undertaking shall disclose:

13.

The objective of this DR is to enable an understanding of the key features of any incentive schemes that are linked to sustainability topics that are in place for members of the administrative, management and supervisory bodies.

14.

If the undertaking has incentive schemes for members of the administrative, management and supervisory bodies that are linked to sustainability topics, it shall disclose how members’ remuneration is linked to sustainability topics, including:

15.

The objective of this DR is to enable an understanding of where, within the sustainability statement, the main steps of the due diligence process (see ESRS 1 General Requirements, Chapter 4) applied with regard to sustainability topics are disclosed.

16.

The undertaking shall explain where its application of the main aspects and steps of the due diligence process are reflected in its sustainability statement (¹¹).

AR 9 for para. 16

The undertaking may present the information required in paragraph 16 in the form of a table, cross-referencing the main steps of its due diligence process to the relevant disclosures in its sustainability statement.

17.

The objective of this DR is to enable an understanding of the undertaking’s risk management and internal control processes and systems in relation to sustainability reporting.

18.

The undertaking shall disclose the scope, main features and components of its risk management and internal control processes and systems in relation to sustainability reporting.

AR 10 for para. 18

The undertaking shall consider the completeness and integrity of the data, and the accuracy of estimation results, as aspects that are relevant in the context of the risk management associated with the reporting process.

19.

The objective of this DR is to enable an understanding of the key elements of the undertaking’s general strategy, business model and upstream and downstream value chain that relate to or affect material impacts, risks and opportunities, in order to enable an understanding of its exposure to such material impacts, risks and opportunities and where they originate.

20.

The undertaking shall disclose the following information about the key elements of its general strategy and business model that relate to, or affect, the topics associated with its material impacts, risks and opportunities:

21.

The objective of this DR is to enable an understanding of the undertaking’s stakeholder engagement and how key stakeholders’ interests and views are brought to the attention of its administrative, management and supervisory bodies and inform its strategy and business model.

22.

The undertaking shall disclose:

23.

The objective of this DR is to enable an understanding of the interactions between the undertaking’s material impacts, risks and opportunities and its strategy and business model, as well as of the related financial effects.

24.

The undertaking shall disclose a high-level description of how material impacts originate from its strategy and business model, the effects of risks and opportunities on its business model and value chain, and how it has addressed, and plans to address, those impacts, risks and opportunities in its strategy and decision-making.

25.

The undertaking shall disclose qualitative and quantitative information about how material risks and opportunities have affected its financial position, financial performance and cash flows for the reporting period (current financial effects).

26.

The undertaking shall disclose qualitative and quantitative information about the material risks and opportunities identified in paragraph 25 for which there is a significant risk of a material adjustment within the next annual reporting period to the carrying amounts of assets and liabilities reported in the related financial statements.

27.

The undertaking shall disclose qualitative and quantitative information on how it expects its financial position, financial performance, and cash flows to change over the short, medium and long term, given its strategy to manage material risks and opportunities (anticipated financial effects).

28.

The undertaking need not provide quantitative information about the current financial effects or anticipated financial effects if it determines that:

29.

The undertaking need not provide quantitative information about the anticipated financial effects of material risks or opportunities if it does not have the skills, capabilities or resources to provide that quantitative information.

30.

In preparing disclosures about its anticipated financial effects, the undertaking shall use all reasonable and supportable information available to it at the reporting date without undue cost or effort (see ESRS 1 General Requirements, paragraphs 94, 95 and 96).

31.

If the undertaking determines that it need not provide quantitative information about the current financial effects or anticipated financial effects of a risk or opportunity for any of the reasons specified in paragraphs 28 and 29, it shall:

32.

When providing quantitative information, the undertaking may present single amounts or ranges.

33.

The undertaking shall disclose qualitative information about the resilience of its strategy and business model regarding its capacity to manage its material risks as disclosed in accordance with paragraph 24. This information shall include how the analysis was conducted and the time horizons considered.

34.

The objective of this DR is to enable an understanding of the process through which the undertaking identifies impacts, risks, opportunities and the related topics, and assesses their materiality, as the basis for determining the disclosures to be made in its sustainability statement (see ESRS 1 General Requirements, Chapter 3).

35.

The undertaking shall disclose:

36.

The objective of this DR is to enable an understanding of the outcome of the materiality assessment, in terms of material impacts, risks and opportunities and material information reported in accordance with ESRS.

37.

The undertaking shall disclose:

38.

Information about policies, actions, metrics and targets shall enable an understanding of the level at which the undertaking manages its material impacts, risks and opportunities. If the undertaking has adopted policies, put in place actions, set targets or uses metrics only for certain aspects of a topic, this shall be reflected in the way the disclosure is prepared and presented, enabling users to understand the specific aspects that are covered.

39.

If the undertaking does not have policies, actions, or targets with reference to a topic related to material impacts, risks and opportunities, it shall disclose this fact.

40.

The undertaking shall apply the requirements specified in GDR-P, GDR-A, GDR-M and GDR-T when disclosing information either in accordance with a topical standard or on an entity-specific basis about:

41.

The objective of this GDR is to enable an understanding of the policies that the undertaking has in place to prevent, mitigate, bring to an end, minimise or remediate its material actual and potential negative impacts, and to manage material risks and pursue material opportunities or positive impacts.

42.

The undertaking shall disclose the following information about policies adopted to manage its material impacts, risks and opportunities:

43.

The undertaking shall disclose whether it has an overarching human rights policy committing to implement (¹⁹) the UN Guiding Principles on Business and Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the OECD Guidelines for Multinational Enterprises. If this is the case, the undertaking shall disclose the information specified in paragraph 42 for that policy and shall specify which groups of affected stakeholders are covered (e.g. own workforce, workers in the value chain, affected communities, consumers and end-users).

AR 34 for para. 43

When disclosing information about its human rights policy to implement the UN Guiding Principles on Business and Human Rights, the undertaking shall consider the International Bill of Human Rights, which consists of the Universal Declaration of Human Rights and the two Covenants that implement them, and the ILO principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.

44.

The objective of this GDR is to enable an understanding of the undertaking’s key actions, taken or planned, to manage its material impacts, risks and opportunities, and where applicable, to achieve the objectives of related policies.

45.

When the undertaking implements key actions to manage material impacts, risks and opportunities, it shall disclose:

46.

Where significant financial resources (operational or capital expenditure) have been or are expected to be allocated to the implementation of the key actions, the undertaking shall:

47.

The objective of this GDR is to support the preparation of the disclosures on metrics by the undertaking.

48.

The undertaking shall disclose the metrics required by topical standards in relation to material impacts, risks and opportunities, as well as metrics defined on an entity-specific basis in accordance with ESRS 1 General Requirements, paragraph 11. This may include metrics used by the undertaking to evaluate its performance and to track the effectiveness of its actions to manage its material impacts, risks and opportunities.

49.

For each metric, the undertaking shall disclose:

50.

The objective of this GDR is to enable an understanding of how the undertaking sets targets, as defined in terms of expected results for people, the environment or the undertaking itself, and of how the undertaking tracks the effectiveness of its policies and actions in relation to its material impacts, risks and opportunities, as well as the overall progress and effectiveness towards the adopted targets over time. This includes – where applicable – whether the progress is aligned with a related action plan or whether any significant facts and circumstances related to the action plan affect the achievement of the target.

51.

The undertaking shall disclose the measurable, time-bound, outcome-oriented qualitative or quantitative targets it has set related to its material impacts, risks and opportunities. For each target, the undertaking shall disclose:

52.

If the undertaking has not set any measurable outcome-oriented targets, it shall disclose whether and, if so, how it nevertheless tracks the effectiveness of its policies and actions in relation to its material impacts, risks and opportunities.

1.

The objective of this Standard is to set out Disclosure Requirements (DRs) related to climate change, particularly with respect to the sub- topics specified in paragraph 6 of this Standard. If not all the sub-topics prescribed by this Standard are to be reported following the materiality assessment, paragraph 30 of ESRS 1 General Requirements applies.

2.

The sustainability statement shall provide information in relation to ESRS E1 Climate Change if this topic relates to material impacts, risks and opportunities. Such information shall cover all the reporting areas listed in paragraph 5 of ESRS 1 General Requirements.

3.

The DRs in this Standard complement the provisions in ESRS 2 General Disclosures, which require the undertaking to disclose information about topics related to material impacts, risks and opportunities, in particular:

4.

In this Standard, each DR is introduced by a disclosure objective except for policies, actions and targets, for which the provisions in ESRS 2 GDR-P, GDR-A and GDR-T provide the necessary framing for the relevant DRs.

5.

This Standard takes into account the EU regulatory frameworks and other relevant frameworks, including the EU Climate Law (Regulation (EU) 2021/1119), the Climate Benchmark Standards Regulation (Regulation (EU) 2020/1818), the Sustainable Finance Disclosure Regulation (SFDR) (Regulation (EU) 2019/2088), the EU Taxonomy Regulation (Regulation (EU) 2020/852) and so-called ‘Pillar 3’ disclosures under the Capital Requirements Regulation (Regulation (EU) 2022/2453).

6.

This Standard sets out DRs with respect to the following sub-topics: climate change mitigation, climate change adaptation and energy.

7.

Climate change mitigation relates to the undertaking’s efforts to limit the increase in the global average temperature to 1,5 °C above pre-industrial levels in line with the Paris Agreement and the objectives of the European Climate Law (Regulation (EU) 2021/1119). This Standard covers DRs related to how the undertaking addresses its GHG emissions as well as the associated transition risks.

8.

Climate change adaptation relates to the undertaking’s process of adjustment to actual and expected consequences of climate change. This Standard covers DRs related to climate-related hazards that may lead to physical climate risks for the undertaking and its adaptation solutions for reducing these risks. It also covers transition risks stemming from the need to adapt to climate-related hazards.

9.

The DRs related to energy cover all types of energy production and consumption.

10.

Social and environmental topics interact with each other. The main points of interaction between ESRS E1 Climate Change and the other topical standards are the following:

11.

The objective of this DR is to enable an understanding of the undertaking’s past, current and future mitigation efforts to ensure that its strategy and business model are compatible with the transition to a sustainable economy and with limiting global warming to 1,5 °C in line with the Paris Agreement and the objectives of the European Climate Law (Regulation (EU) 2021/1119), including achieving climate neutrality by 2050.

12.

The information about the transition plan for climate change mitigation (³²) shall include:

13.

If the undertaking does not have in place a transition plan for climate change mitigation which includes the key features listed in paragraph 12(a), it shall disclose this fact and indicate whether and, if so, when it expects to adopt one.

14.

The objective of this DR is to enable an understanding of how the undertaking identifies and assesses climate-related risks and opportunities for financial materiality.

15.

The undertaking shall explain for each material climate-related risk identified (per ESRS 2 IRO-2, paragraph 37) whether it classifies the risk as a climate-related physical risk or a climate-related transition risk.

16.

In addition to the disclosure provided in accordance with ESRS 2 IRO-1, the undertaking shall disclose key elements of the methodology used to assess how its assets and business activities in its own operations and its upstream and downstream value chain may be exposed and be sensitive over the short, medium and long term to:

17.

If climate-related scenario analysis is used, the undertaking shall disclose:

AR 6 for paras. 16 and 17 (Key elements of the methodology and scenario analysis)

In conducting its climate-related risk analysis, the undertaking shall: The undertaking may use climate-related scenario analysis, for example if it uses such analysis to comply with other requirements or when applying another reporting framework or when the undertaking considers that such analysis helps identifying and assessing climate-related risks and opportunities for financial materiality.

18.

The objective of this DR is to enable an understanding of the extent to which the undertaking’s strategy and business model are prepared for, and can adapt to, material climate-related risks.

19.

In addition to the disclosure in ESRS 2 SBM-3, the undertaking shall disclose the following information on the resilience of its strategy and business model to climate-related risks:

20.

The undertaking shall disclose its climate change mitigation and climate change adaptation policies in accordance with the provisions of ESRS 2 GDR-P.

21.

The undertaking shall disclose its key climate change mitigation and the climate change adaptation actions and resources allocated to their implementation, in accordance with the provisions of ESRS 2 GDR-A.

22.

In addition to ESRS 2 GDR-A, when disclosing current and planned actions, the undertaking shall disclose:

23.

The undertaking shall disclose its climate change targets in accordance with the provisions of ESRS 2 GDR-T.

24.

The undertaking shall disclose the GHG emission reduction targets (³⁴) it has set, including:

25.

The objective of this DR is to provide an understanding of the undertaking’s energy consumption and mix.

26.

The undertaking shall disclose its total energy consumption in megawatt hours (MWh) related to its own operations, disaggregated by:

27.

The undertaking with operations in high climate impact sectors shall further disaggregate its total energy consumption from fossil sources by:

28.

If the undertaking produces energy, it shall also disaggregate and disclose separately its non-renewable energy production and renewable energy production in MWh (³⁶).

29.

The objective of this DR is to enable an understanding of the undertaking’s direct and indirect impacts on climate change as a result of activities in its own operations and in its upstream and downstream value chain.

30.

The undertaking shall:

31.

The undertaking shall disclose its direct biogenic CO₂ emissions from the combustion or biodegradation of biomass separately from scope 1 GHG emissions.

32.

The objective of this DR is to enable an understanding of the undertaking’s actions to reduce and permanently remove GHGs from the atmosphere and of the amount and quality of carbon credits it has purchased or intends to purchase from the voluntary market.

33.

If it has implemented GHG removal and storage projects, the undertaking shall disclose information about the projects it has developed in its own operations or contributed to in its upstream and downstream value chain (⁴¹), including:

34.

The undertaking shall disclose information about any projects outside its own operations and its upstream and downstream value chain that it has financed or intends to finance through any purchase of carbon credits (⁴²), including:

35.

In the case where the undertaking has made public claims of GHG neutrality that involve the use of carbon credits, it shall explain:

36.

The objective of this DR is to enable an understanding of the role of internal carbon pricing in guiding the undertaking’s strategic and operational decision-making to reduce GHG emissions.

37.

The undertaking shall disclose information related to its use of internal carbon pricing schemes, namely:

38.

The objective of this DR is to enable an understanding of how material climate-related physical risks, climate-related transition risks and climate-related opportunities are expected to affect the undertaking’s financial position and future performance. Paragraphs 39 and 42 of this Standard add topical specifications to ESRS 2 SBM 3. The information required for this DR is part of the information on current and anticipated financial effects required under ESRS 2 SBM-3.

39.

The undertaking shall disclose the anticipated financial effects from material physical risks (⁴⁴), including:

40.

The undertaking shall disclose the anticipated financial effects from material transition risks, including:

41.

The undertaking shall disclose the methodology applied to quantify the amounts specified in paragraphs 39 and 40, including the scope adopted in the calculation, critical assumptions, parameters and limitations, and whether the calculation leverages on the process (e.g. scenario analysis) used to identify and assess transition risks.

42.

The undertaking shall disclose the amount of assets or revenue from its business activities related to the identified climate-related opportunities (⁴⁶), including their associated time horizons.

1.

The objective of this Standard is to set out Disclosure Requirements (DRs) related to pollution, particularly with respect to the sub- topics specified in paragraph 6 of this Standard. If not all the sub-topics prescribed by this Standard are to be reported following the materiality assessment, paragraph 30 of ESRS 1 General Requirements applies.

2.

The sustainability statement shall provide information in relation to ESRS E2 Pollution if this topic relates to material impacts, risks and opportunities. Such information shall cover all the reporting areas listed in paragraph 5 of ESRS 1 General Requirements.

3.

The DRs in this Standard complement the provisions in ESRS 2 General Disclosures, which require the undertaking to disclose information about topics related to material impacts, risks and opportunities, in particular:

4.

In this Standard, each DR is introduced by a disclosure objective except for policies, actions and targets, for which the provisions in ESRS 2 GDR-P, GDR-A and GDR-T provide the necessary framing for the relevant DRs.

5.

This Standard takes account of EU regulatory frameworks, including: the EU Action Plan ‘Towards a Zero Pollution for Air, Water and Soil’; the Chemicals Strategy for Sustainability ‘Towards a Toxic-Free Environment’; the Kyiv Protocol on Pollutant Release and Transfer Registers; the E-PRTR (Regulation (EC) No 166/2006 of the European Parliament and of the Council (⁴⁸)) and the IEPR amendments (Regulation (EU) 2024/1244 of the European Parliament and of the Council (⁴⁹) on the Industrial Emissions Portal); the IED (Directive 2010/75/EU of the European Parliament and of the Council (⁵⁰) on the Industrial Emissions Directive) and the IED 2.0 amendments (Directive (EU) 2024/1785 of the European Parliament and of the Council (⁵¹) on the Industrial and Livestock Rearing Emissions); the REACH (Regulation (EC) No 1907/2006 of the European Parliament and of the Council (⁵²) on the Registration, Evaluation, Authorisation and Restriction of Chemicals) and REACH-SPM amendments (Commission Regulation (EU) 2023/2055 (⁵³) on Synthetic Polymer Microparticles); and the CLP (Regulation (EC) No 1272/2008 of the European Parliament and of the Council (⁵⁴) on the Classification, Labelling and Packaging of Substances and Mixtures).

6.

This Standard sets out DRs with respect to the following sub- topics: pollution of air, pollution of water and pollution of soil; microplastics; and substances of concern (SoC), including substances of very high concern (SVHC).

7.

Pollution of air, pollution of water, and pollution of soil refer to the undertaking’s emissions to air, water and soil, as well as to the prevention, control and reduction of such emissions. Emissions to water include emissions to freshwater and to seawater.

8.

DRs on SoC, including SVHC, set disclosure requirements to provide users with an understanding of the related actual impacts or potential impacts, also considering possible restrictions on their production, use, distribution and commercialisation.

9.

Context-specific considerations are particularly important in relation to pollution. If material impacts, risks or opportunities are related to specific geographies, it is important to consider appropriate aggregation or disaggregation of the reported information, e.g. by site, area with water stress or other level in accordance with ESRS 1 General Requirements, Chapter 3.3.2 Level of Aggregation, Disaggregation.

10.

Social and environmental topics interact with each other. The main points of interaction between ESRS E2 Pollution and the other topical standards are the following.

11.

The undertaking shall disclose its pollution -related policies in accordance with the provisions of ESRS 2 GDR-P.

12.

The undertaking shall disclose its key pollution -related actions and resources allocated to the implementation of those actions in accordance with the provisions of ESRS 2 GDR-A.

13.

The undertaking shall disclose its pollution -related targets in accordance with the provisions of ESRS 2 GDR-T.

14.

The objective of this DR is to enable users to understand the undertaking’s emissions of pollutants to air, water and soil, and its manufacturing, use, and release into the environment of microplastics.

15.

The undertaking shall disclose the amounts of material emissions of pollutants to air, water and soil from its own operations, including due to environmental accidents, in the reporting period (⁵⁵).

16.

The undertaking shall disclose the amounts of primary microplastics manufactured or used in its products, and separately, those directly released into the environment.

17.

The objective of this DR is to enable users to understand the undertaking’s material impacts, risks and opportunities linked to the manufacturing, trading or use of SoC and SVHC, including risks arising from changes in regulations.

18.

Manufacturers of substances, formulators of substances or importers of substances, whether on their own or in mixtures, shall disclose the total weight of SoC, and separately, the total weight of SVHC that they:

19.

Users of substances, whether on their own or in mixtures, shall disclose:

20.

Manufacturers of articles, importers of articles or users of articles that contain SVHC shall disclose the names of the substances that are present in a concentration above 0,1 % weight by weight (w/w), as per Article 33 of Regulation (EC) No 1907/2006 (REACH), in:

1.

The objective of this Standard is to set out Disclosure Requirements (DRs) related to water, particularly with respect to the sub- topics specified in paragraph 6 of this Standard. If not all the sub-topics prescribed by this Standard are to be reported following the materiality assessment, paragraph 30 of ESRS 1 General Requirements applies.

2.

The sustainability statement shall provide information in relation to ESRS E3 Water if this topic relates to material impacts, risks and opportunities. Such information shall cover all the reporting areas listed in paragraph 5 of ESRS 1 General Requirements.

3.

The DRs in this Standard complement the provisions in ESRS 2 General Disclosures, which require the undertaking to disclose information about topics related to material impacts, risks and opportunities, in particular:

4.

In this Standard, each DR is introduced by a disclosure objective, except for policies, actions and targets, for which the provisions in ESRS 2 General Disclosures GDR-P, GDR-A and GDR-T provide the necessary framing for the relevant DRs.

5.

This Standard takes account of EU regulatory frameworks and other relevant frameworks, including EU Water Framework Directive (Directive 2000/60/EC of the European Parliament and of the Council (⁵⁶)), EU Drinking Water Directive (Directive (EU) 2020/2184 of the European Parliament and of the Council (⁵⁷)), Industrial Emissions Directive (Directive 2010/75/EU), EU Water Resilience Strategy, the Eco-Management and Audit Scheme (EMAS) Regulation (Regulation (EU) No 1221/2009), UN Watercourses Convention (1997) and UNECE Water Convention (1992).

6.

This Standard sets out DRs with respect to the following sub- topics: water use, which includes water withdrawal; water consumption; water discharge and water stored.

7.

Water encompasses freshwater and other types of water, for example brackish water, from different sources, such as surface water, groundwater, seawater, produced water and third-party water.

8.

Context-specific considerations are particularly important in relation to water. If material impacts, risks or opportunities are connected to specific geographies, it is important to consider appropriate aggregation or disaggregation of the reported information, e.g. by site, basin, area with water stress or any other level in accordance with ESRS 1 General Requirements, Chapter 3.3.2 Level of Aggregation, Disaggregation.

9.

Social and environmental topics interact with each other. The main points of interaction between ESRS E3 Water and the other topical standards are the following.

10.

The undertaking shall disclose its water-related policies in accordance with the provisions of ESRS 2 GDR-P (⁵⁸).

11.

If the undertaking has sites located in areas with water stress that are not covered by its water-related policies, it shall disclose this fact (⁵⁹).

12.

The undertaking shall disclose its key water-related actions and resources allocated to their implementation in accordance with the provisions of ESRS 2 GDR-A.

13.

The undertaking shall specify key actions and resources related to areas with water stress.

14.

The undertaking shall disclose its water-related targets in accordance with the provisions of ESRS 2 GDR-T.

AR 3 for para. 14 (Targets on areas with water stress)

In line with the scope considerations set out in ESRS 2 GDR-T, paragraph 51(c), the undertaking shall, where relevant, express water-related targets with reference to specific geographic areas, such as areas with water stress.

15.

The objective of this DR is to enable users to understand the undertaking’s water performance.

16.

The undertaking shall disclose the following water metrics for its own operations:

1.

The objective of this Standard is to set out Disclosure Requirements (DRs) related to biodiversity and ecosystems, particularly with respect to the sub- topics specified in paragraph 6 of this Standard. If not all the sub-topics prescribed by this Standard are to be reported following the materiality assessment, paragraph 30 of ESRS 1 General Requirements applies.

2.

The sustainability statement shall provide information in relation to ESRS E4 Biodiversity and Ecosystems if this topic relates to material impacts, risks and opportunities. Such information shall cover all the reporting areas listed in paragraph 5 of ESRS 1 General Requirements.

3.

The DRs in this Standard complement the provisions in ESRS 2 General Disclosures, which require the undertaking to disclose information about topics related to material impacts, risks and opportunities, in particular:

4.

In this Standard, each DR is introduced by a disclosure objective except for policies, actions and targets, for which the provisions in ESRS 2 GDR-P, GDR-A and GDR-T provide the necessary framing for the relevant DRs.

5.

This Standard takes account of EU regulatory frameworks and other relevant frameworks, including the vision of the Kunming-Montreal Global Biodiversity Framework and its relevant goals and targets, relevant aspects of the EU Biodiversity Strategy for 2030, EU Birds and Habitats Directives (Directive 2009/147/EC of the European Parliament and of the Council (⁶¹) and Council Directive 92/43/EEC (⁶²)), the Marine Strategy Framework Directive (Directive 2008/56/EC of the European Parliament and of the Council (⁶³)), the 2023 EU Marine Action Plan, the EU Water Framework Directive (Directive 2000/60/EC of the European Parliament), and the Nature Restoration Regulation (Regulation (EU) 2024/1991 of the European Parliament and of the Council (⁶⁴)).

6.

This Standard sets out DRs with respect to the following sub- topics: drivers of biodiversity and ecosystem change; the state of species; the condition and extent of terrestrial, freshwater and marine ecosystems; and ecosystem services.

7.

The terms ‘biodiversity’ and ‘biological diversity’ refer to the variability among living organisms from all sources including, inter alia, terrestrial, freshwater, marine and other aquatic ecosystems and the ecological complexes of which they are part.

8.

Context-specific considerations are particularly important in relation to biodiversity and ecosystems. If material impacts, risks or opportunities are related to specific geographies, it is important to consider appropriate aggregation or disaggregation of the reported information, e.g. by site, ecosystem or another level in accordance with ESRS 1 General Requirements, Chapter 3.3.2 Level of Aggregation, Disaggregation.

9.

Social and environmental topics interact with each other. For instance, direct drivers of biodiversity and ecosystem change are climate change, pollution, land-use change, freshwater -use change and sea-use change, direct exploitation of organisms and invasive alien species. These drivers are covered in ESRS E4 Biodiversity and Ecosystems except for climate change and pollution, which are addressed by ESRS E1 Climate Change and ESRS E2 Pollution respectively. The main points of interaction between ESRS E4 Biodiversity and Ecosystems and the other topical standards are the following.

10.

The objective of this DR is to enable an understanding of the undertaking’s response and contribution to the transition implied by the Kunming-Montreal Global Biodiversity Framework (GBF) if it has in place a biodiversity and ecosystems transition plan and has made public its key features.

11.

If the undertaking has in place a biodiversity and ecosystems transition plan to transform its business model and strategy so that it contributes to the global goal of halting and reversing biodiversity loss, as stated in the GBF, and it has made public the key features of such plan, it shall disclose those features.

12.

The undertaking shall disclose its biodiversity and ecosystems policies in accordance with the provisions of ESRS 2 GDR-P.

13.

In addition to the provisions of ESRS 2 GDR-P, the undertaking shall describe the content of its biodiversity and ecosystems -related policies with respect to:

14.

The undertaking shall disclose its key biodiversity - and ecosystems -related actions and resources allocated to their implementation in accordance with the provisions of ESRS 2 GDR-A.

15.

In addition to the provisions of ESRS 2 GDR-A, the undertaking shall describe any biodiversity offsets used as part of its actions, including the aim of the offsets, the financing effects in monetary terms, the area, type and quality criteria applied, and the standards with which the biodiversity offsets comply.

AR 6 for para. 14 (Actions related to biodiversity and ecosystems)

Actions to be disclosed under paragraph 14 shall consider the right to free, prior and informed consent of indigenous peoples (see also ESRS S3-2).

16.

The undertaking shall disclose its biodiversity and ecosystems targets in accordance with the provisions of ESRS 2 GDR-T.

17.

If the undertaking uses biodiversity offsets in setting its targets, it shall disclose how these offsets were used.

AR 7 for para. 16 (Targets related to biodiversity and ecosystems)

Biodiversity -related targets:

18.

The objective of this DR is to enable an understanding of the performance of the undertaking against material biodiversity and ecosystems change-related impacts, risks and opportunities.

19.

The undertaking shall disclose the following information for material biodiversity and ecosystem change-related impacts, risks or opportunities:

20.

In addition to paragraph 19, and in accordance with ESRS 2 GDR-M, the undertaking shall report metrics related to its material impacts on biodiversity and ecosystems.

1.

The objective of this Standard is to set out Disclosure Requirements (DRs) related to resource use and circular economy, particularly with respect to the sub- topics specified in paragraphs 6 of this Standard. If not all the sub-topics prescribed by this Standard are to be reported following the materiality assessment, paragraph 30 of ESRS 1 General Requirements applies.

2.

The sustainability statement shall provide information in relation to ESRS E5 Resource Use and Circular Economy if this topic relates to material impacts, risks, and opportunities. Such information shall cover all the reporting areas listed in paragraph 5 of ESRS 1 General Requirements.

3.

The DRs in this Standard complement the provisions in ESRS 2 General Disclosures, which require the undertaking to disclose information about topics related to material impacts, risks and opportunities, in particular:

4.

In this Standard, each DR is introduced by a disclosure objective except for policies, actions and targets, for which the provisions in ESRS 2 GDR-P, GDR-A and GDR-T provide the necessary framing for the relevant DRs.

5.

This standard takes account of EU policy and regulatory frameworks, including the EU Circular Economy Action Plan (2020), the European Clean Industrial Deal (2025), the Eco-design for Sustainable Products Regulation (Regulation (EU) 2024/1781 of the European Parliament and of the Council (⁶⁹)), the Waste Framework Directive (Directive 2008/98/EC of the European Parliament and of the Council (⁷⁰)), the Right to Repair Directive (EU) 2024/1799 of the European Parliament and of the Council (⁷¹)) and the Critical Raw Materials Act (Regulation (EU) 2024/1252 of the European Parliament and of the Council (⁷²)).

6.

This Standard sets out DRs with respect to the following sub- topics: resource inflows; resource outflows related to products and services; resource outflows related to waste.

7.

Environmental and social topics interact with each other. The points of interaction between ESRS E5 Resource Use and Circular Economy and the other topical standards are listed below:

8.

The undertaking shall disclose its resource use and circular economy policies in accordance with the provisions of ESRS 2 GDR-P.

9.

In addition to the information required under ESRS 2 GDR-P, if the undertaking integrates circular economy principles or eco-design requirements in its key products and circular economy services, it shall explain how this is done.

10.

The undertaking shall disclose its key resource use and circular economy actions in accordance with the provisions of ESRS 2 GDR-A.

11.

The undertaking shall disclose its resource use and circular economy targets in accordance with the provisions of ESRS 2 GDR-T.

12.

The objective of this DR is to provide an understanding of the undertaking’s resource inflows. This includes information about the types and circularity of resources entering the undertaking.

13.

The undertaking shall disclose the following information:

14.

The objective of this DR is to provide an understanding of how the undertaking contributes to the circular economy by designing, manufacturing and providing products and services in accordance with circular economy principles, and by effectively managing waste.

15.

The undertaking shall disclose:

16.

The undertaking shall disclose the following information on waste from its own operations:

17.

The undertaking shall disclose the total amount of radioactive waste it generates, in accordance with the definition of radioactive waste in Article 3(7) of Council Directive 2011/70/Euratom (⁷⁵) (⁷⁶).

1.

The objective of this Standard is to set out Disclosure Requirements (DRs) related to own workforce, particularly with respect to the sub- topics specified in paragraph 6 of this Standard. If not all the sub-topics prescribed by this Standard are to be reported following the materiality assessment, paragraph 30 of ESRS 1 General Requirements applies except for: The filter of materiality of information defined in ESRS 1 General Requirements, paragraph 23, remains applicable also to these two DRs.

2.

The sustainability statement shall provide information in relation to ESRS S1 Own Workforce if this topic relates to material impacts, risks and opportunities. Such information shall cover all the reporting areas listed in paragraph 5 of ESRS 1 General Requirements.

3.

The DRs in this Standard complement the provisions in ESRS 2 General Disclosures, which require the undertaking to disclose information about topics related to material impacts, risks and opportunities, in particular:

4.

In this Standard, each DR is introduced by a disclosure objective except for policies, actions and targets, for which the provisions in ESRS 2 GDR-P, GDR-A and GDR-T provide the necessary framing for the relevant DRs.

5.

This Standard takes into account the international and European human rights instruments and conventions, including the International Bill of Human Rights; the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises; the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and ILO fundamental conventions; the UN Convention on the Right of Persons with Disabilities; the European Convention of Human Rights; the revised European Social Charter; the Charter of Fundamental Rights of the European Union (EU); the EU policy priorities as set out by the European Pillar of Social Rights; and EU legislation, including the EU labour law acquis.

6.

This Standard sets out DRs with respect to the following sub- topics:

7.

The undertaking’s own workforce includes (i) people who are in an employment relationship with the undertaking (‘employees’); and (ii) people who, for the purposes of reporting under ESRS, are called ‘non-employees’ in the undertaking’s own workforce. The latter comprise people with contracts with the reporting undertaking to supply labour (‘self-employed people’) or people provided by undertakings primarily engaged in ‘employment activities’ (NACE Code 078). Information about the persons referred to as ‘non-employees’ in the undertaking’s own workforce in accordance with this Standard shall not affect their status under applicable labour law. This Standard does not cover workers in the undertaking’s upstream or downstream value chain. These workers are covered in ESRS S2 Workers in the Value Chain.

8.

The definitions of self-employed people and of people provided by undertakings primarily engaged in ‘employment activities’ are based on national legislation. Examples of non-employees in the undertaking’s own workforce that could fall within the scope of own workforce are:

9.

Social and environmental topics interact with each other. The points of interaction between ESRS S1 Own Workforce and the other topical standards are the following:

10.

The undertaking shall describe its policies for managing material impacts, risks and opportunities related to its own workforce in accordance with ESRS 2 GDR-P. It shall state whether these policies cover specific groups within its own workforce (for example, employees working in a particular factory or geography or self-employed people) or all of its own workforce.

11.

The undertaking shall state whether its policies in relation to its own workforce address trafficking in human beings (⁷⁷), forced labour or compulsory labour, and child labour.

AR 1 for para. 10 (Policies related to own workforce)

Examples of policy aspects to disclose are the means of communication the undertaking uses to communicate its policies to the individuals, groups of individuals or entities for whom they are relevant, either because they are expected to implement them (for example, the undertaking’s employees, contractors and suppliers) or because they have a direct interest in their implementation (for example, people in its own workforce, investors).

12.

The objective of this DR is to enable an understanding of the undertaking’s general approach to engagement with its own workforce, including the availability of channels to raise concerns or needs such as grievance mechanisms, and its approach to remedy.

13.

The undertaking shall disclose how it engages directly with its own workforce or workers’ representatives and how the perspectives of its own workforce inform its decisions or activities aimed at managing the actual and potential impacts on its own workforce during the reporting year. This shall include:

14.

The undertaking shall describe the channels available to its own workforce to bring their concerns or needs directly to its attention and have them addressed. In particular, it shall state whether it has a grievance mechanism in place (⁷⁸). It shall also explain how it assesses the effectiveness of these channels.

15.

The undertaking shall describe its general approach to and processes to provide or cooperate in remediation where it has caused or contributed to a material negative impact on people in its own workforce.

16.

The undertaking shall describe the key actions and resources used to manage its material positive and negative impacts, risks and opportunities related to its own workforce in accordance with ESRS 2 GDR-A.

17.

In relation to material negative impacts on its own workforce, the undertaking shall describe:

18.

The undertaking shall disclose qualitative and/or quantitative targets related to its own workforce in accordance with ESRS 2 GDR-T.

AR 6 for para. 18 (Tracking performance)

Engagement with the undertaking’s own workforce or workers’ representatives can inform the undertaking’s tracking and assessment of the effectiveness of its actions disclosed under paragraph 17(b), including the development of metrics, target-setting and/or tracking of performance against those metrics and targets. In particular, in relation to the tracking of performance, such engagement can inform the understanding of the effectiveness of the undertaking’s management of material negative impacts and the identification of lessons learnt or improvements.

19.

The objective of this DR is to provide insight into the undertaking’s approach to employment practices, including security of employment for its own workforce. It also serves as the basis for calculating certain quantitative metrics required by other DRs in this Standard and provides contextual information for those metrics.

20.

The undertaking shall disclose:

21.

The objective of this DR is to enable an understanding of how much the undertaking relies on non-employees as part of its own workforce.

22.

The undertaking shall disclose the total number of non-employees in the undertaking’s own workforce.

23.

The objective of this DR is to enable an understanding of the coverage of collective bargaining agreements and social dialogue for the undertaking’s employees.

24.

The undertaking shall disclose the following information in relation to collective bargaining: