First insights: The future European Sustainability Reporting Standard (ESRS) and the Corporate Sustainability Reporting Directive (CSRD)
With the introduction of the Corporate Sustainability Reporting Directive (CSRD), uniform disclosure requirements will apply to those companies in the European Union that fall under the regulations of this directive. The CSRD will replace the previously applicable Non-Financial Reporting Directive (NFRD). The NFRD affected around 11.000 companies in the European Union. The CSRD will apply to 50.000 European companies. Being a uniform reporting standard, the European Sustainability Reporting Standard (ESRS) will be the framework for reporting under the CSRD. The draft version of this standard is now available for public feedback on EFRAG’s website.
Update: A revised version of the European Sustainability Reporting Standards or ESRS has been released in June 2023. We have compiled this blogpost to share all the information and updates with you.
With this blog post, we would like to provide an initial overview of the structure and required content for sustainability reporting under the ESRS. In doing so, this blog post cannot and does not intend to replace the reading of the draft reporting standard. However, changes to the ESRS after the public consultation are possible.
You can find out more about the CSRD, which companies will be affected by it and what the implementation roadmap looks like in our whitepaper on the CSRD, which can be requested here. Likewise, you can ask for our whitepaper on the ESRS here.
European Sustainability Reporting Standard (ESRS)
A closer look at the ESRS quickly reveals the following:
- The concept of “double materiality” plays a central role. References to materiality assessment are taken up again and again in the individual topics (environment, social, governance) and are reflected in the cross-cutting topics (“cross-cutting” – see below). The concept of “double materiality” is applied here.
- In addition to reporting critical figures, many questions are related to strategies and targets for individual sub-areas that have already been or are still to be implemented.
- The disclosure requirements are extensive and sometimes complex. The processing effort for the questions formulated in the ESRS should not be underestimated. Companies affected by the reporting obligation under the CSRD should obtain an overview of the individual disclosure requirements as early as possible.
Sub-areas of the European Sustainability Reporting Standard
The ESRS is divided into four areas:
- The cross-cutting topics “General principles” and “General, strategy, governance and materiality assessment disclosure requirements”.
- “Environment” with the five sub-areas “Climate change”, “Pollution”, “Water and marine resources”, “Biodiversity and ecosystems”, and “Resource use and circular economy”.
- “Social” with the four sub-areas “Own workforce”, “Workers in the value chain”, “Affected communities”, and “Consumers and end-users”.
- “Governance” with the two sub-areas “Governance, risk management and internal control” and “Business conduct”.
The ESRS consists of 137 disclosure requirements in total. In addition to purely quantitative questions, they also include those relating to strategy, risks, opportunities, impacts and materiality characteristics. That means that the sheer number of disclosure requirements in the individual sub-areas can only be used to a limited extent to conclude the actual processing effort involved.
Example questions
The following examples are intended to illustrate the nature of the questions. The example of greenhouse gas emissions demonstrates the processing effort hidden behind a purely quantitative question. The example of “Materiality Assessments” gives a first indication of the qualitative information that is required.
Greenhouse gas emissions
The disclosure of scope 1, 2 and 3 greenhouse gas emissions (E1-7 to E1-9) is required. Scope 3 emissions, in particular, represent a challenge for companies that should not be underestimated by reporting companies. This is because they are not under the direct control of the reporting company and are divided into upstream and downstream emissions in relation to the value chain.
The GHG Protocol provides extensive information material (PDF document / 182 pages) with assistance for calculating Scope 3 emissions for download.
Materiality Assessment
DR2-IRO1 requires, among other things, a description of how the process to identify material sustainability impacts, risks and opportunities was implemented (“Description of the process to identify material sustainability impacts, risks and opportunities”). This must include a description of which factors were classified as material for the company. In connection with “double materiality“, reference is made to its central importance. It must be explained how the principle of “double materiality” was observed in the process of preparing the sustainability report. Our blogpost “From 0 to Double – How to conduct a Double Materiality Assessment” explains the process of a double materiality assessment.
Challenges for companies
Companies that fall under the CSRD regulations and are required to report according to the ESRS will start the reporting process with different starting positions.
- Companies that already have structured sustainability reporting will adapt their previous reporting to the requirements of the ESRS or continue with their existing reporting and additionally report according to the ESRS. In doing so, they can draw on an existing database, processes and resources established in the company, depending on the reporting standard used to date.
- Companies that do not yet operate structured sustainability reporting must establish the necessary structures and provide the resources needed. This also includes the required personnel resources for data collection and preparation. In addition, it will be essential in many cases to raise awareness of the issue within the company and to build up and live the associated corporate culture.
It is advisable to deal with the requirements of the ESRS at an early stage and to compare which information and data are already available or which processes have to be initiated and which strategies have to be developed to meet the requirements of the ESRS.
NordESG
NordESG is an independent consulting company. Our consulting services are designed to address issues around sustainability and ESG. We support companies in navigating their sustainability landscape and develop strategies and concepts individually tailored to our client’s requirements. Of course, we are happy to be contacted by email. Alternatively, you can make an appointment with us for a free introductory meeting by following this link.
Sources
Draft ESRS: EFRAG 2022 – https://www.efrag.org/lab3?Aspx
