At the heart of the European Sustainability Reporting Standards (ESRS) framework lies a comprehensive and detailed set of datapoints. The ESRS datapoints serve as the building blocks for providing a structured and comparable format for disclosures. These datapoints are outlined in the (Draft) ESRS Datapoints List (Implementation Guidance) and Explanatory Note published by the European Financial Reporting Advisory Group (EFRAG).
With the introduction of the Corporate Sustainability Reporting Directive (CSRD), sustainability reporting becomes more standardized and regulated for companies in the EU. The initial batch of companies falling under the CSRD start reporting under ESRS for the financial year 2024, the subsequent batch will follow 2025.
Understanding the datapoint list is therefore essential for companies to ensure accurate and complete sustainability reporting, steering clear of penalties and reputational risks associated with non-compliance.
In this blog article, we equip sustainability practitioners with the insights needed to navigate the datapoint labyrinth effectively.
👉 Please note that the (Draft) ESRS datapoints List (Implementation Guidance) published by EFRAG are is non-authoritative (see Disclaimer and status of this Explanatory Note) and only accompanies the ESRS delegated act.
👉 Additionally, it's important to note that the EFRAG Explanatory Note and Implementation Guidance material is currently in draft form and could undergo further revisions. We will update this blog article accordingly.
Navigating the ESRS Datapoints List
As sustainability reporting becomes a focal point for stakeholders and regulatory bodies, the ESRS datapoints provide the necessary depth and granularity to go beyond generic statements, offering stakeholders a nuanced understanding of a company's environmental, social, and governance (ESG) practices.
The extensive nature of the ESRS framework is reflected in the (Draft) ESRS Datapoints List (Implementation Guidance), including more than 1.000 rows of datapoints.
The list offers a structural framework for organizing data requirements to ensure ESRS compliance and facilitate a standardized approach.
Each row in the list represents a separable quantitative and qualitative datapoint, and in this way breaks down the disclosures at a granular level. The table shows the related requirements and linkages of each individual datapoint.
Gaining a clear understanding of the list of separable datapoints is crucial to fully grasp the systematic organization of the narrative contents related to the specific “Disclosure Requirement” (DR) or “Application Requirements” (AR).
If you already report your ESG data, this list serves as a foundation for conducting a gap analysis of the existing sustainability information in your company.
Structure of the ESRS Datapoints List
The (Draft) ESRS datapoints List (Implementation Guidance) is presented in Excel format with detailed requirements and references described by the different columns in the table.
It encompasses all standards from ESRS 2 and the Topical ESG standards, excluding ESRS 1 General Requirements, which doesn't stipulate specific disclosures. Within this structure, the datapoints are organized to streamline reporting practices.
💡 ESRS E1 (Climate Change) and ESRS S1 (Own Workforce) have the most individual datapoints with respectively yielding 208 and 189 datapoints in the workbook.
The Minimum Disclosure Requirements (MDR) are centrally compiled in a separate sheet within the workbook, distinguished by a green background color. Each topical standard that needs to apply the MDRs has an exclusive line item, linking the referring requirements to the topical standard.
The columns in the Excel workbook provide valuable information for you to navigate and filter content, including corresponding paragraphs and subparagraphs for each item.
The columns in the datapoints list are organized as follows:
- ESRS (Column A): Referring to the relevant standard within the ESRS such as ESRS 2 or S1
- DR (Column B): Referring to the related disclosure requirement (DR) such as E1-1 or E1.GOV-3
- Paragraph (Column C): Referring to the related paragraph under each DR or AR such as 16a, 16b, 16c, and so forth
- Related AR (Column D): Referring to the corresponding application requirement (AR) for each paragraph such as AR1 or AR2 (Please note that not all datapoints have specific ARs and some ARs concern the entire DR)
- Name (Column E): Briefly describing the detailed requirement such as “Disclosure of transition plan for climate change mitigation” or “Achieved GHG emission reductions”
- Data type (Column F): Classifying data types into qualitative and quantitative data, including narrative, semi-narrative, and numerical elements
- Appendix B - ESRS 2 (Column G): Referring to the data points that can be referenced to EU Regulation such as SFDR (Sustainable Finance Disclosure Regulation), Pillar 3, Benchmark or CL (Climate Law) as described in Appendix B-ESRS 2
- Appendix C - ESRS 1 (Column H): Referring to data points that are subject to phasing-in provisions applicable to companies with less than 750 employees as described to Appendix C of ESRS 1
- Appendix C - ESRS 1 (Column I): Referring to data points that are subject to phasing-in provisions applicable to all companies as described to Appendix C of ESRS 1
- May [V] (Column J): Identifying the voluntary data points (“may disclose”)
A Closer Look at Data Types
The nature of ESRS datapoints goes beyond numbers; it involves a nuanced comprehension of different data types and a large number of datapoints are qualitative, referring to a narrative or semi-narrative format.
The datapoints encompass a spectrum of information, ranging from narrative descriptions to monetary figures, percentages, volumes, and more. Each data type serves a distinct purpose in conveying specific aspects of an organization's sustainability story.
- Narrative: Descriptive text elements that provide context and qualitative insights; Example: Disclosure of decarbonisation levers and key action
- Semi-Narrative: Descriptive elements that can be single text blocks, binary choice (yes/no) or dropdown selections; Example: Removals and carbon credits are used [yes/no]
- Numerical: Quantitative elements, for example monetary, percent or volume
Exemplary Numerical Data Types:
- Monetary: Quantifying financial implications of sustainability initiatives; Example: Net revenue used to calculate GHG intensity
- Percent: Expressing proportions and ratios related to sustainability indicators; Example: Percentage of renewable sources in total energy consumption
- Volume: Quantifying tangible quantities relevant to sustainability practices; Example: Total water recycled and reused
Please see column F in the Excel worksheet or the explanatory note by EFRAG for the entire list of data types. As you delve into this list, the datapoints of different types become a compass for your effective reporting.
As such, the provided datapoints not only ensure accuracy in the representation of data but also add layers of depth to the narrative, making sustainability reporting a more transparent and more insightful practice.
Mandatory and Voluntary ESRS Datapoints
The ESRS list encompasses both mandatory and voluntary datapoints for sustainability reporting. The datapoints marked as "voluntary" are those for which the legal text uses "may" instead of "shall". These voluntary datapoints are optional reporting elements that companies may choose to disclose. The overview in the list makes it easier to recognize the voluntary disclosures.
The datapoints list encompasses the entire spectrum of potential datapoints under sector-agnostic ESRS, regardless of the outcome of a materiality assessment that each company needs to conduct as a first step.
👉 Please consider that each company needs to conduct a materiality assessment to identify the relevant datapoints for the preparation of its sustainability statement.
Relation to Digital Reporting (ESRS XBRL Taxonomy)
EFRAG is tasked with developing an ESRS XBRL Taxonomy, enabling businesses to tag sustainability data in a structured, machine-readable format. This facilitates analysis and eliminates manual errors during information transformation.
This taxonomy is based on Extensible Market Language (XML), which is a means of modeling business information in a format that a computer can understand. It is currently mostly used for financial reporting.
The ESRS XBRL Taxonomy will contain sustainability statement elements, including formal definitions, descriptions and references to reporting terms that are used by different authorities, regions and industries.
Separating the single disclosure items in the narrative text, the (Draft) ESRS Datapoints List (Implementation Guidance) is considered an interim step that may help streamline digital tagging and reduce overlaps. However, it does not represent the digital ESRS XBRL Taxonomy, as the structure can differ due to technical aspects.
Nevertheless, the datapoint list supports the preparation of ESRS sustainability statements that are readable by humans, for example your stakeholders.
Therefore, companies are encouraged to work with the list and leverage it for structuring their narrative disclosures efficiently.
Practical Insights Into ESRS Implementation with Software
Beyond the regulatory realm, the datapoint list can serve as a strategic tool for your ongoing sustainability management.
Leverage the ESRS datapoints to gain valuable insights into your company's sustainability practices, identify areas for improvement, and make informed decisions that align with the broader ESG objectives you might have.
Utilizing software to systematically manage all datapoints, encompassing all related disclosure and application requirements, and address them one by one can substantially reduce your workload and streamline your reporting process.
5 Tips how Software Helps you Manage ESRS Datapoints
- Use the ESRS datapoints list for your initial gap analysis to get prepared for the CSRD reporting requirements – Our software identifies gaps by automatically matching existing data from other reporting formats or assessments with the ESRS datapoints.
- Don't double your workload when ESRS data points overlap with other reporting requirements such as the EU Taxonomy or GRI, but use them to accelerate your sustainability reporting – Sunhat enables you to leverage synergies between requirements by mapping central information.
- Involve your team, other departments of your company, or your suppliers by providing them with easy access to input data into Sunhat – Assign tasks and comment on single datapoints to facilitate a seamless handling process.
- Manage all datapoints of different data types in one central database layer to keep on overview and track progress – Sunhat’s response database stores all sorts of narrative or numerical datapoints with the necessary context and evidence and helps you gain powerful insights.
- Stay ahead of evolving regulatory landscapes without having to decipher each officially published document – Our Sunhat experts keep the guides and templates in the software up-to-date for you.
Sunhat’s software enhances accuracy and transparency but also provides you with a structured and easy-to-use workspace for collecting and updating the required datapoints.
With the comprehensive features of Sunhat’s CSRD Module, you can efficiently navigate the extensive list of ESRS datapoints, ensuring a more precise and effective approach to compliance.