The file I am referring to is publicly available. at this address. Before using it, it is also worth reading the accompanying implementation guidelines. It is worth remembering that the published list is a draft presented by the Sustainability Reporting TEG. If any changes are made to the list after its adoption by the SR TEG and later by the SR Board, we will certainly write about it.
The file contains 11 sheets (corresponding to ESRS 2 and all thematic standards) with detailed lists of all disclosure requirements and individual data points contained therein. Each of them is described by a relevant excerpt from the standard, with a corresponding reference (which standard, which disclosure requirement, and which paragraph of the text). This makes it easy to find the relevant elements in the content of individual standards.
Each data point is also assigned a type. The most common type is narrative, i.e. simply text. It can be of varying length – one sentence, one paragraph, an entire page, or even multiple pages. Some data points are so-called. semi-narrative, i.e., descriptive disclosures, but limited to a mostly closed list of options. There are also many data points that are different numbers (e.g.,. integer, monetary, percentage, mass, energy etc.). Separate columns also indicate whether a given data point stems from other EU legislation (e.g., the SFDR) and whether its reporting may be delayed on the basis of transitional provisions. Data points for which reporting is optional are also specially marked.
The lists of disclosure requirements and data points contained in the file are useful when reading the content of the standards. They provide a structured way of understanding exactly what the regulator expects from us, which can be difficult in the case of long, sometimes complex sentences in the text of the standards. The list can also be used to conduct a gap analysis, i.e., to check what information we have in the company or can easily obtain, and what information and data we are missing and need to address in the coming months. When preparing the report itself, the information from the file can be used as a checklist to verify that we have included all the required data in the report. Auditors verifying the completeness of reports can also use the file in a similar way.
It is very good that EFRAG has done work that will be useful to thousands of companies across Europe. Creating such a list on your own is extremely labor-intensive. I know this because we did a similar breakdown of standards at MATERIALITY a few months ago when we developed a tool for monitoring ESG data for reporting purposes. In total, there are nearly 1,100 data points in the standards, of which less than a quarter are voluntary, over 15% are mandatory data points (i.e., regardless of the results of the materiality assessment), and all the rest are mandatory if they relate to an issue that is material to the reporting company.
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