The Directive and European standards for sustainability reporting

August 2, 2023
• Updated: January 8, 2024
Piotr Biernacki
Sustainability Managing Partner
Soon, all large and some small and medium-sized enterprises will report on sustainability issues in accordance with the CSRD directive. It will be accompanied by a uniform system of European reporting standards (ESRS). Below, we publish a complete set of information that allows everyone to follow the development of the standards.

The European Parliament and the Council adopted the CSRD Directive in the fall of 2022. The directive (its full name is Directive (EU) 2022/2464 of the European Parliament and of the Council of December 14, 2022, amending Regulation (EU) No. 537/2014, Directive 2004/109/EC, Directive 2006/43/EC, and Directive 2013/34/EU as regards corporate sustainability reporting) was published in the Official Journal of the EU and entered into force after twenty days.

Text of the CSRD Directive EN

Text of the CSRD Directive EN

Under the directive, all large companies (whether publicly traded or privately held) will be required to prepare sustainability reports. The reports will be audited and will form an integral part of each company's annual report. Small and medium-sized companies listed on a regulated market will also be subject to these obligations.

The reports will be prepared in accordance with the European Sustainability Reporting Standards (ESRS). The first of these standards have already been issued by the European Commission in the form of delegated acts. The draft standards are being prepared for the Commission by EFRAG (European Financial Reporting Advisory Group). The draft is being developed by a special working group set up by EFRAG (PTF-ESRS, Project Task Force on European Sustainability Reporting Standards), which included Piotr Biernacki, ESG Reporting Partner at MATERIALITY. He served as co-lead of the sub-group that developed the draft cross-cutting standards and sets of guidelines. Since April 2022, Piotr Biernacki has been a member of the Sustainability Reporting Technical Expert Group (SR TEG), a permanent group that prepares draft standards within EFRAG.

On July 31, 2023, the European Commission issued a delegated regulation introducing the first set of ESRS standards. This regulation (Commission Delegated Regulation (EU) 2023/2772) was published in the Official Journal of the EU on December 22, 2023. Below we present the content of the regulation, its annexes, and the accompanying Q&A document.

NOTE: We believe that the Polish language version contains many errors and imprecise wording. Representatives of the European Commission have announced that a correction to the Polish language version of the regulation is expected in mid-2024. Until then, we recommend using the English version whenever possible.

EC Delegated Regulation implementing the first set of ESRS – EN

EC Delegated Regulation implementing the first set of ESRS – EN

Q&A document on the first set of standards

Delegated Regulation 2023/2772 entered into force and has been applicable since January 1, 2024.

Before issuing the delegated regulation, on June 9, 2023, the European Commission presented its draft for public consultation, which is scheduled to end on July 7, 2023. On the European Commission's website you can read the 604 responses provided during the public consultation process, including response provided by MATERIALITY.

Below we present the draft delegated regulation and its annexes containing individual standards, which were subject to public consultation between June 9 and July 7, 2023. For ease of use, we have processed the files so that they contain separate standards. The original files published by the European Commission can be found at the address where the consultations are being conducted.

Draft delegated regulation

Draft Annex I to the Regulation, containing a set of 12 standards

Draft Annex II to the Regulation, containing a set of abbreviations and definitions

Files with drafts of individual standards:
ESRS 1 General Requirements Project

ESRS 2 General Disclosures Project

ESRS E1 Climate Change Project

ESRS E2 Pollution Project

ESRS E3 Water and Marine Resources Project

ESRS E4 Biodiversity and Ecosystems Project

ESRS E5 Resource Use and Circular Economy Project

ESRS S1 Own Workforce Project

ESRS S2 Project: Workers in the Value Chain

ESRS S3 Affected Communities Project

ESRS S4 Consumers and End-Users Project

ESRS G1 Business Conduct Project

Architecture of the European system of sustainability reporting standards:

Draft standards as adopted by the EFRAG Sustainability Reporting Board on November 15, 2022.

Cover note to draft standards adopted by the EFRAG Sustainability Reporting Board on November 15, 2022:

Guiding note 

ESRS 1 General Requirements [draft standard]

ESRS 2 General Disclosures [draft standard]

Topical standards: Environment

ESRS E1 Climate change [draft standard]

ESRS E2 Pollution [draft standard]

ESRS E3 Water and marine resources [draft standard]

ESRS E4 Biodiversity and ecosystems [draft standard]

ESRS E5 Resource use and circular economy [draft standard]

Topical standards: Social

ESRS S1 Own workforce [draft standard]

ESRS S2 Workers in the value chain [draft standard]

ESRS S3 Affected communities [draft standard]

ESRS S4 Consumers and end-users [draft standard]

Topical standards: Governance

ESRS G1 Business Conduct [draft standard]

Draft standards in the version published during the work of the PTF ESRS from January to April 2022.

Guidance note for draft standards.

Cover note for Batch 1 WPS

Cross-cutting standards:

ESRS 1 General provisions: cover note working paper

ESRS 2 Strategy and business model

ESRS 3 Sustainability governance and organization

ESRS 4 Sustainability material impacts, risks, and opportunities

ESRS 5 Definitions for policies, targets, action plans, and resources

Topical standards: Environment

ESRS E1 Climate change

ESRS E2 Pollution

ESRS E3 Water and marine resources

ESRS E4 Biodiversity and ecosystems

ESRS E5 Circular economy

Topical standards: Social

ESRS S1 Own workforce – general

ESRS S2 Own workforce – working conditions

ESRS S3 Own workforce – equal opportunities

ESRS S4 Own workforce – other work-related rights

ESRS S5 Workers in the value chain

ESRS S6 Affected communities

ESRS S7 Consumers and end-users

Topical standards: Governance

ESRS G1 Governance, risk management, and internal control

ESRS G2 Products and services management and quality of relationships with business partners

ESRS G3 Business conduct

Sector-specific standards

ESRS SEC1 Sector classification standard

Presentation

ESRS P1 Sustainability statements

Conceptual guidelines
Note: Conceptual guidelines are not part of the standards and will not be issued by the European Commission in the form of delegated acts. They provide guidance to the standard-setting body, but may also be useful to all other recipients for obtaining a non-binding interpretation of the standards.
ESRG 1 Double materiality

ESRG 2 Characteristics of information quality

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