ESRS and implementation guidelines

On December 22, 2023, Commission Delegated Regulation 2023/2772 introducing the first set of ESRS standards was published in the Official Journal of the EU. The text of the regulation in English and Polish can be found at MATERIALITY and in the system Eur-Lex.

The Official Journal published exactly the same version of the standards that was issued by the Commission on July 31, 2023. This means, unfortunately, that the Polish version is of very poor quality. Commission representatives have informally announced that it should be corrected by mid-2024. However, such a delay, combined with the exceptionally high number of errors, causes great difficulties for companies that are already preparing to report under the ESRS this year. I encourage you to use the English version, or at least to back it up if you run into some incomprehensible cluster of words in the Polish version.

EFRAG, in turn, has published three drafts of its implementation guidelines, known as implementation guidance:
- IG 1 Materiality Assessment Implementation Guidance: guidelines for materiality testing
- IG 2: Value Chain Implementation Guidance: value chain guidelines
- IG 3: Detailed ESRS Datapoints Implementation Guidance: a guideline listing all datapoints (excel file and explanatory note)

Implementation guidelines are documents issued by EFRAG that explain how the ESRS reporting standards system works. They do not have the character of laws, and their application is not mandatory. However, they are worth reading, as in many cases they make it easier to understand what is written in the standards themselves.

The draft guidelines have now been put out for public consultation, which will last until February 2. It is worth taking part in them. First of all, it is worth reporting what type of support through these documents we expect. Should there be more examples in them? Should they contain more detailed questions and answers to them? Or should they have some other function?

I always encourage participation in public consultations on draft documents emerging in the European Union. The more voices in these consultations come directly from companies and experts concerned with sustainable development, the better and more tailored documents will be issued in Brussels. You don't have to fill out the entire consultation form - just write about what you care about in the appropriate section of it.