Implementation guidelines for ESRS standards

June 3, 2024
Piotr Biernacki
Sustainability Managing Partner
Late in the evening of May 31, 2024, EFRAG published three sets of implementation guidance on materiality testing, value chains, and data points. What is the purpose of these documents? Do they further complicate the reporting system, or will they make the work of preparers easier?

EFRAG IG1 Materiality Assessment Implementation Guidance (MAIG) concerns testing and assessing materiality. The document summarizes the principles of double materiality contained in the ESRS standards, presents the general process of testing materiality, discusses the role of stakeholders in testing, and sets thresholds. It also indicates sources external to the ESRS standards (such as other standards and recommendations) that can be used in testing. The second part of the document contains 25 frequently asked questions and answers. I encouraged everyone to read the MAIG draft, because even then it was a useful source of knowledge. Today, it is even more worthwhile to use these guidelines whenever we assess what should be reported in our company and identify significant impacts, risks, and opportunities.

EFRAG IG2 Value Chain Implementation Guidance (VCIG) concerns the value chain in reporting in accordance with ESRS standards. The document explains what a company's value chain is, what role its own operations play in it, what is referred to as upstream and what is referred to as downstream, also pointing to the specific situation of certain entities (associated entities and joint ventures). The guidelines provide detailed explanations of the extent to which information on policies, activities, and objectives should cover more than just own operations, and in which cases data from the value chain must be used when reporting specific metrics. Further on in the guidelines, you will find 11 frequently asked questions with answers, as well as a very useful map of disclosure requirements from the ESRS standards that require information and data to be obtained from the value chain. Reading this map may finally reassure reporting companies, which have been frightened over the past year by various advisors that „now, under ESRS, it will be necessary to collect a huge amount of data from all entities throughout the value chain.” No, you don't, and I have always reminded you of that 😊. In the first few years, obtaining numerical data from the value chain boils down exclusively to reporting GHG emissions in scope 3.

EFRAG IG3 List of ESRS datapoints is simply a detailed list of all data points in all disclosure requirements in ESRS standards. These guidelines consist of two documents: Excel file i notes with explanations. There is nothing new to learn from the IG3 guidelines, but the document is an excellent resource for ensuring that our report contains all the data and information that should be included. The guidelines are also useful when creating a system for collecting and consolidating data in our company or capital group. Even before the IG3 project was created at MATERIALITY, we developed similar material in the summer of 2023, which formed the basis for the data monitoring system we use for reporting purposes. Comparing it with the final version of the list of data points published by EFRAG, we can see that we have not overlooked anything 😊.

The guidelines are published by EFRAG in English. They do not constitute legal provisions – only the standards issued by the European Commission in the form of a Delegated Regulation are binding. The guidelines are primarily intended to assist companies preparing reports, facilitating their understanding and application of the standards. We can also expect that auditors auditing reports will also use these documents.

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