Two days after the publication of the regulation introducing ESRS standards (July 31), the Commission made all language versions available (August 2). We did not actively communicate this information because, unfortunately, the Polish translation contains a large number of errors. Many names and terms are translated using words that are not commonly used in Polish in connection with sustainable development. For example governance has been translated as device, while it is, after all, corporate governance or governance. The text contains such „gems” as description of non-employees belonging to the group of employees – I can already imagine the look of surprise on the faces of the HR department managers when we ask them to provide relevant information on this subject.
Before the regulation introducing ESRSs is published in the Official Journal of the EU, there will still be time to make amendments to the Polish language version. Work in this area is being carried out by, among others, the Polish Association of Listed Companies, with MATERIALITY experts actively participating. However, I would recommend that until the amendments are made, the Polish version of the ESRS should not be used, and if anyone intends to read it, they should do so with the English version open in parallel and compare the two on an ongoing basis. After all, the English version is the original and will help to resolve any doubts regarding the sometimes surprising provisions in the Polish text.
If you have not yet studied the standards at the draft stage, I suggest the following reading order (remember that the complete set of standards can be found on the MATERIALITY website. First, it is worth reviewing one of the shorter standards, e.g., ESRS E2. Pollution or ESRS E3 Water and marine resources. I emphasize that this is about skimming, not thorough reading. Next, you should carefully and thoroughly read ESRS 1. General requirements. This is a user manual for the entire reporting system. Although this standard does not contain any disclosure requirements, i.e., it does not define what specifically needs to be disclosed in the report, it does contain a set of rules according to which we must collect, organize, and disclose information. A prior review of one of the simple thematic standards should make many of the terms used in ESRS 1 more understandable, i.e., we will immediately know in which situations they should be applied.
The next item on your reading list should be ESRS 2. General disclosure of information. It is mandatory in its entirety for all companies. ESRS 2 specifies, among other things, what needs to be disclosed in relation to the company's materiality assessment, i.e., what we need to report about the assessment process itself and how we should present its results. This standard also includes templates for generic disclosures regarding policies, activities and resources, measures, and targets. They should be referred to practically whenever any of the thematic standards require disclosure of these issues, e.g., policies relating to a particular sustainability issue or targets set in this area.
Finally, I would leave studying the thematic standards. There are ten of them, and you can read them in any order. It is worth reading carefully the simple standard that we chose to review at the beginning – you will see how many of its elements suddenly become more understandable. And then, according to your needs, preferences, or interests. Some of the standards are simpler, some contain similar content (e.g., ESRS S2, S3, S4), and some are extremely long and difficult to understand (ESRS E1, E4, S1).
A single reading of the entire set of standards is not enough to familiarize yourself with them. All professionals involved in sustainability reporting will certainly refer to them repeatedly, reread certain sections, and study them in the context of other standards, especially ESRS 1 and 2. When reading these documents, it will also be helpful to refer to the second annex to the delegated regulation, as it contains a list of all definitions and abbreviations used in the standards.
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