Decoding ESRS Data Points: A Practical Guide for Sustainability Practitioners

At the heart of the European Sustainability Reporting Standards (ESRS) framework lies a comprehensive and detailed set of data points. The ESRS data points serve as the building blocks for providing a structured and comparable format for disclosures. These data points are outlined in the ESRS Data Points List ("EFRAG Implementation Guidance 3 List of ESRS Data Points") and Explanatory Note published by the European Financial Reporting Advisory Group (EFRAG).

With the introduction of the Corporate Sustainability Reporting Directive (CSRD), sustainability reporting becomes more standardized and regulated for companies in the EU. The initial batch of companies falling under the CSRD start reporting under ESRS for the financial year 2024, the subsequent batch will follow 2025.

Understanding the datapoint list is therefore essential for companies to ensure accurate and complete sustainability reporting, steering clear of penalties and reputational risks associated with non-compliance.

In this blog article, we equip sustainability practitioners with the insights needed to navigate the datapoint labyrinth effectively.

👉 Please note that the ESRS Data Points List published by EFRAG is non-authoritative (see Disclaimer in this Explanatory Note) and only accompanies the ESRS delegated act.

Navigating the ESRS Data Points List

As sustainability reporting becomes a focal point for stakeholders and regulatory bodies, the ESRS data points provide the necessary depth and granularity to go beyond generic statements, offering stakeholders a nuanced understanding of a company's environmental, social, and governance (ESG) practices.

The extensive nature of the ESRS framework is reflected in the tabular ESRS Data Points List, including more than 1.000 rows of data points.

The list offers a structural framework for organizing data requirements to ensure ESRS compliance and facilitate a standardized approach.

Each row in the list represents a separable quantitative and qualitative datapoint, and in this way breaks down the disclosures at a granular level. The table shows the related requirements and linkages of each individual data point.

Gaining a clear understanding of the list of separable data points is crucial to fully grasp the systematic organization of the narrative contents related to the specific “Disclosure Requirement” (DR) or “Application Requirements” (AR).

If you already report your ESG data, this list serves as a foundation for conducting a gap analysis of the existing sustainability information in your company.

Structure of the ESRS Data Points List

The ESRS Data Points List is presented in Excel format with detailed requirements and references described by the different columns in the table.

It encompasses all standards from ESRS 2 and the Topical ESG standards, excluding ESRS 1 General Requirements, which doesn't stipulate specific disclosures. Within this structure, the data points are organized to streamline reporting practices.

💡 ESRS E1 (Climate Change) and ESRS S1 (Own Workforce) have the most individual data points, each with around 200 data points (including MDRs) in the workbook.

The Minimum Disclosure Requirements (MDR) are centrally compiled in a separate sheet within the workbook called "ESRS 2 MDR", distinguished by a green background color. Each topical standard that needs to apply the MDRs has an exclusive line item, linking the referring requirements to the topical standard.

The columns in the Excel workbook provide valuable information for you to navigate and filter content, including corresponding paragraphs and subparagraphs for each item.

The columns in the data points list are organized as follows:

• ID (Column A): Presenting the unique identifier (ID) for each data point (DP), referring to the corresponding disclosure requirement (DR)
• ESRS (Column B): Referring to the relevant standard within the ESRS such as ESRS 2 or ESRS S1
• DR (Column C): Referring to the related disclosure requirement (DR) such as E1-1 or E1.GOV-3
• Paragraph (Column D): Referring to the related paragraph under each DR or AR such as 16a, 16b, 16c, and so forth
• Related AR (Column E): Referring to the corresponding application requirement (AR) for each paragraph such as AR1 or AR2 (Please note that not all data points have specific ARs and some ARs concern the entire DR)
• Name (Column F): Briefly describing the detailed requirement such as “Disclosure of transition plan for climate change mitigation” or “Achieved GHG emission reductions”, with a link to the corresponding paragraph within an online version of the ESRS legal text (see also column D)
• Data type (Column G): Classifying data types into qualitative and quantitative data, including narrative, semi-narrative, and numerical elements
• Conditional or alternative DP (H): Identifying the conditional and alternative data points (i.e., “if applicable”, "where relevant" in the ESRS legal text)‍
• May [V] (Column I): Identifying the voluntary data points (i.e., “may disclose” in the ESRS legal text), which are additionally highlighted in orange within the ESRS Data Point List‍
• Appendix B - ESRS 2 (Column J): Referring to the data points that can be referenced to EU Regulation such as SFDR (Sustainable Finance Disclosure Regulation), Pillar 3, Benchmark or CL (Climate Law) as described in Appendix B of ESRS 2‍
• Appendix C - ESRS 1 (Column K):  Referring to data points that are subject to phasing-in provisions applicable to companies with less than 750 employees  as described to Appendix C of ESRS 1 ‍
• Appendix C - ESRS 1 (Column L): Referring to data points that are subject to phasing-in provisions applicable to all companies as described to Appendix C of ESRS 1‍

A Closer Look at Data Types

The nature of ESRS data points goes beyond numbers; it involves a nuanced comprehension of different data types and a large number of data points are qualitative, referring to a narrative or semi-narrative format.

The data points encompass a spectrum of information, ranging from narrative descriptions to monetary figures, percentages, volumes, and more. Each data type serves a distinct purpose in conveying specific aspects of an organization's sustainability story.

Data Types:

• Narrative: Descriptive text elements that provide context and qualitative insights; Example: Disclosure of decarbonisation levers and key action‍
• Semi-Narrative: Descriptive elements that can be single text blocks, binary choice (yes/no) or dropdown selections; Example: Removals and carbon credits are used [yes/no]
• Numerical: Quantitative elements, for example monetary, percent or volume

Exemplary Numerical Data Types:

• Monetary: Quantifying financial implications of sustainability initiatives; Example from the data point list: "Net revenue used to calculate GHG intensity"‍
• Percent: Expressing proportions and ratios related to sustainability indicators; Example from the data point list: "Percentage of renewable sources in total energy consumption"‍
• Volume: Quantifying tangible quantities relevant to sustainability practices; Example of the data point list: "Total water recycled and reused"
• Energy: Quantifying the unit of energy; Example of the data point list: "Total energy consumption related to own operations"

Please see column G in the Excel worksheet or the explanatory note by EFRAG for the entire list of data types. As you delve into this list, the data points of different types become a compass for your effective reporting.

As such, the provided data points not only ensure accuracy in the representation of data but also add layers of depth to the narrative, making sustainability reporting a more transparent and more insightful practice.

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Mandatory and Voluntary ESRS Data Points

The ESRS list encompasses both mandatory and voluntary data points for sustainability reporting. The data points marked as "voluntary" are those for which the legal text uses "may" instead of "shall". These voluntary data points are optional reporting elements that companies may choose to disclose. The overview in the list makes it easier to recognize the voluntary disclosures.

The data points list encompasses the entire spectrum of potential data points under sector-agnostic ESRS, regardless of the outcome of a materiality assessment that each company needs to conduct as a first step.

👉 Please consider that each company needs to conduct a materiality assessment to identify the relevant data points for the preparation of its sustainability statement.

Relation to Digital Reporting (ESRS XBRL Taxonomy)

EFRAG is tasked with developing an ESRS XBRL Taxonomy, enabling businesses to tag sustainability data in a structured, machine-readable format. This facilitates analysis and eliminates manual errors during information transformation.

This taxonomy is based on Extensible Market Language (XML), which is a means of modeling business information in a format that a computer can understand. It is currently mostly used for financial reporting.

The ESRS XBRL Taxonomy will contain sustainability statement elements, including formal definitions, descriptions and references to reporting terms that are used by different authorities, regions and industries.

Separating the single disclosure items in the narrative text, the ESRS Data Points List is a step that helps streamline digital tagging and reduce overlaps. However, it does not represent the digital ESRS XBRL Taxonomy, as the XBRL structure differs due to technical aspects.

Nevertheless, the data point list supports the preparation of ESRS sustainability statements that are readable by humans, for example your stakeholders.

Therefore, companies are encouraged to work with the list and leverage it for structuring their narrative disclosures efficiently.

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Practical Insights Into ESRS Implementation with Software

Beyond the regulatory realm, the data point list can serve as a strategic tool for your ongoing sustainability management.

Leverage the ESRS data points to gain valuable insights into your company's sustainability practices, identify areas for improvement, and make informed decisions that align with the broader ESG objectives you might have.

Utilizing software to systematically manage all data points, encompassing all related disclosure and application requirements, and address them one by one can substantially reduce your workload and streamline your reporting process.

5 Tips how Software Helps you Manage ESRS Data Points

1. Use the ESRS data points list for your initial gap analysis to get prepared for the CSRD reporting requirements – Our software identifies gaps by automatically matching existing data from other reporting formats or assessments with the ESRS data points.
2. Don't double your workload when ESRS data points overlap with other reporting requirements such as the EU Taxonomy or GRI, but use them to accelerate your sustainability reporting – Sunhat enables you to leverage synergies between requirements by mapping central information.
3. Involve your team, other departments of your company, or your suppliers by providing them with easy access to input data into Sunhat – Assign tasks and comment on single data points to facilitate a seamless handling process.
4. Manage all data points of different data types in one central database layer to keep on overview and track progress – Sunhat’s response database stores all sorts of narrative or numerical data points with the necessary context and evidence and helps you gain powerful insights.
5. Stay ahead of evolving regulatory landscapes without having to decipher each officially published document – Our Sunhat experts keep the guides and templates in the software up-to-date for you.

Sunhat’s software enhances accuracy and transparency but also provides you with a structured and easy-to-use workspace for collecting and updating the required data points.

With the comprehensive features of Sunhat’s CSRD Module, you can efficiently navigate the extensive list of ESRS data points, ensuring a more precise and effective approach to compliance.

👉 If you’re interested in using our software solution, request a demo or contact us.