Sustainability reporting: EFRAG publishes first implementation guidance

As part of its function as an advisory body and developer of the European Sustainability Reporting Standards (ESRS), the European Financial Reporting Advisory Group (EFRAG) was officially commissioned by the European Commission to prepare implementation guidance (IG) for the first set of ESRS. In order to provide users of the ESRS with targeted and timely support in the preparation of CSRD-compliant sustainability reports, the development of such implementation guidance was given high priority in EFRAG's work program. 

The three implementation guidance documents now published deal with conducting the materiality assessment (IG 1), considering the value chain in the materiality assessment and reporting (IG 2), and listing all data points that can be derived from the ESRS (IG 3). 

Various draft versions of the three implementation guidance documents have been in circulation since the second half of 2023, and a public consultation was held from December 22, 2023 to February 2, 2024. The feedback collected from companies, associations, NGOs and other stakeholders was evaluated following the consultation phase and used as a basis for revising the final versions of the implementation guidance documents that have now been published. It should be noted that these are explicitly non-binding guidelines – in contrast to the ESRS, which were adopted in the form of a mandatory delegated act.

​In detail, the implementation guidance documents include the following content: 

IG 1 on materiality assessment comprises a total of 55 pages and deals with the process of conducting an ESRS-compliant materiality assessment in accordance with the principle of double materiality. The guideline first summarizes the specific ESRS requirements for the materiality assessment and then leads step by step through the process of preparing the materiality assessment in the form of recommendations, application notes and examples. The document also contains a total of 25 FAQs, including on the involvement of stakeholders, reporting on the results of the materiality assessment and definitions of terms.

The 48-page IG 2 on considering the value chain in the materiality assessment and subsequent reporting first defines the term and classifies the relevance of value chain activities in the context of sustainability. Based on this, it explains how reporting boundaries are to be drawn, the extent to which impacts, risks and opportunities in the value chain must be recorded and how the value chain is included in the formulation of policies, actions and targets. IG 2 also contains 10 FAQs on the topic of the value chain as well as a mapping that summarizes the implications of the value chain for each disclosure requirement across all ESRS. 

Unlike the first two implementation guidance documents, IG 3 is not a pure text document, but a comprehensive Excel file. This contains a complete list of the data points that can be derived from the first set of ESRS. In addition to the pure description of the data points, further information is integrated, e.g., the required data type (narrative/semi-narrative/numeric), whether there are transitional provisions for the data point or the binding nature of the data point (binding/voluntary). In addition to the Excel file, an explanatory note​ is provided, which contains descriptive statistics on the number and composition of the data points, among other things. 

In addition to the first three implementation guidance documents, further guidelines are to follow in order to support companies as comprehensively as possible in the preparation of the sustainability report. A fourth implementation guidance (IG 4) on the topic of “Preparation of transition plans” has already been under development for some time. Which topics are dealt with in the form of implementation guidance is largely decided on the basis of input on EFRAG's official ESRS Q&A platform.​​ The platform thus offers ESRS users the opportunity to directly signal their need for support to EFRAG by addressing specific questions.