Understanding and applying ESRS 1 and 2: the key to effective sustainability reporting

ESRS 1 and 2: Cross-reporting standards

The European Sustainability Reporting Standards (ESRS) 1 and 2 are part of the first ESRS set, which was adopted by the European Commission in July 2023. The first set consists of a total of twelve ESRS, whereby ESRS 1 and 2 are cross-cutting standards and contain general requirements and disclosures. The other ten ESRS are topical standards that deal with individual aspects of sustainability.
In the first set of European Sustainability Reporting Standards (ESRS), ESRS 1 and 2 form the fundamental basis. These two standards are cross-divisional and set out the general principles and requirements for sustainability reporting. They are supplemented by ten topical standards that deal with specific aspects of sustainability such as the environment, social and governance issues. ESRS 1 and 2 are therefore key to understanding and structuring sustainability reporting according to these standards.

ESRS 1: General requirements

ESRS 1, a key component of the European Sustainability Reporting Standards, defines the general requirements for sustainability reporting by companies. The aim of ESRS 1 is to give companies an understanding of the basic concepts and structure of the ESRS. It also explains the requirements for completing the CSRD report.
ESRS 1 specifies what information must be included in a sustainability report to provide a comprehensive picture of a company’s impacts, risks and opportunities in relation to environmental, social and corporate governance aspects. Companies must provide information on their governance structure, strategy and business model, how they manage risks and opportunities and their objectives and performance in relation to sustainability. The standard also emphasises the principle of double materiality, which is crucial for assessing whether sustainability topics are reportable. ESRS 1 addresses the following topics in detail:

• Reporting areas
• Qualitative characteristics of information
• The concept of double materiality
• Due diligence obligations
• Value chain
• Time guidelines
• Approach to identifying and preparing sustainability information
• Structure of the CSRD report
• Relationship to other parts of corporate reporting
• Transitional arrangements

ESRS 2: General disclosures

ESRS 2 addresses disclosure requirements for companies. Like ESRS 1, this standard is also sector-independent and therefore applies to all companies regardless of industry. ESRS 2 consists of four reporting areas:

• Impacts, risks and opportunities (IRO): Describes the process by which impacts, risks and opportunities are recorded and assessed, as well as strategies and measures to manage them.
• Governance (GOV): Describes the role of IRO monitoring and control procedures by the organisation’s management.
• Strategy (SBM): Refers to how the organisation’s business model is linked to and influenced by the IRO.
• Metrics and targets (MT): Describes how targets and metrics are to be measured.

ESRS 2 is relevant for all companies, regardless of their size, sector or the particular relevance of their activities to sustainability. It serves as a guideline so that sustainability information can be thoroughly presented in the CSRD report.

Who has to report according to ESRS 1 and 2?

The reporting obligations were simplified by the European Commission with the adoption of the first set of ESRS in order to keep reporting proportionate. As a result, only ESRS 2 from the first set is now mandatory for all companies. For ESRS 1 and the other topical standards, materiality determines whether a topic is reportable or not. ESRS 1 explains how materiality is to be assessed.

Understanding the basic requirements of ESRS

The ESRS standards are a complex framework with requirements that companies must take into account in their reporting. When you start the reporting process, you should therefore first take a close look at the requirements of ESRS 1 and 2 as well as the topical standards. There are supplementary materials for the standards, which describe the requirements in more detail to provide more support. At the beginning, it helps to get an overview of the structure of the standards in order to understand how the requirements are connected, as they are all similarly structured. Additionally, the framework offers the flexibility to reference other reports or pieces of information within your document. To ensure that the reporting process is as efficient as possible, such options should be taken into account from the outset.

Therefore, first try to understand the underlying paradigms of the ESRS and internalise the principles as listed in ESRS 1 Appendix B. This forms the basis for further reporting processes. It is also important to familiarise yourself with the options and transitional provisions and to take these into account in the structure of the reporting process.

This approach ensures regulatory compliance. For companies that are required to comply with the ESRS, fulfilling these obligations is crucial to avoid regulatory penalties and to assure legal compliance. In addition, reporting in accordance with the ESRS standards enables a transparent and comparable presentation of a company’s sustainability performance. This strengthens trust among key stakeholders such as investors, customers, employees and the general public, which is essential for the company’s credibility.

Another important aspect is risk management. The ESRS help companies to identify, manage and report on sustainability risks. Many of these risks can have financial and operational implications, therefore it is essential to manage these risks effectively.

It is therefore a good idea to take a close look at the reporting requirements of ESRS 1 and 2, both to fulfil the compliance requirements and to derive maximum added value for your company from the reporting process.