European Sustainability Reporting Standards (ESRS) – List of phase-in Disclosure Requirements

CSRD, ESRS | 5. October 2023
Phillip Blumenthal
Head of Sustainability

Appendix C of ESRS1 outlines a series of phase-in provisions which allow companies to delay complete disclosure of certain information, even if material. The phase-in provisions are specified by topic and by individual disclosure requirement. Furthermore, the phase-in provisions are partly dependent on the size or nature of the reporting company. Appendix C is buried within the ESRS, so the entire Appendix has been reproduced here in stand-alone form for easier reference. This content is derived directly from Brussels, 31.7.2023, C (2023) 5303 final, ANNEX 1.

Appendix C: List of phased-in Disclosure Requirements

This appendix is an integral part of ESRS 1 and has the same authority as the other parts of the Standard.

ESRSDisclosure RequirementFull name of the Disclosure RequirementPhase-in or effective date (including the first year)
ESRS 2SBM-1Strategy, business model and value chainThe undertaking shall report the information prescribed by ESRS 2 SBM-1 paragraph 40(b) (breakdown of total revenue by significant ESRS sector) and 40(c) (list of additional significant ESRS sectors) starting from the application date specified in a Commission Delegated Act to be adopted pursuant to article 29b(1) third subparagraph, point (ii), of Directive 2013/34/EU.
ESRS 2 SBM-3Material impacts, risks and opportunities and their interaction with strategy and business modelThe undertaking may omit the information prescribed by ESRS 2 SBM-3 paragraph 48(e) (anticipated financial effects) for the first year of preparation of its sustainability statement. The undertaking may comply with ESRS 2 SBM-3 paragraph 48(e) by reporting only qualitative disclosures for the first 3 years of preparation of its sustainability statement, if it is impracticable to preparequantitative disclosures.
ESRS E1E1-6Gross Scopes 1, 2, 3 and Total GHG emissionsUndertakings or groups not exceeding on their balance sheet dates the average number of 750 employees during the financial year (on a consolidated basis where applicable) may omit the datapoints on scope 3 emissions and total GHG emissions for the first year of preparation of their sustainability statement.
ESRS E1E1-9Anticipated financial effects from material physical and transition risks and potential climate-related opportunitiesThe undertaking may omit the information prescribed by ESRS E1- 9 for the first year of preparation of its sustainability statement. The undertaking may comply with ESRS E1-9 by reporting only qualitative disclosures for the first 3 years of preparation of its sustainability statement, if it is impracticable to prepare quantitative disclosures.
ESRS E2E2-6Anticipated financial effects from pollution-related impacts, risks and opportunitiesThe undertaking may omit the information prescribed by ESRS E2- 6 for the first year of preparation of its sustainability statement. Except for the information prescribed by paragraph 40 (b) on the operating and capital expenditures occurred in the reporting period in conjunction with major incidents and deposits, the undertaking may comply with ESRS E2-6 by reporting only qualitative disclosures, for the first 3 years of preparation of its sustainability statement
ESRS E3E3-5Anticipated financial effects from water and marine resources-related impacts, risks and opportunitiesThe undertaking may omit the information prescribed by ESRS E3-5 for the first year of preparation ofits sustainability statement. The undertaking may comply with ESRSE3-5 by reporting only qualitative disclosures, for the first 3 years of preparation of its sustainability statement.
ESRS 4All disclosure requirementsAll disclosure requirementsUndertakings or groups not exceeding on their balance sheet dates the average number of 750 employees during the financial year (on a consolidated basis where applicable) may omit the information specified in the disclosure requirements of ESRS E4for the first 2 years of preparation of their sustainability statement.
ESRS E4E4-6Anticipated financial effects from biodiversity and ecosystem-related impacts, risks and opportunitiesThe undertaking may omit the information prescribed by ESRS E4-6 for the first year of preparation ofits sustainability statement.The undertaking may comply with ESRS E4- 6 by reporting only qualitative disclosures, for the first 3 years of preparation of its sustainability statement
ESRS E5E5-6Anticipated financial effects from resourceuse and circular economy-related impacts, risks and opportunitiesThe undertaking may omit the information prescribed by ESRS E5-6 for the first year of preparation ofits sustainability statement.The undertaking may comply with ESRS E5- 6 by reporting only qualitative disclosures, for the first 3 years of preparation of its sustainability statement
ESRS S1All disclosure requirementsAll disclosure requirementsUndertakings or groups not exceeding on their balance sheet dates, the average number of 750 employees during the financial year (on a consolidated basis where applicable) may omit the information specified in the disclosure requirements of ESRS S1for the first year of preparation of their sustainability statement.
ESRS S1S1-7Characteristics of non-employee workers in the undertaking’s own workforceThe undertaking may omit reporting for all data points in this Disclosure Requirement for the firstyear of preparation of its sustainability statement.
ESRS S1S1-8Collective bargaining coverage and social dialogueThe undertaking may omit this Disclosure Requirement with regardto its own employees in non-EEA countries for the first year of preparation of its sustainability statement.
ESRS S1S1-11Social protectionThe undertaking may omit the information prescribed by ESRS S1-11 for the first year of preparation of its sustainability statement.
ESRS S1S1-12Percentage of employees with disabilitiesThe undertaking may omit the information prescribed by ESRS S1-12 for the first year of preparation of its sustainability statement.
ESRS S1S1-13Training and skills developmentThe undertaking may omit the information prescribed by ESRS S1-13 for the first year of preparation of its sustainability statement.
ESRS S1S1-14Health and SafetyThe undertaking may omit the datapoints on cases of work-related ill-health and on number of days lost to injuries, accidents, fatalities and work-related ill health for the first year of preparation of its sustainability statement.
ESRS S1S1-14Health and SafetyThe undertaking may omit reporting on non-employees for thefirst year of preparation of its sustainability statement
ESRS S1S1-15Work-life balanceThe undertaking may omit the information prescribed by ESRS S1-15 for the first year of preparation of its sustainability statement.
ESRS S2All disclosure requirementsAll disclosure requirementsUndertakings or groups not exceeding on their balance sheet dates the average number of 750 employees during the financial year (on a consolidated basis where applicable) may omit the information specified in the disclosure requirements of ESRS S2for the first 2 years of preparation of their sustainability statement.
ESRS S3All disclosure requirementsAll disclosure requirementsUndertakings or groups not exceeding on their balance sheet dates the averagenumber of 750 employees during thefinancial year (on a consolidated basiswhere applicable) may omit theinformation specified in the disclosurerequirements of ESRS S3 for the first 2years of preparation of theirsustainability statement.
ESRS S4All disclosure requirementsAll disclosure requirementsUndertakings or groups not exceeding ontheir balance sheet dates the averagenumber of 750 employees during thefinancial year (on a consolidated basiswhere applicable) may omit theinformation specified in thedisclosure requirements of ESRS S4 for the first 2 years of preparationof their sustainability statement.

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