IG 3 Datapoint List (May 2024 incl. Addendum) Amendments (July 2025)
Table of Contents
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Executive Summary
This file provides users with a quick and transparent overview of the effects of the recent ESRS revision on individual datapoints. Please note that this file is provided for informational purposes only.
This file is based on Implementation Guidance (IG) 3 List of Datapoints (released May 2024, plus the addendum of December 2024). We extended the original file by a column explaining how each datapoint is affected by the amendments proposed by EFRAG in July 2025 ("Change…" in Column I). We compiled this information based on the 2025 Exposure Drafts, Logs of Amendments, Basis for Conclusion and the ESRS Exposure Draft July 2025 Non-Mandatory Illustrative-Guidance (NMIG).
We categorize changes into different types (e.g., deleted, moved, or amended datapoints) to the best of our knowledge. Doing so, we consider the categorization in the Logs of Amendments as well as the other information sources listed above. While we took care in assigning these categories, we note that there may be different views on the categorization of individual changes. For some changes, our analyses did not yield an unambiguous categorization. We flagged these cases as of uncertain impact (cf. “Comment” in Column J).
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Executive Summary
This table shows an overview of the old IG 3 (2024) datapoints by standard and the remaining shall datapoints after the amendments, based on EFRAG's Basis for Conclusions document and our, granular analysis (see next table).
Status Total ESRS 2 E1 E2 E3 E4 E5 S1 S2 S3 S4 G1
total shall old (IG 3, 2024) 803 134 197 44 27 54 42 127 47 45 44 42
total shall after reduction – EFRAG (ED, 2025) 347 68 92 17 8 12 17 60 19 17 16 21
total shall after reduction – SRN 393 69 112 19 8 13 21 70 23 17 20 21
Our analyses are based on a categorization of each IG 3 datapoints following the wording used in EFRAG's Basis for Conclusions.
Category Total ESRS 2 E1 E2 E3 E4 E5 S1 S2 S3 S4 G1
moved to ARs (no DPs) 27 5 3 0 0 5 0 7 3 2 2 0
deleted "shall" 328 53 76 18 16 32 18 36 17 22 18 22
deleted from mandatory and included in NMIG 64 8 6 8 5 5 5 14 4 4 4 1
moved to shall 6 0 0 0 2 1 0 0 0 0 0 3
new 4 1 0 1 0 0 2 0 0 0 0 0
amended 261 37 84 18 4 11 12 40 15 11 12 17
moved 84 21 27 0 0 1 3 12 8 4 8 0
reformulated and not counted as new 3 0 1 1 0 0 1 0 0 0 0 0
unchanged 38 10 1 0 2 0 4 18 0 2 0 1
Total changes to "shall" datapoints 815 135 198 46 29 55 45 127 47 45 44 44
deleted "may" 141 12 8 15 9 21 14 40 7 8 5 2
Changes to "may" datapoints 141 12 8 15 9 21 14 40 7 8 5 2
Splitting the "deleted shall" category by qualitative* and quantitative datapoints reveals that most of the deleted datapoints were qualitative.
Data Type
deleted
"shall" ESRS 2 E1 E2 E3 E4 E5 S1 S2 S3 S4 G1
Qualitative* 275 48 47 12 13 29 16 32 17 22 18 21
Quantitative 53 5 29 6 3 3 2 4 0 0 0 1
Total 328 53 76 18 16 32 18 36 17 22 18 22
* We aggregate the following data types as qualitative: Table/narrative, narrative, narrative/monetary, narrative/numerical, semi-narrative.
IG 3 Datapoint List (May 2024 incl. Addendum) Amendments (July 2025)
ID ESRS DR Paragraph Related AR Name Data Type May [V] Change IG 3 Datapoint List 2024 vs. Amended ESRS ED 2025
(according to EFRAG)
Comment
Exclude b/c data type is Table or it is a conditional MDR
BP-1_01 ESRS 2 BP-1 5 a Basis for preparation of sustainability statement semi-narrative amended
BP-1_02 ESRS 2 BP-1 5 b i Scope of consolidation of consolidated sustainability statement is same as for
financial statements
narrative deleted "shall"
BP-1_03 ESRS 2 BP-1 5 b ii Indication of subsidiary undertakings included in consolidation that are exempted
from individual or consolidated sustainability reporting
narrative deleted "shall"
BP-1_04 ESRS 2 BP-1 5 c AR 1 Disclosure of extent to which sustainability statement covers upstream and downstream value chain
narrative amended editorial
BP-1_05 ESRS 2 BP-1 5 d Option to omit specific piece of information corresponding to intellectual property,
know-how or results of innovation has been used
semi-narrative amended
BP-1_06 ESRS 2 BP-1 5 e Option allowed by Member State to omit disclosure of impending developments or matters in course of negotiation has been used
semi-narrative moved merged
ESRS 2 BP-1 The undertaking shall state that the general requirements of ESRS 1 have been
applied for the preparation of its sustainability statement with an indication either (i)
that none of the provisions listed in ESRS 2 paragraph 5 apply, or (ii) of which of the provisions listed in SRS 2 paragraph 5 have been applied, leading to the disclosure of
information required in the relevant paragraphs of ESRS 1:
(a) deviation from pre-defined time horizons (ESRS 1, paragraph 78);
(b) adjustments to comparative information (ESRS 1, paragraphs 83, 84 and 85);
(c) application of material judgement, and information subject to significant uncertainties (ESRS 1, paragraph 86);
(d) use of relief when the undertaking discloses metrics with a partial scope (ESRS 1, paragraph 91)
(e) update of disclosures for events after the end of the reporting period (ESRS 1, paragraph 94);
(f) changes in preparation or presentation of sustainability information (ESRS 1, paragraph 95);
(g) reporting errors in prior periods (ESRS 1, paragraph 96 and 97);
(i) presentation of additional information (ESRS 1, paragraphs 108 and 109);
(j) use of relief for metrics in the value chain (ESRS 1, paragraph 92);
(k) use of relief for acquisitions and disposals (ESRS 1, paragraph 74).
new
BP-2_01 ESRS 2 BP-2 9 a Disclosure of definitions of medium- or long-term time horizons
narrative deleted "shall" replaced
BP-2_02 ESRS 2 BP-2 9 b Disclosure of reasons for applying different definitions of time horizons
narrative deleted "shall" merged
BP-2_03 ESRS 2 BP-2 10 a Disclosure of metrics that include value chain data estimated using indirect sources
narrative deleted "shall" overlap/redundant
BP-2_04 ESRS 2 BP-2 10 b Description of basis for preparation of metrics that include value chain data
estimated using indirect sources
narrative deleted "shall" overlap/redundant
BP-2_05 ESRS 2 BP-2 10 c Description of resulting level of accuracy of metrics that include value chain data
estimated using indirect sources
narrative deleted "shall" overlap/redundant
BP-2_06 ESRS 2 BP-2 10 d Description of planned actions to improve accuracy in future of metrics that include
value chain data estimated using indirect sources
narrative deleted "shall"
BP-2_07 ESRS 2 BP-2 11 a Disclosure of quantitative metrics and monetary amounts disclosed that are subject
to high level of measurement uncertainty
narrative/numerical deleted "shall" overlap/redundant
BP-2_08 ESRS 2 BP-2 11 b i Disclosure of sources of measurement uncertainty
narrative deleted "shall" overlap/redundant
BP-2_09 ESRS 2 BP-2 11 b ii Disclosure of assumptions, approximations and judgements made in measurement
narrative deleted "shall" overlap/redundant
BP-2_10 ESRS 2 BP-2 13 a Explanation of changes in preparation and presentation of sustainability information
and reasons for them
narrative deleted "shall" overlap/redundant
BP-2_11 ESRS 2 BP-2 13 b Adjustment of comparative information for one or more prior periods is
impracticable
semi-narrative deleted "shall" partial overlap
BP-2_12 ESRS 2 BP-2 13 b, 13 c Disclosure of difference between figures disclosed in preceding period and revised
comparative figures
Integer deleted "shall" partial overlap
BP-2_13 ESRS 2 BP-2 14 a Disclosure of nature of prior period material errors narrative deleted "shall" partial overlap
BP-2_14 ESRS 2 BP-2 14 b Disclosure of corrections for prior periods included in sustainability statement narrative/numerical deleted "shall" partial overlap
BP-2_15 ESRS 2 BP-2 14 c Disclosure of why correction of prior period errors is not practicable narrative deleted "shall" partial overlap
BP-2_16 ESRS 2 BP-2 15 Disclosure of other legislation or generally accepted sustainability reporting
standards and frameworks based on which information has been included in
sustainability statement
narrative deleted "shall" partial overlap
BP-2_17 ESRS 2 BP-2 15 Disclosure of reference to paragraphs of standard or framework applied narrative deleted "shall" partial overlap
BP-2_18 ESRS 2 BP-2 AR 2 European standards approved by European Standardisation System (ISO/IEC or CEN/CENELEC standards) have been relied on
semi-narrative V deleted "may"
BP-2_19 ESRS 2 BP-2 AR 2 Disclosure of extent to which data and processes that are used for sustainability
reporting purposes have been verified by external assurance provider and found to
conform to corresponding ISO/IEC or CEN/CENELEC standard
narrative V deleted "may"
BP-2_20 ESRS 2 BP-2 16 List of DRs or DPs incorporated by reference narrative deleted "shall" overlap/redundant
BP-2_21 ESRS 2 BP-2 17 Topics (E4, S1, S2, S3, S4) have been assessed to be material semi-narrative unchanged
BP-2_22 ESRS 2 BP-2 17 a List of sustainability matters assessed to be material (phase-in) semi-narrative amended editorial
BP-2_23 ESRS 2 BP-2 17 a Disclosure of how business model and strategy take account of impacts related to
sustainability matters assessed to be material (phase-in)
narrative amended editorial
BP-2_24 ESRS 2 BP-2 17 b Description of any time-bound targets set related to sustainability matters assessed
to be material (phase-in) and progress made towards achieving those targets
narrative/numerical amended editorial
BP-2_25 ESRS 2 BP-2 17 c Description of policies related to sustainability matters assessed to be material
(phase-in)
narrative amended editorial
BP-2_26 ESRS 2 BP-2 17 d Description of actions taken to identify, monitor, prevent, mitigate, remediate or bring end to actual or potential adverse impacts related to sustainability matters
a s-sessed to be material (phase-in) and result of such actions
narrative amended editorial
BP-2_27 ESRS 2 BP-2 17 e Disclosure of metrics related to sustainability matters assessed to be material
narrative/numerical amended editorial
GOV-1_01 ESRS 2 GOV-1 21 a Number of executive members Integer deleted from mandatory and included in NMIG
GOV-1_02 ESRS 2 GOV-1 21 a Number of non-executive members Integer deleted from mandatory and included in NMIG
GOV-1_03 ESRS 2 GOV-1 21 b Information about representation of employees and other workers narrative amended GOV-1_04 ESRS 2 GOV-1 21 c AR 5 Information about member's experience relevant to sectors, products and
geographic locations of undertaking
narrative deleted from mandatory and included in NMIG
GOV-1_05 ESRS 2 GOV-1 21 d Percentage of members of administrative, management and supervisory bodies by
gender and other aspects of diversity
Percent moved GOV-1_06 ESRS 2 GOV-1 21 d Board's gender diversity ratio Percent moved
GOV-1_07 ESRS 2 GOV-1 21 e Percentage of independent board members Percent moved
GOV-1_08 ESRS 2 GOV-1 22 a Information about identity of administrative, management and supervisory bodies or
individual(s) within body responsible for oversight of impacts, risks and opportunities
narrative amended GOV-1_09 ESRS 2 GOV-1 22 b AR 3 Disclosure of how body's or individuals within body responsibilities for impacts, risks
and opportunities are reflected in undertaking's terms of reference, board mandates
and other related policies
narrative moved GOV-1_10 ESRS 2 GOV-1 22 c AR 4 Description of management's role in governance processes, controls and procedures used to monitor, manage and oversee impacts, risks and opportunities
narrative deleted "shall" GOV-1_11 ESRS 2 GOV-1 22 c i Description of how oversight is exercised over management-level position or
committee to which management's role is delegated to
narrative deleted "shall" GOV-1_12 ESRS 2 GOV-1 22 c ii Information about reporting lines to administrative, management and supervisory bodies
narrative deleted "shall" GOV-1_13 ESRS 2 GOV-1 22 c iii Disclosure of how dedicated controls and procedures are integrated with other
internal functions
narrative deleted "shall" GOV-1_14 ESRS 2 GOV-1 22 d Disclosure of how administrative, management and supervisory bodies and senior
executive management oversee setting of targets related to material impacts, risks
and opportunities and how progress towards them is monitored
narrative amended GOV-1_15 ESRS 2 GOV-1 23 AR 5 Disclosure of how administrative, management and supervisory bodies determine whether appropriate skills and expertise are available or will be developed to oversee sustainability matters
narrative moved GOV-1_16 ESRS 2 GOV-1 23 a Information about sustainability-related expertise that bodies either directly possess or can leverage
narrative moved GOV-1_17 ESRS 2 GOV-1 23 b Disclosure of how sustainability-related skills and expertise relate to material
impacts, risks and opportunities
narrative deleted "shall"
GOV-2_01 ESRS 2 GOV-2 26 a Disclosure of whether, by whom and how frequently administrative, management
and supervisory bodies are informed about material impacts, risks and opportunities, implementation of due diligence, and results and effectiveness of policies, actions, metrics and targets adopted to address them
narrative deleted "shall"
GOV-2_02 ESRS 2 GOV-2 26 b Disclosure of how administrative, management and supervisory bodies consider
impacts, risks and opportunities when overseeing strategy, decisions on major
transactions and risk management process
narrative amended
GOV-2_03 ESRS 2 GOV-2 26 c Disclosure of list of material impacts, risks and opportunities addressed by
administrative, management and supervisory bodies or their relevant committees
narrative deleted "shall" overlap/redundant
GOV-2_04 ESRS 2 GOV-2 AR 6 Disclosure of how governance bodies ensure that appropriate mechanism for performance monitoring is in place
narrative V deleted "may"
GOV-3_01 ESRS 2 GOV-3 29 AR 7 Incentive schemes and remuneration policies linked to sustainability matters for members of administrative, management and supervisory bodies exist
semi-narrative amended editorial
GOV-3_02 ESRS 2 GOV-3 29 a Description of key characteristics of incentive schemes narrative unchanged
GOV-3_03 ESRS 2 GOV-3 29 b Description of specific sustainability-related targets and (or) impacts used to assess performance of members of administrative, management and supervisory bodies
narrative amended
GOV-3_04 ESRS 2 GOV-3 29 c Disclosure of how sustainability-related performance metrics are considered as performance benchmarks or included in remuneration policies
narrative moved
GOV-3_05 ESRS 2 GOV-3 29 d Percentage of variable remuneration dependent on sustainability-related targets
and (or) impacts
Percent unchanged
GOV-3_06 ESRS 2 GOV-3 29 e Description of level in undertaking at which terms of incentive schemes are
approved and updated
narrative deleted "shall"
GOV-4_01 ESRS 2 GOV-4 30; 32 AR 8 - AR 10 Disclosure of mapping of information provided in sustainability statement about due diligence process
narrative deleted "shall" overlap/redundant
GOV-5_01 ESRS 2 GOV-5 36 a AR 11 Description of scope, main features and components of risk management and
internal control processes and systems in relation to sustainability reporting
narrative amended editorial
GOV-5_02 ESRS 2 GOV-5 36 b AR 11 Description of risk assessment approach followed narrative deleted from mandatory and included in NMIG
GOV-5_03 ESRS 2 GOV-5 36 c AR 11 Description of main risks identified and their mitigation strategies narrative deleted "shall"
GOV-5_04 ESRS 2 GOV-5 36 d AR 11 Description of how findings of risk assessment and internal controls as regards
sustainability reporting process have been integrated into relevant internal functions
and processes
narrative deleted from mandatory and included in NMIG
GOV-5_05 ESRS 2 GOV-5 36 e AR 11 Description of periodic reporting of findings of risk assessment and internal controls
to administrative, management and supervisory bodies
narrative deleted from mandatory and included in NMIG
SBM-1_01 ESRS 2 SBM-1 40 a i AR 12-13 Description of significant groups of products and (or) services offered
narrative amended
SBM-1_02 ESRS 2 SBM-1 40 a ii AR 12-13 Description of significant markets and (or) customer groups served
narrative moved
SBM-1_03 ESRS 2 SBM-1 40 a iii AR 12-13 Number of employees (head count), at end of period Integer deleted "shall" overlap/redundant
SBM-1_04 ESRS 2 SBM-1 40 a iii AR 12-13 Number of employees (head count), during period Integer deleted "shall" overlap/redundant
SBM-1_05 ESRS 2 SBM-1 40 a iv AR 12-13 Description of products and services that are banned in certain markets
narrative unchanged
SBM-1_06 ESRS 2 SBM-1 40 b AR 12-13 Total revenue Monetary deleted "shall"
SBM-1_07 ESRS 2 SBM-1 40 b AR 12-13 Revenue by significant ESRS Sectors Table/Monetary deleted "shall"
SBM-1_08 ESRS 2 SBM-1 40 c AR 12-13 List of additional significant ESRS sectors in which significant activities are developed or in which undertaking is or may be connected to material impacts
semi-narrative deleted "shall"
SBM-1_09 ESRS 2 SBM-1 40 d i AR 12-13 Undertaking is active in fossil fuel (coal, oil and gas) sector semi-narrative amended
SBM-1_10 ESRS 2 SBM-1 40 d i AR 12-13 Revenue from fossil fuel (coal, oil and gas) sector Monetary moved to ARs (no DPs)
SBM-1_11 ESRS 2 SBM-1 40 d i AR 12-13 Revenue from coal Monetary moved to ARs (no DPs)
SBM-1_12 ESRS 2 SBM-1 40 d i AR 12-13 Revenue from oil Monetary moved to ARs (no DPs)
SBM-1_13 ESRS 2 SBM-1 40 d i AR 12-13 Revenue from gas Monetary moved to ARs (no DPs)
SBM-1_14 ESRS 2 SBM-1 40 d i AR 12-13 Revenue from Taxonomy-aligned economic activities related to fossil gas Monetary moved to ARs (no DPs)
SBM-1_15 ESRS 2 SBM-1 40 d ii AR 12-13 Undertaking is active in chemicals production semi-narrative unchanged
SBM-1_16 ESRS 2 SBM-1 40 d ii AR 12-13 Revenue from chemical production, i.e., its activities fall under Division 20.2 of Annex I to Regulation (EC) No 1893/2006 Monetary unchanged
SBM-1_17 ESRS 2 SBM-1 40 d iii AR 12-13 Undertaking is active in controversial weapons semi-narrative unchanged
SBM-1_18 ESRS 2 SBM-1 40 d iii AR 12-13 Revenue from controversial weapons Monetary unchanged
SBM-1_19 ESRS 2 SBM-1 40 d iv AR 12-13 Undertaking is active in cultivation and production of tobacco semi-narrative unchanged
SBM-1_20 ESRS 2 SBM-1 40 d iv AR 12-13 Revenue from cultivation and production of tobacco Monetary unchanged
SBM-1_21 ESRS 2 SBM-1 40 e AR 12-13 Description of sustainability-related goals in terms of significant groups of products
and services, customer categories, geographical areas and relationships with
stakeholders
narrative moved merged
SBM-1_22 ESRS 2 SBM-1 40 f AR 12-13 Disclosure of assessment of current significant products and (or) services, and
significant markets and customer groups, in relation to sustainability-related goals
narrative deleted "shall""overlap"/redundant
SBM-1_23 ESRS 2 SBM-1 40 g AR 12-13 Disclosure of elements of strategy that relate to or impact sustainability matters
narrative deleted "shall"
SBM-1_24 ESRS 2 SBM-1 41 List of ESRS sectors that are significant for undertaking semi-narrative deleted "shall" overlap/redundant
SBM-1_25 ESRS 2 SBM-1 42 AR 14 Description of business model and value chain narrative amended
SBM-1_26 ESRS 2 SBM-1 42 a Description of inputs and approach to gathering, developing and securing inputs narrative deleted "shall"
SBM-1_27 ESRS 2 SBM-1 42 b Description of outputs and outcomes in terms of current and expected benefits for
customers, investors and other stakeholders
narrative deleted "shall"
SBM-1_28 ESRS 2 SBM-1 42 c AR 15 Description of main features of upstream and downstream value chain and undertakings position in value chain
narrative moved merged
SBM-2_01 ESRS 2 SBM-2 45 a AR 16 Description of stakeholder engagement narrative amended
SBM-2_02 ESRS 2 SBM-2 45 a i AR 16 Description of key stakeholders narrative deleted "shall"
SBM-2_03 ESRS 2 SBM-2 45 a ii AR 16 Description of categories of stakeholders for which engagement occurs narrative deleted "shall"
SBM-2_04 ESRS 2 SBM-2 45 a iii AR 16 Description of how stakeholder engagement is organised narrative deleted from mandatory and included in NMIG
SBM-2_05 ESRS 2 SBM-2 45 a iv AR 16 Description of purpose of stakeholder engagement narrative deleted from mandatory and included in NMIG
SBM-2_06 ESRS 2 SBM-2 45 a v AR 16 Description of how outcome of stakeholder engagement is taken into account narrative deleted "shall"
SBM-2_07 ESRS 2 SBM-2 45 b AR 16 Description of understanding of interests and views of key stakeholders as they
relate to undertaking's strategy and business model
narrative amended
SBM-2_08 ESRS 2 SBM-2 45 c Description of amendments to strategy and (or) business model narrative deleted "shall"
SBM-2_09 ESRS 2 SBM-2 45 c i Description of how strategy and (or) business model have been amended or are
expected to be amended to address interests and views of stakeholders
narrative deleted "shall"
SBM-2_10 ESRS 2 SBM-2 45 c ii Description of any further steps that are being planned and in what timeline
narrative deleted "shall"
SBM-2_11 ESRS 2 SBM-2 45 c iii Further steps that are being planned are likely to modify relationship with and views of stakeholders
semi-narrative deleted "shall"
SBM-2_12 ESRS 2 SBM-2 45 d Description of how administrative, management and supervisory bodies are informed about views and interests of affected stakeholders with regard to sustainability-related impacts
narrative amended
SBM-2_13 ESRS 2 SBM-2 45 e Description of how governance bodies oversee strategy alignment with stakeholder views
narrative amended editorial
SBM-3_01 ESRS 2 SBM-3 48 a AR 17-AR 18 Description of material impacts resulting from materiality assessment narrative moved
SBM-3_02 ESRS 2 SBM-3 48 a AR 17-AR 18 Description of material risks and opportunities resulting from materiality assessment narrative moved
SBM-3_03 ESRS 2 SBM-3 48 b AR 18 Disclosure of current and anticipated effects of material impacts, risks and opportunities on business model, value chain, strategy and decision-making, and how undertaking has responded or plans to respond to these effects
narrative amended
SBM-3_04 ESRS 2 SBM-3 48 c i AR 18 Disclosure of how material negative and positive impacts affect (or are likely to
affect) people or environment
narrative moved
SBM-3_05 ESRS 2 SBM-3 48 c ii AR 18 Disclosure of whether and how material impacts originate from or are connected to
strategy and business model
narrative moved
SBM-3_06 ESRS 2 SBM-3 48 c iii AR 18 Description of nature of activities or business relationships through which undertaking is involved with material impacts
narrative moved
SBM-3_07 ESRS 2 SBM-3 48 d AR 18 Disclosure of current financial effects of material risks and opportunities on
financial position, financial performance and cash flows and material risks and opportunities
for which there is significant risk of material adjustment within next annual reporting period to carrying amounts of assets and liabilities reported in related financial
states
narrative/monetary amended
SBM-3_08 ESRS 2 SBM-3 48 e AR 18 Disclosure of anticipated financial effects of material risks and opportunities on
financial position, financial performance and cash flows over short-, medium- and
long-term
narrative/monetary amended
SBM-3_09 ESRS 2 SBM-3 48 f AR 18 Information about resilience of strategy and business model regarding capacity to
address material impacts and risks and to take advantage of material opportunities
narrative amended
SBM-3_10 ESRS 2 SBM-3 48 g AR 18 Disclosure of changes to material impacts, risks and opportunities compared to previous reporting period
narrative moved
SBM-3_11 ESRS 2 SBM-3 48 h AR 18 Disclosure of specification of impacts, risks and opportunities that are covered by
ESRS Disclosure Requirements as opposed to those covered by additional entity-specific disclosures
narrative deleted "shall" overlap/redundant
IRO-1_01 ESRS 2 IRO-1 53 a Description of methodologies and assumptions applied in process to identify
impacts, risks and opportunities
narrative amended
IRO-1_02 ESRS 2 IRO-1 53 b Description of process to identify, assess, prioritise and monitor potential and actual
impa cts on people and environment, informed by due diligence process
narrative moved merged
IRO-1_03 ESRS 2 IRO-1 53 b i Description of how process focuses on specific activities, business relationships,
geographies or other factors that give rise to heightened risk of adverse impacts
narrative amended
IRO-1_04 ESRS 2 IRO-1 53 b ii Description of how process considers impacts with which undertaking is involved
through own operations or as result of business relationships
narrative moved merged
IRO-1_05 ESRS 2 IRO-1 53 b iii Description of how process includes consultation with affected stakeholders to understand how they may be impacted and with external experts
narrative amended editorial
IRO-1_06 ESRS 2 IRO-1 53 b iv Description of how process prioritises negative impacts based on their relative
severity and likelihood and positive impacts based on their relative scale, scope and
likelihood and determines which sustainability matters are material for reporting purposes
narrative amended
IRO-1_07 ESRS 2 IRO-1 53 c Description of process used to identify, assess, prioritise and monitor risks and opportunities that have or may have financial effects
narrative moved merged
IRO-1_08 ESRS 2 IRO-1 53 c i Description of how connections of impacts and dependencies with risks and opportunities that may arise from those impacts and dependencies have been considered
narrative amended
IRO-1_09 ESRS 2 IRO-1 53 c ii Description of how likelihood, magnitude, and nature of effects of identified risks
and opportunities have been assessed
narrative deleted "shall"
IRO-1_10 ESRS 2 IRO-1 53 c iii Description of how sustainability-related risks relative to other types of risks have been prioritized
narrative amended editorial
IRO-1_11 ESRS 2 IRO-1 53 d Description of decision-making process and related internal control procedures narrative amended
IRO-1_12 ESRS 2 IRO-1 53 e Description of extent to which and how process to identify, assess and manage
impacts and risks is integrated into overall risk management process and used to
evaluate overall risk profile and risk management processes
narrative deleted "shall"
IRO-1_13 ESRS 2 IRO-1 53 f Description of extent to which and how process to identify, assess and manage opportunities is integrated into overall management process
narrative deleted "shall"
IRO-1_14 ESRS 2 IRO-1 53 g Description of input parameters used in process to identify, assess and manage material impacts, risks and opportunities
narrative/numerical moved merged
IRO-1_15 ESRS 2 IRO-1 53 h Description of how process to identify, assess and manage impacts, risks and opportunities has changed compared to prior reporting period
narrative amended
IRO-2_01 ESRS 2 IRO-2 56 Disclosure of list of data points that derive from other EU legislation and information on their location in sustainability statement
semi-narrative amended
IRO-2_02 ESRS 2 IRO-2 56 AR 19 Disclosure of list of ESRS Disclosure Requirements complied with in preparing
sustainability statement following outcome of materiality assessment
semi-narrative amended
IRO-2_03 ESRS 2 IRO-2 57 Explanation of negative materiality assessment for ESRS E1 Climate change
narrative amended
IRO-2_04 ESRS 2 IRO-2 58 Explanation of negative materiality assessment for ESRS E2 Pollution
narrative V deleted "may"
IRO-2_05 ESRS 2 IRO-2 58 Explanation of negative materiality assessment for ESRS E3 Water and marine
resources
narrative V deleted "may"
IRO-2_06 ESRS 2 IRO-2 58 Explanation of negative materiality assessment for ESRS E4 Biodiversity and
ecosystems
narrative V deleted "may"
IRO-2_07 ESRS 2 IRO-2 58 Explanation of negative materiality assessment for ESRS E5 Circular economy
narrative V deleted "may"
... (truncated for brevity; the full document contains additional datapoint changes across MDR-, EIR-, S-, G- series and more)
E1.GOV-3_01 E1 E1.GOV-3 13 Disclosure of whether and how climate-related considerations are factored into
remuneration of members of administrative, management and supervisory bodies
narrative moved
E1.GOV-3_02 E1 E1.GOV-3 13 Percentage of remuneration recognised that is linked to climate related
considerations
percent moved
E1.GOV-3_03 E1 E1.GOV-3 13 Explanation of climate-related considerations that are factored into remuneration of members of administrative, management and supervisory bodies
narrative moved
E1-1_01 E1 E1-1 14 AR 1 Disclosure of transition plan for climate change mitigation
narrative deleted "shall" replaced
E1-1_02 E1 E1-1 16 a AR 2 Explanation of how targets are compatible with limiting of global warming to one
half degrees Celsius in line with Paris Agreement
narrative moved
E1-1_03 E1 E1-1 16 b Disclosure of decarbonisation levers and key action
narrative moved
E1-1_04 E1 E1-1 16 c Disclosure of significant operational expenditures (Opex) and (or) capital
xpenditures (Capex) required for implementation of action plan
narrative moved
E1-1_05 E1 E1-1 16 c Financial resources allocated to action plan (OpEx) monetary moved
E1-1_06 E1 E1-1 16 c Financial resources allocated to action plan (CapEx) monetary moved
E1-1_07 E1 E1-1 16 d AR 3 Explanation of potential locked-in GHG emissions from key assets and products and of how locked-in GHG emissions may jeopardise achievement of GHG emission
reduction targets and drive transition risk
narrative amended
E1-1_08 E1 E1-1 16 e AR 4 Explanation of any objective or plans (CapEx, CapEx plans, OpEx) for aligning
cconomic activities (revenues, CapEx, OpEx) with criteria established in Commission Delegated Regulation 2021/2139
narrative deleted "shall" uncertainty about impact on DPs
E1-1_09 E1 E1-1 16 f Significant CapEx for coal-related economic activities monetary amended
E1-1_10 E1 E1-1 16 f Significant CapEx for oil-related economic activities monetary amended
E1-1_11 E1 E1-1 16 f Significant CapEx for gas-related economic activities monetary amended
E1-1_12 E1 E1-1 16 g AR 5 Undertaking is excluded from EU Paris-aligned Benchmarks semi-narrative deleted "shall"
E1-1_13 E1 E1-1 16 h Explanation of how transition plan is embedded in and aligned with overall business
strategy and financial planning
narrative moved
E1-1_14 E1 E1-1 16 i Transition plan is approved by administrative, management and supervisory bodies semi-narrative moved
E1-1_15 E1 E1-1 16 j Explanation of progress in implementing transition plan narrative unchanged
E1-1_16 E1 E1-1 17 Date of adoption of transition plan for undertakings not having adopted transition plan yet
gYear amended
E1.SBM-3_01 E1 E1.SBM-3 18 Type of climate-related risk semi-narrative moved
E1.SBM-3_02 E1 E1.SBM-3 19 a AR 6, AR 13 Description of scope of resilience analysis narrative amended
E1.SBM-3_03 E1 E1.SBM-3 19 b AR 7a, AR 13 Disclosure of how resilience analysis has been conducted narrative amended
E1.SBM-3_04 E1 E1.SBM-3 19 b AR 7a, AR 13 Disclosure of when resilience analysis has been conducted date amended
E1.SBM-3_05 E1 E1.SBM-3 AR 7b Time horizons applied for resilience analysis semi-narrative deleted "shall"
E1.SBM-3_06 E1 E1.SBM-3 19 c AR 8a, AR 13 Description of results of resilience analysis narrative amended
E1.SBM-3_07 E1 E1.SBM-3 AR 8 b Description of ability to adjust or adapt strategy and business model to climate
change
narrative amended
E1.IRO-1_01 E1 E1.IRO-1 20 a, AR 9 AR 10 Description of process in relation to impacts on climate change narrative deleted "shall"
E1.IRO-1_02 E1 E1.IRO-1 20 b AR 13-AR 14 Description of process in relation to climate-related physical risks in own operations
and along value chain
narrative deleted "shall"
E1.IRO-1_03 E1 E1.IRO-1 AR 11 a AR 13-AR 14 Climate-related hazards have been identified over short-, medium- and long-term
time horizons
semi-narrative amended editorial
E1.IRO-1_04 E1 E1.IRO-1 AR 11 a AR 13-AR 14 Undertaking has screened whether assets and business activities may be exposed to
climate-related hazards
semi-narrative amended editorial
E1.IRO-1_05 E1 E1.IRO-1 AR 11 b AR 13-AR 14 Short-, medium- and long-term time horizons have been defined semi-narrative deleted "shall"
E1.IRO-1_06 E1 E1.IRO-1 AR 11 c AR 13-AR 14 Extent to which assets and business activities may be exposed and are sensitive to
ididentified climate-related hazards has been assessed
semi-narrative amended
E1.IRO-1_07 E1 E1.IRO-1 AR 11 d AR 13-AR 14 Identification of climate-related hazards and assessment of exposure and sensitivity
are informed by high emissions climate scenarios
semi-narrative amended
E1.IRO-1_08 E1 E1.IRO-1 21 AR 13-AR 14 Explanation of how climate-related scenario analysis has been used to inform
identification and assessment of physical risks over short, medium and long-term
narrative amended
E1.IRO-1_09 E1 E1.IRO-1 20 c AR 13-AR 14 Description of process in relation to climate-related transition risks and opportunities in own operations and along value chain
narrative deleted "shall"
E1.IRO-1_10 E1 E1.IRO-1 AR 12 a AR 13-AR 14 Transition events have been identified over short-, medium- and long-term time horizons
semi-narrative amended
E1.IRO-1_11 E1 E1.IRO-1 AR 12 a AR 13-AR 14 Undertaking has screened whether assets and business activities may be exposed to
transition events
semi-narrative amended
E1.IRO-1_12 E1 E1.IRO-1 AR 12 b AR 13-AR 14 Extent to which assets and business activities may be exposed and are sensitive to
ididentified transition events has been assessed
semi-narrative amended editorial
E1.IRO-1_13 E1 E1.IRO-1 AR 12 c AR 13-AR 14 Identification of transition events and assessment of exposure has been informed by
climate-related scenario analysis
semi-narrative amended
E1.IRO-1_14 E1 E1.IRO-1 AR 12 d AR 13-AR 14 Assets and business activities that are incompatible with or need significant efforts
to be compatible with transition to climate-neutral economy have been identified
semi-narrative deleted "shall"
E1.IRO-1_15 E1 E1.IRO-1 21 AR 13-AR 14 Explanation of how climate-related scenario analysis has been used to inform
identification and assessment of transition risks and opportunities over short, medium and long-term
narrative amended
E1.IRO-1_16 E1 E1.IRO-1 AR 15 AR 13-AR 14 Explanation of how climate scenarios used are compatible with critical climate
e-related assumptions made in financial statements
narrative deleted "shall" uncertainty about impact on DPs
E1.IRO-1_17 E1 E1.IRO-1 20 (b) (i) AR 11, AR 13-AR 15 Description of process in relation to identification of climate-related hazards,
considering at least high emission climate scenarios
narrative deleted "shall"
E1.IRO-1_18 E1 E1.IRO-1 20 (b) (ii) AR 11, AR 13-AR 15 Description of process in relation to assessment of how assets and business activities may be exposed to climate-related hazards, creating gross physical
risk for undertaking
narrative deleted "shall"
E1.IRO-1_19 E1 E1.IRO-1 20 (c) (i) AR 11-AR 15 Description of process in relation to identification of climate-related transition
events, considering at least climate scenario in line with limiting global warming to
1.5 °C with no or limited overshoot
narrative deleted "shall"
E1.IRO-1_20 E1 E1.IRO-1 20 (c) (ii) AR 11-AR 15 Description of process in relation to assessment of how assets and business activities may be exposed to climate-related transition events, creating gross transition risks or opportunities for undertaking
narrative deleted "shall"
E1.MDR-P_01-06mdrp mdrp mdrp mdrp mdrp mdrp amended yes
E1-2_01 E1 E1-2 25 AR 16-AR18 Sustainability matters addressed by policy for climate change semi-narrative deleted "shall"
E1.MDR-P_07-08mdr_no_pmdr_no_p mdr_no_p mdr_no_p mdr_no_p yes
E1.MDR-A_01-12mdra mdra mdra mdra mdra mdra amended yes
E1-3_01 E1 E1-3 29 a Decarbonisation lever type semi-narrative amended
E1-3_02 E1 E1-3 AR19d Adaptation solution type semi-narrative V deleted "may"
E1-3_03 E1 E1-3 29 b Achieved GHG emission reductions ghgEmissions amended
E1-3_04 E1 E1-3 29 b Expected GHG emission reductions ghgEmissions amended
E1-3_05 E1 E1-3 AR21 Explanation of extent to which ability to implement action depends on availability
and allocation of resources
narrative deleted "shall"
E1-3_06 E1 E1-3 29 c i AR 20 Explanation of relationship of significant CapEx and OpEx required to implement
actions taken or planned to relevant line items or notes in financial statements
narrative/monetary amended uncertainty about impact on DPs
E1-3_07 E1 E1-3 29 c ii,16 c AR 22 Explanation of relationship of significant CapEx and OpEx required to implement
actions taken or planned to KPIs required under Commission Delegated Regulation (EU) 2021/2178
narrative amended uncertainty about impact on DPs
E1-3_08 E1 E1-3 29 c iii,16 c AR 20 Explanation of relationship of significant CapEx and OpEx required to implement
actions taken or planned to CapEx plan required by Commission Delegated Regulation (EU) 2021/2178
narrative amended uncertainty about impact on DPs
E1.MDR-A_13-14mdr_no_amdr_no_a mdr_no_a mdr_no_a mdr_no_a yes
E1.MDR-T_01-13mdrt mdrt mdrt mdrt mdrt mdrt moved yes
E1-4_01 E1 E1-4 33 AR 27-AR 29 Disclosure of whether and how GHG emissions reduction targets and (or) any other
targets have been set to manage material climate-related impacts, risks and opportunities
narrative deleted "shall" overlap/redundant
... (additional datapoint entries continue with numerous edits and moves across ESRS 2 MDR-P, MDR-A, MDR-T, MDR-M, MDR-T, and other sections; due to length, full repetition is not shown here)
E4-1_01 E4 E4-1 13 a AR 1- AR 3 Disclosure of resilience of current business model(s) and strategy to biodiversity and
ecosystems-related physical, transition and systemic risks and opportunities
narrative deleted "shall" overlap/redundant
E4-1_02 E4 E4-1 13 b AR 1- AR 3 Disclosure of scope of resilience analysis along own operations and related upstream
and downstream value chain
narrative deleted "shall" overlap/redundant
E4-1_03 E4 E4-1 13 c AR 1- AR 3 Disclosure of key assumptions made (biodiversity and ecosystems) narrative deleted "shall" overlap/redundant
E4-1_04 E4 E4-1 13 d AR 1- AR 3 Disclosure of time horizons used for analysis (biodiversity and ecosystems) narrative deleted "shall" overlap/redundant
... (continues with similar restructuring across E4 datapoints)
E5.MDR-P_01-06mdrp mdrp mdrp mdrp mdrp mdrp amended yes
E5-1_01 E5 E5-1 15a Disclosure of whether and how policy addresses transitioning away from use of
virgin resources, including relative increases in use of secondary (recycled) resources
narrative moved
E5-1_02 E5 E5-1 15b Disclosure of whether and how policy addresses sustainable sourcing and use of
renewable resources
narrative moved
E5-2_01 E5 E5-2 20 a Description of higher levels of resource efficiency in use of technical and biological materials and water
narrative deleted "may"
... (and so on through the E5 datapoints)
Appendix: Change Highlights
This section provides high-level context on the distribution of datapoint changes across ESRS standards and datapoint types, including the proportion of datapoints moved to ARs, deleted from mandatory, and edited editorially. It also captures uncertainty notes where changes could not be unambiguously categorized.
- Moved to ARs (no DPs): 27 datapoints across various ESRSs
- Deleted
- Updated editorially
- Amended datapoints across IG 3 MDR-, EIR-, SBM-, IRO- and GOV-series
- Numerous qualitative/quantitative data-type shifts and re-categorizations
For more in-depth, line-by-line comparisons, consult the NMIG (Non-Mandatory Illustrative Guidance) amendments and the Logs of Amendments cited at the top of this document.
Related Topics: ESRS revisions, NMIG, EFRAG amendments, sustainability reporting, datapoint analysis
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