EFRAG IG 3: List of ESRS datapoints – Explanatory note

Disclaimer
This implementation guidance is non-authoritative and accompanies the European
Sustainability Reporting Standards (ESRS), as stipulated in Articles 19a and 29a of Directive
2013/34/EU (the Accounting Directive), but does not form part of them. This means that if
anything in this guidance appears to contradict any requirement or explanation in ESRS,
ESRS take precedence. This implementation guidance is issued following EFRAG’s due
process for such non-authoritative documents and under the sole responsibility of EFRAG.
EFRAG assumes no responsibility or liability whatsoever for the content or any
consequences or damages directly, indirectly or incidentally arising from following the
advice or guidance contained in this document. Users of this document are advised to
exercise their own judgment in applying ESRS. Information contained in this document
should not be substituted for the services of an appropriately qualified professional.
This implementation guidance has been developed for use by large listed and unlisted
companies that are subject to CSRD. It is therefore not intended for use by listed small and
medium-sized enterprises which adopt future LSME standards and other (not listed) SMEs
voluntarily reporting based on the future VSME standards.
This implementation guidance relates to the sector-agnostic ESRS as adopted by the
European Commission on 31 July 2023, and published in the Official Journal on 22
December 2023. Sector-specific standards may add sector specifications to be followed by
specific sectors.

About EFRAG
EFRAG’s mission is to serve the European public interest in both financial and sustainability
reporting by developing and promoting European views in the field of corporate reporting.
EFRAG builds on and contributes to progress in corporate reporting. In its sustainability
reporting activities, EFRAG provides technical advice to the European Commission in the
form of draft European Sustainability Reporting Standards (ESRS) elaborated under a
robust due process and supports the effective implementation of ESRS. EFRAG seeks input
from all stakeholders and obtains evidence about specific European circumstances
throughout the standard-setting process. Its legitimacy is built on excellence, transparency,
governance, due process, public accountability and thought leadership. This enables
EFRAG to speak convincingly, clearly, and consistently and to be recognised as the
European voice in corporate reporting and a contributor to global progress in corporate
reporting.

EFRAG is funded by the European Union through the Single Market Programme in which
the EEA-EFTA countries (Norway, Iceland and Liechtenstein) as well as Kosovo participate.
Any views and opinions expressed here are, however, those of the author(s) only and do
not necessarily reflect those of the European Union, the European Commission or of
countries that participate in the Single Market Programme. Neither the European Union,
the European Commission nor the countries participating in the Single Market Programme
can be held responsible for them.

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 EFRAG IG 3: List of ESRS datapoints – Explanatory note

Table of contents
1. Content and objective of this implementation guidance ............................................. 4
2. Relationship between the list of datapoints and ESRS XBRL taxonomy..................... 5
3. How to read the Excel workbook....................................................................................... 6
4. Explanation of data types presented in column G (based on the XBRL Data
Type Registry) ........................................................................................................................ 7
Appendix A: Differences between EFRAG IG 3 and the future digital ESRS XBRL
taxonomy ................................................................................................................................ 9
Appendix B: Statistics on the number of datapoints ........................................................ 11
General overview ........................................................................................................................... 11
Datapoints by type......................................................................................................................... 13
Datapoints subject to phasing-in provisions applicable to all undertakings............. 14
Datapoints subject to phasing-in provisions applicable to undertakings with
less than 750 employees ........................................................................................................ 15

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 EFRAG IG 3: List of ESRS datapoints – Explanatory note

1. Content and objective of this implementation

guidance
1. EFRAG releases EFRAG IG 3: List of ESRS datapoints as part of its implementation
supporting activities, which consist of issuing non-authoritative implementation
guidance and other material to support the application of sector-agnostic ESRS ‘Set 1’
adopted by the European Commission via a delegated act on 31 July 2023 and
published in the Official Journal of the European Union on 22 December 2023
(‘ESRS’).
2. EFRAG IG 3 presents in Excel format the complete list of all disclosure requirements
in sector-agnostic standards. The Excel file covers all the standards except for ESRS 1
General Requirements, as it does not set disclosure requirements. EFRAG IG 3: List of
ESRS datapoints is aimed at supporting undertakings in their preparation of the first
sustainability statement according to the ESRS.
3. Appendix A in this document explains the differences between this list in Excel format
and the ESRS Set 1 Draft XBRL Taxonomy.
4. Appendix B provides statistics on the datapoints: 161 datapoints are mandatory
irrespective of the materiality assessment; a further 622 datapoints1 are subject to the
materiality assessment2.
5. The first group of undertakings in the scope of the CSRD will prepare their
sustainability statement under ESRS starting from 1 January 2024. Others will follow
from 1 January 2025. For the undertakings that already report their ESG data, this list
can be used as a basis to perform a data gap analysis. For them and for the other
preparers, this list provides a structure to organise the data requirements in in order
to comply with the ESRS.
6. EFRAG IG 3 lists the detailed requirements contained in each Disclosure Requirement
and the related Application Requirements, with additional information (columns)
useful to navigate and filter the content (i.e., the corresponding paragraph and
subparagraphs of each item).
7. The list follows the structure of the detailed requirements in ESRS and as such reflects
the architecture of the content corresponding to a given disclosure objective (or
Disclosure Requirement – ‘DR’): each separable datapoint is presented as a separate
item in this list. The goal of the standard setter in drafting ESRS has been to promote
comparability on sustainability data across undertakings. Qualitative disclosures
within a DR that are conceptually separable, i.e., usable independently from the rest
of the narrative text, have been presented separately as different items in the list.
8. A datapoint encompasses a clearly separable and specific piece of information
required by the ESRS Disclosure Requirements (DRs), generally at the level of each
paragraph, subparagraph and sub-subparagraph. Paragraphs mandating the
disclosure of information that is also completely covered in more detail by subsequent
subparagraphs are not included as datapoints3.

1
Excluding the number of datapoints in ESRS 2 related to the Minimum Disclosure Requirements on Policies,
Actions and Targets, which are to be reported on top of the topical disclosures when the undertaking has adopted
PAT related to a given material sustainability matter.
2
In addition, ESRS contain 269 voluntary datapoints marked as ‘may disclose’.
3
The same applies to paragraphs whose only function is that of introducing subsequent ones, which are often
identifiable in legal texts with the wording ‘… shall include the following: …’. Paragraphs providing
methodological instructions for the disclosure of other datapoints, identifiable with the wording ‘… shall consider
…’ or ‘… shall take into account …’, are also not considered as datapoints.
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 EFRAG IG 3: List of ESRS datapoints – Explanatory note

9. ESRS 1 paragraph 16 remarks that ‘each Disclosure Requirement consists of one or

more distinct datapoints’ and that ‘the term “datapoint” can also refer to a narrative
sub-element of a Disclosure Requirement.’
10. Application Requirements (ARs) are considered as separate datapoints mainly when
they require the disclosure of quantitative information. If they only give instructions for
the disclosure of other datapoints, they are only provided as corresponding
references.
11. This list covers the full universe of possible datapoints under sector-agnostic ESRS
irrespective of the outcome of the materiality assessment to be performed by each
undertaking to prepare its sustainability statement, considering EFRAG IG 1:
Materiality Assessment Implementation Guidance and EFRAG IG 2: Value Chain
Implementation Guidance. Furthermore, Appendix C of ESRS 1 as well as ESRS 2
General requirements BP-2 paragraph 17 define phase-ins for individual datapoints,
disclosure requirements or standards based on the number of employees or specific
financial years. These phase-ins are also illustrated in the list.
12. Finally, this list does not cover the preparation of entity-specific disclosures (see
paragraph 11 of ESRS 1).

2. Relationship between the list of datapoints and

ESRS XBRL taxonomy
13. EFRAG has received the mandate to develop a digital taxonomy reflecting the ESRS
(and Article 8 disclosures, per the EU environmental Taxonomy Regulation 2020/85)
in XBRL format. The digital ESRS XBRL Taxonomy is designed for undertakings to tag
their sustainable statements in a structured, machine-readable format. This enables
users of ESRS disclosures to analyse the information, avoiding manual and error-prone
transformation from a PDF or printed document. The intention is for undertakings to
digitally tag (or mark up) sustainability information within their current human-
readable reporting format, reflecting the content of the relevant requirements in ESRS.
14. EFRAG launched the public consultation on 8 February 2024 on the ESRS Set 1 Draft
XBRL taxonomy. The final ESRS XBRL Taxonomy will then be handed over to the EC
and ESMA. The digital tagging will have to be performed in the European Single
Electronic Format (ESEF) according to an adjusted Regulatory Technical Standard
(RTS) that will be developed by ESMA on the basis of the technical advice on the ESRS
Set 1 Draft XBRL Taxonomy that will be released by EFRAG in 2024.
15. This list does not represent the digital ESRS XBRL taxonomy and cannot be used as a
basis for the preparation of the machine-readable sustainability reporting (see below).
EFRAG IG 3 contains the line items only for tables as a whole, which will be used to
further disaggregate datapoints. The structure of the data in EFRAG IG 3 and of the
future ESRS XBRL Taxonomy may differ for technical reasons. In particular, the digital
modelling of the datapoints requires technical implementation that is not suitable for
use with a human-readable tool like the List of ESRS datapoints (e.g., avoiding multiple
tagging, technical details and attributes for dimensions and tables – see Appendix A).
However, beyond technical differences, the two deliverables are based on full
consistency.
16. While the list does not represent the ESRS XBRL Taxonomy and cannot be used as a
basis for the preparation of the machine-readable sustainability reporting, it may
support the preparation of human-readable reports that will be easier to digitalise. In
particular, it can be used to organise the reporting in a more structured way to assist
the machine-readable format of the reporting, as required by the CSRD.

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 EFRAG IG 3: List of ESRS datapoints – Explanatory note

17. As such, EFRAG IG 3 may be considered an intermediate step on the way to delivering
the ESRS XBRL Taxonomy. It may also be used as a useful tool to advance the
preparation of the machine-readable sustainability statement. Separating the single
disclosure items in the narrative text as illustrated in EFRAG IG 3 may help to
streamline the future digital tagging and avoid overlapping and extensive use of so-
called ‘continuations’4. Therefore, EFRAG encourages preparers to use the list of
detailed disclosure requirements to prepare the structure of the human-readable
ESRS sustainability statements.

3. How to read the Excel workbook

18. The list has been prepared for the detailed requirements embedded in 11 out of 12
standards released in Set 1, which are provided in separate worksheets. ESRS 1 does
not include any dedicated DR but only general requirements and therefore has not
been included in this list. Nevertheless, some requirements deriving from ESRS 1 will
be included in the ESRS Digital Taxonomy (i.e., comparative data). The Excel
workbook contains a separate worksheet for each topical standard. It is important to
note the corresponding disclaimer and the instructions provided on each worksheet.
19. The short description of each datapoint provided in column F is linked to the
respective paragraph in the ESRS text via a hyperlink; by clicking on the name of the
datapoint, a browser window will open up with the relevant paragraph highlighted in
red.5
20. The Minimum Disclosure Requirements (MDRs) of ESRS 2 are presented only once6,
in a separate worksheet, as they have to be disclosed for each sustainability matter.
Each topical standard referencing the MDR has a dedicated hyperlink. Hyperlinks
allow to navigate from each topical standard to the corresponding MDR worksheet
datapoints. If the undertaking does not provide disclosure on policies, targets or
actions, it still needs to disclose the reasons for that, as indicated via hyperlinks to the
MDR worksheet and the corresponding datapoints of ESRS 2 paragraphs 62 and 81.
21. The following table describes the content of each column provided in the Excel
worksheets of EFRAG IG 3: List of ESRS datapoints.
• Column A Unique identifier for each DP, with reference to the
corresponding Disclosure Requirement (DR)
• Column B Reference to the corresponding ESRS (i.e., ESRS 2, E1)
• Column C Reference to the corresponding Disclosure Requirement (DR)
• Column D Reference to the corresponding paragraph under each DR
• Column E Reference to the related Application Requirement
• Column F Short description of the detailed requirement and the
corresponding disclosure (Name), including a hyperlink to the corresponding
paragraph of column D in an online version of the ESRS text

4
‘Continuations’ are required when the narrative disclosure referring to an XBRL tag is disseminated in different
sections of the Inline XBRL report.
5
The online version of the ESRS provided through the hyperlinks is a reproduction of the version published in the
Official Journal on 22 December 2023. It is made available for use only in conjunction with this implementation
guidance.
6
They are applicable whenever the undertaking discloses on policies, actions and targets in relation to a material
sustainability matter following topical standards or on an entity-specific basis.
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 EFRAG IG 3: List of ESRS datapoints – Explanatory note

• Column G Data type classification (Narrative, Semi-Narrative and Numerical

Elements)
• Column H Separate identification of the conditional and alternative
datapoints (‘if applicable’, ’where relevant’)
• Column I Separate identification of the voluntary datapoints (‘may
disclose’), additionally highlighted in orange
• Column J Reference to the data reported under Appendix B-ESRS 2 (SFDR,
Benchmark and Pillar 3)
• Column K Indicates the years of phase-in for the respective datapoint
according to Appendix C of ESRS 1 for undertakings with less than 750
employees
• Column L Indicates the years of phase-in for the respective datapoint
according to Appendix C of ESRS 1

4. Explanation of data types presented in column G

(based on the XBRL Data Type Registry)
22. Corresponding units per data type can be found in the XBRL Unit Type Registry:
• Table – dimensional table where dimensions are used as breakdowns or as
disaggregation of the line items in the list.
• Narrative – used for narrative-formatted disclosures (textblocks) not restricted
in any way in formatting, length or content (can contain images or tables; can
span over one sentence, one paragraph, five pages or 100 pages; can be
‘continued’ in the human-readable report).
• MDR-A, MDR-P, MDR-M, MDR-T– references the corresponding datapoints
from the ESRS 2 Minimum Disclosure Requirements on Actions, Policies,
Metrics and Targets.
• Boolean – Yes or No disclosure (True or False, 1 or 0), subject to paragraph 23.
• Enumeration – Selection menu (multiple selection if appropriate), subject to
paragraph 23.
• Integer – integral data type, only non-decimal positive numbers.
• Monetary – decimal number representing currency.
• Percent – percentage.
• Gyear – date (year only).
• Date – date (day, month, year).
• Mass – the mass item type represents the mass of an object that can be
measured.
• Area – the area item type is used to indicate that an element represents an area
(e.g., hectare).
• Decimal – numbers; might also include intensity rates, which require the
disclosure of the corresponding numerator and denominator.
• Intensity – represents a ratio with a numerator and a denominator.

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 EFRAG IG 3: List of ESRS datapoints – Explanatory note

• Volume – the Volume item type is used to indicate that an element represents
a volume and can be used to express the volume of any substance, be it solid,
liquid or gas.
• Energy – the energy item type represents a unit of energy.
23. When referring to ‘numerical’ data types, all quantitative types are considered. The
term ‘semi-narrative’ is used to describe data types that can be used to enrich narrative
disclosures (textblocks), i.e., Booleans and enumeration.
24. Boolean datapoints relate to disclosures that are either True or False, e.g., ‘The
undertaking shall disclose … whether it has operations that affect threatened species’
(ESRS E4.16 c).
25. Enumeration datapoints relate to disclosures that the undertaking can select from a
pre-defined list, e.g., ‘The undertaking shall explain for each material climate-related
risk it has identified whether the entity considers the risk to be a climate-related
physical risk or climate-related transition risk’ (ESRS E1.18). In this case, the
undertaking has to disclose one of the two provided options (climate-related physical
risk or climate-related transition risk).
26. Datapoints are identified with the data type ‘table’ when the ESRS require a
disaggregation or breakdown of datapoints into different categories. The
presentation in an ESRS statement does not necessarily require it to be in tabular
format unless a specific ESRS requires it.
27. When the ESRS require the inclusion of quantitative information within narrative
disclosures (e.g., ‘The undertaking shall … relate significant monetary amounts of
CapEx and OpEx required to implement the actions taken or planned to relevant line
items in the financial statements’ – ESRS E1.29(c)(i)), the respective datapoint is
identified with a mixed data type (in this case, narrative/monetary).

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 EFRAG IG 3: List of ESRS datapoints – Explanatory note

Appendix A: Differences between EFRAG IG 3 and the

future digital ESRS XBRL taxonomy
1. EFRAG IG 3: List of ESRS datapoints has been prepared by adopting the same
methodology as the one used for the development of the draft ESRS Digital taxonomy
(see the approved Methodology and Architecture paper – 26 April 2023) in order to
ensure consistency. However, given its nature as a tool that supports a human-
readable exercise, there are some differences in detailed approaches that are applied
when creating this list in contrast to the digital ESRS XBRL taxonomy. These differences
are illustrated in this appendix.
2. The term ‘item’ is used to represent a row in the list of detailed requirements, while
the term ‘XBRL element’ is used to represent a tag in the digital ESRS XBRL taxonomy.
Methodology for ESRS XBRL
Comparison Methodology to create EFRAG IG 3
Taxonomy
Data Type Categories A. Numerical, quantitative datapoints Idem
(percentage, monetary);
B. Non-numerical but comparable
types (date, year, semi-narrative
elements);
C. Narrative types (textblocks).
Data type A 1 entry for each individual detail Idem
[Numerical] requirement (irrespective of location)
Data Type B 1 item for each semi-narrative data point 1 element for each semi-narrative data
[Semi-narrative – / (e.g., Yes/No, or dropdown for list of point (e.g., Yes/No, or dropdown for
Dropdowns and ESRS sectors) list of ESRS sectors)
Booleans]
Data Type C No item for each Level 1 (representing a 1 element for each Level 1 (DR as a
[Narrative] DR as a whole) whole)
1 item for each Level 2 (a, b, c) 1 element for each Level 2 (a, b, c)
1 item for each Level 3 (i., ii, iii) 1 element for each Level 3 (i., ii, iii)
Granularity Level 2 + Level 3 of the human-readable Level 1 + Level 2 + Level 3 of the
version of the ESRS. human-readable version of the ESRS.
Level of Separability Idem Idem
‘Whether and how’ Not included as a separate item in case 1 Boolean element related to
the content has already captured by ‘whether’ (Y/N), and 1 item related to
other elements covering the same ‘how’ (textblock)
paragraph.
Tables representing Line items without dimensions (e.g., Line items with all possible
multidimensional Countries or ESRS Sectors). dimensions separately implemented
breakdowns of Comparative information and (e.g., Countries /ESRS Sectors/GHG
(mainly quantitative) breakdown by time horizon (short-, categories, etc.).
datapoints (e.g., GHG medium- and long-term), where The dimensions include the
breakdown by required by ESRS, are not included in comparative information in terms of
country or gender the list. time horizons and targets, where
breakdowns in the required by ESRS.
social standards)
Entity-specific aspects Not included Implemented as ‘typed dimensions’
enabling undertakings to digitally tag
entity specific aspects of the
disclosures (e.g., targets, actions,
policies, subsidiaries, operating
segments, etc.)
Appendix C (SFDR, Yes Yes, including the reference to the
Benchmark, Pillar 3) corresponding regulation.
reference

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 EFRAG IG 3: List of ESRS datapoints – Explanatory note

3. Finally, the digital XBRL taxonomy reuses XBRL elements whenever possible in the
presentation link base. This reduces the total number of XBRL elements compared to
EFRAG IG 3: List of ESRS datapoints, which includes one entry for each distinct
paragraph of the ESRS. For instance, the item ‘Disclosure of decarbonisation levers
and key action’ corresponding to paragraph 16(b) of ESRS E1-1 can be implemented
in the XBRL taxonomy by reusing the XBRL elements from ESRS 2, paragraph 68(a)
(Disclosure of key actions) and from ESRS E1-4, paragraph 34(f) ‘Explanation of
decarbonisation levers identified’. Another example is the social standards, which
repeat various disclosure requirements for different groups of employees, non-
employees, workers in the value chain, affected communities and consumers and end
users. While the ESRS XBRL taxonomy reuses single XBRL elements across those
standards and uses dimensions to differentiate the topics, the list of datapoints
provides one item per standard.

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 EFRAG IG 3: List of ESRS datapoints – Explanatory note

Appendix B: Statistics on the number of datapoints

1. The following statistics provide an overview of the number of datapoints provided in
the Excel spreadsheet. It is important to note that the number of datapoints is not
equal to the number of disclosed facts in a human-readable and digital report. There
are a number of factors that will lead to individual numbers of disclosures of
undertakings, such as: comparative information, usage of optional breakdowns for an
individual required datapoint, number and structure of individual policies, actions and
targets (e.g., one per topic, per matter, per material IRO), entity-specific disclosures
and individual circumstances in terms of phase-in provisions and the materiality
assessment.

General overview
2. The following table includes a presentation on the number of ‘Shall’ datapoints and
‘May’ datapoints for each ESRS that are set out in the application requirements and
disclosure requirements. The number of ‘Shall’ datapoints are separately distributed
according to (i) datapoints to be reported irrespective of the materiality assessment
and (ii) datapoints subject to the materiality assessment.
3. Datapoints that have to be reported irrespective of the materiality assessment (in
short, ‘always to be reported’) are those in ESRS 2 and those relating to IRO-1 in each
topical standard.
4. Minimum Disclosure Requirements (MDR) datapoints are presented in a separate
table as they have to be considered for disclosure purposes when the undertaking
identifies a sustainability matter as material and when the undertaking discloses
policies, actions and/or targets on an entity-specific basis. According to ESRS 1
paragraph 13, the undertaking shall apply the minimum disclosure requirements
regarding policies, actions, metrics and targets together with the corresponding
Disclosure Requirements in topical and sector-specific ESRS.
5. MDR datapoints are therefore counted separately and excluded from the count of the
datapoints in the topical ESRS. Tables’ datapoints are also excluded from the count as
the line items of such table have been considered instead.

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6. The following table presents the total number of conditional and alternative
datapoints7. Conditional datapoints are those that only have to be disclosed in certain
cases (‘if applicable’, ‘where relevant’) while alternative datapoints are instead only
alternative to each other and, therefore, only one has to be disclosed (e.g., when
disclosing the number of employees in ESRS S1.50 a, undertakings may choose to
report it at the end of the reporting period or as an average over the reporting period).

7
60 DPs (29%) identified as conditional or alternative are also voluntary.

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Datapoints by type
7. The following tables set out the number of datapoints by standard and type: seven
datapoints have been excluded as they are subject to phase-in (ESRS 2 BP2,
paragraph 17).
8. There are specific Minimum Disclosure Requirements (MDR) on Policies, Actions,
Targets and Metrics (PAT&M) in ESRS 2 Chapter 4.2 and 5. They have to be considered
for disclosure purposes when the undertaking has adopted PAT or reported Metrics
related to material sustainability matters.
9. The tables indicate the classification of the ‘Shall,’ ‘MDR’ and ‘May’ datapoints by data
type. The category of numerical datapoints includes different types of data (i.e.,
monetary, volume, percentage, decimal).
10. Only the ‘Shall’ datapoints in ESRS 2 and DR IRO 1 datapoints in topical standards are
always to be reported; all other ‘Shall’ datapoints are (i) applicable only when the
undertaking concludes that the relevant topic is material and (ii) subject to materiality
under the provisions of ESRS 1 paragraphs 31 to 35. All MDR datapoints are to be
reported only for material matters, per each policy/action/target that the undertaking
discloses.
11. The following table provides the required datapoints per standard per data type:

12. The following table provides the required datapoints per MDR-PAT&M per
sustainability matter per data type:

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13. The following table shows voluntary (‘may’) datapoints per standard per data type.

Datapoints subject to phasing-in provisions applicable to all

undertakings
14. The following table indicates the number of datapoints that are subject to phasing-in
provisions applicable to all undertakings, as defined in ESRS 1, Appendix C. The table
presents different columns corresponding, respectively, to 1, 2 and 3 years of phasing-
in.

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Datapoints subject to phasing-in provisions applicable to

undertakings with less than 750 employees
15. The following table indicates the number of datapoints that are subject to phasing-in
provisions applicable to undertakings or groups not exceeding on its balance sheet
date the average number of 750 employees during the financial year, according to BP
2 paragraph 17 of ESRS 2.

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