Carbon Measures and the E-ledgers framework – a Big Bang in the carbon accounting world?

Last week, on October 27, Carbon Measures and the International Chamber of Commerce (ICC) announced the formation of an independent expert panel that will work to develop guidelines and implementation steps to establish a global carbon emissions accounting system based on activity-based costing principles from financial accounting.

It’s a concept developed by two academics, Professors Robert Kaplan from Harvard University and Karthik Ramanna who currently works at the University of Oxford, first published in the Nov/Dec 2021 issue of the Harvard Business Review, winning the journal’s 2022 McKinsey Prize for “groundbreaking management thinking.”

They also published a paper in Harvard Business Review on 12 April 2022: “We Need Better Carbon Accounting. Here’s How to Get There.”

“About 90 years ago, a small group of experts from business and academia gathered in the wider public interest to create GAAP for financial accounts. Their innovation allowed capital markets to scale like never before,” recently said Karthik Ramanna, Professor of Business and Public Policy and Director of the Transformational Leadership Fellowship at the University of Oxford.

“We are at a stage today where a similar set of rigorous, technologically agnostic, policy-neutral accounting principles are needed for supply-chain emissions. If done right, these principles can bring to bear the full power of capitalism to accelerate decarbonization while driving energy abundance.”

Who are the people and organisations behind Carbon Measures?

Karthik Ramanna will co-chair Carbon Measures’ new technical expert group alongside its CEO, Amy Brachio, the former Global Vice Chair of Sustainability at EY for nearly three decades.

Carbon Measures is a global coalition comprised of businesses across a range of industries and countries, including ADNOC, Air Liquide, Banco Santander, BASF, Bayer, CF Industries, EQT Corporation, ExxonMobil, EY, Global Infrastructure Partners (a part of BlackRock), Honeywell, Linde, Mitsubishi Heavy Industries, Mitsui.

Carbon Measures is also calling for new policy that “unlocks innovation, competition and market-based solutions to reduce emissions”.

The International Chamber of Commerce (ICC) is an institutional representative of more than 45 million companies in over 170 countries, promoting international trade, responsible business conduct and a global approach to regulation, in addition to providing market-leading dispute resolution services. Their members include many of the world’s leading companies, SMEs, business associations and local chambers of commerce.

S&P Global Commodity Insights, a division of S&P Global (NYSE: SPGI), is the independent knowledge partner for the initiative. S&P Global is the world’s foremost provider of credit ratings, benchmarks, analytics and workflow solutions in the global capital, commodity and automotive markets.

Carbon Measures will be present at COP30 with the backing of some of the world’s most influential companies and business groups.

It is listed as a sponsor of Brazil’s dedicated corporate platform, Sustainable Business COP. The platform’s CEO, Ricardo Mussa, told Reuters recently that it planned to put carbon accounting reform at the top of its agenda for the summit.

The ICC is the UN’s official business representative for COP30, so it will have significant opportunities to promote the project throughout the event.

What is a “ledger-based” carbon accounting approach?

The initiative aims to transform how we account for emissions by tracking the cradle-to-gate emissions embedded in products and services as they move through the economy, and reimagining carbon accounting as a “ledger-based” process focused on capturing product-level emissions.

Rather than LCA’s process-based approach, when an asset is transferred from one company to another, its carbon footprint goes with it. So, just as the asset moves from one financial ledger to another, the ‘E-liability’ moves from one ‘E-ledger’ to another.

Activity-based costing provides rigorous allocation methodologies for assigning shared overhead emissions to specific products, an area where LCA sometimes relies on simplified rules.

Chain-of-custody tracking creates audit trails similar to financial accounting, potentially enabling higher-quality assurance. Emphasis on supplier-specific data might address some GHG Protocol Scope 3 quality concerns.

E-Ledgers’ “mutually exclusive and collectively exhaustive” is designed to eliminate mathematical double counting by ensuring each ton of CO₂ is counted only once as it transfers through supply chains.

This, they argue, will eliminate problems around double counting: when more than one company takes responsibility for the same tonne of carbon because it qualifies as someone’s Scope 1 emissions and someone else’s Scope 3, for example.

The strength of the E-ledgers system is that it uses the knowledge developed by accountants over hundreds of years to guide its measurement approach.

It is a system that has been tried and tested with “dollars” and is readily convertible to a system that uses “emissions.”

The firm only needs to measure its own emissions, which means that these numbers can be easily verified by an external auditor.

The information on upstream emissions is all reported to the firm by its suppliers, which eliminates the need for estimates of these emissions by the firm, and increases reliability.

If all firms in a value chain used E-ledgers, they would all use the same measurement approach and reporting emissions on a product-level basis, which increases comparability.

The weakness of the E-ledgers system is that it requires application across all entities engaging with the business in order to be accurate at the “reasonable assurance” threshold.

Businesses need to be willing to cooperate with each other and provide the necessary information about emissions to the next entity along the supply chain.

E-ledgers also requires allocations of emissions both over time and across products, which can lead to accounting questions and concerns.

E-liabilities (emissions) and E-assets (removals) explained by the E-Ledgers Institute

The E-ledgers Institute is a “not-for-profit learning organization advancing rigorous emissions-accounting practices to drive innovation in energy efficiency worldwide”, by developing an open-source and free-to-use set of emissions-accounting principles.

It announced the release of a draft Proto-Standard for product-level emissions accounting and auditing using the E-liability method in September 2024.

E-liability is an accounting algorithm that allows organizations to calculate the greenhouse gas emissions embedded in any product or service in as close to real-time as practical, in a manner that is auditable to the highest standards used in financial accounting.

The E-liability approach produces, for every product and service in the economy, an accurate and auditable measure of its total “cradle-to-gate” emissions.

“This allows purchasers – whether a company acquiring a batch of cement, a consumer buying a movie on their tablet, or an investor looking for their next project – to see the total emissions impact of creating that specific product or delivering that specific service.”

Just as E-liabilities refer to units of GHG emissions (into the atmosphere) that can be attributed to a given entity or product, E-assets refer to units of GHG removals (from the atmosphere) that can be attributed to a given entity or product.

E-Ledger’s E-asset framework establishes the conditions under which an act of removing GHG from the atmosphere can be recognized as a tradeable asset on an E-ledger and when such an asset can be used to “net” against E-liabilities (to help establish, for instance, an entity or product’s claim to be “net zero”).

Together, E-liabilities and E-assets provide the two sides of the E-ledgers framework, a comprehensive system for managing emissions and instruments that counteract those emissions.

“The duality of E-ledgers ensures that organizations are incentivized and accountable for both emissions and removal actions.”

What’s the main difference between the E-Ledger approach and GHG Protocol?

The GHG Protocol measurement approach aims at helping the firm understand its sources of emissions and focuses on disclosure, whereas E-ledgers aims at creating a worldwide platform that tracks emissions over borders and across entities at the product level and focuses on accountability.

The GHG Protocol takes a “top-down” view and focuses on responsibility: a business measures emissions created throughout its value chain (in short, emissions created by the supplier side, the firm itself, and in the customer line).

It is introspective in the sense that its focus is on helping the business understand how much emissions are created from its activities. The idea is to “take stock” of the carbon emissions, and from there develop strategies to reduce them over time.

In contrast, E-ledgers takes a “bottom-up” approach and focuses on control: a business measures emissions embedded in the products or services it owns and sells (cradle-togate emissions).

With the E-ledgers approach buyers are held liable for emissions, but not so much the sellers.

This is probably why the oil & gas industry is interested. Unlike traditional GHG Protocol Scope 3 accounting, the E-ledgers approach doesn’t require companies to take responsibility for emissions produced by their sold products.

Exxon, one of the initial members of the Carbon Measure, has made its feelings about the GHG Protocol very clear already, describing it as a “flawed reporting standard” in a lawsuit filed last week against California’s climate disclosure requirements.

The oil major doesn’t want to be forced by regulators to adopt parts of the framework it doesn’t approve of, it explained, “such as the requirement to publish base-year emissions recalculations and the requirement to report the full range of Scope 3 emissions”.

But others argue that the GHG Protocol measurement approach allows for investors to understand inherent risk across the entire value chain of a company and to create “collective accountability for a collective problem”.

However, reliability is a concern. The numbers rely on public emissions factors that may not be appropriate to the firm’s situation; and the numbers are estimates made by the management team and can contain significant estimation error (because it can be impossible for the firm to obtain actual data on the emissions such as for customer use of their products).

Verifiability is also a concern. The estimates made can be audited but the audit will tend to be limited in nature and focus on checking the management’s calculations, not necessarily on checking whether the emissions information is accurate.

These challenges mean that from an external stakeholders’ point of view, it could be difficult to trust the information provided, and there could be concerns with selective disclosure.

The partnership between GHG Protocol and ISO (14067)

Things are moving fast in the carbon accounting world. On 9 September 2025 ISO and GHG Protocol also announced that they will harmonize their GHG standards and co-develop new standards for GHG emissions measurement and reporting.

It is a major step towards a more common global language for emissions accounting – implicitly acknowledging existing hurdles to today’s approach.

The GHG Protocol Corporate Standard has been developed over 25 years and adopted by 97% of S&P 500 companies with a global reach. It’s currently integrated in the ISSB/IFRS-S and EU ESRS sustainability standards.

The protocol’s fundamental strength lies in comprehensive accountability.

By requiring companies to report direct (Scope 1), purchased energy (Scope 2), and value chain (Scope 3) emissions, it ensures businesses take responsibility for emissions they influence but don’t directly control.

However, although encouraging use of primary data, Scope 3 reporting often relies on industry averages and estimation methods limiting precision and audit-ability.

The GHT Protocol also faces legitimate challenges around product-level granularity and Scope 3 data quality. While the GHG Protocol Product Standard exists, it hasn’t achieved widespread implementation.

The ISO standard (14067), based on Life Cycle Assessment (LCA) principles, with a product carbon footprint methodology, provides a systematic framework for assessing environmental impacts across a product’s life cycle – from raw material extraction through production, use, and disposal.

The partnership between GHG Protocol and ISO aims to harmonize both approaches while developing enhanced product carbon footprint standards, resulting in a more common global language for emissions measurement and reporting.

Will Carbon Measures replace or collaborate?

In an article publishes on 8 October 2025, Robert G. Eccles argues that the partnership between GHG Protocol and ISO creates infrastructure for precise product-level data that carbon pricing mechanisms increasingly require, from border carbon adjustments to carbon-differentiated procurement to internal carbon pricing systems.

Eccles also argue that E-Ledgers’ product-level precision could enable more sophisticated mechanisms for carbon pricing, but that the theoretical appeal of E-Ledgers “rests upon a seamless, unbroken chain of emissions tracking from raw materials to end-user”, which is “near to impossible”.

He argues that “modern supply chains are inherently complex and fragmented, spanning thousands of actors across national borders, divergent regulatory jurisdictions, and varying technological capabilities”.

This would lead to a partial adoption creating critical failure modes: Chain-of-custody breakage, Interoperability gaps, and Assurance infeasibility since auditors cannot opine on incomplete chains.

He concludes that “the need for near-universal buy-in for E-Ledgers to work remains a substantial—perhaps insurmountable—barrier to practical implementation”.

And that “in the interest of users, the only realistic approach is a collaborative one. E-Ledgers’ activity-based costing principles could strengthen how LCA allocates shared resources and overhead emissions to specific products, improving precision without replacing the underlying framework.

For downstream emissions, producers would continue reporting estimated use-phase impacts as disclosure requirements under GHG Protocol frameworks, maintaining accountability for product design choices even though product-level tracking shows transfers to customers. This preserves comprehensive climate accountability while improving upstream data precision.”

In Eccles opinion, “if E-Ledgers competes with the GHG Protocol/ISO partnership rather than contributing to it, the consequences for carbon pricing (and corporate decarbonization) would be severe.

It would create incompatible methodologies and additional confusion. Companies would face impossible choices, regulators couldn’t design consistent policies, and carbon pricing mechanisms would lack standardized data. Parallel development of technology platforms, assurance procedures, professional training, and regulatory frameworks would divert scarce resources from climate action to methodological competition.”

Conclusion

The launch of Carbon Measures, basing carbon accounting on financial accounting principles, can be regarded as a Big Bang in the carbon accounting world, in a time when sustainability accountability is facing strong political headwinds.

Given the current ESG trends, the powerful actors behind the Carbon Measures initiative, the cost and complexity of GHG Protocol Scope 3 carbon accounting, and the fact that the GHG Protocol method will be disputed in court, the Carbon Measures’ discourse to enable the “full power of capitalism to accelerate decarbonization while driving energy abundance”, seems to be in the spirit of the times.

I would not be surprised if the “perhaps insurmountable barrier to practical implementation” turns out to be not so insurmountable after all.

Leila Hellgren

CEO & Co-founder at Cleerit

 

Sources:

https://www.forbes.com/sites/bobeccles/2025/10/08/carbon-pricing-needs-data-standards-not-a-standards-war/

https://e-ledgers.institute/

https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5441754

https://www.businesswire.com/news/home/20251027348594/en/Carbon-Measures-and-International-Chamber-of-Commerce-Launch-Technical-Expert-Panel-on-Carbon-Accounting

https://real-economy-progress.com/exxon-and-the-international-chamber-of-commerce-are-kicking-off-a-campaign-to-redesign-carbon-accounting-rules/

https://hbr.org/2022/04/we-need-better-carbon-accounting-heres-how-to-get-there

https://www.afp.com/fr/node/3800680#:~:text=The%20initial%20member%20companies%20of,Mitsui%20%26%20Co.%3B%20Mitsui%20O.S.K.

 

#CSRD, #ESRS, #CarbonAccounting, #CarbonMeasures, #E-Ledgers, #GHGProtocol

 

The EU Deforestation Regulation (EUDR) is back on track

Yesterday (21/10) the European Commission proposed targeted measures to ensure the timely implementation of EU Deforestation Regulation, EUDR, a key initiative to fight deforestation:

⭕ For large and medium companies, the entry into application of the EUDR remains 30 December 2025, but to ensure a gradual phase-in of the rules, they will benefit from a grace period of six months for checks and enforcement.

⭕ For micro- and small enterprises, the EUDR will enter into application one year later, on 30 December 2026.

⭕ Downstream operators and traders should no longer be obliged to submit due diligence statement, meaning that only one submission in the EUDR IT system at the entry point in the market will be required for the entire supply chain.

Downstream operators and traders are those that commercialise the relevant EUDR products once they have been placed on the EU market, for example, retailers or large EU manufacturing companies.

The reporting obligations and the responsibility would then be focused on the operators placing first the products on the market.

⭕ Micro and small primary operators would only submit a simple, one-off declaration in the EUDR IT system.

When the information is already available, for instance in a Member State database, the operators do not have to take any action in the IT System themselves.

This simplification replaces the previous need for regular submissions of due diligence statements.

📅 Next steps

The European Parliament and the Council will now discuss the Commission’s proposal. They would need to formally adopt the targeted amendment of the EU Deforestation Regulation before it can come into effect.

The Commission calls on the European Parliament and the Council to swiftly adopt the proposal for an extended implementation period by the end of year 2025.

Source: Commission proposes targeted measures to ensure the EU Deforestation Regulation

⭕ ESRS E4, datapoints 24.d and 38.a, require companies to disclose adopted policies to address deforestation and relevant metrics.

👉 Read more and download the EU guide to understanding deforestation due diligence obligations here: https://cleeritesg.com/index.php/2025/03/06/eudr-compliance-a-guide-to-understanding-deforestation-due-diligence-obligations/

EUDR, CSRD, ESRS, ESG, SustainabilityReporting, SustainabilityGovernance

The CBAM simplification is now official

On 29 September 2025 the European Council adopted a regulation that simplifies the EU’s carbon border adjustment mechanism (CBAM), as part of the ‘Omnibus I’ legislative package.

It was published 17 October 2025 as regulation (EU) 2025/2083 of the European Parliament and of the Council of 8 October 2025 amending Regulation (EU) 2023/956 as regards simplifying and strengthening the carbon border adjustment mechanism (Text with EEA relevance). The text can be found here: Regulation – EU – 2025/2083 – EN – EUR-Lex

The climate ambition behind the CBAM remains unchanged – about 99% of embedded emissions in the imported CBAM goods will remain covered.

Main elements of the regulation:

⭕ A new ‘de minimis’ mass threshold whereby imports up to 50 tonnes per importer per year will not be subject to CBAM rules.

The measure is expected to exempt mainly SMEs and individuals, which import small or negligible quantities of goods covered by the CBAM regulation.

⭕ Imports of CBAM goods will be allowed under several conditions pending CBAM registration of the importer, to avoid any disruptions for importers in the beginning of 2026.

⭕ The authorisation procedure, the data collection processes, the calculation of emissions, verification rules, and the financial liability calculation of authorised CBAM declarants have been simplified for all importers of CBAM goods.

⭕ The amended regulation contains adjustments of provisions on penalties and on the rules regarding indirect customs representatives.

ℹ️ The CBAM equalises the price of carbon between domestic products and imports and ensure that the EU’s climate objectives are not undermined by production relocating to countries with less ambitious policies.

It also helps reduce the risk of carbon leakage by encouraging producers in non-EU countries to green their production processes.

🌿 Background

The EU’s carbon border adjustment mechanism is the EU’s tool to equalise the price of carbon paid for EU products operating under the EU emissions trading system (ETS) with that of imported goods, and to encourage greater climate ambition in non-EU countries.

In early 2026, the Commission will assess whether to extend the scope of the CBAM to other ETS sectors and how to help exporters of CBAM products at risk of carbon leakage.

Source:

CBAM: Council signs off simplification to the EU carbon leakage instrument – Consilium

ESMA: European common enforcement priorities (ECEP) for the 2025 sustainability statements

On 14 October 2025 the European Securities and Markets Authority (ESMA) issued its annual Public Statement setting out the European common enforcement priorities (ECEP) for the 2025 annual financial reports (which includes sustainability statements and ESEF requirements) of issuers admitted to trading on European Economic Area (EEA) regulated markets.

ESMA, together with national enforcers in the EEA (enforcers), will pay particular attention to these areas when examining the application of the relevant reporting requirements.

Based on the examinations performed, enforcers will take enforcement actions whenever material misstatements are identified and ESMA will subsequently report on their findings.

ESMA underlines the responsibility of management and supervisory bodies of issuers as well as the importance of the oversight role of audit committees to:

  • ensure the overall internal consistency of the annual financial report [including the sustainability statement],
  • implement and supervise internal controls, and
  • ultimately contribute to high-quality annual financial reports [including sustainability statements].

Cleerit’s summary and recommendations

  • Conduct your DMA at the level of IRO (and not at the higher level of topics / sub-topics), and map your IROs to the sustainability matters in ESRS 1 AR 16.
  • Add your entity specific topics when relevant if they are not present in AR 16.
  • Mark your entity-specific topics disclosures for their easier identification within the statement.
  • Describe the specific steps in your specific DMA process in detail as required by IRO-1, do not just reproduce ESRS 1 instructions or EFRAG guidance.
  • The datapoint (ESRS2.53.g) describing the input parameters (evidence, data sources, scope of operations covered, assumptions…) used in process to identify, assess and manage material impacts, risks and opportunities (IROs), is particularly important.
  • When disclosing on your materiality thresholds, be specific (per type of IRO, topic, etc) and not boilerplate generic, and detail the scales applied.
  • Be transparent on how you have considered gross impacts (i.e., before the effect of any prevention, mitigation or remediation actions) .
  • Do not confuse negative impact mitigation with positive impact, nor risk mitigation with opportunity.
  • Affected stakeholders should be identifiable, and related disclosures should give an understanding of how their interests and views were integrated in the materiality process, when that was the case.
  • Disclosures (especially SBM-3) should provide a complete view of your material IROs and how they relate to your strategy and business model and how you manage them.
  • In this regard, ESMA reminds you of the embedded logic of the ESRS, whereby this objective is being achieved through disclosing the policies, actions and targets (MDR) – or the absence thereof – and metrics related to the corresponding sustainability matters.
  • Ensure that the information is not excessively scattered in your report as this would defeat the overall purpose of readability and clarity.
  • Include a reference to the Disclosure Requirement (and the datapoint) to increase the accessibility and readability of the sustainability statement. ESMA points out that this way, the disclosures are complete and adapted to the future digital tagging of the information.
  • ESMA also encourages the use of hyperlinks to facilitate internal references.
  • Use the IRO-management models provided in Cleerit to structure the description of your IROs, policies, targets, actions and related metrics.
  • Use the ESRS templates provided in Cleerit, and click on the “?” of each datapoint to read and take into account the expected information. (Do not rely only on the information provided in the datapoint name.)

ESMA’s priorities related to sustainability statements

Due to the uncertainty linked to the current regulatory context, ESMA has exceptionally carried over two of the priorities from its ECEP 2024, namely the

  1. implementation of the ESRS requirements on materiality, and the
  2. scope and structure of the sustainability statement.

Both areas relate to fundamental features of sustainability reporting.

This year’s priorities on materiality considerations were also informed by the results of a fact-finding exercise ESMA conducted to take stock of evidence from the first cycle of ESRS reporting.

Read more about this analysis here: https://cleeritesg.com/index.php/2025/10/14/esma-has-analysed-91-esrs-statements-for-fy-2024-key-findings/

  1. Implementation of the ESRS requirements on materiality

Materiality considerations play a key role in sustainability reporting under the ESRS as the results of the two-step assessment (materiality of Impacts, Risks and Opportunities – IROs and materiality of information) determine the topical disclosures to be provided by the undertaking. As such, double materiality is the filter which ensures the decision-usefulness of reported information for all users of the sustainability statement.

Disclosure Requirement IRO-1

In the light of this structural importance of materiality, ESMA stresses the particular care that should be brought to the disclosures in ESRS 2 pertaining to the assessment process followed by the issuer.

The related Disclosure Requirement (IRO-1) is broken down in several datapoints in the current set of ESRS.

While ESMA’s fact-finding showed that this led to detailed accounts of the methodology and procedural steps taken, the resulting disclosures were in some cases boilerplate when they mostly reproduced the concepts defined in ESRS 1 or the generic approach suggested in EFRAG’s Implementation Guidance on Materiality Assessment (IG1).

Insufficient insight was sometimes provided on how individual issuers had adapted these criteria and steps to their facts and circumstances.

In this regard, ESMA wishes to highlight the datapoint related to the input parameters to the materiality assessment process.

This datapoint is meant to shed light on the basis for determining whether an IRO is material.

These inputs include the data sources, scope of operations that are covered (including in relation to specific geographies or activities) and other considerations, such as the key assumptions relied upon.

On the same line, the disclosures related to the thresholds should help users of the sustainability statement understand the main considerations relied upon for the determination of material sustainability matters, most notably for the matters whose materiality issuers were most uncertain of during the assessment process.

For negative impacts, this can be done through detailing the severity scale that was applied for particular matters.

For risks, disclosure of the indicator used for setting the threshold, or even of the quantitative threshold itself may be most enlightening.

ESMA also expects issuers to be transparent on how they have considered gross impacts (i.e., before the effect of any prevention, mitigation or remediation actions) in their materiality assessment process.

ESMA finally reminds issuers that information regarding the engagement with internal and external stakeholders for the purpose of the materiality assessment refers to affected stakeholders. This group of stakeholders should be identifiable, and related disclosures should help users understand how their interests and views were integrated in the materiality process, when that was the case.

Disclosure Requirement SBM-3

As for information on the results of the assessment process, ESMA underlines the importance of the ESRS 2 disclosures (SBM-3 and IRO-2) which can serve as entry points to the sustainability statement for users.

These disclosures should provide a complete view of the issuer’s material IROs and how they relate to its strategy and business model and also guide the user to where and how the management of these.

IROs (including entity-specific ones) is addressed in the topical sections of the sustainability statement.

In this regard, ESMA reminds issuers of the embedded logic of the ESRS, whereby this objective is being achieved through disclosing the policies, actions and targets – or the absence thereof – and metrics related to the corresponding sustainability matters.

Regarding the description of the IROs, ESMA recalls the disclosure requirement in SBM-3 of ESRS 2, including the related time horizon and whether the IROs arise in the issuer’s own operations or in the value chain.

ESMA recommends that this description also includes explanations of any interdependency among the material IROs, where relevant, and help ensure that the positive impacts identified are not confused with mitigation of negative impacts.

Regarding connection between the IROs and the topical disclosures, ESMA notes that comparability among issuers is better achieved when IROs are mapped to the ESRS topics and sub-topics and when the ESRS terminology is used in the description of the IROs, whenever relevant.

Together with the table of disclosures required in IRO-2 and EFRAG’s explanation of the links between ESRS sustainability matters and disclosure requirements, such mapping can assist the users of sustainability statements in more easily navigating through the topical disclosures. This mapping would also help with the identification of the IROs which are addressed by entity-specific disclosures, as required by SBM-3.

More generally, ESMA encourages as a good practice the systematic signposting of the entity-specific disclosures for their easier identification within the statement. 

Non-material information

ESMA finally reminds issuers that non-material information, in cases allowed by the ESRS, should be clearly identified and not obscure material information.

  1. Scope and structure of the sustainability statement

Scope of the sustainability statement

Regarding the scope of the sustainability statement, ESMA reminds issuers that, according to ESRS 1, the sustainability statement shall be for the same reporting undertaking as the financial statements.

When the sustainability statements are subject to scope limitations with regards to entities in the value chain (see paragraph 133 of ESRS 1), ESMA stresses the need to be fully transparent and report on any consequences of such limitations.

In addition, in case the scope of targets has evolved compared to the previous year, issuers should be transparent about any adjustment to the baseline of their targets.

Structure of the sustainability statement

In line with its recommendations in the priority above, ESMA urges issuers to consider the usability and readability of the sustainability statement in line with paragraph 111 (b) of ESRS 1 which sets as a general objective for the presentation of the disclosures to facilitate access and understanding of the reported information.

A structure of the sustainability statement in four parts (General, Environment, Social, Governance) is prescribed by ESRS 1 but the ESRS also allow for some flexibility in the presentation of the different elements.

Cross-referencing within the sustainability statement, for instance, can be used to avoid unnecessary duplication and emphasise connections among disclosures.

However, issuers need to find a balance to ensure that the information is not excessively scattered as this would defeat the overall purpose of readability and clarity.

Similar considerations are valid for the issuers using the possibilities for incorporation by reference mentioned in ESRS 1.

ESMA notes that a practical solution for issuers to increase the accessibility and readability of the sustainability statement while making use of the flexibilities allowed by the ESRS can be to include a reference to the Disclosure Requirement (e.g., “E2-5”, “S1-5”) when disclosing the related information.

This way, the disclosures are complete and adapted to the future digital tagging of the information.

ESMA also encourages the use of hyperlinks to facilitate internal references.

Connectivity to other parts of the issuer’s corporate reporting

Finally, ESMA recalls that ESRS 1 requires issuers to illustrate the connections to other parts of their corporate reporting.

In this regard, ESMA highlights the requirement in ESRS 1 regarding the monetary amounts or other quantitative information included in the sustainability statement that are also presented in the financial statements (direct connectivity).

Taxonomy disclosures

As for Taxonomy disclosures, the Omnibus package included a Delegated Act amending the Taxonomy Disclosures Delegated Act and the Climate and Environmental Delegated Act.

The EC adopted this Delegated Act in July 2025. It will be in force after the scrutiny period if the co-legislators do not raise objections.

Undertakings are encouraged to apply the revised rules to their 2026 disclosures (financial year 2025) but have the option to apply the previous rules to that reporting cycle.

Acknowledging the changing regulatory environment, ESMA has not included specific recommendations on Taxonomy disclosures in the ECEP 2025.

Access the full document from ESMA here: https://www.esma.europa.eu/sites/default/files/2025-10/ESMA32-2064178921-9254_Public_Statement_-_2025_European_Common_Enforcement_Priorities.pdf

Access the full ECEP package from ESMA here: https://www.esma.europa.eu/document/2025-ecep-package

#CSRD, #ESRS, #ESG, #Strategy, #Governance, #SustainabilityReporting, #CleeritESG

Assessment of published ESRS statements by AMF – DMA outcome & SBM-3

AMF, the French Financial Markets Authority assessed a sample of ESRS statements published by French listed companies under the CSRD for financial year 2024.

This report is very valuable as it gives you information on what the financial marketplace is expecting from your sustainability reports.

We will send you the information regrouped by subject.

Below you will a summary of the key findings related to the Double Materiality Assessment outcome and description of IROs (ESRS 2 SBM-3). 

Reporting on materiality assessment outcomes (SBM-3)

There is an increased comparability with a widespread use of the ESRS 1 AR16 list of topics and sub-topics (standardized terminology), even if the mapping with these ESRS topics is sometimes unclear

The format, granularity and location of these disclosures are very heterogeneous.

Several companies present both a brief overview of the material IROs in the general section and a more detailed description of IROs in the topical sections, which seems to be a balanced approach to avoid duplications and increase overall readability of the report.

Many companies present the results of the DMA in tables or with narrative information.

Only a few companies presented a matrix that maps IROs on financial and impact materiality axes (in addition to other narrative information).

One common evolution is the replacement of the “stakeholders’ view” axis by the broader “impact materiality” axis.

As a good practice, a few companies provide a comparison of the DMA results with previous reporting periods (with more or less details on the changes). Others explain that the results were not comparable because of changes in methodology.

Examples of common shortcomings:

  • While most companies report on all their material topics, a few companies only report on most material/critical topics (which is not in line with ESRS requirements).
  • The nature of IRO is unclear (e.g. to distinguish risk vs impact or « positive » vs. « negative ») or the description of the IRO is missing or boilerplate (e.g. for impacts, not possible to understand the effect on people or the environment, as required by SBM-3).
  • Missing information on associated time horizons or location in the value chain. Few companies explain difficulties to evaluate IROs on different time horizons.
  • Unclear mapping between material IROs and sustainability topics (listed in ESRS 1 AR 16) and unclear identification of entity-specific subtopics.
  • Mitigation of a negative impact is sometimes presented as a positive impact (or a potential sustainability risk is presented as an opportunity).
  • Inconsistencies in the list of material IROs presented in different parts of the statement.
  • Presentation of materiality matrix with no precise axes (line drawn for materiality threshold with no figure/explanation on the construction of the graph).

Distinction of gross vs. net IROs and their description

Not all companies clearly distinguish between gross and net IROs when presenting the result of the DMA (if prevention and mitigation actions were taken into consideration or not), although several companies explain that the aim of the DMA process is to identify gross IROs.

We sometimes noted some confusion: some companies present their mitigation efforts (net IROs) within their IRO-1 sections, which should be focused on gross IROs in line with the ESRS.

A good practice identified was that several companies establish a link between the DMA results and risk factors identified in the management report.

Most refer to the sustainability statement in the risk factors section. However, the difference with the ESRS approach is not explained.

Some companies make the connection within the sustainability statement itself and explain the differences with risk factors (ESRS based on gross assessment, vs. risk factors based on net risks assessment).

Current financial effects (SBM-3, 48d)

Many companies do not disclose information on current financial effects required by SBM-3.

For other companies, the methodology used is often not presented (for example: how net effects are assessed).

Some companies explain that they do not have current financial effects, without explaining the methodology.

Some companies provide generic narrative disclosures (only describing the nature of the risk or very brief explanation on both financial effects and impacts on people of an IRO in the same paragraph).

Few provide more specific information by referring to the current financial effects presented in the notes in the financial statement.

Anticipated financial effects (SBM-3, 48e)

Most companies do not disclose this information, and some companies explicitly state that they are relying on the phase-in option.

Among the few companies that report that they have assessed anticipated financial effects, only one provides quantitative estimates on a voluntary basis but restricted to short term horizons.

There is not always a clear distinction between current and anticipated financial effects in the disclosures.

 

Source: https://www.amf-france.org/sites/institutionnel/files/private/2025-10/amf_study_csrd_reporting_the_way_forward_2025.pdf

 

When you use Cleerit ESG to structure and document your IROs and double materiality assessment you increase both ESRS compliance and make CSRD useful for your business as it will help you identifying issues material for your resilience and competitiveness. Contact us if you want to know more >>>

 

Assessment of published ESRS statements by AMF – DMA & IRO-1

AMF, the French Financial Markets Authority assessed a sample of ESRS statements published by French listed companies under the CSRD for financial year 2024.

This report is very valuable as it gives you information on what the financial marketplace is expecting from your sustainability reports. We will send you the information regrouped by subject. Below you will a summary of the key findings related to the Double Materiality Assessment (DMA) process (ESRS 1 & ESRS 2 IRO-1).

 

Presentation of the DMA process (in IRO-1) 

Overall, a heterogeneity was noted with regard to the level of detail and degree of compliance with the required data points on the presentation of the DMA process (IRO-1 data points).

Some companies provide detailed explanations per topic while others present more generic information on how the process was conducted.

Compliance with all IRO-1 data points was generally partial. For instance, a large number of companies do not disclose the topical IRO-1 associated with their non-material topics, although these are always to-be disclosed data points.

Specific information on the DMA process related to social topics is provided only in very rare cases.

 

Input parameters, sources/assumptions

Some companies provide incomplete or boilerplate disclosures on the input parameters used (for instance, only focusing on material topics or providing broad references applicable to all topics such as “industry benchmarks”).

Others disclose very specific information on the sources/assumptions that informed the DMA process.

For social-related topics information on input parameters is often not specified, contrary to other environmental topics.

Some companies provided interesting contextual information on the methodology used in relation to certain materiality criteria. For example, they explain that

  • the “scale” of the impacts is assessed in relation to % of people concerned vs. environmental parameters, or
  • pollution impacts’ severity is assessed via concentration metrics vs. volume metrics only.

 

Duplicating the content of ESRS 1

Many provide extensive explanations on the definition of impact materiality and financial materiality and the different criteria that must be considered in application of the ESRS (often by duplicating the content of ESRS 1).

These elements can be useful for non-expert readers in the context of the first ESRS application.

However, in some cases, the IRO-1 disclosures have little informative value as they reproduce the content of ESRS 1 with no or few methodological explanations specific to the issuer (for instance, only boilerplate disclosures stating that judgements were applied).

Therefore, it is sometimes difficult to understand how the two processes for impact and financial materiality are designed in practice.

 

Unclear distinction between a risk and an impact

In some cases, the distinction between a risk and an impact is not clear due to misuse of terminology (e.g. use of the term « risk » associated with the description of an impact) or because the company explains that the same materiality threshold is used for both impact and risks.

 

Information on materiality thresholds

Information on impact materiality thresholds is very often generic or missing, limiting the understanding of the DMA methodology used and demonstrating the need for further guidance in this area.

Example of generic disclosures are:

  • boilerplate disclosure on the existence of a threshold
  • theoretical quantitative threshold (such as: “on a scale from 1 to 5 in terms of materiality score, the impact materiality thresholds is set at 3”), which does not inform on the parameters specific to the entity that define materiality.

Companies may have had difficulties identifying relevant thresholds at consolidated level and only defined generic thresholds at macro level.

A focused assessment of E2 and E4 disclosures showed that the information on how impact thresholds are determined is generally not provided at the topic-level although materiality depends on the nature of topics.

 

Good practices

Conducting an assessment at the level of IRO (vs. at the higher level of topics only) is important since companies should present their IROs and how they manage them, in line with CSRD objectives.

It is key to maintain the assessment of actual and potential impact as well as risks before taking into consideration mitigation efforts, to provide a complete overview of the company’s sustainability profile (meaning not a net assessment).

The most useful data points in IRO-1 are information on the input parameters and their link with the materiality thresholds specific to sustainability topics, as well as information on the nature of financial thresholds (several good practices were identified in 2025).

These disclosures are most useful when the company specify which inputs (sources, tools) were used in relation to a particular sustainability topic (e.g. mention of databases such as UNEP’s ENCORE, WWF’s Water Risk Filter in relation to specific environmental topics or mention of specific rating tools for the business conduct topic). Many companies also cited the Aqueduct water risk tool from the Word Resources Institute to assess water-related risks.

Good practices include the following information in IRO-1:

  • a brief explanation on how criteria for impacts or risks are assessed, with concrete examples of input parameters taken into account (e.g. for the “scope” criteria: % of sites or financial expenditures related to the impact)
  • information on the difference between the assessment methodology for risks and for opportunities (cases were rare)
  • specific information on impact vs. financial materiality thresholds (see below on thresholds)
  • precise explanations on the alignment or partial alignment between financial materiality assessment and the ERM (enterprise risks management) process.

Good practices already observed for financial thresholds include:

  • Explaining the articulation with the company’s overall risk management process and ESRS thresholds (either to explain alignment or differences).
    • However, some companies provided boilerplate explanations on the alignment with the financial statement thresholds.
  • Specifying the nature of the thresholds used (e.g. based on EBITDA or revenue) or even giving the threshold itself: e.g. “critical if >27% of EBITDA”, “threshold set at a probable risk of €50 million.

 

Limits and difficulties identified by companies or auditors on the DMA

As a good practice, several companies explicitly report challenges related to the execution or scope of their materiality assessment

However, the consequences of these difficulties are not always clear (reliability of data? limited scope/coverage? etc.) and the reasons for limitations were not always given.

Examples of challenges and limits identified by companies are:

  • Difficulties in defining materiality thresholds
  • Lack of value chain data or reliability of value chain data. As a consequence, several companies focused their DMA this year on their own operations and tier-1 value chain – a company mentions in particular the lack of upstream data to assess negative biodiversity impacts and water-related IROs.
  • Difficulties in quantifying sustainability risks (translating qualitative risks into measurable financial or impact terms).
  • Risks associated with certain topics were not assessed (limited scope/coverage of the DMA assessment)

Very few auditors specifically point out limits in the company’s DMA process.

 

Source: https://www.amf-france.org/sites/institutionnel/files/private/2025-10/amf_study_csrd_reporting_the_way_forward_2025.pdf

 

When you use Cleerit ESG to structure and document your IROs and double materiality assessment you increase both ESRS compliance and make CSRD useful for your business as it will help you identifying issues material for your resilience and competitiveness. Contact us if you want to know more >>>

ESMA has analysed 91 ESRS statements for FY 2024 – key findings

As part of its objective to coordinate European supervision and enforcement related to corporate sustainability disclosures, ESMA has analysed 91 ESRS statements (whereof 31 voluntarily applied the ESRS) covering FY 2024, published by European issuers from 23 Member States listed in regulated markets, subject to limited assurance (or reasonable assurance in some cases) against ESRS.

The issuers were selected by national enforcers for the purpose of performing the analysis. Issuers with more than 1,000 employees represent 90% of the sample, while 78% have more than 3,000 employees. The median number of employees for the whole sample is close to 10,000 employees. The issuers of the sample are active in a broad variety of sectors.

ESMA’s conclusions are very valuable as it gives you information on what the financial marketplace is expecting from your sustainability reports.

Below you will a summary of the key findings related to disclosure of the double materiality assessment process (IRO-1), the disclosure of IROs (SBM-3) and auditor’s materiality considerations.

Based on these findings, ESMA urges issuers to:

  • Avoid boilerplate disclosures in the description of their materiality assessment process and provide clarity on how they have exercised judgements.
  • Whenever relevant, map their material IROs with the ESRS sustainability matters (ESRS 1 AR16) and use ESRS terminology to describe them.
  • Identify the IROs for which entity-specific disclosures are provided in addition to ESRS disclosures.
  • Disclose adopted Policies, Actions, Targets (or indicate their absence) and Metrics for each material sustainability matter, including the entity-specific matters (i.e. those that are not listed in AR16).
  • More generally, ensure that the overall objective of the sustainability statement (i.e, disclose material IROs and describe how they are managed) is met and increase usability through facilitating connections between the disclosure of material IROs and the topical disclosures.

 

KEY FINDINGS

IRO-1 Double materiality assessment process

Around 60% of the sample met the overall objective of the IRO-1 disclosure requirement, which is to provide transparency on how the double materiality assessment was conducted. Although encouraging in the first year of application, this result shows room for improvement.

80% of the issuers reported that they used their sustainability due diligence to inform the materiality assessment process. Only 3 issuers disclosed that they had no due diligence process while 8% others did not report whether they had relied on their due diligence process although they conducted one.

While demonstrating that issuers have put in place formal steps to structure their materiality assessment, some disclosures were boilerplate and did not provide meaningful insight on the judgements made regarding the materiality of their Impacts, Risks and Opportunities (IROs), in particular for impacts.

The proportion of issuers disclosing sufficient information as required under the IRO-1 topical datapoints was lower, especially when the topic was eventually not found material (54%). In addition, less than 45% of the issuers disclosed these datapoints in the General information part of the sustainability statement.

A majority of the issuers in the sample provided a separate description of the processes for identifying, assessing, prioritising and monitoring impacts, and risks and opportunities. For 22% of the sample, however, it was not the case.

While risks and opportunities derive from impacts in many cases, a description of the process for determining the materiality of the associated financial risks can provide useful insights to the user of the sustainability statement, for instance regarding how the approach that was followed relates to the overall corporate risk assessment process.

For 72% of the issuers, it was clear that the materiality assessment process considered gross impacts. For the others, the situation was either unclear, or in some cases, materiality was assessed based on net impacts (integrating mitigation or prevention measures and controls to adjust the final score of impacts and/or risks). This unclarity or divergence in practice may hinder comparability of the materiality assessment results, for instance when considering two issuers from the same sector.

Regarding the use of thresholds in the materiality assessment process, either in relation to impacts or risks and opportunities, or both, close to 80% of the sample provided some explanations on how they had set qualitative or quantitative thresholds for determining their material IROs.

This result illustrates the effort made in structuring the materiality assessment process. Two issuers provided information only on impacts thresholds, and 17 (almost 20% of the sample) did not disclose any information about thresholds.

Good practices were especially noted regarding disclosure of thresholds for financial materiality, where some issuers provided detailed information on the nature of the threshold (e.g., based on revenue or EBITDA), with some also disclosing the quantitative threshold they have set.

As an example of good practice for impact materiality when relying on a 5-level scale (e.g., no impact, low, medium, high, very high), explanations were provided that, for the scope component of severity for an environmental impact, “low” corresponds to an issue observed in one location only and “medium” in a few locations, while “high” is widespread and “very high” observed in all locations.

This shows the attention issuers have paid to formalising the materiality assessment process.

However, some of them merely replicated in their disclosures the scoring steps suggested in the Implementation Guidance [EFRAG IG1]. This led to boilerplate disclosures in some cases (especially for impact materiality), when the issuers did not explain which considerations specific to their entity have been factored into the assessment.

Good practices for information on input parameters include the mention of specific tools or methodologies (e.g., LEAP approach for environmental matters, tools for the identification of areas at high water stress) or information sources (e.g., sector benchmarks, human rights country databases).

The other issuers did not disclose sufficient information on at least one of the three broad areas provided as examples in the standard (data sources, scope or assumptions). The least reported was the assumptions. Data sources or scope were also not reported in several cases.

A slight majority of issuers in the sample (54%) provided sufficient information on the IRO-1 datapoints of the topics eventually found non-material and more than 27% of the issuers did not provide any information.

 

SBM-3 Description of IROs and entity-specific information

Most issuers in the sample (close to 90%) provided a brief description of their material IROs DP ESRS2 SBM-3 par 48 (a).

For the remaining 10 issuers, the disclosures were found to be incomplete, either because the description was missing for one or more material IROs or because it was unclear.

In particular, the description of where, in the issuer’s business model, own operations or value chain, the IRO was concentrated was missing in a limited number of cases or considered insufficient.

Many of the IROs disclosed by issuers could be mapped to the ESRS sustainability matters (as listed in Application Requirement AR16 of ESRS 1), providing clarity and comparability for the users when those were covered by standardised topical disclosures.

In some cases, however, it was unclear from the description whether the IRO was related to an AR16 sub-topic or sub-sub-topic or not.

Close to 70% of the issuers disclosed entity-specific information, either related to IROs not covered by ESRS sustainability matters or complementing the ESRS disclosure requirements.

This could demonstrate a good understanding of the requirement to complement the ESRS disclosures with entity-specific disclosures when necessary, noting however that entity-specific disclosures are not to be used where ESRS disclosures would apply.

While some issuers opted to present their material IROs with a mapping of the AR16 (ESRS 1) sustainability matters they were related to, this is not an explicit requirement of the ESRS and the use of different terminology made the reconciliation difficult for some issuers, especially when the requirement to identify IROs covered by entity-specific disclosures was not complied with.  This in turn made it difficult in some cases to ascertain that the embedded logic of the ESRS had been followed.

This logic calls for identification of the IRO and disclosure of Policies, Actions, Targets and Metrics for the related sustainability matter (or their absence) either through disclosing under the ESRS disclosure requirements or through providing entity specific disclosures. On this point, explicit signposting of the IROs covered by entity-specific disclosures as part of the SBM-3 disclosures, and of the entity-specific disclosures themselves, was noted as a good practice by national enforcers.

Notwithstanding the limitations noted above, the national enforcers sought to reconcile the IROs with the AR16 sustainability matters at topic, sub-topic and sub-sub-topic level to evaluate the granularity of the materiality assessment.

For Climate change (E1) sustainability matters, which 100% of the sample considered material, 94% of the issuers had at least one IRO referring to one of the sub-topics. For Resource use and circular economy (E5), which 78% of the issuers found material, 70% identified at least one IRO at sub-topic level.

For Own workforce (S1), national enforcers found that close to 80% of the issuers had at least one IRO which could be traced back to an AR16 sub-sub-topic. This reflects the higher granularity of the S1 sustainability matters in AR16 but also shows how, where they were provided with a more granular framework, issuers used it for conducting their materiality assessment and disclosing the results.

Depending on the topics sufficient granularity may be helpful for both preparers and users to more specifically identify the issue at stake and ensure relevant topical disclosures, either standardised or entity-specific where needed.

Regarding IROs covered by entity-specific disclosures, the largest group identified at topic level broadly relates to data, cybersecurity and use of AI. 26% of the sample disclosed an IRO related to these issues.

Some divergence in practices was noted by national enforcers as in some cases IROs which seemed similar were presented as a separate entity-specific matter, while in others they were associated with the Consumers and end users (S4) or Business conduct (G1) topics.

Guidance could be developed to help determine how these IROs can be connected with the ESRS framework and foster convergence in practice.

Other but less frequent entity-specific sustainability matters related to innovation and research, and tax.

For some of the IROs reported as material, it is questionable whether they refer to issues within scope of the sustainability statement (e.g., customers’ satisfaction, corporate citizenship).

In other cases, the limited description made it difficult to understand the related IRO (e.g., product portfolio, investment projects).

Targets

As part of the analysis, a check was conducted on whether targets had been disclosed for the sustainability matters found material, or in their absence, whether the issuer had provided a negative statement.

National enforcers found that more than 71% of the population disclosed either the targets or a negative statement. For the remainder, however, at least one target was missing with no negative statement.

This situation was more likely to be encountered in relation to social topics (especially Consumers and end users – S4) and Governance (G1) but was also noted for environmental topics for some of the issuers.

National enforcers noted that a number of targets were of a generic nature or expressed as high-level commitments.

Clear identification of the targets (as well as of policies and actions), or of their absence, in a summary table presenting them with the related material IROs and sustainability matters was noted as good practice, enabling easy reference for the user of the sustainability statement.

In a few cases, a clear indication of the non-materiality of the disclosure was missing, for instance when the issuer disclosed information on a sustainability matter which had not been considered material in the results of the materiality assessment.

Reporting of lists

Close to 90% of the sample provided a list of the disclosure requirements they had complied with. 85% reported a list of the datapoints derived from other EU legislation, with 70% reporting complete information, including whether these datapoints had been assessed to be material or not and where they could be found in the sustainability statement.

Assurance

The analysis also considered whether the auditor’s or assurance provider’s opinion referred to any materiality considerations.

For almost all issuers, the auditor or independent assurance services provider delivered unqualified limited assurance conclusions regarding the sustainability reports prepared in accordance with ESRS.

A qualified opinion was delivered for two issuers of the sample reporting under CSRD and ESRS.

The opinions pointed at significant omissions in the sustainability statement, including in relation to the materiality assessment for one of the issuers.

For four other issuers, the auditor or independent assurance services provider did not qualify its opinion but stressed materiality considerations as emphasis of matter in its opinion.

When related to the materiality assessment process, these were either of a general nature or more specific (highlighting for instance a disclosure mentioning the limitation of the materiality assessment in the supply chain to tier 1 for a specific sustainability matter).

In other cases, the emphasis of matter related to the application of the materiality regime prescribed by the ESRS (e.g., omission of material disclosures).

Emphasis of matters were also mentioned in relation to non-materiality-related reporting areas.

They pointed at, for instance, the scope limitations reported in the basis for preparation of the disclosures, the use of estimates or uncertainties associated with the quantitative metrics.

 

We strongly recommend that you use the IRO E/S/G plan in Cleerit to structure your information on IROs, policies, actions, targets and metrics related to sustainability matters in AR16 (pre-created in Cleerit), before including these the information in a tabular form into the datapoints in the ESRS templates. This will ensure that you structure the information as expected by the financial market. Don’t hesitate to contact us if you need further guidance on this point >>>

 

Source: https://www.esma.europa.eu/sites/default/files/2025-10/ESMA32-846262651-5288_Fact_finding_on_materiality_disclosures_in_sustainability_statements.pdf

The Parliament’s Committee on Legal Affairs (JURI) has voted to adopt the EPP Omnibus comprise

The 13/10 the Parliament’s Committee on Legal Affairs (JURI) voted to adopt the EPP Omnibus comprise (17 votes for, 6 against and 2 abstentions), with 4 items being particularly politically sensitive according to Jörgen Warborn (EPP):

🟣 Scope

➡️ CSRD: 1000 employees and net annual turnover above 450 M€ (this would also apply to sustainability reporting under green taxonomy rules)

➡️ CS3D: 5000 employees and net yearly turnover above 1,5 bn€ (incl foreign businesses with a net turnover in the EU above the same threshold)

For firms no longer covered by the rules, reporting would be voluntary, in line with Commission guidelines. Sector-specific reporting would also become voluntary.

The European Central Bank has expressed concerns that the reduction in scope leaves a blind spot regarding the companies’ exposition to climate-related financial risks – but Jörgen explained that he finds that “the balance is now good” and that one-to-one relations between companies and banks can fill this blind spot.

‼️ The financial markets and large companies will set the expectations with regards to reporting and due diligence. Sustainability governance and reporting is the new normal.

🟣 Transition plan (vote 13/12, most narrow majority, will it hold in the plenary vote?)

➡️ No difference made in CSRD
➡️ Transitions plans are still mandatory in CS3D
➡️ But “legally binding implementing actions” would not be required by CS3D (“saying exactly what you actually have to do”)

🟣 Civil liability issue

Businesses should be liable for damages caused by breaches of due diligence obligations under national law, rather than at the EU level.

The maximum fine level for offending companies would remain at 5% of their global turnover, and the Commission and EU member states should provide guidance for national authorities on these penalties.

➡️ Previous criticism was linked to the old CS3D according to Jörgen Warborn
➡️ Now the EU parliament, commission and council are aligned
➡️ This issue is not linked to simplification, but to the need for investments in Europe to create growth according to Jörgen Warborn

🟣 CS3D due diligence

Instead of systematically asking for information required for their due diligence assessments from their business partners, MEPs want CS3D in-scope companies to adopt a risk-based approach (different from the Council’s position, now subject to negotiations), whereby they only ask for the necessary information where there is the plausible prospect of an adverse impact in their business partners’ activities.

Next steps

Should the Parliament approve the committee mandate at the next plenary session (expected next week), MEPs and EU governments should start negotiations on the final text of the legislation on 24 October.

The final trilogy session is planned for Dec. 8, with the objective to give companies predictability for 2026.

You can listen to the press conference here: Press conference by Jörgen WARBORN (EPP, SE), rapporteur on simplified sustainability reporting and due diligence requirements – Multimedia Centre

Assessment of published ESRS statements by AMF – ESRS E1 Climate change

AMF, the French Financial Markets Authority assessed a sample of ESRS statements published by French listed companies under the CSRD for financial year 2024.

This report is very valuable as it gives you information on what the financial marketplace is expecting from your sustainability reports. Below you will a summary of the key findings related to ESRS E1 Climate change.

We strongly recommend that you use the IRO E plan in Cleerit ESG to structure your information on E1 IROs, policies, actions and targets, before including these tables into the datapoints in the ESRS templates. We also recommend that you set up a specific governance model in Cleerit to structure and report on your transition plan by decarbonisation lever. This will ensure that you structure the information as expected by the financial market. Don’t hesitate to contact us if you need further guidance on this point.

E1 Transition plans

There is an overall improvement as compared to previous non-financial statements in terms of quality and comparability (use of denominations, consistency, etc.) which highlight the added value of the ESRS.

None of the transition plans (TPs) covered in the sample can be considered compliant with all ESRS data points.

Beyond the mere “tick-the-box” exercise, AMF assessed whether TPs manage to convey a sense of the broader undertaking’s strategy which is consistent throughout the report.

In this respect major difficulties are still present in the TPs’ building blocks:

  • target-setting;
  • decarbonisation levers;
  • financial resources.

« Net-zero » targets and « GHG neutrality » claims (E1-7)

Some improvements are identified compared to previous non-financial statements: some companies deleted unclear claims from previous reports and show considerable efforts in adjusting to the ESRS framework (for example, the 90-95% reduction pathway with the possibility for justified sectoral variations, associated with a Net-Zero target).

However, there is still a lot of confusion with the use of the following concepts:

Net Zero claims, which are very popular (probably due to extensive use of SBTi external validation) are undermined by 3 types of breaches:

  • Not respecting the 90-95% reduction ambition, in both absolute and gross value.
  • Not covering the scope of GHG emissions, especially along the value chain (3 Scopes).
  • Dealing with residual emissions (5-10%): disclosures tend to be succinct or inexistant. Some issuers explain that the action plans to neutralize residual emissions are not yet fully defined.

The use of GHG neutrality claims (although less common) also raises questions:

  • Confusion with the net-zero claim (or transition plans).
  • Lack of reporting associated with the claim: cf. the 3 items of §61 of E1-7 which are important to understand the consistency of the claim with E1-4 targets and their reliance on the use of carbon credits.

AMF recommends preserving the “net-zero” concept in the revised ESRS (with a minimum 90-95% GHG reduction pathway), which the ESRS has helped to strengthen, while clarifying some aspects such as the options available for residual emissions (carbon credits + removals) and the different types of removals (transfer of CO2).

AMF recommends clarifying the expectations around “carbon neutrality claims”: emission reductions vs use of carbon credits and removals; target-setting (all Scopes, etc.) – thereby clarify the interactions between the two notions. 

Reporting on GHG emissions reduction targets

A few surprising shortcomings with regards to clear ESRS expectations:

  • Although rare, AMF still finds some targets set in intensity value for non-financial institutions. In this case, the associated absolute value is not always (clearly) displayed. For financial institutions, targets are usually set in intensity and sector-by-sector (except for fossil fuels).
  • Gross value reporting: some undertakings are setting targets in net value (taking into account removals or credits), either explicitly (rare) or implicitly. In the latter case, the information on the use of carbon credits or removals is not easy to spot.

Overall, there seems to remain some confusion around the identification of actions that are eligible as GHG reduction levers under E1-4 compared to actions that should be excluded from these targets (carbon credits, removals, avoided emissions, cf. section on E1-7).

Some companies do not make a clear distinction between GHG emission reduction in their value chain (reported under E1-4) and emissions associated with carbon credits or removals (to be reported under E17) – they are netting these different types of emissions.

This is not compliant with the requirements in E1-4 to set targets in gross value, by excluding emissions associated with removals, carbon credits and avoided emissions.

Depending on the tool used, different reporting requirements are expected: E1-4 for very specific types of removals (transfer of CO2 into geological storage) vs E1-7 for other removal and carbon credits mechanisms.

Scope 3: undertakings could also be clearer on the consistency between the scope of their targets (E1-4) and their GHG inventory boundaries (E1-6) as climate targets are sometimes set on a limited number of Scope 3 categories.

For financial undertakings, AMF is still seeing significant differences in the scope of reporting from one financial institution to the other

More generally, climate reporting tends to lack explanations around the methodology used to set targets:

  • Are they derived from a sectoral decarbonisation pathway?
  • What are the underlying scenarios?
  • Justification of the reference year; explanations on the consideration of future developments, etc.).

Good practice

Use of the “AR 48 table” that puts into perspective the GHG inventory (including Scope 3 Categories) with the entity’s targets. 

Decarbonisation levers

Qualitative description

Practices tend to be heterogenous with some companies displaying a simple list of items while others strive to be more granular (for instance, separating actions taken from actions planned for the future) and comply with MDR-A requirements [on actions] .

Overall, the latter [MDR-A] tend to be missing (time horizons, clear scope, expected outcomes…).

Financial resources allocated to the transition plan

Information on the nature and the amounts of CapEx/OpEx allocated to the transition plan is identified as the most difficult step to be taken by companies on transition planning.

This leads to various types of reporting practices (including good practices):

  • Detailed reporting by lever, by type of expenditure (Human, CapEx, Opex) and for both planned and future resources across different time horizons
  • Detailed reporting for part of the requirements (resources already planned)
  • Aggregated reporting: a few overall figures (x billion in low-carbon overall actions)
  • No quantitative reporting but with justifications: non-materiality or challenges to disentangle low carbon investments from general Capex
  • No reporting at all on financial resources

AMF noticed very few elements of reconciliation between the resources associated with the transition plan (if any– see point above) and the financial statements.

Source: https://www.amf-france.org/sites/institutionnel/files/private/2025-10/amf_study_csrd_reporting_the_way_forward_2025.pdf

When you use Cleerit ESG to structure your E1 disclosures on transition plans, IROs and PATs you increase both ESRS compliance and organizational efficiency. Contact us if you are interested in learning more >>>.

Assessment of published ESRS statements by AMF – ESRS S1 Own workforce

AMF, the French Financial Markets Authority assessed a sample of ESRS statements published by French listed companies under the CSRD for financial year 2024.

This report is very valuable as it gives you information on what the financial marketplace is expecting from your sustainability reports. We will send you the information regrouped by subject. Below you will a summary of the key findings related to ESRS S1 Own workforce.

We strongly recommend that you use the IRO E/S/G plans in Cleerit to structure your information on IROs, policies, actions and targets, before including these tables into the datapoints in the ESRS templates. This will ensure that you structure the information as expected by the financial market. Don’t hesitate to contact us if you need further guidance on this point.

The AMF (Autorité des Marchés Financiers) regulates the French financial marketplace, its participants and the investment products distributed via the markets. It also ensures that investors are properly informed and is a driving force behind regulatory change at both European and international levels. As an independent public authority, it has regulatory powers and a substantial level of financial and managerial independence. To carry out their tasks, AMF is required to regulate, authorize, monitor and where necessary, inspect, investigate and enforce.

Overall comments on ESRS S1 Own workforce first-wave disclosures (FY 2024)

For social-related topics specific information on the DMA process is provided only in very rare cases, and information on input parameters (sources/assumptions) is often not specified.

Policies, actions and targets (PAT) disclosures are overly narrative and often lack the structure and precision needed for usability and comparability. This narrative-heavy approach results in lengthy but low-informational disclosures.

While some companies articulate the alignment clearly between PATs, and their explicit linkage to the material impacts, risks, and opportunities (IROs) identified during DMA, most disclosures remain siloed, preventing readers from understanding how corporate responses are tailored to material sustainability topics.

Many companies rely on general wording, high-level ambitions, or reaffirmations of principles (e.g. alignment with international frameworks or « commitment to diversity »), without operational details.

Good practices:

  • Embedding the IRO-to-response logic systematically across S1 disclosures would enhance narrative coherence, reduce duplication, and reinforce alignment with the ESRS architecture.
  • Using tables to summarize the expected outcomes, time horizons and progress of actions, provides clearer insight into how impacts are managed.

PATs – policies, actions and targets

Human rights and DEI policies are disclosed almost systematically, but often in very boilerplate terms, without explaining how international frameworks are translated into internal processes.

DEI-related disclosures sometimes omit a breakdown of the types of discrimination addressed.

Not all concretely explain how the effectiveness of policies is monitored (internal audit mechanisms, examples of corrective actions taken in response to policy breaches…), and only a small number explain how the effectiveness of actions is assessed over time.

Very few provide information on the financial or operational resources allocated to actions.

Companies still structuring their sustainability governance and processes likely lack the tools or processes to track and disclose the associated resources deployed, even for topics deemed material.

The quality and usefulness of targets vary widely. Only a few are precise and time-bound, while others are broad qualitative aspirations.

Only a minority report on progress year-over-year, or even indicate a reference value preventing stakeholders from assessing the effectiveness of the actions deployed.

Very few companies disclose changes to targets or metrics over time, thereby missing the opportunity to explain strategic reorientations or learning processes.

Nearly none of the companies provide evidence of engagement with workers or relevant stakeholders in the design or monitoring of targets, which calls into question the degree to which the targets reflect operational priorities or workforce realities. Where engagement is mentioned, it remains high-level and provides little information about the actual performance management process.

When companies do not set targets, they either don’t indicate it or mention the absence of a target without explaining the underlying reasons (e.g. lack of data, etc.).

Gender and age breakdown metrics are valued by investors, but the prevailing disclosure approach remains largely descriptive and non-analytical, often limited to high-level figures without commentary or interpretation.

Very few companies provide a breakdown by job function, a level of detail that helps identify potential imbalances – such as age concentration in lower-level positions or lack of age diversity in management roles.

In most cases, disclosures do not discuss how age diversity is monitored or linked to workforce planning or inclusion goals. This suggests a low level of maturity in how companies use this metric as a tool for organizational development.

Source: https://www.amf-france.org/sites/institutionnel/files/private/2025-10/amf_study_csrd_reporting_the_way_forward_2025.pdf

By using Cleerit ESG to structure your S1 disclosures on IROs and PATs you will increase both ESRS compliance and organizational efficiency. Contact us if you are interested in learning more >>>.