ESRS structure and data model

The Commission Q&A describes 12 ESRS: two cross-cutting standards, five environmental standards, four social standards, and one governance standard. ESRS 1 contains general principles and does not itself set specific disclosure requirements. ESRS 2 contains general disclosures and is mandatory for all companies in CSRD scope.

For the data model, treat ESRS 1 as the rulebook for concepts such as double materiality, reporting boundaries, value-chain information, time horizons, and presentation. Treat ESRS 2 and topical standards as disclosure modules that can produce reportable data points, narrative text, metrics, policies, actions, targets, and cross-references.

EFRAG IG 3 is useful for building the human-readable reporting inventory, but it is not the binding standard and it is not the digital XBRL taxonomy. The grounding material states that IG 3 presents the complete list of disclosure requirements in sector-agnostic standards, except ESRS 1 because ESRS 1 does not set disclosure requirements.

Use the IG 3 structure as a control inventory: standard, disclosure requirement, paragraph, datapoint text, data type, phase-in field where relevant, materiality status, source system, owner, evidence, and report location. The inventory should distinguish mandatory ESRS 2 and IRO-1 datapoints from datapoints that become reportable only when the topic is material.

A maintainable ESRS data model should separate requirement metadata, reporting judgments, source data, evidence, and publication output. Combining all of those into one collection spreadsheet makes assurance and digital tagging harder because the same field is asked to serve legal interpretation, workflow control, and report production at the same time.

Use stable identifiers that can survive report drafting changes. The paragraph reference and taxonomy concept are not the same thing: a paragraph reference anchors the legal requirement, while a taxonomy concept or dimension anchors machine-readable tagging. Keep both, and allow many-to-many relationships where one narrative disclosure maps to several tags or one tag is reused across related disclosures.

Do not treat the IG 3 datapoint workbook as the machine-readable taxonomy. The XBRL taxonomy explains that EFRAG developed a digital taxonomy for ESRS Set 1 and a separate Article 8 taxonomy, while ESMA is responsible for defining authoritative tagging rules for digital reporting under ESRS Set 1 through the ESEF regulatory process.

The practical implication is simple: design the human-readable sustainability statement so it is easy to tag later, but keep a separate tagging layer. That layer should capture XBRL concepts, dimensions, units, period type, scale, hidden facts where needed, and review status without forcing report writers to draft in taxonomy order.

CSRD digital reporting is expected to include sustainability reporting and Article 8 EU Taxonomy disclosures in the electronic reporting format. EFRAG's Article 8 XBRL Taxonomy material says EFRAG is transposing Article 8 disclosure requirements into machine-readable format as technical support, not defining the legal content of those requirements.

Model Article 8 data as its own sub-ledger. It uses different concepts from ESRS topics: economic activities, eligibility, alignment, turnover, CapEx, OpEx, environmental objectives, DNSH criteria, minimum safeguards, financial-undertaking templates, and nuclear or fossil gas templates where relevant. Then connect the Article 8 outputs to the sustainability statement and digital-tag review.

The data model is ready for report drafting only when the company can trace every disclosure from ESRS source to materiality conclusion, owner, evidence, report location, and tagging treatment. Missing fields should stop publication review, not be left as late-stage copy edits.

The most common failure pattern is mixing three tasks: deciding what is material, collecting the data, and deciding how the disclosure will be tagged. Keep those decisions linked but distinct so assurance reviewers and digital reporting specialists can test them independently.