FAQCSRDESRS

CSRD topical ESRS scoping What must be reported after the materiality assessment

Under ESRS, ESRS 2 applies irrespective of the topic. Topical ESRS disclosures are scoped through double materiality, but material disclosure requirements are not optional.

This FAQ explains how to decide which topical standards, disclosure requirements, datapoints, and omitted-topic explanations belong in the sustainability statement.

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Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Questions
4

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

Topical ESRS scoping under the CSRD starts with the double materiality assessment. ESRS 2 general disclosures still apply, while environmental, social, and governance topical standards are reported when the related impacts, risks, opportunities, disclosure requirements, or datapoints are material.

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4 of 4 questions
Question 1

Does every CSRD reporter have to report every topical ESRS?

No. The Commission explains that ESRS 2 General Disclosures is mandatory for companies in CSRD scope, while the other standards, disclosure requirements, and datapoints are subject to materiality assessment. That means the undertaking reports relevant information and may omit information that is not material for its business model and activity.

This does not make topical disclosure requirements voluntary. If a topical matter, disclosure requirement, or datapoint is material under ESRS double materiality, the information has to be disclosed. The materiality assessment itself is part of the assurance perimeter under the Accounting Directive framework.

  • Start with ESRS 2 because its cross-cutting disclosures apply irrespective of which sustainability matter is considered.
  • Assess topical ESRS by impacts, risks, and opportunities, including both impact materiality and financial materiality.
  • When a topical matter is material, use the related ESRS disclosure requirements to identify the information to report.
  • If a material impact, risk, or opportunity is not covered or is insufficiently covered by ESRS, add entity-specific disclosure rather than leaving the matter unexplained.
Citations
Question 2

How should teams scope topical ESRS after finding a material matter?

Move from the material sustainability matter to the related disclosure requirements, then to the specific datapoints needed to meet those requirements. EFRAG's implementation guidance describes this as determining material matters first and then determining material information at the more granular level of disclosure requirements or datapoints.

The assessment should cover the undertaking's own operations and upstream and downstream value chain. It should also apply objective criteria and thresholds that fit the undertaking's facts and circumstances, because ESRS does not mandate one fixed sequence of steps for the materiality assessment.

  • Identify actual and potential impacts, risks, and opportunities connected with the topic.
  • Decide whether the matter is material from the impact perspective, financial perspective, or both.
  • Map material matters to ESRS topical standards and disclosure requirements.
  • Apply materiality of information at disclosure-requirement and datapoint level so the sustainability statement includes relevant, faithful, decision-useful information.
  • Document thresholds or criteria used to determine which information is material, because ESRS 2 IRO-2 requires an explanation of that determination.
Citations
Question 3

What must still be disclosed when a topical ESRS is not material?

A non-material topical ESRS is not simply invisible. ESRS 2 IRO-2 requires the sustainability statement to list the disclosure requirements complied with and to make understandable which topics were omitted as not material as a result of the materiality assessment.

If climate change is assessed as not material and the undertaking omits all ESRS E1 disclosure requirements, ESRS 2 requires a detailed explanation of the materiality-assessment conclusions for climate change, including forward-looking analysis of conditions that could make climate change material in the future. For other non-material topics, the undertaking may provide a brief explanation of the materiality-assessment conclusions.

  • Provide the ESRS 2 IRO-2 list of disclosure requirements included in the sustainability statement, with page or paragraph references.
  • Explain how material information was determined for the material impacts, risks, and opportunities that are reported.
  • For a fully omitted ESRS E1 Climate change standard, include the detailed non-materiality explanation and forward-looking analysis required by ESRS 2.
  • For other fully omitted topical ESRS, consider a brief explanation of the materiality-assessment conclusion so users can understand why the topic is absent.
Citations
Question 4

How do Appendix B and EU-law datapoints affect topical ESRS scoping?

Some ESRS datapoints correspond to information needed under other EU sustainable-finance frameworks, including SFDR, benchmark, and Capital Requirements Regulation disclosures. ESRS 2 IRO-2 requires a table of all Appendix B datapoints that derive from other EU legislation, showing where they appear in the sustainability statement or marking them as not material.

For these EU-law datapoints, silence is not enough when the undertaking assesses the datapoint as not material. The table must still identify the datapoint and indicate Not material. That is different from many other omitted non-material metrics, where omission after a structured materiality assessment can be implicit.

  • Build a content index for disclosure requirements included in the sustainability statement.
  • Maintain an Appendix B datapoint table for EU-law-derived datapoints.
  • When an Appendix B datapoint is not material, mark it as Not material in the table rather than just omitting it.
  • Keep the basis for not-material conclusions aligned with the same materiality thresholds and criteria used for other ESRS information.
Citations
Recommended next step

Review topical ESRS scoping before drafting disclosures

Use the materiality assessment, ESRS 2 IRO-2 content index, and Appendix B datapoint table to decide which topical ESRS disclosures belong in the sustainability statement.

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Check CSRD and ESRS scoping questions against cited source material.

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Discuss CSRD and ESRS implementation

Review materiality outcomes, topical ESRS coverage, and sustainability-statement evidence with Sorena.

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Primary sources

References and citations

ESRS implementation guidance documents
efrag.org
Referenced sections
  • Identifies EFRAG's non-authoritative IG 1 materiality guidance, IG 2 value-chain guidance, and IG 3 datapoint list as implementation support for ESRS scoping.
"non-authoritative implementation guidance"
European sustainability reporting standards (ESRS)
xbrl.efrag.org
Referenced sections
  • Supports the ESRS 2 IRO-2 Appendix B table requirement for EU-law-derived datapoints and the instruction to indicate Not material where applicable.
"the undertaking shall indicate "Not material" in the table"
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