Datapoint — the minimum unit of information in the ESRS sustainability statement

A textile brand reporting CSRD wave 1 navigates the corpus of datapoints applying a double-materiality filter. It deploys the applicable ones in its Sustainability Statement and explicitly declares the discarded ones.

• Mandatory

  It reports the 84 mandatory datapoints of ESRS 2 General Disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) without exception.

• Material E1

  It reports ~78 datapoints of E1 Climate Change with MDR-P/A/M/T + Scope 1+2+3 + transition plan + SBTi 1.5°C targets.

• Material S1

  It reports ~52 datapoints of S1 Own Workforce with policies + actions + metrics (gender pay gap, accidents, training).

• NOT material

  It does NOT report topical datapoints of E4 Biodiversity (concluded as NOT material in IRO-1) except the E4-specific IRO-1 which remains mandatory.

• XBRL

  It tags each reported datapoint with its canonical ESRS XBRL tag. The Sustainability Statement is published in xHTML format with embedded XBRL.

Common mistakes

• "Datapoint" is not equivalent to "KPI" or "metric" — it also includes narrative sub-elements.

  ESRS 1 ¶16 in faithful paraphrase: the term "datapoint" may also refer to a narrative sub-element of a Disclosure Requirement. A datapoint may be a figure (Scope 1 emissions in tCO₂eq), a percentage (% gender pay gap), a binary field (YES/NO on a human-rights policy in C6 VSME) or a narrative sub-block (description of the due-diligence process under GOV-4). Quantitative KPIs are a sub-category within datapoints — most ESRS datapoints are narrative.

• Not all datapoints are mandatory: 622 depend on the materiality analysis and 269 are voluntary.

  EFRAG IG 3 ¶4 + footnote 1 in faithful paraphrase: 161 datapoints mandatory irrespective of materiality + 622 subject to materiality + 269 voluntary "may disclose". ESRS 1 ¶29 only requires the General Disclosures of ESRS 2 to be disclosed (i.e. all the disclosure requirements and datapoints specified in ESRS 2) and the disclosure requirements (including their datapoints) of the topical ESRS related to the disclosure requirement IRO-1. A well-conducted materiality analysis can legitimately reduce the report to a subset of the 1,052 — but only within the 622 subject to the filter.

• When a datapoint from Appendix B (derived from other EU legislation) is omitted, it must be explicitly declared "not material".

  ESRS 1 ¶35 in faithful paraphrase: if the company omits the information prescribed by a datapoint deriving from other EU legislation listed in Appendix B of ESRS 2, it shall explicitly declare that the information is "not material". ESRS 2 IRO-2 ¶56 requires the table with all the Appendix B datapoints indicating location or "not material". Silently omitting an Appendix B datapoint (without the explicit declaration) breaches the standard — it is one of the most frequent errors in the first exercise.

• A datapoint is not the unit of digital tagging: it is the unit of information — tagging is the XBRL representation of the datapoint.

  Each datapoint (quantitative or narrative) has a unique identifier in the XBRL ESEF taxonomy. Digital tagging is the process of marking the datapoint with its identifier so that it is machine-readable per ESRS 1 ¶111(b) in faithful paraphrase. EFRAG IG 3 (May 2024) lists the taggable identifiers. A sustainability statement with datapoints without XBRL tagging breaches the ESEF and does not allow automated extraction by supervisors or investors — it breaches ESRS 1 ¶111(b).

• The figure of 1,052 datapoints corresponds to the sector-agnostic perimeter — the sectoral ESRS will add more when adopted.

  EFRAG IG 3 ¶4 covers the 12 cross-cutting and topical sector-agnostic standards adopted by Delegated Reg. (EU) 2023/2772. The sectoral ESRS (e.g. textiles when adopted) will add additional datapoints. Communicating "1,052 datapoints in total ESRS" as an invariant figure is incorrect as the sectoral ones are adopted — ESRS 1 ¶10 anticipates this progressive increase.

Frequently asked questions