MDR — Minimum Disclosure Requirements (Policies, Actions, Metrics, Targets)

A textile brand that has identified E1 Climate Change as a material matter in its IRO-1 + SBM-3 matrix must report the four MDR categories for that topic in its Sustainability Statement.

• MDR-P

  A decarbonisation policy approved by the Board in 2024 with a cradle-to-grave scope. Documented due process.

• MDR-A

  Actions 2025-2027: transition of tier 2 suppliers to solar spinning with capex allocated in the strategic plan.

• MDR-M

  Metrics: Scope 1+2 via the GHG Protocol; Scope 3 categories 1+11+12 via the PEFCR Apparel & Footwear v3.1 methodology.

• MDR-T

  Approved SBTi 1.5°C target: -42 per cent Scope 1+2 vs 2023 baseline; -25 per cent absolute Scope 3 by 2030. Biennial review by the Sustainability Committee.

Common mistakes

• MDR is not a separate Disclosure Requirement: it is a cross-cutting skeleton applied to each material topical.

  ESRS 2 ¶60 in faithful paraphrase: the MDR are applied together with the Disclosure Requirements (including their Application Requirements) of the relevant topical and sector ESRS. The MDR are not reported as a standalone topical — they are applied IN EACH material topical (E1, E3, S1, S2, S3, G1, etc.). A company with 6 material topicals applies MDR-P/A/M/T 6 times, once for each topical, with the specific content of each.

• The canonical order of the MDR is Policies → Actions → Metrics → Targets — not MDR-A first.

  EFRAG IG 3 ¶4 footnote 1 in faithful paraphrase: "Minimum Disclosure Requirements on Policies, Actions and Targets". ESRS 2 §4.2 lists MDR-P first (¶63-65), MDR-A second (¶66-69) in the policies and actions chapter; ESRS 2 §5 lists MDR-M first (¶73-77), MDR-T second (¶78-81) in the metrics and targets chapter. The logical sequence: the policy defines the what and the why; the actions implement; the metrics measure; the targets quantify the destination. Reporting in the wrong order hampers comparability and the readability of the sustainability statement.

• The absence of a policy, action or target must be declared explicitly — it is not silently omitted.

  ESRS 2 ¶62 on policies and actions in faithful paraphrase: if the company cannot disclose the information on policies and actions required by the applicable ESRS because it has not adopted policies or actions relating to the specific material matter, it shall disclose that circumstance and the reasons why it has not adopted them. ¶72 applies analogously to targets. ¶81 adds: if there are no targets, disclose whether the company will set them + timeframe + alternative level of ambition. The company may NOT skip MDR-P/A/M/T silently — it must declare the absence and justify it.

• MDR-M metrics include entity-specific ones, not only those predefined in the ESRS.

  ESRS 2 ¶76 in faithful paraphrase: the metrics include those defined in the ESRS and those identified on an entity-specific basis, whether taken from other sources or developed by the company itself. If a textile company defines an entity-specific metric (e.g. % of GRS-certified recycled fibre or % of garments with a DPP-ready QR), it must document it under MDR-M ¶77 with methodology, assumptions, external validation (if any), name and unit — the same rigour as for standard ESRS metrics.

• MDR-T targets must be measurable, time-bound and outcome-oriented — not vague or process goals.

  ESRS 2 ¶79(b) in faithful paraphrase: measurable, time-bound and outcome-oriented targets, set by the company to achieve the policy objectives, defined in terms of the expected outcomes for people, the environment or the company in relation to material impacts, risks and opportunities. The three conditions are cumulative: (1) measurable (quantifiable), (2) time-bound (with a specific deadline), (3) outcome-oriented (focused on the external outcome, not internal effort). Targets such as "improve the sustainability of the chain" do not qualify — they must be "90% of tier 1 suppliers audited with a code of conduct in force by 31 Dec 2027".

Frequently asked questions