Sustainability statement — ESRS sustainability statement

A wave 1 textile brand prepares the canonical structure of its first sustainability statement.

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  Identifies the mandatory ESRS 2 disclosures (BP-1 to IRO-2) that are reported ALWAYS.

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  Applies the double materiality matrix to identify material topicals (E1, E2, E5, S1, S2 where applicable).

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  For each material topical, deploys the required disclosures with MDR-P/A/M/T.

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  Engages an external auditor (Big Four) for limited assurance with an annual mandate.

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  Tags the sustainability statement with the ESRS XBRL taxonomy before official publication.

Common mistakes

• The sustainability statement is not a standalone report: it is a section of the management report.

  ESRS 1 ¶110, in faithful paraphrase: within the company's management report. CSRD Art. 19a inserts the obligation into a clearly identifiable and dedicated section of the management report (Dir. 2013/34/EU as amended). It is not a separate sustainability report, nor an annex, nor a standalone document — it is the dedicated section of the management report. Companies that traditionally published a separate Sustainability Report under GRI must restructure to integrate the sustainability statement within the management report with unequivocal identification.

• The four-part structure of ESRS 1 ¶115 is MANDATORY — not optional.

  ESRS 1 ¶115, in faithful paraphrase: shall structure its sustainability statement in four parts, in the following order. It is not a recommendation. The company cannot reorder the parts, regroup topicals between social and governance, or omit any part (although within each part non-material topicals are omitted with an explanation). ESRS 1 Appendix F offers a non-binding example, but the four-part structure in that order is invariant.

• The sustainability statement does not equate to Annual Report + ESG: it integrates specific obligations (Taxonomy Art. 8) already in its environmental part.

  ESRS 1 ¶115, in faithful paraphrase: environmental information (including the disclosures under Art. 8 of Regulation (EU) 2020/852) — the EU Taxonomy information (Art. 8 Reg. 2020/852, which requires companies to disclose turnover, CapEx and OpEx aligned with environmental objectives) is an integral part of the Environmental section of the sustainability statement, not a separate annex nor a distinct report. Companies with separately published Taxonomy reports must integrate them into Part 2.

• Limited assurance is MANDATORY from the first financial year — it is not voluntary.

  CSRD Art. 1 point 7 amends Art. 34 of Dir. 2013/34/EU, requiring limited assurance of the sustainability statement by a statutory auditor or independent assurance services provider. The application date follows the staggered timetable of CSRD Art. 5(2): 1 Oct 2026 for large PIEs (public-interest entities). Reasonable assurance is foreseen from 1 Oct 2028, conditional on the Commission adopting standards. The company cannot opt to publish without assurance.

• The sustainability statement must be published in XHTML with datapoints tagged in XBRL — it is not a static PDF.

  ESRS 1 ¶111(b), in faithful paraphrase: in a format that is both human-readable and machine-readable. The format is the European Single Electronic Format (ESEF, Delegated Reg. 2018/815 as amended) — human-readable XHTML with datapoints tagged in XBRL. EFRAG IG 3 (May 2024) provides the official list of 161 mandatory datapoints + 622 subject to materiality + 269 voluntary taggable datapoints. Companies with a static PDF sustainability statement do not comply with ESRS 1 ¶111(b).

Frequently asked questions