From The Trenches
CSRD Hub Newsletter #6
July 2024

​A major area of focus for many companies is S1.

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Not only is it the single standard with the largest number of disclosures, but it is also one that is likely to be included by most companies. It is also the standard that most early ESRS adopters were likely to include in their reports this year.

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Let’s take a closer look at a few lessons from companies in building their S1 disclosures.

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Requirements scavenger hunt

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S1 requires a close reading of the full set of standards materials, particularly the Application Requirements.

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Most S1 Disclosure Requirements have mandatory Application Requirements that span required definitions of terms to required formats. In addition, extensive references to global instruments and other regulations mean that a careful and full reading before getting started is critical.

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Pay particular attention as well to the S1-specific IRO-1, which outlines topics and measures which should be included as part of the materiality assessment.

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Headcount, FTEs, and non-employee workers

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Measuring the number of employees for sustainability reporting has always been somewhat challenging, given some companies report FTEs and others headcount.

In S1, some metrics require headcount, while others allow for FTEs. In addition, some include employees only, while in other cases, non-employee workers are also required. Sorting these out first is critical.

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Keep in mind also that these figures should be closely reconciled to the numbers used in the financial statements, and some (such as S1-6) will require a direct reference to the corresponding metrics in the financial sections of the report.

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Definitions matter (and so do national / local variations)

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One element that makes workforce reporting challenging is the varied definitions of worker and worker definitions. This remains in S1, but a few other variations are worth noting.

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First, ESRS doesn’t define disabilities specifically under S-12, but requires reporting in line with legal definitions (and limitations). The standard does, however, address the UN Convention on the Rights of Persons with Disabilities (UNCRPD): “Persons who have long-term physical, mental, intellectual or sensory impairments which in interaction with various barriers may hinder their full and effective participation in society on an equal basis with others.”

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Another area requiring national or local input is adequate wage. While adequate wage is defined at a high level, how it is calculated depends on location.

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Taking inspiration

 

Several companies have done a good job incorporating comprehensive S1 disclosures into their “test run” ESRS reports.

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Allianz

Allianz’ 2023 Annual Report includes extensive S1 reporting using required formats across the metrics section. This is a great example in particular for large organizations with a global footprint.

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Scan Global

Scan Global’s Sustainability Report is built based on the ESRS structure and includes good narrative information for most S1 disclosures. They haven’t fully incorporated the required formats outlined in Application Requirements, but most data are included.

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Recticel

Recticel’s 2023 Annual Report includes a sustainability section aligned to the ESRS structure, including a helpful index and effective use of formats and data as outlined in S1. They note clearly where a disclosure may not yet be included because the materiality assessment is ongoing.

 

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We are finalizing our comprehensive S1 topical training, which we would be happy to discuss in more detail.

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In case you missed it

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- We Mean Business: EARLY ADOPTERS’ CSRD REPORTING. This guide could have been much more robust if best practice examples tied more directly to specific disclosures and requirements, but for those looking for especially climate-related disclosures (transition plans in particular) and a list of ESRS early adopters, this might provide new information. See the list of reports in the appendix.

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CEAOB: Draft Guidelines on Limited Assurance in Sustainability Reporting. The CSRD requires the adoption of limited assurance standards by the European Commission by 1 October 2026 at the latest to clarify what is expected from practitioners when carrying out a limited assurance engagement regarding the sustainability information reported pursuant to the ESRS.

Absent those standards, this document is intended to provide high level assistance to facilitate a common understanding of some of the key aspects of the limited assurance engagement requirements introduced by the CSRD. While not a protocol or assurance standard per se, insights into what assurance providers pay attention to is outlined, including in terms of completeness, and consistency of process.

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EFRAG Connectivity Project. Many organizations face the challenge of where to include the broad range of required sustainability data in ways that are comprehensive yet understandable and with minimal duplication. EFRAG has published a new paper on connectivity considerations for sustainability and financial information in the annual report.

While not part of ESRS guidance, it aims to help practitioners understand ways in which information across sustainability and financial sections could be better connected, including via location and through consistency of narrative.

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EFRAG and TNFD Reveal Strong Alignment Between ESRS and TNFD Recommendations 

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The IFRS will assume responsibility for the Transition Plan Taskforce (TPT) Disclosure Framework  and associated guidance and materials. As many tackling ESRS know, the transition plan is a core focus of E1.​​​​

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Become smarter in CSRD with SmartCSRD:

 

All CSRD Hub members now have access to SmartCSRD, a chatbot designed to answer your CSRD-related questions. Users are asking insightful questions and getting valuable support for their CSRD projects. Check out some of the brilliant queries being explored!

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- I'm doing my double materiality assessment and want. to take into account my customers perspectives while identifying IROs related to them and downstream value chain. In order to get these insights from customers, I am interviewing our head of sales who will be representing all my customers. Give me a list of questions that I can ask this person?

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- What is the difference between business relationships and affected stakeholders?

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- How to identify a list of impacts, risks, and opportunities for CSRD double materiality assessment (before scoring)?

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You can start asking questions NOW! Click on the image below