ESRS E2 Pollution Disclosure Requirements: What Your Client’s File Needs

When ESRS E2 applies and when it doesn’t

ESRS E2 is a materiality-gated standard. Unlike E1, there is no special justification requirement if pollution is assessed as not material. If the double materiality assessment concludes that pollution creates no material impacts, risks, or opportunities, the company simply doesn’t report on E2. No explanation is required beyond the standard ESRS 1 paragraph 30 disclosure.

Four sub-topics fall within E2’s scope: pollution of air, pollution of water, pollution of soil, and microplastics. A fifth area, substances of concern (SoC) and substances of very high concern (SVHC), cuts across the first four. Companies can assess materiality at the sub-topic level. A manufacturing client with significant air emissions but negligible water discharges can report on air pollution without reporting on water, provided the DMA supports that conclusion.

Context-specificity matters more in E2 than in most other ESRS standards. The November 2025 draft added a new paragraph (paragraph 8) stating that if material pollution-related impacts are concentrated in specific geographies, companies should consider disaggregating disclosures by site or region. A client with one heavily regulated facility and four clean office locations shouldn’t report a single blended pollution figure. Assurance providers should expect site-level data for the material locations.

The materiality trigger for E2 most commonly fires for companies in manufacturing (chemicals, coatings, metals, food processing in particular), mining, waste management, and industrial agriculture. But it can also apply further downstream. A retailer selling products containing SVHC above the 0.1% weight-by-weight REACH threshold has a potential E2 disclosure obligation if that exposure creates material impacts or risks. The question isn’t whether the company produces pollution directly; it’s whether pollution-related impacts or risks are material to the business model.

The six disclosure requirements explained

ESRS E2 contains six numbered disclosure requirements in two blocks: impact, risk, and opportunity management (E2-1 through E2-3) plus metrics and targets (E2-4 through E2-6). The structure mirrors the other environmental ESRS standards.

E2-1: Policies related to pollution (paragraph 10)

The company discloses its pollution-related policies in accordance with ESRS 2 GDR-P. This is a qualitative disclosure. The policy description should cover how the company prevents and controls pollution across its operations and, where material, its value chain. For assurance, the testable question is whether a documented policy exists and whether the disclosed description matches operational reality. A policy that describes “zero discharge to surface water” when the client holds a water discharge permit is an internal consistency issue that will surface during procedures.

E2-2: Actions and resources related to pollution (paragraph 11)

The company discloses its key pollution-related actions and the significant resources allocated to implementing them, per ESRS 2 GDR-A. The disclosure must include quantified resource allocation (OpEx and CapEx) where material. A company spending €1.2M on flue gas treatment upgrades should disclose that figure here, connected to the specific action it funds.

The distinction between E2-2 and E2-1 is straightforward: E2-1 describes the policy intent, E2-2 describes the money and effort behind it. If your client has a policy but no budgeted actions, that’s a legitimate disclosure under the standard, but it’s also a red flag for the assurance provider testing whether the policy is genuine or aspirational.

E2-3: Targets related to pollution (paragraph 12)

Pollution-related targets per ESRS 2 GDR-T. Targets must be specific and measurable. “Reduce pollution” is not a target. “Reduce NOx emissions at the Antwerp facility by 30% against the 2024 baseline by 2028” is. The standard references the Science-Based Targets Initiative for Nature (SBTN) interim guidance as one methodology for setting targets tied to ecological thresholds, though using it is not mandatory.

Companies can also reference the EU Taxonomy’s Substantial Contribution criteria for Pollution Prevention and Control when defining their targets (per the application requirements in Appendix B). This creates a useful link between the E2 target disclosure and the company’s Taxonomy reporting, if applicable.

E2-4: Pollution of air, water, and soil (paragraphs 13–16)

This is the core quantitative disclosure. The company reports the amounts of material pollutant emissions to air, water, and soil from its own operations, including emissions from environmental accidents during the reporting period. Emissions must be presented in appropriate mass units (tonnes, kilograms) for each pollutant.

The boundary matters. The seven greenhouse gases covered by ESRS E1 (CO2, CH4, N2O, HFCs, PFCs, SF6, NF3) are excluded from E2-4. Everything else belongs here: NOx, SOx, particulate matter, volatile organic compounds (VOCs), heavy metals, ozone-depleting substances (ODS), and ammonia (NH3). ESRS E2 paragraph 9(a) makes this exclusion explicit.

E2-4 also covers microplastics. Companies must disclose primary microplastics released to the environment (those intentionally manufactured at small size). The July 2025 draft added a provision for secondary microplastics, those resulting from the breakdown of larger plastic items or produced unintentionally during the product lifecycle. For secondary microplastics, the standard permits qualitative or quantitative disclosure, including estimates. This reflects the genuine measurement difficulties in this area.

For companies already reporting under the European Pollutant Release and Transfer Register (E-PRTR, now superseded by Regulation (EU) 2024/1244 establishing the Industrial Emissions Portal), much of the data required by E2-4 will already exist. Application Requirement AR 4 explicitly notes this overlap. Use existing E-PRTR/IEPR data as the starting point and supplement where the ESRS disclosure requires additional granularity.

E2-5: Substances of concern and substances of very high concern (paragraphs 17–19)

This disclosure covers the company’s production, use, distribution, and commercialisation of SoC and SVHC. Paragraph 17 states the objective: to help users understand the material impacts on health and the environment stemming from these substances.

The July 2025 amendments introduced a significant scope restriction. Detailed requirements in paragraph 17 now apply only to undertakings operating in the chemical sector, defined as companies manufacturing chemical substances (NACE code C.20 and related activities). A retailer or distributor handling products containing SVHC may still need to disclose under E2-5 if the substances create material impacts, but the required level of detail is lower than for a chemical manufacturer.

For chemical sector companies, the disclosure must include total volumes of SoC and SVHC produced, used, or commercialised, split by substance or substance group. SVHC are defined by reference to the REACH Regulation (Regulation (EC) No 1907/2006) candidate list. The 0.1% weight-by-weight threshold in REACH Article 33 is the de facto quantitative trigger for article-level disclosure.

This distinction between chemical manufacturers and other companies is one of the most practically significant changes in the July 2025 draft. During the first reporting cycle, the uniform application of E2-5 created confusion for downstream users who didn’t manufacture substances but handled products containing them. The revised approach gives proportionate treatment without removing the disclosure obligation entirely.

E2-6: Anticipated financial effects from pollution-related risks (paragraphs 20–22)

The company discloses anticipated financial effects from material pollution-related risks and opportunities. This includes operating and capital expenditures related to pollution incidents and environmental remediation, as well as an assessment of products and services at risk over short, medium, and long time horizons. AR 31 and AR 32 clarify that incidents include production interruptions arising from supply chain or own-operations pollution events.

This disclosure pairs with the financial statements. An environmental provision recognised under IAS 37 for site remediation should be consistent with the pollution risk quantified here. If E2-6 discloses a €3M remediation liability over the medium term and the financial statements show no provision or contingent liability, the assurance provider has a cross-referencing issue that will appear in testing.

The E1/E2 boundary: which emissions go where

This is the most common classification question across the environmental standards. The answer is straightforward but easy to overlook in practice.

ESRS E1 covers seven greenhouse gases: CO2, CH4, N2O, HFCs, PFCs, SF6, and NF3. These are disclosed in E1-8 (gross emissions) and explicitly excluded from E2-4. ESRS E2 paragraph 9(a) states this directly.

Everything else falls under E2-4. NOx, SOx, particulate matter, VOCs, ammonia, heavy metals, ozone-depleting substances, and water pollutants all belong in the pollution standard. Some of these substances are connected to climate change (NOx contributes to tropospheric ozone formation; ODS deplete the stratospheric ozone layer), but they are reported under E2, not E1.

The practical implication: a client’s air emissions report from a regulated facility will contain both GHGs (E1-8) and non-GHG pollutants (E2-4). Your assurance working paper should map each reported substance to the correct standard. Double-counting (reporting methane in both E1-8 and E2-4) and omission (reporting only GHGs while overlooking NOx) are both findings.

Water pollutant disclosures also require attention to the E2/E3 boundary. ESRS E3 (Water and Marine Resources) covers water consumption volumes and water stress. Pollutant loads discharged to water belong in E2. A client discharging treated wastewater containing quantifiable concentrations of heavy metals or nitrogen reports the volumes in E3 and the pollutant loads in E2.

What the July 2025 amendments changed

The Amended ESRS Exposure Drafts published in July 2025 made four changes to ESRS E2 that affect how practitioners document the file.

Context-specific disaggregation is now explicitly called for. New paragraph 8 states that when pollution-related impacts are concentrated in specific geographies or sites, the company should consider disaggregating disclosures. This isn’t a new requirement per se, since ESRS 1 Chapter 3.3.2 already covered aggregation principles. But the explicit mention in E2’s own text signals that regulators and assurance providers should expect site-level data where pollution is localised.

The chemical sector restriction on E2-5 is new. Previously, the substances of concern disclosure applied broadly to any company producing, using, distributing, or commercialising SoC and SVHC. Paragraph 17 now narrows the detailed disclosure requirements to companies manufacturing chemical substances. Other companies may still disclose under E2-5 if substance-related impacts are material, but at reduced granularity.

Secondary microplastics disclosure was added to E2-4. The 2023 version covered only primary microplastics (intentionally manufactured). July 2025 extends the scope to secondary microplastics (resulting from breakdown of larger plastics or produced unintentionally during the product lifecycle), though with a lower evidence threshold allowing qualitative information or estimates.

Value chain recognition was strengthened. The amended text more clearly acknowledges that pollution reporting may need to extend beyond own operations. Transfers of water pollutants to external treatment facilities, for example, may require entity-specific disclosures when material. This has implications for companies that outsource wastewater treatment and previously reported only on their own direct discharges.

The broader Omnibus context also affects E2. The stop-the-clock directive delays Wave 2 and Wave 3 reporting by two years. The Omnibus I Content Proposal narrows the CSRD’s scope to companies with at least 1,000 employees and €450M net turnover. Assurance requirements stay at limited assurance permanently (the Omnibus removes the planned transition to reasonable assurance). For mid-market audit firms, this means the E2 reporting population will be smaller than originally anticipated, but the companies that remain in scope will be larger and more likely to have material pollution exposures.

Worked example: documenting E2 for a Belgian chemical distributor

Claus & Maertens NV, a Ghent-based chemical distributor with €48M revenue and 95 employees. One warehouse with solvent handling and repackaging operations. Distribution of industrial cleaning products across Benelux.

Step 1. Confirm E2 materiality at sub-topic level

The DMA identifies pollution of air as material (VOC emissions from solvent handling in the warehouse, approximately 8.2 tonnes per year based on the company’s existing Flemish environmental permit reporting). Pollution of water is not material (no process water discharge; only domestic wastewater to municipal treatment). Pollution of soil is not material (no historical contamination, site on concrete slab with containment bunding). Microplastics are not material (products are liquid chemical formulations, no plastic pellet handling).

Substances of concern are material: Claus & Maertens distributes and repackages four products containing SVHC above the 0.1% w/w REACH threshold (two containing diisocyanates, two containing chromium trioxide). The company is a distributor, not a chemical manufacturer, so the detailed paragraph 17 requirements for the chemical sector do not apply. Disclosure under E2-5 still applies because the substance-related impacts are material, but at reduced granularity.

Step 2. Disclose pollution-related policies (E2-1)

Claus & Maertens has a documented VOC management policy linked to its Flemish VLAREM II permit conditions. The policy sets annual VOC emission limits per product category and describes the extraction and carbon filtration system in the repackaging hall. The working paper confirms the policy exists, is dated, and was approved by the managing director in January of the reporting year.

Step 3. Report VOC emissions (E2-4)

Total VOC emissions for the reporting period: 8.2 tonnes. Source: the company’s annual Flemish E-PRTR declaration (submitted to VMM, the Flemish Environment Agency). The working paper cross-references the E-PRTR submission number and the measurement methodology (mass balance based on solvent purchase and product output volumes).

No other pollutant emissions to air are material. No pollutant emissions to water or soil are reportable. No microplastics disclosures apply. The seven GHGs are excluded from this disclosure per ESRS E2 paragraph 9(a) and reported under E1-8 where applicable.

Step 4. Disclose substances of concern (E2-5)

Claus & Maertens distributes products containing two SVHC categories: diisocyanates (used in polyurethane coatings, two product lines, total distributed volume 42 tonnes in the reporting period) and chromium trioxide (used in metal treatment products, two product lines, total distributed volume 6.8 tonnes). Because the company isn’t a chemical manufacturer, disclosure stays at the reduced granularity level: substance categories, total volumes, and a description of the material impacts (occupational health risk for downstream users, potential soil contamination from improper handling).

The disclosure notes that chromium trioxide is on the REACH Authorisation List (Annex XIV) and that continued distribution depends on the supplier holding a valid authorisation. This fact also forms the basis for the E2-6 anticipated financial effect.

Step 5. Quantify anticipated financial effects (E2-6)

One material financial effect: if the chromium trioxide authorisation held by Claus & Maertens’ supplier expires without renewal (current expiry: September 2030), the company loses approximately €1.9M in annual revenue from the two affected product lines. That represents 4% of total revenue. The disclosure states the exposure amount, the time horizon (medium-term, 2028–2032), and the trigger condition (REACH authorisation expiry). Use the financial ratio calculator to assess this revenue concentration risk relative to the client’s overall margin and liquidity position.

This file demonstrates a proportionate E2 disclosure for a company where pollution is material but concentrated in two areas: VOC emissions and SVHC distribution. Working papers connect every datapoint to a named source document, apply the E1/E2 boundary correctly, and flag the one forward-looking financial exposure. A limited assurance engagement would find a traceable chain from the Flemish environmental permit and E-PRTR data through to the sustainability statement.

Additional assurance considerations for E2 files

Two points on the assurance approach for E2 files deserve specific attention. First, the CEAOB’s September 2024 guidelines on limited assurance under the CSRD expect practitioners to test the completeness of environmental metrics, not just their accuracy. For E2, completeness means verifying that the client has identified all material pollutants, not just the ones for which measurement data was conveniently available. A client with an IED permit listing six regulated pollutants but disclosing only two in the sustainability statement has a completeness gap.

Second, the interaction between E2 and the financial statement audit matters more than most teams expect. Environmental provisions under IAS 37, contingent liabilities under IAS 37.86, and environmental insurance disclosures can all be tested against the E2-6 anticipated financial effects. If the engagement team performs both the financial audit and the sustainability assurance, this cross-referencing should happen within the same review cycle. If different teams handle each engagement, formal communication between them on E2-related findings prevents inconsistencies from reaching the final reports.

Practical checklist for your current engagement

1. Run the DMA for pollution at sub-topic level (air, water, soil, microplastics) and document which sub-topics are material. Record the basis for any exclusion in the same working paper.
2. Map the client’s air emissions inventory to confirm which substances go to E1 (the seven GHGs) and which go to E2 (everything else). Classification errors between E1-8 and E2-4 are the most common boundary mistake.
3. Check whether the client holds an Industrial Emissions Directive permit or reports to the E-PRTR/IEPR. If yes, the data for E2-4 likely already exists. Use it as the primary source to reduce the data collection burden.
4. For SVHC-containing products, verify whether the client is a chemical manufacturer (NACE C.20) or a downstream user/distributor. That distinction determines the level of detail required in E2-5.
5. Cross-check E2-6 anticipated financial effects against IAS 37 provisions and IFRS 7 risk disclosures in the financial statements. Inconsistencies between the sustainability statement and the financial statements will surface during assurance procedures.
6. If pollution impacts are concentrated at specific sites, confirm that disclosures disaggregate by location rather than reporting a single blended figure. Amended ESRS E2 paragraph 8 sets this expectation explicitly.

Common mistakes to avoid

• Confusing E-PRTR thresholds with ESRS materiality: The E-PRTR/IEPR reporting threshold is not the same as ESRS materiality. A client whose NOx emissions fall below the E-PRTR threshold (100,000 kg/year for NOx) may still have material pollution disclosures under E2-4 if those emissions create material impacts or financial risks at a lower volume. The CEAOB guidelines on limited assurance expect practitioners to assess materiality against the ESRS framework, not against regulatory reporting thresholds designed for a different purpose.
• Substance lists without volumes or context: First-cycle reporters frequently disclosed SVHC as a list of substance names without volumes, concentrations, or a connection to impacts. ESRS E2-5 requires quantitative disclosure (volumes produced, used, distributed) where the company is in the chemical sector, and at minimum a qualitative description of material impacts for all others. A substance list without context fails the disclosure requirement.

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Further reading and source references

• ESRS E2, Pollution: the topical standard governing pollution-related disclosures under the CSRD.
• ESRS 1, General Requirements: governs materiality assessment and aggregation principles (Chapter 3.3.2).
• REACH Regulation (Regulation (EC) No 1907/2006): defines substances of very high concern and the 0.1% w/w threshold for article-level disclosure.
• CEAOB Guidelines, Limited Assurance Engagements on Sustainability Reporting (September 2024): covers completeness and accuracy testing for environmental metrics.