Key Points
- EFRAG's IG 3 catalogue identifies 1,178 individual datapoints across the 12 sector-agnostic ESRS standards.
- A datapoint can be quantitative (tonnes CO2e), semi-narrative (a yes/no flag), or narrative (a free-text policy description).
- The simplified ESRS submitted to the European Commission in January 2026 cut mandatory datapoints by 61% and removed all voluntary datapoints entirely.
- Omitting a mandatory datapoint without a documented materiality rationale is the fastest way to receive an assurance qualification on the sustainability statement.
What is an ESRS Datapoint?
The ESRS organise disclosures in a three-tier hierarchy. At the top sit the topical standards (ESRS E1 through G1). Each standard contains disclosure requirements, and each disclosure requirement breaks down into individual datapoints. ESRS 1.31 defines the relationship: a disclosure requirement prescribes what information the entity must provide on a material sustainability matter, while datapoints specify the granular elements that satisfy that prescription. Think of the disclosure requirement as the question and the datapoints as the line items in the answer.
ESRS 1.35 introduces a materiality filter at the datapoint level. Even when a disclosure requirement is triggered by the double materiality assessment, the entity may omit an individual datapoint if it concludes the information is not material and not needed to meet the objective of the disclosure requirement. That judgment must be documented. EFRAG's Implementation Guidance IG 3 (finalised May 2024) catalogues every datapoint in a machine-readable Excel file, classifying each by data type (quantitative, semi-narrative, or narrative) and by whether it is mandatory, voluntary, or subject to a phase-in. The simplified ESRS standards that EFRAG submitted to the European Commission in January 2026 reduced mandatory datapoints by 61%, bringing the count from over 1,000 to around 400, and eliminated the voluntary category altogether. The European Commission expects to adopt the revised standards via delegated act by mid-2026, with application from FY 2027 and optional early adoption for FY 2026.
Worked example: Rossi Alimentari S.p.A.
Client: Italian food production company, FY 2025, revenue EUR 67M, IFRS reporter. Rossi is a large undertaking in scope for Wave 2 CSRD reporting (now deferred to FY 2027 by the stop-the-clock directive), but management elects to prepare a voluntary sustainability statement for FY 2025 to build internal processes ahead of the mandatory year.
Step 1 — Identify applicable disclosure requirements from material topics
Rossi's IRO assessment identified four material topical standards: ESRS E1 (climate change), ESRS E2 (pollution), ESRS S1 (own workforce), and ESRS G1 (business conduct). The sustainability team maps the disclosure requirements within each standard. ESRS E1 alone contains 9 disclosure requirements (E1-1 through E1-9).
Step 2 — Decompose disclosure requirements into datapoints
For ESRS E1-6 (gross Scope 1, 2, and 3 greenhouse gas emissions), the team identifies 22 individual datapoints from the EFRAG IG 3 register. These range from quantitative metrics (Scope 1 emissions in tonnes CO2e, Scope 2 location-based and market-based figures) to narrative elements (methodology description, base year, emission factor sources). The team counts 187 applicable datapoints across the four material topical standards plus ESRS 2.
Step 3 — Apply the datapoint-level materiality filter
Rossi's Scope 3 category 11 (use of sold products) is negligible because the entity produces perishable food consumed within days of purchase. The team documents that the three datapoints relating to use-phase emissions under E1-6 are not material and not needed to meet the disclosure requirement's objective. Scope 3 category 1 (purchased goods and services), by contrast, represents 72% of the entity's total carbon footprint and all related datapoints are retained.
Step 4 — Populate and validate
The team collects data for the remaining 184 datapoints. Scope 1 emissions total 4,800 tonnes CO2e. Scope 2 emissions (market-based) are 6,200 tonnes CO2e. The gender pay gap under ESRS S1 stands at 8.1%. Each quantitative datapoint is reconciled to a source system (energy invoices, HR payroll, procurement spend analysis).
Conclusion: Rossi's datapoint register of 184 populated items (from an initial population of 187 applicable datapoints, with 3 omitted on materiality grounds) is defensible because each inclusion traces to a triggered disclosure requirement, each omission carries a documented rationale per ESRS 1.35, and every quantitative figure reconciles to source data.
Why it matters in practice
Entities confuse disclosure requirements with datapoints and treat the two as interchangeable in their materiality documentation. A disclosure requirement can be mandatory while individual datapoints within it remain subject to the entity-level materiality filter under ESRS 1.35. Teams that apply materiality only at the disclosure-requirement level either over-report or under-document. The assurance provider needs to see a judgment trail at the datapoint level, not just at the topic level.
The EFRAG IG 3 register classifies datapoints as mandatory, voluntary, or subject to phase-in, but teams frequently treat the register itself as the legal text. EFRAG's implementation guidance is non-binding. The legally binding requirements sit in Commission Delegated Regulation (EU) 2023/2772. Where the IG 3 register and the delegated regulation diverge (particularly on phase-in timelines for value chain data under ESRS S2 and S3), the regulation prevails.
ESRS datapoint vs. GRI disclosure
| Dimension | ESRS datapoint | GRI disclosure |
|---|---|---|
| Legal status | Legally binding for in-scope EU undertakings via CSRD delegated regulation | Voluntary unless mandated by national regulation |
| Materiality gate | Double materiality assessment determines which disclosure requirements activate; ESRS 1.35 adds a second filter at the datapoint level | GRI 3 (2021) requires entities to report disclosures for each material topic; no separate datapoint-level filter |
| Data types | Classified as quantitative, semi-narrative (boolean, enumeration), or narrative per EFRAG IG 3 | Disclosures include quantitative metrics and management approach narratives; no formal semi-narrative category |
| Assurance requirement | Subject to limited assurance from first reporting year under CSRD | No mandatory assurance; GRI encourages external assurance but does not require it |
| Interoperability | EFRAG published a GRI-ESRS interoperability index (November 2024) mapping equivalent disclosures; approximately 80% of GRI disclosures have a corresponding ESRS datapoint | GRI aligned its Universal Standards revision to facilitate interoperability with ESRS |
An entity already reporting under GRI can use the EFRAG interoperability index to map existing disclosures to ESRS datapoints, but the mapping is not one-to-one. ESRS datapoints for Scope 2 emissions require both location-based and market-based figures, while GRI 305-2 permits either. Auditors reviewing a dual reporter should verify that the GRI-to-ESRS mapping does not create gaps in the ESRS datapoint population.
Related terms
Frequently asked questions
How many ESRS datapoints does my company need to report?
The total depends on which topical standards pass the double materiality gate. EFRAG IG 3 catalogues 1,178 datapoints across all 12 standards, but a typical mid-sized entity with four material topical standards will face 150 to 250 applicable datapoints after the materiality filter. The simplified ESRS (expected adoption mid-2026) will reduce that baseline by roughly 61%, with application from FY 2027.
Can I omit a mandatory ESRS datapoint?
Yes, under a strict condition. ESRS 1.35 permits the entity to omit a datapoint within a triggered disclosure requirement if the information is assessed as not material and not needed to meet that requirement's objective. The omission must be documented with the rationale. Omitting without documentation exposes the sustainability statement to a qualification from the assurance provider under ESRS 1.36.
What is the difference between a datapoint and a disclosure requirement?
A disclosure requirement is the broader obligation (for example, "disclose gross Scope 1 GHG emissions"). Datapoints are the granular items within that obligation: the emissions figure in tonnes CO2e, the methodology description, the base year, and the percentage from regulated emission trading schemes. ESRS 1.31 defines the hierarchical relationship. Materiality is assessed at both levels, but the logic differs.