Key Points
- A single disclosure requirement can contain anywhere from two to over thirty individual datapoints.
- EFRAG's original Set 1 catalogue lists approximately 1,178 datapoints across all twelve ESRS standards.
- Report a disclosure requirement when the parent topic passes the double materiality gate; report each datapoint within it unless a specific exemption applies.
- Confusing the two levels causes teams to omit mandatory datapoints while believing they have satisfied the disclosure requirement.
Side-by-side comparison
| Dimension | Disclosure requirement | Datapoint |
|---|---|---|
| Level in the ESRS hierarchy | Named obligation within a topical or cross-cutting standard (e.g., ESRS E1-6 on gross Scope 1 GHG emissions) | Individual item nested inside the disclosure requirement (e.g., Scope 1 emissions in tonnes CO2e, the methodology used, the emission factors applied) |
| What triggers it | The double materiality assessment identifies the parent topic as material; ESRS 2 disclosure requirements apply unconditionally | Activated when its parent disclosure requirement is in scope; individual datapoints marked "may disclose" in ESRS 1 Set 1 were voluntary until the simplified ESRS removed them |
| Granularity | Sets the subject and the reporting objective | Specifies the precise metric, narrative, or binary indicator the entity must produce |
| How EFRAG catalogues it | Identified by standard and numbered label (e.g., E1-6, S1-9, GOV-1) | Listed in the EFRAG IG 3 Excel workbook with a unique reference per item |
| Materiality filter | Subject to topical materiality assessment under ESRS 1 paragraphs 37–58 (except ESRS 2, which is unconditional) | Follows its parent disclosure requirement; under the simplified ESRS (expected adoption mid-2026), mandatory datapoints drop from approximately 1,178 to around 320 |
When the distinction matters on an engagement
The gap between these two levels bites hardest during scope-setting for sustainability assurance. An assurance provider who scopes procedures at the disclosure requirement level (confirming that the entity "addressed" ESRS E1-6) without tracing downward into each constituent datapoint will miss omissions. ESRS 1.18 states that the term "shall disclose" indicates a prescribed disclosure requirement or datapoint. An entity that reports its Scope 1 emissions total but omits the breakdown by greenhouse gas type has satisfied one datapoint while leaving another blank within the same disclosure requirement.
First-cycle Wave 1 reports (FY 2024) showed this gap repeatedly. Entities filed a narrative paragraph under a disclosure requirement and treated the requirement as complete, when the EFRAG IG 3 workbook listed four or five individual datapoints that each required separate data collection.
Worked example: Rossi Alimentari S.p.A.
Client: Italian food production company, FY 2026, revenue EUR 67M, IFRS reporter, first-time CSRD reporter under the Omnibus I scope (1,200 employees, voluntary early adoption of simplified ESRS).
Step 1 — Identify applicable disclosure requirements
Rossi's double materiality assessment concludes that climate change is material from both perspectives. ESRS E1 contains nine disclosure requirements (E1-1 through E1-9). After applying materiality at the disclosure requirement level, the sustainability team determines that eight of the nine apply; E1-9 (anticipated financial effects from physical and transition risks) is assessed as not material because Rossi's physical risk exposure is immaterial relative to EUR 67M revenue.
Step 2 — Map datapoints within each disclosure requirement
For E1-6 (gross Scope 1, 2, and 3 GHG emissions), the EFRAG IG 3 workbook lists over fifteen individual datapoints under the original Set 1. Under the simplified ESRS, the mandatory datapoints for E1-6 drop to around six.
Step 3 — Collect and validate data for each datapoint
Rossi's Scope 1 emissions total 4,800 tonnes CO2e (from two production sites using natural gas boilers and a refrigerated fleet). The data owner extracts gas consumption from utility invoices and fleet fuel from fuel card records. Each datapoint traces to a source document.
Step 4 — Verify disclosure requirement completeness
The sustainability team checks each active disclosure requirement against its constituent datapoints using the EFRAG IG 3 register. E1-6 has six mandatory datapoints under the simplified ESRS; all six are populated. E1-4 (climate transition plan) has four mandatory datapoints; the team discovers that the target-year interim milestones datapoint is blank and escalates to the CFO for data.
Conclusion: Rossi's ESRS E1 disclosures are defensible because the team mapped every disclosure requirement to its constituent datapoints and verified completeness at the datapoint level.
Why it matters in practice
Teams treat completion of the disclosure requirement as binary: either the entity "addressed" it or it did not. ESRS 1.18 distinguishes between "shall disclose" (mandatory) items at both the disclosure requirement and the individual datapoint level. Omitting a single mandatory datapoint within a disclosure requirement that the entity otherwise reported is an incomplete disclosure, not a compliant one.
Assurance providers sometimes scope their procedures at the disclosure requirement level without building a datapoint-level population. ISAE 3000 (Revised) paragraph 47 requires the practitioner to determine the scope of the engagement with sufficient precision. A scope statement that references "ESRS E1 disclosure requirements" without specifying which datapoints were tested leaves the engagement vulnerable to a finding that completeness was not adequately addressed.
Related terms
Frequently asked questions
How many datapoints does each ESRS disclosure requirement contain?
The count varies by standard and by disclosure requirement. ESRS E1-6 (GHG emissions) contains over fifteen datapoints in the original Set 1, reduced to around six under the simplified ESRS expected for adoption mid-2026. ESRS 2 GOV-1 (governance structure) contains eight. The EFRAG IG 3 Excel workbook provides the definitive count per disclosure requirement, broken down by mandatory and (in Set 1) voluntary status.
Do I need to report every datapoint if the disclosure requirement is material?
Under the original ESRS Set 1, mandatory datapoints within a material disclosure requirement must all be reported unless a specific phase-in or exemption applies (ESRS 1 paragraphs 129–132 provide transitional reliefs for certain Scope 3 and value chain datapoints). Voluntary "may disclose" datapoints were optional. The simplified ESRS (expected adoption mid-2026) removes all voluntary datapoints entirely and reduces mandatory datapoints from approximately 1,178 to around 320.
Can I omit a datapoint within a material disclosure requirement based on materiality?
Under the original Set 1, ESRS 1.35 permits omission of a datapoint if the information is not material and not needed to meet the disclosure requirement's objective. The entity must document the rationale. The simplified ESRS introduces a limited ability to omit specific datapoints where the entity can demonstrate that the information is not material at the datapoint level.