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), narrative (a free-text policy description), or tabular (a breakdown by category).
- 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?
A mid-sized manufacturer opens the EFRAG IG 3 Excel workbook for the first time and sees 1,178 rows. Each row is a single ESRS datapoint (DP). Without a clear understanding of where DPs sit in the ESRS architecture, the sustainability team either tries to report every row (burning months of effort on immaterial items) or skips the workbook entirely and writes a few narrative paragraphs per topic. Both responses fail the assurance provider's completeness check.
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 (DRs), and each DR breaks down into individual DPs. ESRS 1.31 defines the relationship: a DR prescribes what information the entity must provide on a material sustainability matter, while DPs specify the granular elements that satisfy that prescription. Think of the DR as the question and the DPs as the line items in the answer.
ESRS 1.35 introduces a materiality filter at the DP level. Even when a DR is triggered by the double materiality assessment, the entity may omit an individual DP if it concludes the information is not material and not needed to meet the objective of the DR. That judgment must be documented. EFRAG's Implementation Guidance IG 3 (finalised May 2024) catalogues every DP in a machine-readable Excel file, classifying each by data type (quantitative, semi-narrative, narrative, or tabular) and by whether it is mandatory or subject to a phase-in. The simplified ESRS standards that EFRAG submitted to the European Commission in January 2026 reduced mandatory DPs 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.
Rossi Alimentari S.p.A. is an Italian food production company reporting under IFRS with FY 2025 revenue of EUR 67M. 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 DRs 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 DRs within each standard. ESRS E1 alone contains 9 DRs (E1-1 through E1-9).
Step 2. Decompose DRs into DPs
For ESRS E1-6 (gross Scope 1, 2, and 3 greenhouse gas emissions), the team identifies 22 individual DPs 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, and consolidation approach). The team counts 187 applicable DPs across the four material topical standards plus ESRS 2.
Step 3. Apply the DP-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 DPs relating to use-phase emissions under E1-6 are not material and not needed to meet the DR's objective. Scope 3 category 1 (purchased goods and services), by contrast, represents 72% of the entity's total carbon footprint and all related DPs are retained.
Step 4. Populate and validate
The team collects data for the remaining 184 DPs. 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 DP is reconciled to a source system (energy invoices, HR payroll, procurement spend analysis, or ERP extraction logs).
Rossi's DP register of 184 populated items (from an initial population of 187 applicable DPs, with 3 omitted on materiality grounds) is defensible because each inclusion traces to a triggered DR, 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 DRs with DPs and treat the two as interchangeable in their materiality documentation. A DR can be mandatory while individual DPs within it remain subject to the entity-level materiality filter under ESRS 1.35. Teams that apply materiality only at the DR level either over-report or under-document. The assurance provider needs to see a judgment trail at the DP level, not just at the topic level. Without that trail, the whole exercise starts to look like a tick-box exercise rather than a genuine materiality assessment.
We have seen teams spend weeks ticking and bashing through the EFRAG IG 3 register, treating it as the legal text, only to discover during fieldwork that the register 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. Getting this wrong after weeks of data collection is genuinely demoralising for the team.
ESRS datapoint vs. GRI disclosure
| Dimension | ESRS DP | 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 DRs activate; ESRS 1.35 adds a second filter at the DP level | GRI 3 (2021) requires entities to report disclosures for each material topic; no separate DP-level filter |
| Data types | Classified as quantitative, semi-narrative (boolean, enumeration), narrative, or tabular 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 DP | 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 DPs, but the mapping is not one-to-one. ESRS DPs 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 DP population.
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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.