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
The most common mistake in first-cycle CSRD filings is treating the disclosure requirement (DR) and the datapoint (DP) as the same thing. A team writes a narrative paragraph under a DR and marks it complete, while four or five individual DPs within that DR remain blank. The table below maps the structural differences between the two levels so that gap does not survive into the assurance engagement.
| Dimension | Disclosure requirement (DR) | Datapoint (DP) |
|---|---|---|
| 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 DR (e.g., Scope 1 emissions in tonnes CO2e, the methodology used, the emission factors applied, and the consolidation approach) |
| What triggers it | The double materiality assessment identifies the parent topic as material; ESRS 2 DRs apply unconditionally | Activated when its parent DR is in scope; individual DPs 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, binary indicator, or tabular breakdown 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 DR; under the simplified ESRS (expected adoption mid-2026), mandatory DPs 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 DR level (confirming that the entity "addressed" ESRS E1-6) without tracing downward into each constituent DP will miss omissions. ESRS 1.18 states that the term "shall disclose" indicates a prescribed DR or DP. An entity that reports its Scope 1 emissions total but omits the breakdown by greenhouse gas type has satisfied one DP while leaving another blank within the same DR.
First-cycle Wave 1 reports (FY 2024) showed this gap repeatedly. Entities filed a narrative paragraph under a DR and treated the requirement as complete, when the EFRAG IG 3 workbook listed four or five individual DPs that each required separate data collection. In our experience, the teams doing this were not being careless. They simply had no system for tracking completeness below the DR level, so the exercise became ticking and bashing through a topic list without opening the IG 3 workbook at all. It is frustrating to discover completeness gaps only when the assurance provider raises them weeks before the filing deadline.
Worked example: Rossi Alimentari S.p.A.
Rossi Alimentari S.p.A. is an Italian food production company with FY 2026 revenue of EUR 67M, reporting under IFRS. Rossi is a first-time CSRD reporter under the Omnibus I scope (1,200 employees, voluntary early adoption of simplified ESRS).
Step 1. Identify applicable DRs
Rossi's double materiality assessment concludes that climate change is material from both perspectives. ESRS E1 contains nine DRs (E1-1 through E1-9). After applying materiality at the DR 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 DPs within each DR
For E1-6 (gross Scope 1, 2, and 3 GHG emissions), the EFRAG IG 3 workbook lists over fifteen individual DPs under the original Set 1. Under the simplified ESRS, the mandatory DPs for E1-6 drop to around six.
Step 3. Collect and validate data for each DP
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 DP traces to a source document.
Step 4. Verify DR completeness
The sustainability team checks each active DR against its constituent DPs using the EFRAG IG 3 register. E1-6 has six mandatory DPs under the simplified ESRS; all six are populated. E1-4 (climate transition plan) has four mandatory DPs. The team discovers that the target-year interim milestones DP is blank and escalates to the CFO for data.
Rossi's ESRS E1 disclosures are defensible because the team mapped every DR to its constituent DPs and verified completeness at the DP level. Without that DR-to-DP reconciliation, the filing would have gone out with a gap that the assurance provider would have caught during fieldwork.
Why it matters in practice
Teams treat completion of the DR as binary: either the entity "addressed" it or it did not. ESRS 1.18 distinguishes between "shall disclose" (mandatory) items at both the DR and the individual DP level. Omitting a single mandatory DP within a DR that the entity otherwise reported is an incomplete disclosure, not a compliant one. When teams treat DR-level completion as sufficient, the sustainability statement becomes a tick-box exercise that papers over real gaps in the underlying data.
Assurance providers sometimes scope their procedures at the DR level without building a DP-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 DPs were tested leaves the engagement vulnerable to a finding that completeness was not adequately addressed.
Related terms
Related tools
Related reading
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.