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Which of the following can organizations use to identify actual and potential IROs during Step B of the double materiality assessment process? Select all options that apply.
During Step B of the double materiality assessment process, organizations must identify actual and potential impacts, risks, and opportunities (IROs). The ESRS framework recommends the following methods:
A . The list of sustainability matters in ESRS 1 AR 16
ESRS 1 Application Requirement (AR) 16 provides a comprehensive reference list of sustainability matters to consider when identifying IROs.
This list includes environmental, social, and governance topics aligned with EU sustainability objectives.
C . Due diligence processes
ESRS requires organizations to use due diligence processes to identify negative sustainability impacts.
Due diligence aligns with frameworks such as the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights.
This ensures that potential risks and opportunities are assessed based on international sustainability standards.
D . Feedback from stakeholders
Stakeholders, including employees, suppliers, customers, and affected communities, provide crucial insights into sustainability impacts.
ESRS mandates engagement with affected stakeholders as part of the IRO identification process.
Why is B. Financial materiality thresholds incorrect?
Financial materiality thresholds apply later in the process (Step C) when evaluating the financial impact of sustainability matters.
Step B focuses only on identifying IROs, making financial thresholds irrelevant at this stage.
Conclusion:
Organizations should use the ESRS 1 AR 16 sustainability matters list, due diligence processes, and stakeholder feedback to identify IROs in Step B of the double materiality assessment. Financial materiality thresholds do not apply in this step.
Official Commission Delegated Regulation (EU) 2023/2772, various EFRAG guidance documents, and CSRD-related references:
Commission Delegated Regulation (EU) 2023/2772, ESRS 1, AR 16: List of Sustainability Matters for Identifying IROs.
EFRAG Compilation of Explanations (January - July 2024): Confirmation that due diligence and stakeholder input are part of IRO identification.
Indicate whether the following statement is true or false.
All EU Member States decided that only statutory financial auditors are allowed to conduct the assurance of the sustainability statement, excluding other audit firms or Independent Assurance Service Providers.
Not all EU Member States have decided that only statutory financial auditors are allowed to conduct the assurance of the sustainability statement. The Corporate Sustainability Reporting Directive (CSRD) mandates that sustainability reports be assured by an external party, but it allows Member States to decide whether assurance engagements can be performed by firms other than statutory financial auditors.
Key Provisions:
Limited Assurance Requirement:
The CSRD introduces a phased approach to assurance, starting with limited assurance and transitioning to reasonable assurance over time (expected by 2028).
Initially, limited assurance is required across all Member States.
Flexibility for Member States:
EU Member States have discretion to allow other independent assurance service providers to conduct the sustainability assurance, in addition to statutory auditors.
Some countries may restrict sustainability assurance to statutory auditors, but this is not an EU-wide rule.
Upcoming EU Assurance Standards:
The European Commission is working on developing a common EU assurance standard for sustainability reporting.
The Committee of European Auditing Oversight Bodies (CEAOB) has issued non-binding guidelines on limited assurance for sustainability reporting.
Thus, the statement is false because not all EU Member States have restricted sustainability assurance to statutory financial auditors. Some allow other independent assurance providers to conduct the engagements.
Official Reference:
CSRD (Directive (EU) 2022/2464) Assurance Provisions.
EU Platform on Sustainable Finance Report (February 2025) -- Assurance Standards and Guidelines.
CEAOB Guidelines on Limited Assurance for Sustainability Reporting (September 2024).
Which of the following correctly fills the gaps in the sentences below?
The ESRS Taxonomy acts as a __________ for tagging sustainability disclosures, ensuring data is structured, consistent, and comparable across organizations.
The CSRD requires sustainability information to be reported in a __________ format, making it accessible to both people and machines.
Under the CSRD, sustainability reports will eventually be uploaded to the __________ platform, centralizing public financial and non-financial information across the EU.
Correct Sentence Completion:
The ESRS Taxonomy acts as a framework for tagging sustainability disclosures, ensuring data is structured, consistent, and comparable across organizations.
The CSRD requires sustainability information to be reported in a digitally accessible format, making it available for both people and machines.
Under the CSRD, sustainability reports will eventually be uploaded to the European Single Access Point (ESAP), centralizing public financial and non-financial information across the EU.
Explanation of the Selected Answer:
ESRS as a 'framework' -- The ESRS taxonomy defines a structure that allows sustainability data to be categorized and tagged effectively.
'Digitally accessible format' -- The CSRD mandates reporting in machine-readable formats such as XBRL to improve transparency and comparability.
European Single Access Point (ESAP) -- ESAP will serve as the centralized EU platform for sustainability and financial disclosures.
EU Taxonomy Regulation and CSRD Reporting Structure
EFRAG Explanation on ESRS Digital Reporting
How do the ESRS define stakeholders?
According to the European Sustainability Reporting Standards (ESRS) under the Commission Delegated Regulation (EU) 2023/2772, stakeholders are defined as individuals or groups who can affect or be affected by the undertaking. The ESRS distinguishes between two main groups of stakeholders:
Affected stakeholders: These are individuals or groups whose interests are affected or could be affected -- positively or negatively -- by the undertaking's activities and its direct and indirect business relationships across its value chain.
Users of sustainability statements: These include primary users of general-purpose financial reporting (e.g., existing and potential investors, lenders, and other creditors such as asset managers, credit institutions, and insurance undertakings) and other users, including the undertaking's business partners, trade unions, social partners, civil society and non-governmental organizations, governments, analysts, and academics.
Furthermore, engagement with affected stakeholders is a crucial aspect of the undertaking's ongoing due diligence process and sustainability materiality assessment. This involves identifying and assessing actual and potential negative impacts to inform the materiality assessment process for sustainability reporting.
Official Reference:
Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 supplementing Directive 2013/34/EU on sustainability reporting standards.
ESRS 1: General Requirements, Section 3.1 (Stakeholders and their relevance to the materiality assessment process).
Select all the correct steps for conducting a double materiality assessment based on the ESRS.
The double materiality assessment involves identifying sustainability matters that are material either from:
An impact perspective (the organization's effects on people and the environment).
A financial perspective (how sustainability matters affect the organization financially).
The correct steps in conducting this assessment include:
(A) Comparing identified material topics with ESRS 1 AR 16 -- This ensures alignment with predefined sustainability matters in ESRS.
(C) Using ESRS 2 IRO-1 -- This disclosure requirement mandates companies to report on their methodology for identifying impacts, risks, and opportunities.
(D) Following SBM-3 of ESRS 2 -- This section provides requirements for disclosing the material impacts, risks, and opportunities identified through the materiality assessment.
Why the other options are incorrect:
(B) False: Entity-specific disclosures must cover all material sustainability topics, even those not explicitly covered in ESRS.
(E) False: Both financial and impact materiality must be considered (double materiality), not just financial materiality.
(F) False: Double materiality assessments are mandatory for all organizations reporting under ESRS.
Commission Delegated Regulation (EU) 2023/2772, Section 3.3 on Double Materiality
EFRAG Compilation on Double Materiality Assessments, providing step-by-step guidance on ESRS compliance