1. February 2024

ASCG comments on EFRAG IG 3 List of ESRS Datapoints

After the ASCG had already commented on the two implementation guidance drafts regarding the materiality analysis and the value chain (Draft EFRAG IG 1 Materiality assessment implementation guidance, Draft EFRAG IG 2 Value chain implementation guidance) two weeks ago, the feedback on Draft IG 3 List of ESRS Datapoints was submitted to EFRAG on January 31.

The ASCG explicitly welcomes this part of the implementation guidance, as it helps undertakings in gaining a better understanding of the ESRS requirements. However, the DRSC recommends that some details of the list be corrected or clarified. For example, the phase-in provisions and the limited scope for some requirements (high climate impact sectors) do not yet seem to be fully reflected in the list. Furthermore, it should be reviewed whether the IG3 goes beyond the ESRS requirements in some cases. For further details, please refer to the text of the comment letter.