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Batch 1 working papers on the European Sustainability Reporting Standards have already been released

They will complement the Corporate Sustainability Reporting Directive (CSRD)


On 18 January 2022, Batch 1 working papers on the European Sustainability Reporting Standards were published by the European Commission’s task force to complement the Corporate Sustainability Reporting Directive.

Newsletter: Sustainability Insights

What are Batch 1 working papers?

Batch 1 working papers were developed by PTF-ESRS (Project Task Force – European Sustainability Reporting Standard) at the European Financial Reporting Advisory Group (EFRAG). The WPs are still subject to changes and comprise:

  • four cross-cutting standards (Strategy and business model; Sustainability governance and organisation; Sustainability material impacts, risks and opportunities; Definitions for policies, targets, action plans and resources);
  • one topical standard (Climate change);
  • two conceptual guidelines (Double materiality; Characteristics of information quality).

Batches 2 and 3 will be made available in the coming weeks. Subsequent steps include submission of the WPs for consideration and debate, also by dedicated expert working groups, and then to public consultation. The full version of the document is available on EFRAG’s website.

Who will be affected?

Potentially, starting from 2024, the new obligations will apply to approx. 49 thousand businesses across the EU, including 3 thousand large enterprises in Poland (the number of small and medium-sized listed entities should be around 180), this including non-listed companies. We believe that so far only about 10 percent of them are ready for the change. The standards define how entities should report on a number of issues relating to sustainability. They will cover all large, public and private enterprises as well as companies listed on regulated markets, which meet the following CSRD requirements: more than 250 employees or financial criteria (balance sheet total >EUR 43 million and net revenues >EUR 50 million).

What does it mean for businesses?

Action needs to be taken today to get ready for the change. The regulations are gradually coming into effect, starting from the 2021 reporting cycle (this applies, among other things, to the taxonomy), and are likely to be required to be implemented fully in the 2023 cycle. This means that in practice, entities will only have eighteen months to design and get their ESG reporting going, assign responsibilities, train staff and put the missing governance processes in place.

Those which have not:

  • reported their non-financial data in accordance with recognized methodologies and guidelines (GRI, SASB, IIRC, TCFD) before;
  • had their report validated by a third party;
  • developed a clear ESG strategy or put enterprise risk management systems, taking account of ESG and climate risks, in place;
  • devised their detailed decarbonization plans, including potential investment valuations and temperature change scenarios;
  • estimated their emissions footprint, e.g. in the value or supply chain (scope 3) – may need, depending on the pace, from 2 to 5 years to implement the changes (!).

How can we help?

Please contact us if you wish to:

  • Learn more about the practical implications of the regulations for your company.
  • Create a plan to transform your ESG processes within the required time limits.
  • Make calculations considering this year’s taxonomy requirements with the help of our experts.
  • Implement a digital tool for ESG reporting and governance in your organization.

Why work with us?

  • We have fifteen years of experience in advising our clients on sustainability.
  • We have our representative in the EFRAG task force, contributing to the development of CSRD and the European Reporting Standards.
  • We have carried out more than a hundred ESG reporting projects (GRI, IIRC, TCFD, NFRD) focusing on compliance with regulations and ESG ratings.
  • We are an active member of a networking group bringing insights into sustainability reporting.
  • Currently, we are helping several large multinational groups gain an understanding of the practical impact of the new regulatory framework on their organizations, in addition to preparing their data capture and reporting systems, strategic ESG gaps (policies and procedures) and taxonomy calculations for the change.

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