Revivo

ESRS E2: Pollution (Juli 2025 draft)

Bilde av Kari Eline Strandjord
Kari Eline Strandjord
pollution from pipes in a city
Photo: @scutal, unsplash

ESRS E2 addresses pollution, including emissions to air, water, and soil, as well as the management of hazardous chemicals. The revised standards provide a leaner and more focused path to compliance, especially by moving general process requirements to the cross-cutting standards (ESRS 1 and ESRS 2).

Reduction in data points

The revision of ESRS E2 has resulted in a significant reduction in data points:

  • The number of mandatory ("shall") data points has been reduced from 44 to only 17.
  • All 20 previously voluntary ("may") data points have been completely eliminated.

This represents a total reduction of 61.4% in the number of data points in the standard, significantly easing the reporting burden.

Structural changes: A more focused standard

A central change is that several requirements have been moved to the general standard ESRS 2. This creates a more logical reporting flow and removes unnecessary repetition.

  • Removal of Process Requirements (IRO-1): The requirement to describe the process for identifying material impacts, risks, and opportunities (IRO-1) has been removed from E2 and is now fully covered in ESRS 2.
  • Consolidation of Policy, Actions, and Targets (PATs): The detailed, topic-specific requirements for policies (E2-1), actions (E2-2), and targets (E2-3) have been replaced. Reporting shall now follow the general requirements in ESRS 2 (GDR-P, GDR-A, and GDR-T).
  • Removal of Expected Financial Effects (E2-6): The requirement to disclose expected financial effects (E2-6) has been removed from E2 and consolidated under the general requirements in ESRS 2 SBM-3.

Detailed Review of the Revised Disclosure Requirements (DRs)

Here is a complete overview of the remaining disclosure requirements in the new ESRS E2:

Disclosure Requirement E2-1: Policies related to pollution

Undertakings shall now describe their policies for managing material impacts, risks, and opportunities related to pollution.

  • What's new? This disclosure requirement is no longer a standalone requirement in E2. Instead, it refers directly to the general requirement in ESRS 2 GDR-P. This means that undertakings no longer need to prepare a separate policy description specifically for pollution but can integrate this into their overall policy reporting.

Disclosure Requirement E2-2: Actions and resources related to pollution

This requirement obliges undertakings to disclose their most important actions and the resources allocated to implement them.

  • What's new? Similar to E2-1, this requirement is now consolidated. Reporting shall follow the general requirement for actions and resources in ESRS 2 GDR-A. This removes the need for a separate, detailed action plan solely for pollution in this standard.

Disclosure Requirement E2-3: Targets related to pollution

Here, the undertaking shall disclose the targets they have set to reduce pollution.

  • What's new? This requirement has also been moved and shall now be reported in accordance with the general requirement for targets in ESRS 2 GDR-T. This simplifies reporting by allowing all targets to be presented in a unified manner.

Disclosure Requirement E2-4: Pollution of air, water, and soil

This is a key quantitative requirement that obliges undertakings to report the quantity of material emissions of pollutants.

  • What's new?
    • Exclusion of greenhouse gases: It is now clearly specified that the seven greenhouse gases covered by ESRS E1 shall not be included here to avoid double reporting.
    • Removal of E-PRTR reference: The reference to the European Pollutant Release and Transfer Register (E-PRTR) has been removed to simplify reporting for companies operating outside the EU.
    • Increased flexibility: The requirement for a specific methodological prioritization (e.g., direct measurement over estimation) has been removed from the standard itself and moved to non-binding guidance.

Disclosure Requirement E2-5: Substances of concern and very high concern

This requirement addresses the undertaking's impact on health and the environment through hazardous substances.

  • What's new? The requirement itself has been retained, but the detailed guidance and methodology have been simplified and made less prescriptive. This gives companies more flexibility in how they report on these substances, while the core of the requirement remains.

Conclusion

The revised ESRS E2 is clear evidence of EFRAG's commitment to simplification. By moving general requirements to ESRS 2 and removing voluntary data points, the standard has become more focused on the mandatory, quantitative results related to pollution. This will not only reduce the reporting burden but also improve the quality and comparability of sustainability information.

-----

Important information: This article was written using AI to analyze EFRAG's draft new ESRS standards (July 2025). Please remember that this is based on a draft and is not official advice. We do our best to ensure everything is correct, but always recommend consulting the original sources. Please let us know if you find any errors.