DataSolmu blog
Keep Additional Sustainability Disclosures Clear
Give each additional disclosure a clear purpose, evidence owner and place in the reporting process.
A sustainability reporting team can receive more information requests than it can sensibly turn into public disclosures. A customer wants a particular metric, a lender asks for another breakdown, and an internal team wants to describe an initiative. Each request may have a useful purpose. The reporting decision still needs an explanation.
EFRAG's May 2024 materiality assessment guidance discusses additional information from other legislation and generally accepted sustainability reporting frameworks alongside information about material matters. That distinction gives reporting teams a useful starting point: understand why an item is being requested before deciding how to present it.
This article draws on that non-authoritative guidance for the 2023 ESRS. Teams should check the standards and requirements applicable to their reporting period. The workflow below is DataSolmu's practical recommendation, rather than a prescribed reporting procedure.
Give The Request A Clear Purpose
Start with a sentence explaining the decision the information is intended to support. Record who requested it and whether the request arises from a stated requirement, a reporting framework, a contractual relationship or a voluntary communication choice. A customer request deserves a response, but its arrival alone does not establish a public reporting obligation.
Then connect the request to the reporting team's existing assessment. Does it help explain an identified material impact, risk or opportunity? Does it serve a separate information need? Is the requested figure even defined consistently with the information already prepared? These questions help the team decide what needs further review.
Check The Evidence Before Choosing The Wording
Consider a fictional equipment supplier whose customer requests a breakdown of water use for one production site. The supplier has a verified group total, but the site estimate uses an allocation method that has not yet been reviewed.
A useful response starts by finding the owner of that estimate. The team can document the period, site boundary, allocation method and uncertainty, then decide what the evidence supports. Publishing the site estimate beside the group total without explaining their different bases could make the information difficult to interpret.
Our recommended decision record is short: the requested information, its purpose, evidence owner, calculation basis, known limitations and the person responsible for resolving them. An open evidence gap should remain visible through the review.
Decide Where The Information Helps The Reader
Once the purpose and evidence are understood, review the proposed location with the people responsible for the report. Possible outcomes include a clearly explained addition to the sustainability statement, a separate customer response, or further work before any claim is made. The appropriate outcome depends on the request and the applicable requirements.
For an addition to the report, make its purpose and basis understandable. Check whether a reader could mistake a site estimate for a group metric, or a voluntary explanation for the conclusion of the materiality assessment. Avoid repeating the same figure in several places with slightly different definitions.
Keep The Decision Available For Next Year
The same request may return with a different boundary or deadline. Preserve the reason for the earlier decision so that the next reviewer can see what has changed. A new customer need, stronger evidence or a changed reporting basis may justify a different response.
For DataSolmu, the practical value is a traceable connection between the information request and the publication decision. A Varmennappi workflow should make the purpose, evidence gap and review outcome easy to follow, while the reporting organisation remains responsible for the final judgement.
Varmennappi supports reporting-data management, evidence traceability, validation workflows, and XBRL-related output review. It does not provide legal advice, auditor assurance, regulator acceptance, or a guarantee of CSRD, ESRS, VSME, ESEF, or XBRL filing compliance. Customers remain responsible for final reporting judgments, source-data quality, filing decisions, and professional review.
Source
EFRAG IG 1: Materiality Assessment Implementation Guidance — May 2024