How to write an ESRS sustainability statement: Complete checklist

 1. Align with the management report

• Link to your corporate strategy: Investors and analysts will integrate your ESRS data points into their valuation models. Ensure that each data point aligns with your corporate strategy and equity story.
• Maintain a consistent narrative: Approach sustainability reporting with the same precision as financial reporting. Tie each sustainability claim back to your overall business strategy and operating context.
•  Example: If your emissions have increased year-on-year, explain this in the context of expanding operations, but also highlight your long-term decarbonisation strategy. 

 2. Conduct a double materiality assessment (DMA)

• Identify key sustainability matters: Start with a broad range of topics, then screen them based on their relevance to your industry, focusing on both “impact” and “financial” perspectives.
• Prioritise material topics: After your screening process, focus on topics that have significant ESG impacts, risks or opportunities.
• Tip: Use your DMA results to ensure material ESG topics are represented in your business strategy, including targets and actions, something you can do easily with our Plan and Strategise solution.

 3. Organise data point disclosures

• Data-point-by-data-point approach: Each disclosure must specifically address relevant ESRS data points. This approach enables compliance and makes your report easier to analyse for investors and financial analysts.
• Link impacts to business strategy: Provide a narrative about how your environmental or social impacts affect your business model.
• Example: If your workforce training is a key part of decarbonising your operations, ensure the data connects to operating new technology and delivering on decarbonisation goals. You can align this process using our Plan & Strategise solution.

 4. Use appendices effectively

• Include detailed tables: Use an appendix to present your ESRS 2 content index and the EU datapoint table. This keeps the main narrative clean while offering in-depth details for analysts.
• Include data below materiality thresholds: For data that is no longer material but still requested by investors or ratings agencies, place it in the appendix of the sustainability statement for transparency.

 5. Ensure faithful representation

• Meet ESRS qualitative characteristics: Your data must be faithfully represented, ensuring it is complete, neutral and accurate. It must also be relevant, understandable, verifiable, and comparable across reporting periods and with other companies in your industry.
• Avoid selective disclosure: Clearly state all material topics, and explain any that you deem non-material to avoid potential issues with auditors or analysts.
• Example: If biodiversity is not material to your operations, provide a justification, particularly if it’s a concern in your industry. For better management of your supply chain impacts, consider our Supplier Assessment solution.

 6. Structure your sustainability statement

• Four key sections: Organise your report according to the ESRS structure, including general information, environmental data, social aspects, and governance details.
• Utilise a wireframe: Ensure that your report’s structure is compliant with ESRS guidelines while maintaining readability and a logical flow of information.
• Provide narrative support: Strengthen your data disclosures by linking each point back to your business model and strategy.

 7. Prepare for audit

• Conduct pre-audit checks: Ensure that all material data points have been disclosed and properly tracked, and verify phase-in options taken, if any.
• Verify completeness: Use dashboards or tools to track your progress, ensuring all disclosures have been addressed. This is where visualisations can come in handy, as they allow you to get a general overview of your entire progress.

Final thoughts

Writing a comprehensive ESRS sustainability statement requires balancing technical compliance with narrative clarity. This checklist will guide you through the key steps to ensure that your report is both compliant and insightful. Our expert advisors can assist.

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