ESRS 2 General Disclosures
ESRS 2 is the mandatory cross-cutting standard of CSRD reporting that defines overarching disclosures on governance, strategy, the materiality process as well as metrics and targets, and applies to every reporting company regardless of its sector.
ESRS 2 "General Disclosures" is the only cross-cutting and consistently mandatory standard within the set of European Sustainability Reporting Standards (ESRS) that apply under the Corporate Sustainability Reporting Directive (CSRD). Whereas the topical standards (ESRS E1 to E5, S1 to S4 and G1) only come into play after the materiality assessment, ESRS 2 must be fully applied by every company subject to reporting obligations. It therefore forms the foundation of the sustainability statement and ensures that readers can interpret the reporting in the context of the business model, strategy and steering structures.
In terms of content, ESRS 2 is structured into four areas: basis for preparation (BP-1, BP-2), governance (GOV-1 to GOV-5), strategy (SBM-1 to SBM-3) and the management of impacts, risks and opportunities (IRO-1 and IRO-2). Companies disclose how the administrative, management and supervisory bodies are involved in sustainability matters, how incentive schemes are structured, which material impacts, risks and opportunities exist along the value chain, and how the double materiality process (impact and financial materiality) was carried out. SBM-3 links the identified material topics to the business model and strategy.
ESRS 2 also contains the central rules for the interaction with the topical standards: for each material topic, the relevant minimum disclosure requirements must be met (MDR-P on policies, MDR-A on actions, MDR-T on targets and MDR-M on metrics). The data points must be tagged in machine-readable form in accordance with the ESRS/ESEF taxonomy and published in a clearly delineated sustainability section of the management report. A diligent implementation of ESRS 2 is therefore a precondition for an auditable report and the subsequent external assurance, which initially takes the form of limited assurance.
Legal Basis
ESRS 2 (Delegated Regulation (EU) 2023/2772); Art. 19a, 29a, 29b Directive 2013/34/EU (CSRD); Sections 289b et seq., 315b et seq. German Commercial Code (HGB)
Practical Example
A compliance officer at a reporting machinery manufacturer prepares the first CSRD report. She does not start with climate metrics but with ESRS 2: she documents how the supervisory board is informed about sustainability risks (GOV-1, GOV-2), describes the business model and value chain (SBM-1) and discloses the approach to the double materiality assessment (IRO-1). Only after determining the material topics does she add the topical disclosures, mapping policies, actions, targets and metrics for each topic to the ESRS 2 minimum disclosure requirements, so that the report can later withstand the requirements of the statutory audit.