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ESRS E3: Water and Marine Resources · 2026-5010-final

Disclosure Requirement E3-1

Policies (Water)

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official EFRAG source.

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Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by EFRAG

To prepare this disclosure

15datapoints↓ 6claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain the water-related policies it has in place and how those policies shape its approach to water use, water impacts and water-related risks. In practice, the report should show whether there is a clear policy framework, what it covers, and how it connects to the organisation’s actual activities and decision-making.

The practical focus is on whether the policy coverage is broad enough to matter across the business, not just at a few well-known sites. Readers will want to understand if the policy applies across operations, value chain activities where relevant, and different geographies, and whether it is used consistently rather than existing only as a high-level statement.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Have you settled which water-related activities the policy actually covers: taking water in, using it, releasing it, or storing it? Have you decided whether the policy applies only to your own sites, or also to parts of the wider supply chain? Have you pinned down which water-stress test you are using, including the indicator, the cut-off point, and whether the check is done at basin level? Have you agreed what counts as a water-stress area for this write-up, including the scarcity, quality, and access factors you will use? Can every statement you plan to include be traced back to a named internal source or documented method? Have you fixed the policy name, its stated aims, and any external standards or benchmarks it refers to, using the same definitions throughout?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Water-stress sites List the sites that sit in areas where local water stress is relevant, using the organisation’s chosen location screening and the reporting-period site set. Site register mapped to location screening output; water-risk map or basin lookup; period-end site list. Sustainability / Environment

Stress-site coverage State whether the organisation has covered the relevant sites in its water-stress review for the period, using a simple yes/no response. Completed disclosure checklist; site screening workbook; sign-off from the reporting owner. Sustainability / Environment

Unscreened sites Name any sites that were not included in the water-stress review and identify them clearly enough to trace each one back to the site register. Exception log; site register; screening workbook showing excluded locations. Sustainability / Environment

Coverage note Explain why any sites were left out of the water-stress review, using a brief business explanation tied to the actual screening process. Exception log with reasons; approval notes; internal methodology memo. Sustainability / Environment

Water policy title Provide the name of the policy or policy set that governs water-related management in the organisation. Approved policy register; document control record; intranet policy library. Legal / Sustainability

Policy coverage area Describe which water activities the policy addresses, such as taking water, using it, releasing it, or keeping it in storage. Policy text; policy summary matrix; control framework mapping. Sustainability / Operations

Policy coverage share Enter the share of the organisation’s activities covered by the water policy, using the reporting basis chosen for operations or the wider value chain. Coverage calculation workbook; organisational boundary mapping; policy applicability assessment. Sustainability / Finance

Water policy aims Summarise the main aims the water policy is meant to achieve, in practical terms that reflect the approved policy intent. Policy document; board or management approval paper; policy objectives section. Sustainability / Operations

Referenced standards List the external or internal standards, codes, or frameworks the water policy says it relies on or aligns with. Policy references section; compliance register; standards library. Legal / Sustainability

Water stress drivers Describe which local water-stress drivers were considered, such as limited supply, poor water quality, or restricted access. Risk assessment notes; basin screening output; local context review. Environment / Risk

Risk aspects reviewed State which risk aspects were assessed when judging water stress, using the organisation’s own risk categories and review notes. Risk assessment template; methodology note; review sign-off. Risk / Environment

Water indicator Name the indicator or index used to judge water stress, such as the chosen external metric or internal proxy. Methodology note; screening workbook; source indicator documentation. Environment / Data

Stress threshold State the cut-off used to decide when a location counts as water-stressed, including the exact threshold applied in the analysis. Methodology note; calculation workbook; threshold approval record. Environment / Risk

Basin review Confirm whether the assessment was done at river-basin level and identify the basin-based unit used for the review. Basin map; screening output; geographic methodology note. Environment / GIS

Assessment method Describe the method used to assess water stress, including the steps, data sources, and decision logic applied. Methodology paper; calculation workbook; source data list; review sign-off. Environment / Data

＋ Show E3-1 sub-elements (LRA working checklist)

How to prepare it

1Start by naming the water-related policy you are reporting on, then set out its intended aims and the business areas it covers. Be clear whether it applies to water withdrawal, use, release, storage, or a mix of these, and state whether the policy reaches only your own operations or also parts of the wider value chain.

2Define the basis you used to identify water-stressed locations. Record the stress factors you considered, the risk aspects you assessed, the indicator or screening tool you relied on, the cut-off you applied, and whether the assessment was done at basin level. Keep the method specific enough that another reviewer could follow the same logic.

3Collect the source material that supports the policy details and the location screening. Pull together internal policy documents, site lists, location assessments, and any other records that show how you decided which sites fall within the relevant water-stress screen and how you applied the chosen method.

4Assemble the disclosure content in a way that matches the required data points. Provide the policy name, its scope, the coverage across operations and value chain, the objectives, and any standards or frameworks you relied on. Then set out the water-stress location information, including the sites covered, whether the coverage is complete, any sites left out, and the explanation for those gaps.

5Document any exclusions, partial coverage, or changes in approach. If some sites are not included, explain why. If your method, threshold, or assessment boundary has changed from the prior period, note that clearly so the reported figures or narrative can be understood in context.

6Before finalising, check the disclosure against the official source and the underlying evidence. Confirm that each required item is present, the wording is consistent with your records, and the location screen, policy description, and explanations all align with the source material.

Request the data

Request the water policy and site coverage details

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

Which water-related policy applies, what does it cover, and which sites in water-stressed areas are included or left out?

Use your organisation’s own wording first (for example, your water, utilities, site environment, or operational risk terms), then map that wording to the reporting fields. Do not ask the owner to think in framework language; ask for the documents and site list they already use, and only translate to the disclosure labels at the end.

Weak request

Please provide the ESRS E3:E3-1 policy coverage for water stress, including the policy scope, objectives, standards referenced, and the sites covered and uncovered.

Why it fails: It uses framework language that many operational teams will not use day to day, so the owner may not know which document or site list to pull. It also bundles several ideas into a single abstract ask, which makes it harder to answer cleanly and increases the risk of partial or inconsistent evidence.

Better request

Please send the current water policy or equivalent site environment document, plus the list of sites your team has flagged as being in water-stressed areas. For each site, show whether it is covered by the policy, and if not, give the reason. Include the source file, version/date, and the method you used to identify water-stressed locations. Use your own site and water terms; we will map them to the reporting fields.

Formal email template

Subject: Request for water policy and site coverage details for reporting

Dear [name],

We are preparing the sustainability reporting pack and need your help with the water policy and the related site coverage information.

Please send, for [reporting period]:
- the current water-related policy or equivalent document used by your team;
- the policy name and the areas it covers in your own terms;
- the objectives or aims set out in the document;
- any standards, rules, or internal references it points to;
- how your team screens for water-stressed locations;
- the list of sites identified as being in water-stressed areas;
- which of those sites are covered by the policy;
- any sites in water-stressed areas that are not covered, with a short reason.

Please also include the source system or file location, the version/date, and the person who can confirm the information.

If it is easier, you can return the information in your own format and we will map it to the reporting fields. Please check the official source before sign-off.

Many thanks,
[preparer name]

Short Teams / Slack version

Hi [name] — could you send the current water policy/equivalent and the site list for water-stressed locations for [period]? Please include which sites are covered, any not covered and why, plus the source file/version. Use your team’s own terms; we’ll map them to the reporting fields. Please check the official source before sign-off. धन्यवाद / thanks.

Industry examples

Food and beverage manufacturing

Context. The business has multiple plants and relies on local water supply for production and cleaning.

Adapted request. Please send the current water management policy or plant environment procedure, plus the list of plants in water-stressed basins. For each plant, show whether it is covered by the policy and note any excluded sites with the reason. Include the basin-screening method, the threshold used, and the document version/date.

Example response. Plant A and Plant C are in water-stressed basins and are covered by the policy. Plant B is not in a stressed basin. A leased packing site in a stressed basin is excluded because the landlord controls water systems. Screening used the local basin risk map with a high-risk cut-off.

Data centres / digital infrastructure

Context. The business operates sites with high cooling-water dependence and tracks water risk by location.

Adapted request. Please provide the current water risk and utilities policy, together with the list of data centres and support sites in water-stressed areas. Show which sites are covered, which are not, and why. Include the risk indicator used, the basin-level assessment basis, and the source system or register.

Example response. DC-01 and DC-04 are in water-stressed areas and are covered by the policy. DC-02 is outside the stressed area list. A small office in a stressed area is not covered because it has no direct site water operations. The team used a basin-level water scarcity indicator and a site risk register.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

Explain how the organisation defined the water-risk review, including the policy scope, the parts of the business or value chain covered, the water-related issues considered, the indicator chosen, the cut-off used, and whether the assessment was carried out at basin level.

Context note

Set out what the figures mean in practice by showing how many sites are in water-stressed areas, how many were covered by the review, which sites were not included, and how the policy and assessment approach relate to the organisation’s water exposure.

Fluctuation statement

If the numbers changed from a prior period, explain whether that was driven by a wider or narrower site coverage, a different basin-level result, a revised indicator or threshold, or a change in the sites identified as exposed to water stress.

Content index entry

E3-1 Policies (Water) — [location / page] / [notes]

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Preparation tools & forms

Professional preparation tools for E3-1 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

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01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Go deeper · E3-1

Learn to prepare this disclosure end-to-end

This guide covers one Disclosure Requirement. The ESRS / CSRD Reporting course walks the full European workflow — double materiality, datapoints, evidence and assurance — with exercises on your own data.

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Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

We set out which water-related policies we relied on, and for each one we explained the part of the business it applies to, what it is meant to achieve, and any external framework or rule it draws on.An assurer may test whether the policy list is complete, whether the stated business coverage matches the actual policy documents, and whether the named objectives and references are supported by the underlying texts.Approved policy register; copies of the relevant policy documents; mapping showing each policy to the business areas covered; internal notes or sign-off papers showing the stated aims and any referenced standards were checked against the source documents.

Where a site in a water-stressed area is outside our water-related policy coverage, we said so and identified the gap clearly.An assurer may probe whether the exclusion is real, whether the site list is complete, and whether the gap has been described consistently with the policy scope used elsewhere in the report.Site inventory; policy scope matrix; list of locations flagged as outside coverage; review notes explaining the exclusion decision; management approval of the final wording.

For the water-stress screen, we used a view that considered how much water is available, whether the water is fit for use, and whether people can actually access it.An assurer may challenge whether the screening basis really covered all three dimensions, whether the chosen indicators were applied consistently, and whether the classification of stressed areas is defensible.Methodology paper; indicator definitions; source datasets; basin or catchment analysis files; working papers showing how quantity, quality and access factors were considered; review and approval records.

Our risk review looked at three angles: operational exposure, legal or regulatory pressure, and possible damage to reputation.An assurer may test whether the risk assessment genuinely covered all three dimensions, whether the assessment was applied to the right locations or activities, and whether the conclusions are supported by evidence.Risk assessment template; completed risk registers; workshop outputs; legal/compliance input; reputational risk notes; evidence of review by the responsible team.

We documented the basis for the water-stress classification, including the indicator used, the cut-off applied, the basin-level approach and the method followed.An assurer may ask whether the classification basis is complete, whether the threshold is justified, whether the basin-level logic is applied consistently, and whether the method is reproducible from the records held.Method statement; calculation workbook or model; indicator source and definition; threshold rationale; basin mapping files; version-controlled working papers; sign-off evidence.

We can show how the stress screen was built from a method that was adapted to local conditions and informed by people with local knowledge.An assurer may probe whether the method was genuinely tailored, whether local input was relevant and documented, and whether the final classification still follows a consistent logic across locations.Local consultation notes; site or basin-specific inputs; methodology changes log; evidence of local expert review; comparison between standard and adapted approaches; approval records for the final method.

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes or records evidencing the relevant engagement or consultation

Common reporting gaps

Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.

Common gaps

Mistakes to avoid when collecting the data

Wrong owner

Chasing the sustainability team alone can miss the people who actually run water controls, site operations, or basin assessments, so the draft is built from the wrong source.

Framework language first

Asking for answers in disclosure terms instead of the business's own wording often produces vague replies that staff cannot map back to the real policy or process.

No clear boundary

If nobody states whether the policy covers sites, the wider supply chain, or both, the collected data can mix separate populations that should stay apart.

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Where judgement is often needed

Set the policy boundary when sites move in or out of the group

Decide whether to include newly bought or sold sites in the policy description for the reporting period, and explain the cut-off date and any restatement approach used.

Handle different local meanings for the same water topic

Where country teams use different labels or legal concepts for withdrawal, use, discharge or storage, pick one internal wording, map the local terms to it, and note the mapping in the explanation.

Decide how far the policy reaches beyond owned operations

If the policy also covers suppliers, contractors or other parts of the wider chain, state clearly which parts are in scope and which are not, using the organisation’s own operating language.

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Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Food processing

We mapped our water-related policy to our own sites and the parts of the value chain where water use or releases matter, covering withdrawal, use, discharge and storage. The policy sets targets to cut freshwater demand, improve reuse, and reduce exposure in stressed river basins; it refers to internal water rules plus external references such as the local water authority guidance and the Alliance for Water Stewardship standard. - We identified 12 sites in water-stressed areas out of 40 sites in scope, so 28% of our sites are in those locations; 8 sites are not yet covered by the site-level review, because two were acquired late in the year and six are still being brought into the monitoring process. - For the stress screen we used a basin test based on WRI Aqueduct, with a threshold of medium-high or above; the assessment considered scarcity, water quality and access, and we applied it at basin level rather than only at site level.

Illustrative only; figures and wording are synthetic and for training purposes.

Illustrative (synthetic) example — Pharmaceutical manufacturing

Our group uses a water management policy that applies to our facilities and to upstream suppliers where water dependence is material, and it covers taking water in, using it, releasing it and holding it on site. The policy aims to reduce water intensity, protect continuity in water-constrained basins, and strengthen supplier controls; it draws on internal operating rules together with ISO 14046 and basin plans issued by local authorities. - We found 5 sites in water-stressed basins out of 18 sites reviewed, which is 28%; the site review is complete for those 18 sites, so there are no uncovered sites in this reporting set. - For the screening we used the Water Exploitation Index Plus, set at a high-stress cut-off, and we assessed scarcity, water quality and access at basin level to decide where the main risks sit.

Illustrative only; figures and wording are synthetic and for training purposes.

Company reportsReal published reports

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How companies report E3-1 in practice

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

Mowi ASA

Food Production — Animal Source · Norway · 2024

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Mowi ASA’s Integrated Annual Report 2024 includes a covered narrative on water risk management, specifically mentioning the use of the Aqueduct version 4.0 assessment tool to evaluate overall water risk and ensure responsible water management (p.81). The report also references monitoring water withdrawal, consumption, and discharge, as well as setting water-related targets and supplier requirements related to water (pp.25, 83). However, no detailed quantitative data or comprehensive narrative on water management methodology or outcomes was found, leaving some aspects unclear or missing.

LANXESS Aktiengesellschaft

Chemicals · Germany · 2025

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LANXESS Aktiengesellschaft's Corporate Sustainability Report 2025 provides limited information on water-related disclosures, with a mention of water consumption management on page 55 and identification of 14 water risk sites on page 57. The report references policies related to water management in a general manner on page 22 but does not provide detailed narrative or quantitative data on water use or risk mitigation. Overall, the report lacks clear, quotable evidence or comprehensive data on water-related sustainability practices.

Aena S.M.E., S.A.

Air Transportation — Airport Services · Spain · 2025

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Aena S.M.E., S.A.'s 2025 Sustainability report provides unclear narrative context related to its integrated policies on quality, environmental, energy efficiency, occupational health and safety management, and sustainability objectives (p.153). The report references various environmental disclosures such as policies and actions related to pollution and water and marine resources, but does not clearly disclose specific data points or detailed descriptions for these areas (pp.69, 72, 157). Notably, no quotable evidence or numeric values directly addressing the disclosure were found, indicating a lack of clear or comprehensive reporting on this specific topic.

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Check your understanding

Scenarios to work through

A manufacturing group has a water policy covering factory withdrawals and wastewater discharges, but the draft only names the policy and says it applies to operations. It does not say whether it also reaches suppliers that manage water on the group’s behalf.

QShould the policy summary stay at that high level, or should you spell out which water-related activities it covers and whether it extends into the value chain?

Reveal model answer →

A food producer has a water stewardship policy that mentions reducing use and improving discharge quality, but the team is unsure whether to include water storage because the policy was written before a new reservoir project started.

QDo you leave storage out because it was not in the original draft, or do you update the policy description to reflect the water-related matters it now governs?

Reveal model answer →

A chemicals company has a board-approved water policy, but the draft report says only that the policy exists and was reviewed this year. It does not explain what the policy is trying to achieve or which external or internal standards it draws on.

QWhat extra detail should the preparer add so the policy summary is useful to a reader?

Reveal model answer →

A retail group has several sites in dry regions, but the water policy only says it applies to the company overall. The team is unsure whether it must say anything about those stressed locations or the way the business checks for them.

QWhen some sites sit in water-stressed areas, what should the policy disclosure make clear about coverage and the basis for identifying those sites?

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Framework references