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

Disclosure Requirement E3-4

Water Metrics

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

11datapoints↓ 6claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain the water-related numbers it uses to show how it manages water impacts and dependencies. In practice, that means reporting the relevant metrics clearly and consistently, so readers can understand the organisation’s water performance, how it is tracking change over time, and where the main water-related pressures or improvements are showing up.

The practical focus is on coverage and comparability: the organisation should be clear about whether the figures cover all operations, selected sites, or only material locations, and how those boundaries were set. It should also make clear what the metrics do and do not include, so users can judge whether the data reflects the full business or only a subset such as high-profile or high-risk sites.

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 fixed which sites, operations, and water flows are included in each figure, so the totals are built on the same scope throughout? Have you chosen the time basis for the numbers, and will every figure come from that same reporting period? Can each amount be traced back to a named source, such as meter records, invoices, logs, or a calculation file? For the water held on site, have you agreed what counts as stored water in your own operations, so the team uses one definition? For the recycled and reused amounts, have you separated those two streams in a way your records can support without double counting? Have you settled the method, inputs, and assumptions for any calculated figures, and are the units set to cubic metres everywhere?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Total water used Capture the organisation-wide volume of water consumed in the reporting period, in cubic metres, using the same boundary and period as the rest of the water dataset. Water balance, utility invoices, meter reads, site water logs, consolidation workbook. Environment / Sustainability

Water use in stressed areas Capture the volume of water consumed during the period from locations identified as water-stressed, in cubic metres, using the same boundary and period as the total water figure. Site register with water-stress flag, meter data by site, water-risk mapping, consolidation workbook. Environment / Sustainability

Total water taken Capture the total volume of water withdrawn during the reporting period, in cubic metres, across all relevant sources within the reporting boundary. Utility bills, abstraction records, meter logs, supplier statements, site water registers. Operations / Facilities

Total water released Capture the total volume of water discharged during the reporting period, in cubic metres, for all relevant outlets within the reporting boundary. Effluent logs, discharge permits, treatment plant records, meter data, site environmental logs. Operations / Facilities

Water recycled Capture the volume of water that was processed and returned for use again during the reporting period, in cubic metres. Process water logs, recycling plant records, reuse tracking sheets, site engineering records. Operations / Facilities

Water reused Capture the volume of water that was used again in operations during the reporting period, in cubic metres, after an initial use. Reuse logs, site water management records, process flow records, engineering sign-off. Operations / Facilities

Water stored Capture the volume of water held in storage at the reporting date, in cubic metres, using the same cut-off date and boundary as the rest of the water data. Tank level reports, reservoir records, site inventory, meter and gauge readings at period end. Operations / Facilities

Calculation approach Describe the method used to calculate the reported water figure, including the formula or approach applied and how the result was derived. Calculation workbook, methodology note, internal control sheet, reviewer sign-off. Environment / Sustainability

Method inputs List the input variables used in the calculation, including W and D, and explain what each input represents in the working. Calculation template, source-data mapping, methodology note, model input sheet. Environment / Sustainability

Key assumptions State the assumptions applied in the calculation, including any estimation choices, conversion factors, or missing-data treatments used to produce the figure. Method note, estimation policy, calculation workbook comments, approval trail. Environment / Sustainability

Measurement units Capture the unit used for the reported water figure, confirming that the same unit is used consistently across the dataset and supporting calculations. Reporting template, calculation workbook, unit labels in source files, QA check. Environment / Sustainability

＋ Show E3-4 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first. Decide which sites, operations and water-related activities sit inside the scope for this disclosure, so every later figure is built on the same perimeter.

2Agree the measurement basis for each water item. Define what your team will treat as consumption, intake, release, recycling, reuse and stored water, and make sure the same unit is used throughout the pack.

3Gather the source records and working papers. Pull together meter reads, supplier or utility statements, site logs, treatment records and any other evidence needed to support the numbers and the narrative method note.

4Calculate and compile the reported amounts. Prepare the totals for overall use, use in stressed areas, intake, discharge, recycled volumes, reused volumes and stored volumes, and record the method, inputs and assumptions used to derive them.

5Explain any exclusions, estimates or changes in approach. If a site, stream or period is left out, or if the calculation basis has changed, document why and show how that affects the reported figures.

6Check the draft against the source requirements before sign-off. Confirm that every required number and text field is present, the units are consistent, and the final submission matches the official source material and internal evidence.

Request the data

Request the site water figures and method notes

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

What water volumes, storage figures, and calculation notes do we need for the reporting period, across our own sites and operations?

Use your organisation’s own water and utilities terms first, then map them to the reporting fields. Ask for the figures the team already tracks in meters, bills, plant logs, discharge records, reuse/recycling logs, and storage records; avoid framework labels unless your team already uses them.

Weak request

Please provide the ESRS E3:E3-4 water metrics for the period, including all required data points and the calculation method.

Why it fails: This uses framework language that many operational teams will not recognise, and it does not tell the owner which records to pull, which sites are in scope, or what supporting notes are needed. It is too abstract to action quickly.

Better request

Please send the water figures your team already holds for [period] and [sites/boundary]: water used, water taken in, water sent out, recycled water, reused water, storage, and any split for sites in water-scarce areas. For each figure, include the source record, unit, whether it is metered/billed/estimated/modelled, and the method and assumptions used to build the number. If your team uses different site or utilities labels, keep those labels and we will map them.

Formal email template

Subject: Request for water figures and method notes for [reporting period]

Hi [name/team],

Please could you send the water data and supporting notes for [reporting period] for [boundary/sites]. We need the figures your team already holds for:
- total water used/consumed
- the part linked to sites in water-scarce areas
- total water taken in
- total water sent out
- water recycled on site
- water reused on site
- water held in storage

Please also include:
- the source record or system for each figure
- the unit used in the source record
- whether each figure is metered, billed, estimated, or modelled
- the calculation method used
- the inputs and assumptions behind the calculation
- any conversion factors used

If you already track these under different site or utilities terms, please use those terms in your reply and we will map them. A simple table is fine.

Please send this by [date]. If anything is unclear, I’m happy to talk it through.

Thanks,
[preparer name]

Short Teams / Slack version

Hi [name/team] — could you share the water figures for [period] for [sites/boundary]? Please include the totals you already track for water used, water taken in, water sent out, recycled/reused water, storage, and any water-scarce site split, plus the source, unit, method, and assumptions. Use your own site/utility terms and we’ll map them. Thanks.

Industry examples

Manufacturing

Context. A factory with process water, cooling systems, and a wastewater treatment plant.

Adapted request. Please share the water figures for [period] for the factory and any linked utilities records: incoming mains water, process water, cooling water, treated effluent, recycled process water, reused water, and tank storage. Include the meter or log source, unit, method, and any assumptions used to combine site readings.

Example response. Plant log shows 48,200 m3 incoming water, 6,400 m3 recycled on site, 2,100 m3 reused after treatment, 39,700 m3 discharged, and 1,850 m3 stored in tanks. All figures are meter-based except one estimated discharge value, which is noted with the assumption used.

Hospitality / Real Estate

Context. A portfolio of hotels and office buildings with utility bills and building management system data.

Adapted request. Please send the water figures for [period] across the portfolio: mains water use, any water held in tanks, any reuse or recycling from building systems, and the split for any sites flagged as water-scarce. Please include the bill or system source, unit, and whether each figure is billed, metered, or estimated.

Example response. Portfolio spreadsheet lists 12,300 m3 total water use, 1,100 m3 in water-scarce locations, 240 m3 reused from greywater systems, and 90 m3 stored in backup tanks. Sources are utility bills and BMS exports, with one estimate for a missing meter reading.

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 figures were built, including the calculation approach used, the inputs applied, the assumptions made, and the fact that all amounts are reported in cubic metres.

Context note

Set out what the numbers mean in practice by distinguishing water taken in, water actually used, water released, water kept in storage, and water that was recycled or reused, including the portion linked to stressed locations.

Fluctuation statement

If any measure moved materially, explain whether the change came from operational activity, site mix, water-saving actions, recycling or reuse practices, storage changes, or shifts in exposure to stressed areas.

Content index entry

E3-4 Water Metrics — [location / page] / [notes]

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Preparation tools & forms

Professional preparation tools for E3-4 — 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 · E3-4

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.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

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Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

We limited the coverage figure to water used in our own sites and activities, and we documented which locations and processes were included or left out.An assurer will test whether the boundary was set consistently, whether any sites or activities were omitted without a clear reason, and whether the reported figure matches the stated scope.Boundary memo; site list and inclusion/exclusion log; consolidation or reporting scope notes; management sign-off on the final scope; reconciliation between the included sites and the reported total.

For the stress-area figure, we first mapped our operations against the relevant water-stress locations and then only counted the water linked to those places.The main challenge is whether the stress-area filter was applied correctly, whether the location mapping is current, and whether any facilities in stressed areas were missed or misclassified.Geographic mapping or GIS output; list of facilities in stressed locations; source used to define stress areas; working papers showing how the subset was calculated; review notes for any borderline sites.

Our discharge number was built from the operational records we hold for releases from our own activities, with any non-routine items tracked separately and assessed before inclusion.An assurer will probe whether all relevant outflows were captured, whether the same basis was used across sites, and whether unusual or one-off discharges were treated consistently.Site discharge logs; wastewater or effluent records; consolidation workbook; treatment or transfer records where relevant; explanation of any exclusions, estimates, or one-off adjustments.

We calculated the recycled-and-reused figure from internal records showing water sent back into use, and we checked that the same volume was not counted twice.The key risk is double counting, especially where water moves through more than one reuse step or site, and whether the evidence supports the reported amount.Reuse and recycling logs; process flow records; meter data; calculation sheets showing any de-duplication; controls over transfers between facilities; reviewer sign-off.

The stored-water amount was prepared from our operational records for water held on site, and we separated storage from water that had already been used or discharged.An assurer will look for confusion between storage, consumption, and discharge, and will test whether the storage figure reflects actual held volumes rather than estimates without support.Tank or reservoir inventories; site stock records; meter readings; engineering or operations logs; calculation support for any estimated volumes; evidence of review before publication.

We compiled the withdrawal figure from source records showing water taken into our operations, and we reconciled it to the underlying meters, invoices, or supplier statements where available.The assurer will test whether withdrawals were measured on a consistent basis, whether purchased and abstracted water were handled correctly, and whether the total ties back to source evidence.Meter data; utility invoices; abstraction permits or supplier statements; site-level withdrawal logs; consolidation worksheet; reconciliation to the final reported total.

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 for meter readings instead of the site, utilities, or facilities lead means the figures come from people who do not hold the operational records.

Framework language only

Asking for the data in reporting jargon rather than the business's own terms leaves teams unsure whether you mean intake, outflow, reuse, storage, or another local measure.

No boundary set

Collecting numbers without first fixing which sites, activities, and water sources are in scope leads to totals that cannot be compared or defended.

＋ Show 5 more

Where judgement is often needed

Set the cut-off date for bought or sold sites

Choose one reporting cut-off for acquisitions and disposals, apply it consistently across all water figures, and explain any material change in the perimeter from the prior period.

Map local water labels to one group-wide meaning

Where country teams use different local labels or utility categories, define a single internal meaning for each water flow, state the mapping used, and note any places where the local source does not fit neatly.

Decide how to treat borderline operations and shared sites

Make a clear call on whether partially controlled sites, joint operations, leased premises, or other edge-of-scope locations are included, then describe the rule used to keep the boundary consistent.

＋ Show 7 more

Examples

Illustrative examples

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

Illustrative (synthetic) example — Food processing

We report our water figures for the year using cubic metres. Our figures cover water taken in, water sent out, water kept on site, and the amounts we treated for another use or sent back into use; we also show the share of use in stressed catchments and explain the method, inputs and assumptions used to calculate the numbers.

Synthetic example only. It shows how a reporter might present the required water metrics and the calculation basis in plain language.

Illustrative water balance and reuse profile (m³)

Water taken in during the year420000180000

Water sent out during the year410000170000

Water kept on site at year end2500015000

Water treated for another use1800012000

Water put back into use220008000

Illustrative (synthetic) example — Textiles manufacturing

We present our annual water position in cubic metres and explain how the figures were built up. The disclosure separates total use, use in stressed areas, intake, outflow, water held on site, and the volumes recovered for another cycle or reused, together with the calculation approach, inputs and assumptions.

Synthetic example only. It shows a different plausible reporter and a different set of internally consistent figures.

Illustrative water balance and reuse profile (m³)

Water taken in during the year260000140000

Water sent out during the year250000130000

Water kept on site at year end120008000

Water treated for another use140006000

Water put back into use160004000

Company reportsReal published reports

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How companies report E3-4 in practice

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

LANXESS Aktiengesellschaft

Chemicals · Germany · 2025

Open report →

LANXESS Aktiengesellschaft’s Corporate Sustainability Report 2025 provides specific data on water consumption in water risk areas, reporting a volume of 1,290,351 m3 with 946,414 m3 recycled (p.59). The report also references water consumption metrics relative to net sales and sets a target to reduce water consumption by 10% by 2030 compared with the base year 2024 (pp.58, 56). However, the report lacks clear narrative or methodological explanations regarding water volume calculations, and no additional volume data beyond the figures on page 59 are provided.

Fluidra, S.A.

Electrical Equipment and Machinery · Spain · 2025

Open report →

Fluidra's 2025 Integrated Annual Report provides some contextual information on water management, including statements that water discharge equals water withdrawal, indicating no net water consumption (p.134), and mentions of water reuse rates at specific facilities (p.133). The report also references calculations of the water footprint in terms of direct and indirect flows (p.136) and includes discussion of water intensity by consumption (p.135). However, the report does not clearly disclose specific volume values in cubic meters for water consumption, and the methodology or detailed narrative on this metric remains unclear or absent.

UPM-Kymmene Oyj

Forest and Paper Products · Finland · 2024

Open report →

UPM-Kymmene Oyj’s 2024 Annual Report references water consumption metrics, including water withdrawal, outflow, and consumption in cubic metres, particularly on page 95, but does not provide clear quantitative values for these volumes. The report mentions improvements in water efficiency at the mill level (p.94) and refers to total water recycled and reused as well as water consumption per net revenue (p.74), though specific figures or detailed disclosures are not clearly presented. Narrative explanations or methodology related to water volume disclosures are either missing or unclear throughout the report.

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Check your understanding

Scenarios to work through

A manufacturing site buys water from the local utility, sends some process water to treatment, and keeps a small tank on site for firefighting. The site team has separate meter reads for incoming supply, outgoing effluent, and the tank level at year-end, but the finance pack only shows one net water figure.

QWhich separate figures should you prepare for the disclosure, and how should you treat the tank water and any water used again on site?

Reveal model answer →

A group has three sites, but only one sits in a water-stressed area. The local team can identify the site’s total water use, yet it has not split out the portion linked to that stressed location because the utility bill is combined with other sites.

QWhat should you do before finalising the water-use figures for the report?

Reveal model answer →

A food processor recycles cooling water internally and also reuses treated water for cleaning. The operations team has one combined estimate for both activities, but the sustainability team needs the disclosure completed for year-end reporting.

QCan you report one combined number for both activities, or do you need to separate them?

Reveal model answer →

An engineering site estimates water withdrawal from pump runtime and flow rates because one meter failed mid-year. The team has recorded the calculation approach, the inputs used, and the assumptions about downtime, but the draft note only shows the final number.

QWhat extra information should accompany the water metric so a reviewer can understand how the number was built?

Reveal model answer →

Framework references