Disclosure focus
This disclosure asks an organisation to explain the water- and marine resources-related targets it has set, and how those targets are meant to drive action. In practice, the report should make clear what each target is about, the time horizon, the baseline or starting point where relevant, and how progress will be tracked. It should also show whether the target is linked to the organisation’s material water-related impacts, risks or opportunities, rather than being a general sustainability ambition.
The practical focus is on whether the targets are meaningful and usable for decision-making. That means readers should be able to see the scope of coverage — for example, whether a target applies across the whole business, specific regions, high-risk sites, or only selected operations — and understand any boundaries, assumptions or dependencies. The aim is to let users judge how far the targets reflect the organisation’s real water exposure and how credible the planned progress is.
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.
Preparation
Key datapoints to prepare
＋ Show E3-3 sub-elements (LRA working checklist)
Set the starting point used for comparison.
State the water measure being tracked, such as use or take.
Set out the planned cuts in water use or withdrawal.
Give the target figures to be reached.
Say when each target is due.
Break targets down by river basin or other geographic area.
Identify which water-stressed areas are included.
How to prepare it
1Set the reporting boundary first: decide which sites, operations, basins or other geographies are in scope, and make sure any water-stress locations that the target covers are clearly included.
2Define each target in business terms: state the aim, the water-related measure you are using, the starting point, the end date or milestone, and whether the target is for lowering use, withdrawals, or another water outcome.
3Gather the source records behind the target: pull together the calculations, site data, management papers, and any location mapping needed to support the figures and the narrative.
4Prepare the disclosure content: present the target values and the related details in a way that lets a reader see what is being measured, from which starting point, over what period, and for which parts of the business or geography.
5Record any limits or changes to the scope: explain where a basin, region, or water-stress area is included or left out, and note any changes in the target basis, coverage, or timing so the reader can follow the comparison.
6Check the draft against the source material: confirm the wording and figures match the underlying records and the official ESRS source, and resolve any gaps before finalising.
Request the data
Request the water target evidence from the operational owner
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What water-related targets has the business set, what do they measure, what baseline and end date do they use, and where do they apply across sites or water-stressed locations?
Use the organisation’s own wording first, then map it to the reporting disclosure. Ask for the business’s normal terms for water use, intake, discharge, site groups, catchments, and stressed locations rather than framework labels.
Weak request
Please send the ESRS E3 targets data for disclosure E3-3, including the target metric, baseline, timeline, reduction target, and basin/geography coverage.
Why it fails: This uses framework language that many operational owners will not use day to day, so it can slow the response and produce a partial answer. It also does not ask for the business’s own wording, source file, approval status, or the site-level split needed to check what is actually covered.
Better request
Please send the latest water target pack or tracker from your team. I need the wording you use internally, what it measures, the baseline year and value, the end date or milestone, the planned reduction or improvement, any split by basin or region, and which water-stressed sites are included. Please add the source, version/date, and any approval note.
Industry examples
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
State which water measures are included, how each one is defined, what starting figure is used, the time horizon for each goal, and how any planned reduction is calculated.
Context note
Explain what the figures show in practice by linking the starting level, the intended end level, and the places where the targets apply, especially where water pressure is higher.
Fluctuation statement
If the figures move from one period to the next, note whether the change reflects a revised starting point, a different target date, a wider or narrower geographic scope, or a change in the reduction plan.
Content index entry
E3-3 Targets — [location / page] / [notes]
Download Centre
Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner, wrong language
People often ask the sustainability team in framework terms instead of the water, operations, or site lead who actually holds the target records and uses the organisation’s own labels.
No clear boundary
Teams sometimes pull target data without first fixing which sites, business units, or regions are in scope, so the figures mix different parts of the business.
Mixed time basis
Data gets collected against the wrong period when one team uses the current reporting year and another uses a different planning year or cut-off date.
Different counting bases blended
A target tied to one measure is sometimes combined with figures built on another basis, such as mixing volume, withdrawal, or consumption records without separating them.
Source labels stripped out
During consolidation, the original names from spreadsheets, systems, or site logs are lost, making it hard to trace what each target number actually came from.
Separate populations merged
Targets for different basins, geographies, or water-stress locations are sometimes rolled together even though they should stay distinct for collection and review.
Evidence details missing
The team saves the number but not the supporting metadata, such as the source file name, date extracted, version, or preparer, so the trail cannot be checked later.
No sign-off trail
Draft target data is passed along without a named reviewer or approval record, leaving no clear evidence of who checked the figures before they were used.
Where judgement is often needed
Choosing the cut-off date for the target set
Pick one date for the target snapshot, explain why that date was used, and keep the same basis when you compare later updates unless you clearly explain a change.
Deciding what happens after buying or selling a business
State whether the target line was rebuilt to reflect acquisitions or disposals, and describe any restatement so readers can see whether the starting point moved.
Handling different local water labels across countries
If sites use different local terms for the same water measure, map them to one internal definition, explain the mapping, and note any places where the local label does not line up neatly.
Setting the boundary for mixed-use sites and shared assets
Explain how you treated locations, assets, or operations that sit partly inside and partly outside the reporting scope, including any split allocation or exclusion rule.
Using measured figures versus estimates
Say where the target baseline or progress figure comes from direct measurement and where it is estimated, and explain the method used when actual readings were not available.
Choosing the geography for basin or stress-area targets
If a target is set by river basin, region, or stressed area, describe the map or classification used and how you dealt with sites that fall near a boundary or in more than one area.
Setting the baseline when data quality is uneven
If the starting point combines different data quality levels, explain which sources were used, how gaps were filled, and whether any parts of the baseline were excluded.
Rounding and small differences in totals
State the rounding rule used for target values and progress figures, and make clear when small differences are only due to rounding rather than a change in the underlying data.
Protecting sensitive site-level information
Where site detail could reveal sensitive operational information, disclose the target at a higher level of grouping, explain the aggregation approach, and keep the grouping consistent over time.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food processing
We set a 2030 water-use goal for our own operations: to cut freshwater intake by 30% from a 2024 starting point of 10,000 m³, with progress tracked as total water withdrawn. The target applies to three river basins where we operate, including two water-stressed areas, and we will report basin-by-basin progress against the same baseline each year. - Baseline year: 2024; starting volume: 10,000 m³. - Target level: 7,000 m³ by 2030, which is a 30% cut from the starting point. - Geographic coverage: three basins in total; two of them are water-stressed.
This example shows how to describe a water-reduction target using a clear starting point, a quantified end point, a deadline, the measure being tracked, and the geographic scope, including stressed areas.
Illustrative (synthetic) example — Textiles
Our group has a 2035 plan to reduce process-water demand in our manufacturing sites by 25% from a 2025 baseline of 8,000 m³, using total water withdrawal as the tracked measure. The same goal covers four catchments across two countries, and three of those catchments are classed as water-stressed, so we will monitor delivery separately for each geography. By the end of 2035, we aim to reach 6,000 m³ overall, with annual updates showing movement from the baseline toward that level.
This example demonstrates a target stated as a percentage cut and an absolute end value, linked to a baseline year, a deadline, the metric used, and basin-level coverage that includes stressed locations.
How companies report E3-3 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Saipem SpA
Oil and Gas · Italy · 2025
Saipem SpA’s 2025 Consolidated Sustainability Statement includes a covered datapoint on the reduction of freshwater withdrawn for domestic use, reporting a target of 60% of applicable sites with a baseline and methodology mentioned on page 102. The report also provides partial supporting context on metrics and targets related to various topics, referencing specific ESRS standards on page 18. However, the disclosure lacks a clear headline value for some targets, and several narrative items relevant to the disclosure are not found or remain unclear within the report.
LANXESS Aktiengesellschaft
Chemicals · Germany · 2025
LANXESS Aktiengesellschaft’s 2025 Corporate Sustainability Report provides several concrete data points related to environmental targets, including a baseline value of 861 metric tons set in 2024 as the basis for a reduction target (p.50) and a goal to reduce water consumption by 10% by 2030 compared with the 2024 base year (p.56). The report also references Scope 3 reduction efforts aligned with the 1.5°C climate goal (p.40) and mentions a 9% absolute reduction of water withdrawals at sites, though this is less clearly disclosed (p.55). However, some expected narrative details are missing or unclear, with no direct evidence found for certain datapoints and some related context lacking precise disclosure.
Danone S.A.
Food Production — Animal Source · France · 2025
Danone S.A.'s Universal Registration Document 2025 reports a commitment to reduce absolute scope 1 and 2 energy and industrial greenhouse gas emissions by 36% by 2025 and 46.3% by 2030, with related targets and progress discussed on page 226. The report includes some context on water consumption intensity reduction on page 444, but this is not clearly disclosed as a specific datapoint. Other expected disclosures are not found or remain unclear in the report.
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Scenarios to work through
A manufacturing group has set a 2030 water-use goal for its two plants in a river basin that is already under pressure. The draft note says the aim is to 'use less water', but it does not yet say what measure is being tracked or what year is being used as the starting point.
QWhat should the preparer confirm before finalising the target description?
Reveal model answer →Hide answer ↑They should make sure the target is described with enough detail to show what is being measured, where the starting point sits, and when the target is meant to be reached. If the goal is a cut in water use, the note should also make clear the reduction element rather than leaving it as a vague ambition.
Why this matters · A target needs a clear metric, a baseline and a time horizon, not just a general ambition.
A food producer has one water target for all sites, but only three of its eight sites are in areas with water stress. The sustainability team is unsure whether the same target can be used for the stressed sites and the other locations.
QHow should the preparer think about the scope of the target?
Reveal model answer →Hide answer ↑They should check whether the target is meant to cover specific basins or other geographic areas, and whether it separately covers locations exposed to water stress. If the organisation uses different coverage for different places, that distinction should be made plain rather than blending all sites into one undifferentiated target.
Why this matters · Where water pressure differs by location, the target scope should show which basins or stressed areas it covers.
A beverage company has a target to cut freshwater withdrawals by 20% by 2030 against a 2024 baseline. During drafting, the team realises that the 2024 figure was based on total water use, not withdrawals alone, because the two terms were mixed up in the source data.
QWhat is the right judgement on the target wording?
Reveal model answer →Hide answer ↑The preparer should align the target with the same measure used for the baseline and the reduction aim. If the baseline was built from the wrong water measure, the target description needs to be corrected so the starting point and the reduction metric match and the reader can compare them properly.
Why this matters · The baseline and the target must be built on the same water measure.
A paper mill has a target to reduce water consumption by 15% by 2028 from a 2022 baseline. The draft includes the percentage and end date, but it does not say whether the target applies to the whole business or only to sites in water-stressed regions.
QWhat extra judgement should the preparer make before sign-off?
Reveal model answer →Hide answer ↑They should confirm whether the target is set for the whole organisation or only for particular basins or stressed locations, and then state that clearly. If the target is limited to certain geographies, that limitation should be visible so users can see the intended coverage and compare it with the organisation’s water-risk profile.
Why this matters · Readers need to know whether a water target is company-wide or limited to specific places.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
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FAQ
Questions this page answers
What do I need to have ready for E3-3 before I start drafting the disclosure?+−
Use the page’s datapoint list as your starting checklist: target statement, measurement basis, starting point, target date, cut in water use, basin target split and stress-area coverage. The page also gives a step-by-step preparation flow, so you can move from scoping to drafting in a structured way.
How do I use the E3-3 step-by-step preparation section in practice?+−
Treat it as a working sequence for building the disclosure rather than a theory note. It is there to help you define the scope, gather the right inputs, and turn them into a draft that is ready for review.
What data points should I collect for the E3-3 water target disclosure?+−
The page says to prepare seven core datapoints: target statement, measurement basis, starting point, target date, cut in water use, basin target split and stress-area coverage. Collect these in a consistent format so they can be checked against the evidence pack and used in the draft output.
How should I set the measurement basis for E3-3 so the numbers are usable in the draft?+−
The page flags measurement basis as one of the required datapoints to prepare, so you should define it clearly before drafting. Keep it consistent with the rest of the figures so the target, starting point and cut in water use can be read together.
Who should own the E3-3 data collection and sign-off process?+−
The page does not assign roles, but it is designed for use by sustainability or ESG managers, HR or data owners, and assurance reviewers. In practice, you would use it to coordinate ownership across whoever holds the target, water-use and location data, then route the pack for review.
What evidence do I need to make E3-3 assurance-ready?+−
The page includes an evidence pack with five items and also lists six assurance claims to verify, each with a claim, risk and evidence angle. Use those together to build a file that shows where each reported figure came from and how it was checked.
What are the common mistakes to avoid when preparing E3-3?+−
The page has a section on common reporting gaps and mistakes, so it is meant to help you spot weak points before sign-off. Use it as a pre-assurance check to catch missing datapoints, unclear scope or unsupported figures.
How do I use the E3-3 workbook download to build the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to help you organise the preparation and evidence process. Use it alongside the page’s checklist, assurance claims and draft-output section to move from raw inputs to a reviewable draft.
What can I take from the E3-3 printable Library Card PDF?+−
The printable Library Card is part of the Download Centre and is meant as a practical companion to the page. Use it as a quick reference while you gather data, check the evidence pack and prepare the draft.
How do I turn the E3-3 data into a draft disclosure?+−
The page includes a draft-output section with visualisation ideas, narrative starters and a content-index line. That gives you a ready-made way to turn the prepared datapoints into a short narrative and a structured draft for review.
More questions this page can help with
E3-3 water target disclosure checklist: what should I collect before drafting?E3-3 target statement and starting point: how should I document them?E3-3 measurement basis: what does the page want me to capture?E3-3 basin target split: how do I present it in the workbook?E3-3 stress-area coverage: how do I evidence it for assurance?E3-3 evidence pack: what should go in it?E3-3 assurance claims: how do I use the claim-risk-evidence table?E3-3 common reporting gaps: what mistakes should I check for?E3-3 workbook download: how do I use the .xlsx file to prepare the disclosure?E3-3 printable Library Card PDF: what is it for?E3-3 draft output: what narrative starters are available?E3-3 from company reports table: how can I use the examples without treating them as a template?
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