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ESRS E3: Water·Disclosure Requirement E3-1
Policies related to water
Practical guidance for preparing this disclosure. Use this card to identify the information to prepare, verify claims and organise supporting evidence. For exact requirements, always refer to the official European Commission source.
Published passport
Last reviewed 2026-07-24
Reviewed by
Dr Ross KurinkoLinkedIn
Strategic ESG Advisor · IFRS S1 & S2 / GRI / ESRS expert
GRI Certified Global Trainer · PhD, University of Cambridge · ESG-AI expert
15+ years on FTSE 100 & Fortune Global 500 disclosures
Canary Wharf, London
LRA educational guidance · Not issued or endorsed by European Commission
Standard
ESRS E3: Water
Disclosure Requirement E3-1 · 2026-5010-final
Last reviewed
2026-07-24
LRA educational guidance · Not issued or endorsed by European Commission
To prepare this disclosure
Disclosure focus
E3-1 reports water-related policies in accordance with ESRS 2 GDR-P. It links each policy to material water-related impacts, risks or opportunities and describes the policy's contents, objectives, scope, accountability and relevant commitments.
Where the undertaking has sites in areas with water stress that are not covered by water-related policies, it discloses that fact. Screening methods, thresholds and basin reviews may support this conclusion but are not separate E3-1 requirements.
If no water-related policy exists for a material water matter, the undertaking records that fact through the applicable ESRS 2 disclosure route rather than inventing a policy title.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official European Commission source.
Before you start
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key information to prepare
| Preparation field | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Material impacts, risks and opportunities | Identify the material impacts, risks or opportunities that each policy addresses. | Dated source records, governance papers and approval evidence supporting material impacts, risks and opportunities. | Sustainability reporting |
| Policy contents and objectives | Describe the policy's key contents and general objectives. | Dated source records, governance papers and approval evidence supporting policy contents and objectives. | Sustainability reporting |
| Policy scope and exclusions | Describe scope or exclusions across own operations, upstream and downstream value chain, geographies and affected stakeholder groups where defined. | Dated source records, governance papers and approval evidence supporting policy scope and exclusions. | Sustainability reporting |
| Accountability | Identify the most senior level in the undertaking accountable for implementation. | Dated source records, governance papers and approval evidence supporting accountability. | Sustainability reporting |
| Third-party commitments | Identify third-party standards or initiatives only where the policy commits the undertaking to respect them through implementation. | Dated source records, governance papers and approval evidence supporting third-party commitments. | Sustainability reporting |
| Stakeholder interests and availability | Explain how key stakeholder interests were considered and how the policy is made available to affected stakeholders where relevant. | Dated source records, governance papers and approval evidence supporting stakeholder interests and availability. | Sustainability reporting |
| Policy changes | Describe material policy changes during the reporting period, where applicable. | Dated source records, governance papers and approval evidence supporting policy changes. | Sustainability reporting |
| Uncovered sites in areas with water stress | State whether any own-operation sites in areas with water stress are not covered by water-related policies. | Dated source records, governance papers and approval evidence supporting uncovered sites in areas with water stress. | Environment / Sustainability reporting |
＋ Show E3-1 sub-elements (LRA working checklist)
Identify the material impacts, risks or opportunities that each policy addresses.
Describe the policy's key contents and general objectives.
Describe scope or exclusions across own operations, upstream and downstream value chain, geographies and affected stakeholder groups where defined.
Identify the most senior level in the undertaking accountable for implementation.
Identify third-party standards or initiatives only where the policy commits the undertaking to respect them through implementation.
Explain how key stakeholder interests were considered and how the policy is made available to affected stakeholders where relevant.
Describe material policy changes during the reporting period, where applicable.
State whether any own-operation sites in areas with water stress are not covered by water-related policies.
How to prepare it
Use the GDR-P scope structure and revised ESRS E3 Water; do not include marine resources as though they remained part of E3.
Collect and reconcile the records for: Material impacts, risks and opportunities; Policy contents and objectives; Policy scope and exclusions; Accountability; Third-party commitments; Stakeholder interests and availability; Policy changes; Uncovered sites in areas with water stress.
The uncovered-site statement applies when sites in areas with water stress exist; internal screening evidence supports but does not replace the disclosure.
Draft the response using the defined terms shown in the disclosure focus; do not substitute broader internal labels.
Review the final wording against every requirement and the supporting governance or data records before sign-off.
Request the data
Request the disclosure evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Provide the water-policy inventory, material-IRO mapping, scope and accountability evidence, policy changes, third-party commitments and the list of own-operation sites in areas with water stress not covered by policy.
Use the organisation's own role and document names, but preserve the defined ESRS terms and the scope described above.
Better request
Provide the water-policy inventory, material-IRO mapping, scope and accountability evidence, policy changes, third-party commitments and the list of own-operation sites in areas with water stress not covered by policy.
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
Use the official term areas with water stress and distinguish policy content from supporting water-stress screening controls.
Context note
Do not calculate policy coverage percentages unless they are useful entity-specific information and clearly labelled as such.
Download Centre
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.
Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| Material impacts, risks and opportunities is reported accurately and completely. | The response omits, misclassifies or overstates material impacts, risks and opportunities. | Dated source records, governance papers and approval evidence supporting material impacts, risks and opportunities. |
| Policy contents and objectives is reported accurately and completely. | The response omits, misclassifies or overstates policy contents and objectives. | Dated source records, governance papers and approval evidence supporting policy contents and objectives. |
| Policy scope and exclusions is reported accurately and completely. | The response omits, misclassifies or overstates policy scope and exclusions. | Dated source records, governance papers and approval evidence supporting policy scope and exclusions. |
| Accountability is reported accurately and completely. | The response omits, misclassifies or overstates accountability. | Dated source records, governance papers and approval evidence supporting accountability. |
| Third-party commitments is reported accurately and completely. | The response omits, misclassifies or overstates third-party commitments. | Dated source records, governance papers and approval evidence supporting third-party commitments. |
| Stakeholder interests and availability is reported accurately and completely. | The response omits, misclassifies or overstates stakeholder interests and availability. | Dated source records, governance papers and approval evidence supporting stakeholder interests and availability. |
| Policy changes is reported accurately and completely. | The response omits, misclassifies or overstates policy changes. | Dated source records, governance papers and approval evidence supporting policy changes. |
| Uncovered sites in areas with water stress is reported accurately and completely. | The response omits, misclassifies or overstates uncovered sites in areas with water stress. | Dated source records, governance papers and approval evidence supporting uncovered sites in areas with water stress. |
Evidence pack to prepare
Common reporting gaps
Using the old Water and Marine Resources title.
Omitting GDR-P elements.
Treating screening methodology as the disclosure itself.
Requiring a policy coverage percentage.
Failing to provide an absence-of-policy route.
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Framework references
Relevant ESRS requirements and related disclosures
Available framework references and nearby disclosures relevant to preparing this requirement.
ESRS
E3-1
within ESRS E3: Water
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