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London Reporting Academy ESRS E3 · Water · Disclosure Requirement E3-1

Applicable from FY2027

This revised ESRS edition applies from reporting year 2027. For reporting years 2024–2026, use the ESRS 2023 edition.

Policies related to water

E3-1 · mandatory · coverage + narrative

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.

Start preparing ↓ Official European Commission source ↗

Disclosure focus

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.

Prepare

What to collect before drafting

Tick each field as the evidence lands. Owners are the teams that usually hold the source files.

  • Material impacts, risks and opportunities

    Sustainability reporting

    Identify the material impacts, risks or opportunities that each policy addresses.

    Evidence Dated source records, governance papers and approval evidence supporting material impacts, risks and opportunities.

    Watch for The published response for material impacts, risks and opportunities is incomplete or does not match the supporting records.

  • Policy contents and objectives

    Sustainability reporting

    Describe the policy's key contents and general objectives.

    Evidence Dated source records, governance papers and approval evidence supporting policy contents and objectives.

    Watch for The published response for policy contents and objectives is incomplete or does not match the supporting records.

  • Policy scope and exclusions

    Sustainability reporting

    Describe scope or exclusions across own operations, upstream and downstream value chain, geographies and affected stakeholder groups where defined.

    Evidence Dated source records, governance papers and approval evidence supporting policy scope and exclusions.

    Watch for The published response for policy scope and exclusions is incomplete or does not match the supporting records.

  • Accountability

    Sustainability reporting

    Identify the most senior level in the undertaking accountable for implementation.

    Evidence Dated source records, governance papers and approval evidence supporting accountability.

    Watch for The published response for accountability is incomplete or does not match the supporting records.

  • Third-party commitments

    Sustainability reporting

    Identify third-party standards or initiatives only where the policy commits the undertaking to respect them through implementation.

    Evidence Dated source records, governance papers and approval evidence supporting third-party commitments.

    Watch for The published response for third-party commitments is incomplete or does not match the supporting records.

  • Stakeholder interests and availability

    Sustainability reporting

    Explain how key stakeholder interests were considered and how the policy is made available to affected stakeholders where relevant.

    Evidence Dated source records, governance papers and approval evidence supporting stakeholder interests and availability.

    Watch for The published response for stakeholder interests and availability is incomplete or does not match the supporting records.

  • Policy changes

    Sustainability reporting

    Describe material policy changes during the reporting period, where applicable.

    Evidence Dated source records, governance papers and approval evidence supporting policy changes.

    Watch for The published response for policy changes is incomplete or does not match the supporting records.

  • Uncovered sites in areas with water stress

    Environment / Sustainability reporting

    State whether any own-operation sites in areas with water stress are not covered by water-related policies.

    Evidence Dated source records, governance papers and approval evidence supporting uncovered sites in areas with water stress.

    Watch for The published response for uncovered sites in areas with water stress is incomplete or does not match the supporting records.

Before you start

  • Use the GDR-P scope structure and revised ESRS E3 Water; do not include marine resources as though they remained part of E3.
  • The uncovered-site statement applies when sites in areas with water stress exist; internal screening evidence supports but does not replace the disclosure.
  • Have the supporting records and the final response been reconciled?
＋ Show E3-1 sub-elements (LRA working checklist)

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

Download preparation tools for E3-1 with free verified email access for 24 hours. Source-report links remain public.

Free · Email access
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 ↧

Check

For each claim, check the evidence

  • Material impacts, risks and opportunities is reported accurately and completely.

    Risk The response omits, misclassifies or overstates material impacts, risks and opportunities.

    Evidence to check Dated source records, governance papers and approval evidence supporting material impacts, risks and opportunities.

  • Policy contents and objectives is reported accurately and completely.

    Risk The response omits, misclassifies or overstates policy contents and objectives.

    Evidence to check Dated source records, governance papers and approval evidence supporting policy contents and objectives.

  • Policy scope and exclusions is reported accurately and completely.

    Risk The response omits, misclassifies or overstates policy scope and exclusions.

    Evidence to check Dated source records, governance papers and approval evidence supporting policy scope and exclusions.

  • Accountability is reported accurately and completely.

    Risk The response omits, misclassifies or overstates accountability.

    Evidence to check Dated source records, governance papers and approval evidence supporting accountability.

  • Third-party commitments is reported accurately and completely.

    Risk The response omits, misclassifies or overstates third-party commitments.

    Evidence to check Dated source records, governance papers and approval evidence supporting third-party commitments.

  • Stakeholder interests and availability is reported accurately and completely.

    Risk The response omits, misclassifies or overstates stakeholder interests and availability.

    Evidence to check Dated source records, governance papers and approval evidence supporting stakeholder interests and availability.

  • Policy changes is reported accurately and completely.

    Risk The response omits, misclassifies or overstates policy changes.

    Evidence to check Dated source records, governance papers and approval evidence supporting policy changes.

  • Uncovered sites in areas with water stress is reported accurately and completely.

    Risk The response omits, misclassifies or overstates uncovered sites in areas with water stress.

    Evidence to check 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

ESRS

E3-1

within ESRS E3: Water

Open official source →

Guides that settle this question

ESRS E3 Water: Withdrawal, Consumption, Discharge and Water-Stress Reporting →

Related & explore

Actions & Resources → CardTargets → CardWater Metrics → CardBrowse all disclosures →

More in ESRS E3 →Browse full catalogue →Search all disclosures →

How this library is built 1,211 published reports indexed 315,012 pages with page-level citations 272 published cards in the active catalogue
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