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London Reporting Academy ESRS E3 · Water · Disclosure Requirement E3-3

Applicable from FY2027

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

Targets related to water

E3-3 · mandatory · narrative disclosure

E3-3 reports measurable, time-bound and outcome-oriented qualitative or quantitative targets related to material water impacts, risks or opportunities, using the ESRS 2 GDR-T structure.

Disclosure focus

A water target need not always be a numerical reduction in withdrawal or consumption. It may address another material water outcome, provided its value or qualitative level, scope, period, methodology and relationship to policies and actions are clear.

Baseline values and base years are reported if defined by the undertaking. Milestones are reported if they have been set; neither should be presented as an unconditional field for every target.

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 to which each target relates.

    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.

  • Relationship to policies and actions

    Sustainability reporting

    Describe the target's relationship to policy objectives and actions.

    Evidence Dated source records, governance papers and approval evidence supporting relationship to policies and actions.

    Watch for The published response for relationship to policies and actions is incomplete or does not match the supporting records.

  • Target value or level

    Sustainability reporting

    State the defined quantitative target value or qualitative target level, whether it is absolute or relative where relevant, and the unit of measurement.

    Evidence Dated source records, governance papers and approval evidence supporting target value or level.

    Watch for The published response for target value or level is incomplete or does not match the supporting records.

  • Target scope

    Sustainability reporting

    Describe scope across own operations, upstream and downstream value chain and geographical boundaries.

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

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

  • Target period and milestones

    Sustainability reporting

    State the target period and any milestones or interim targets that have been set.

    Evidence Dated source records, governance papers and approval evidence supporting target period and milestones.

    Watch for The published response for target period and milestones is incomplete or does not match the supporting records.

  • Baseline

    Sustainability reporting

    If the undertaking defined a baseline, state its value or level and base year.

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

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

  • Methodologies and assumptions

    Sustainability reporting

    Describe methodologies and significant assumptions used to define the target.

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

    Watch for The published response for methodologies and assumptions is incomplete or does not match the supporting records.

  • Stakeholder involvement

    Sustainability reporting

    Describe how stakeholders were involved in setting the target where applicable.

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

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

  • Performance and revisions

    Sustainability reporting

    Report performance against the target and explain revisions to targets, methodologies or assumptions.

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

    Watch for The published response for performance and revisions is incomplete or does not match the supporting records.

Before you start

  • Apply targets to the stated own-operations, value-chain and geographical scope and preserve the link to material water-related IROs.
  • If no measurable target exists, disclose the applicable absence and tracking information required by ESRS 2 rather than constructing an artificial target.
  • Have the supporting records and the final response been reconciled?
+ Show E3-3 sub-elements (LRA working checklist)

How to prepare it

Apply targets to the stated own-operations, value-chain and geographical scope and preserve the link to material water-related IROs.
Collect and reconcile the records for: Material impacts, risks and opportunities; Relationship to policies and actions; Target value or level; Target scope; Target period and milestones; Baseline; Methodologies and assumptions; Stakeholder involvement; Performance and revisions.
If no measurable target exists, disclose the applicable absence and tracking information required by ESRS 2 rather than constructing an artificial target.
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 target register, material-IRO and policy/action links, values or levels, units, scope, periods, baselines where defined, methodology, assumptions, stakeholder involvement and progress evidence.

Use the organisation's own role and document names, but preserve the defined ESRS terms and the scope described above.

Better request

Provide the target register, material-IRO and policy/action links, values or levels, units, scope, periods, baselines where defined, methodology, assumptions, stakeholder involvement and progress evidence.

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 full GDR-T structure and keep reduction targets as one possible target type rather than the universal model.

Context note

Use areas with water stress where relevant, but do not replace the complete target scope with a basin or stressed-area split.

Download Centre

Preparation tools & forms

Download preparation tools for E3-3 with free verified email access for 24 hours. Source-report links remain public.

Free · Email access

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.

  • Relationship to policies and actions is reported accurately and completely.

    Risk The response omits, misclassifies or overstates relationship to policies and actions.

    Evidence to check Dated source records, governance papers and approval evidence supporting relationship to policies and actions.

  • Target value or level is reported accurately and completely.

    Risk The response omits, misclassifies or overstates target value or level.

    Evidence to check Dated source records, governance papers and approval evidence supporting target value or level.

  • Target scope is reported accurately and completely.

    Risk The response omits, misclassifies or overstates target scope.

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

  • Target period and milestones is reported accurately and completely.

    Risk The response omits, misclassifies or overstates target period and milestones.

    Evidence to check Dated source records, governance papers and approval evidence supporting target period and milestones.

  • Baseline is reported accurately and completely.

    Risk The response omits, misclassifies or overstates baseline.

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

  • Methodologies and assumptions is reported accurately and completely.

    Risk The response omits, misclassifies or overstates methodologies and assumptions.

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

  • Stakeholder involvement is reported accurately and completely.

    Risk The response omits, misclassifies or overstates stakeholder involvement.

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

  • Performance and revisions is reported accurately and completely.

    Risk The response omits, misclassifies or overstates performance and revisions.

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

Evidence pack to prepare

Common reporting gaps

  • Using the old standard title.
  • Presenting seven internal fields as the official checklist.
  • Omitting material-IRO and policy/action links.
  • Requiring a quantitative reduction target.
  • Treating baseline and milestones as unconditional.
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Framework references

Relevant ESRS requirements and related disclosures

ESRS

E3-3

within ESRS E3: Water

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Guides that settle this question

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