Level 2 · Decision guide·ESRS · Disclosure guides
Can One Dataset Support Both ESRS and IFRS S1/S2 Reporting?
A master data and evidence model for shared definitions, controlled calculations and framework-specific materiality, boundary, disclosure and compliance adjustments.
Published passport
Current as at 10 August 2026
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
Edition written against
—
Source-grounded implementation guide
Published
10 Aug 2026
Knowledge Hub guide
Last reviewed
10 Aug 2026
Short answer
The answer, before the reasoning
Yes - one governed master dataset and evidence repository can support both ESRS and IFRS S1/S2, provided it is designed as a layered system rather than a single final reporting table. The shared layer should hold stable reference data, source observations, evidence, methodologies, controls and approvals.
Separate framework overlays should then record materiality conclusions, reporting and metric boundaries, required disaggregation, estimates, presentation and compliance status. The aim is “capture once, transform transparently, report separately”, not “one number must appear identically everywhere”.
Without a common data spine, teams repeatedly request the same workforce, climate, supplier and financial information, create conflicting spreadsheets and lose the evidence trail. Without framework overlays, the opposite problem appears: a number calculated for one boundary or decision purpose is copied into another framework without testing definitions, materiality, value-chain coverage or methodology. A mature model prevents both duplication and false consistency.
Technical status
EDITORIAL STATUS
<p>One evidence spine is realistic; one undifferentiated output is not The revised ESRS were adopted by the European Commission on 3 July 2026. At the review date they had not yet entered into force; the legally applicable ESRS remained Delegated Regulation (EU) 2023/2772 as amended by the 2025 Quick Fix. Before publication, confirm Official Journal publication, entry into force, any early-application route and the reporting period addressed. This article proposes an implementation model, not a prescribed software schema. Each organisation must adapt it to its reporting entity, systems, controls, assurance scope and applicable standard editions.</p>
Quick orientation
Figure 1. A common evidence spine with controlled framework overlays supports efficient ESRS and IFRS S1/S2 reporting. London Reporting Academy learning visual.
Quick orientation
- Applies to
- Organisations building or redesigning a sustainability data platform for ESRS, IFRS S1/S2 or multiple reporting bases.
- Primary decision
- Which information belongs in the common master/evidence layer and which adjustments and approvals must remain framework-specific.
- Key source
- Revised ESRS 1 and ESRS 2; IFRS S1 general requirements and IFRS S2; applicable topical standards and methodologies.
- Common confusion
- Believing that a “single source of truth” means there can be only one boundary, one materiality result or one published value for every metric.
1. The target architecture: one governed evidence spine
The most useful definition of “one dataset” is not one spreadsheet. It is a controlled information model in which every reported statement and metric can be traced to source data, methodology, boundary, transformation, judgement, evidence and approval. The model can be implemented in spreadsheets, a data warehouse, a sustainability platform or a hybrid architecture. The control principles are more important than the product.
In practice
| Layer | Purpose | Typical records |
|---|---|---|
| 1. Master reference data | Provide stable identifiers and relationships used by every framework. | Legal entities, sites, assets, products, activities, accounts, suppliers, customers, investees, geographies, reporting periods and units. |
| 2. Observations and evidence | Store source facts and records before framework interpretation. | Meter readings, invoices, payroll extracts, contracts, policies, minutes, legal decisions, stakeholder evidence, complaints and audit reports. |
| 3. Methodology and calculations | Document how raw observations become controlled measures. | Definitions, factors, models, allocation rules, scenarios, estimates, uncertainty, restatements and methodology changes. |
| 4. Framework overlays | Apply reporting-specific decisions without overwriting the source layer. | Materiality result, reporting boundary, metric boundary, disclosure mapping, disaggregation, relief, omission and compliance status. |
| 5. Reporting outputs | Freeze approved publications and downstream formats. | ESRS sustainability statement, IFRS disclosures, content/index tables, digital tags, assurance extracts and board packs. |
Rule
Single source of truth - the stronger definition
<p>The source observation and its provenance should be singular and controlled. Different reporting outputs may legitimately use different aggregations or adjustments. Those differences are acceptable when they are rule-based, approved, reconcilable and explained; they are a control failure when they arise from parallel uncontrolled spreadsheets.</p>
2. Minimum master data model
A reusable system starts with dimensions that are independent of any one disclosure number. Stable IDs allow the same facility, employee population, supplier, asset or financial account to appear in several calculations without relying on names that change over time.
In practice
| Object | Minimum fields | Why it matters |
|---|---|---|
| Legal entity | Entity ID, name, jurisdiction, parent, consolidation method, ownership, effective dates and reporting roles. | Supports reporting entity, group boundary, local overlays and eliminations. |
| Site / asset | ID, entity, location, activity, operational status, ownership/control, basin/ecosystem and effective dates. | Supports physical risk, emissions, water, biodiversity and operational metrics. |
| Counterparty / relationship | ID, type, relationship, tier, geography, contract, SME/sector classification, start/end date and risk flags. | Supports value-chain impacts, financed emissions, supplier data and concentration risks. |
| Sustainability matter / IRO | Stable matter ID, topic, impact/risk/opportunity, cause/linkage, affected group/resource, geography, time horizon and evidence links. | Connects materiality, strategy, policies, actions, metrics, targets and financial effects. |
| Metric definition | Metric ID, label, unit, numerator, denominator, boundary, method, standard reference, owner and version. | Prevents the same label being used for different measures. |
| Evidence object | Evidence ID, type, source system, date, owner, access class, retention, reviewer and linked claims. | Creates assurance traceability and privacy/security control. |
3. Shared definitions: use a dictionary with controlled variants
Some definitions can be genuinely shared: reporting period, currency, legal entity, source system, owner, evidence status and basic location identifiers. Others require a common concept with framework-specific variants. For example, “value chain”, “material”, “financial effects”, “Scope 3 coverage” or “workforce” may look common but need precise qualifiers.
The dictionary should include “do not combine” warnings. For example, a workforce denominator used for an ESRS employee metric may not equal the population used for an IFRS industry metric; a market-based Scope 2 figure may not replace a required location-based figure; and a financial-effects estimate may have different time-horizon or probability treatment from a risk register value.
In practice
| Dictionary field | Example | Control rule |
|---|---|---|
| Canonical concept | Gross Scope 1 GHG emissions | One concept ID used across systems and languages. |
| Framework definition | ESRS E1 boundary / IFRS S2 boundary | Store exact version, paragraph and decision rule. |
| Unit and conversion | tCO2e; GWP set; currency conversion | Version factors and retain calculation date. |
| Reporting boundary | Consolidated group; operational control; equity share; portfolio exposure | Never infer from the metric name; store boundary explicitly. |
| Time basis | Financial year; measurement date; average population | Prevent mixing point-in-time and period measures. |
| Disaggregation | Country, sector, asset class, gender, supplier type | Store required and optional dimensions separately. |
| Estimate flag | Primary data / secondary data / modelled / proxy | Disclose limitations and improvement plan where material. |
In practice
4. The common evidence record
| Field | Minimum content | Assurance purpose |
|---|---|---|
| Record identity | Metric/claim ID, entity/site, reporting period and version. | Shows exactly what the evidence supports. |
| Source and extraction | System, report/query, extraction date, parameters and responsible owner. | Enables reperformance and completeness testing. |
| Transformation | Formula, code, factors, allocation, exclusions and manual adjustments. | Enables recalculation and identifies model risk. |
| Boundary and applicability | Included/excluded population, framework use and materiality link. | Prevents silent scope changes. |
| Estimate and uncertainty | Estimate type, assumptions, sensitivity, limitation and improvement plan. | Supports transparent judgement and uncertainty disclosure. |
| Review and approval | Preparer, reviewer, date, findings, resolution and approver. | Demonstrates segregation and release control. |
| Access and retention | Public/restricted/legal-privilege class, retention period and deletion rule. | Protects confidential and personal information while preserving audit trail. |
In practice
5. What remains separate
| Decision area | Why it cannot be collapsed | Controlled output |
|---|---|---|
| Materiality | ESRS impact, ESRS financial and IFRS investor materiality have different purposes and criteria. | Separate result, rationale, evidence, threshold, approver and date. |
| Reporting and value-chain boundary | Both frameworks start from the financial reporting entity, but value-chain and metric rules differ. | Boundary map and framework/metric inclusion flags. |
| Disclosure requirements | Shared data does not satisfy different narrative, disaggregation, methodology or industry requirements. | Requirement-to-field mapping and residual gap register. |
| Estimates and reliefs | Each framework has its own proportionality, relief and disclosure rules. | Relief decision log, estimate methodology and limitation wording. |
| Presentation | ESRS sustainability statement and IFRS general purpose financial-report disclosures have different location and structure rules. | Separate document assembly and digital-tagging maps. |
| Compliance statements | A mapping or shared dataset does not demonstrate full compliance. | Independent requirement checklist and authorised claim. |
| Assurance | Subject matter, criteria, scope and legal obligation may differ. | Separate assurance mapping and evidence request list. |
6. Controlled adjustment register
Every difference between a shared base measure and a framework output should be recorded as an adjustment rather than hidden in the final spreadsheet. The register can be simple, but it must explain why the adjustment exists and how it was approved.
In practice
| Field | Example entry |
|---|---|
| Adjustment ID | ADJ-GHG-2026-014 |
| Base metric | Purchased-goods emissions - global supplier model v3 |
| Target output | IFRS S2 Scope 3 / ESRS E1 Scope 3 |
| Adjustment type | Boundary / definition / disaggregation / estimate / restatement / timing |
| Reason | ESRS output includes an entity-specific category disaggregation; IFRS output applies material investor information aggregation. |
| Amount / effect | Quantitative bridge and affected records. |
| Evidence | Methodology, calculation workbook, mapping and reviewer note. |
| Owner / approver | Data owner, framework owner and finance/internal-control approval. |
| Effective period | FY2026; supersedes previous rule from FY2025. |
| Disclosure implication | Basis-of-preparation or methodology-change wording required. |
Rule
Reconciliation rule
<p>The system should be able to produce a bridge from the common source population to every published value. The bridge does not need to be public in full, but it should be available to reviewers and assurance providers and should explain material differences across reports.</p>
Hypothetical scenario
Illustrative example - not company data
<p>A group collects supplier spend, quantities, product categories, supplier-specific emissions and secondary emission factors. The source layer stores every supplier record once. A calculation layer produces a gross Scope 3 estimate with data-quality scores. The ESRS overlay links categories to material climate IROs, adds required methodology and limitation information and preserves the ESRS reporting undertaking. The IFRS overlay tests investor materiality, applies the required disclosure aggregation and industry context, and supports the IFRS compliance checklist. Where the same number is used, it points to the same approved calculation. Where outputs differ, the adjustment register explains the reason.</p>
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
In practice
7. Worked example: one Scope 3 supplier dataset
| Control point | Shared record | ESRS overlay — IFRS overlay |
|---|---|---|
| Supplier identity | Supplier ID, group, location, sector and relationship. | Value-chain impact/risk link and reporting boundary. — Business-model/value-chain concentration and prospects link. |
| Activity and factor | Quantity/spend, factor source, year, geography and data quality. | E1 methodology, category significance and estimate limitations. — IFRS S2 methodology, material information and industry context. |
| Calculation | Gross emissions, allocation and uncertainty. | ESRS-required presentation/disaggregation and comparatives. — IFRS S2 required Scope 3 disclosure and material disaggregation. |
| Review | Owner, reviewer, evidence and sign-off. | ESRS technical/legal release gate. — IFRS compliance and investor-materiality release gate. |
8. Governance and access model
Evidence access should be role-based. Public report wording may be supported by restricted worker, whistleblowing, legal, customer or commercially sensitive records. The platform should expose the existence, owner and review status of restricted evidence without granting broad access to the underlying content.
In practice
| Role | Primary responsibility | Should not approve alone |
|---|---|---|
| Data product owner | Reference data, source integration, definitions, lineage and access. | Framework materiality or compliance claims. |
| Framework owner - ESRS | ESRS materiality, requirements, boundary overlays, statement and legal basis. | Underlying source-system completeness without data-owner review. |
| Framework owner - IFRS | IFRS materiality, disclosure requirements, industry guidance and compliance checklist. | ESRS impact conclusions. |
| Finance / consolidation | Reporting entity, financial effects, account reconciliations, currency and controls. | Impact-materiality conclusions. |
| IT / security | Architecture, role-based access, backups, change management and audit logs. | Technical reporting interpretation. |
| Internal control / assurance liaison | Control design, evidence requests, findings and remediation. | Management’s final reporting judgements. |
| Board / authorised committee | Approve material judgements, claims and release. | Prepare underlying data or bypass unresolved critical findings. |
9. Minimum system requirements
Stable IDs and effective dates for entities, sites, relationships, metrics, IROs and evidence.
Version-controlled data dictionary with framework definitions and prohibited combinations.
Source lineage from published value to extraction, transformation and source record.
Framework overlays for materiality, boundary, disclosure mapping, adjustments and compliance.
Segregated workflow for prepare, review, approve, freeze, publish and restate.
Role-based access and audit logs for confidential, personal and legally privileged evidence.
Reconciliation capability across reports, financial statements and previous periods.
Estimate and uncertainty fields with methodology, assumptions and improvement plans.
Change management for standards, factors, organisational changes and mapping versions.
Export controls for Word/PDF drafting, digital tagging, assurance samples and board packs.
In practice
10. A 12-month implementation roadmap
| Phase | Priority work | Controlled output |
|---|---|---|
| Months 1-2 - scope and inventory | Confirm reporting bases, entities, materiality workflow, systems, data owners and priority metrics. | Architecture decision, source inventory and gap register. |
| Months 3-4 - dictionary and master data | Create IDs, definitions, boundaries, units, periods and ownership. | Approved data dictionary and master entity/site/relationship tables. |
| Months 5-7 - priority data products | Build climate, workforce and financial-effects pipelines with evidence and controls. | Reperformable calculations and evidence records. |
| Months 8-9 - framework overlays | Map ESRS and IFRS requirements, materiality, adjustments, disclosures and claims. | Framework matrices and adjustment register. |
| Months 10-11 - dry run and assurance | Produce draft outputs, reconcile differences, test controls and answer mock evidence requests. | Dry-run reports, findings and remediation log. |
| Month 12 - release and improvement | Freeze approved outputs, archive evidence, record lessons and plan next-cycle automation. | Published version, sign-offs, changelog and improvement roadmap. |
Hypothetical scenario
Illustrative wording - adapt to actual systems
<p>“The group operates a common sustainability data and evidence model for ESRS and IFRS S1/S2 reporting. Source observations are retained once with common entity, period, unit, methodology and evidence identifiers. Framework-specific materiality conclusions, reporting boundaries, disclosure mappings and adjustments are maintained as separate controlled overlays. Where a published value differs between reporting bases, the difference is documented in an adjustment and reconciliation register. The use of a common source record does not imply that the related disclosure requirements or compliance assessments are equivalent.”</p>
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
In practice
Common mistakes and corrections
| Mistake | Consequence | Correction |
|---|---|---|
| Building the platform around disclosure numbers only | Every standards update requires structural rework and source data cannot be reused flexibly. | Model stable business objects, observations and evidence first; map disclosures in overlays. |
| Using metric names as definitions | The same label contains different boundaries or formulas. | Assign metric IDs and versioned definitions. |
| Overwriting source data with reporting adjustments | The original evidence and audit trail are lost. | Preserve immutable source records and separate transformations. |
| One materiality flag for all frameworks | Framework decisions cannot be explained or assured. | Store separate materiality fields and approvals. |
| No adjustment register | Different public figures appear unexplained. | Create quantitative bridges with purpose, evidence and sign-off. |
| Evidence links in personal folders | Records become inaccessible, insecure or version-ambiguous. | Use a controlled repository with permissions, retention and immutable references. |
| Automation before definitions are stable | The system scales inconsistency. | Approve dictionary, boundaries and controls before integration. |
| Treating software validation as technical compliance | A completed workflow may still use wrong requirements or judgements. | Maintain human framework review and compliance sign-off. |
Readiness
Implementation checklist
- Reporting bases, standards editions, entities, periods and intended claims are documented.
- Master IDs exist for entities, sites, assets, counterparties, IROs, metrics and evidence.
- The data dictionary separates canonical concepts from framework-specific definitions.
- Every reported metric stores unit, period, boundary, methodology, estimates and owner.
- Source extractions and transformations are reperformable and version controlled.
- ESRS impact, ESRS financial and IFRS materiality decisions are separately approved.
- Framework overlays preserve requirements, disaggregation, reliefs and compliance status.
- All framework differences are captured in an adjustment and reconciliation register.
- Restricted evidence has role-based access, retention and audit logs.
- Finance reconciles reporting entities, financial effects and relevant amounts to financial statements.
- Dry-run reports have been tested through mock assurance requests.
- The published dataset is frozen, archived and connected to a changelog and next-cycle improvement plan.
In practice
Source register
| ID | Official source | Role in article — Status |
|---|---|---|
| S1 | Commission Delegated Regulation C(2026) 5010 final and annex - revised ESRS 1 and ESRS 2 | Reporting undertaking, materiality, information, estimates, GDRs and statement architecture — Adopted 3 July 2026; entry into force pending at review date |
| S2 | IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information | Reporting entity, materiality, connected information, sources, judgements, uncertainty and compliance — Issued 2023; current applicable edition to be checked |
| S3 | IFRS S2 Climate-related Disclosures | Climate metrics, methodologies, value chain, financial effects and targets — Issued 2023; current amendments to be checked |
| S4 | ESRS-ISSB Standards Interoperability Guidance, May 2024 | Official implementation guidance on commonalities and differences — Based on 2023 ESRS; not equivalence |
| S5 | Applicable ESRS topical standards and SASB/industry guidance | Metric-specific definitions and disaggregation — Version and sector dependent |
| S6 | Organisation’s financial statements, consolidation policy and internal-control framework | Primary system and evidence anchors — Entity-specific |
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