ESRS Disclosure Matrix and Content Index: requirements, ARs, datapoints, owners, evidence, controls, assurance status and report locations

2026 REVISED ESRS · HOW-TO / TOOL GUIDE

A practical control model linking material IROs, DRs, ARs, datapoints, owners, evidence, assurance and final pages

ANSWER · EXPLAIN · APPLY · EVIDENCE · CONNECT · PUBLISH

© 2026 London Reporting Academy. Educational technical guidance.

An effective ESRS mapping system has three distinct layers. First, the materiality layer links each material impact, risk or opportunity to a topic or sub-topic. Second, the requirements layer links that topic to ESRS 2, GDR, topical DRs, mandatory ARs and any entity-specific information. Third, the reporting-control layer links each information request to an owner, source, methodology, evidence, control, assurance status and final report location.

The public content index required by IRO-2 is a much narrower output: it helps users locate the Disclosure Requirements with which the undertaking has complied. Confusing the public index with the internal matrix usually leaves important datapoint, evidence and control questions unmanaged.

Figure 1. End-to-end traceability from the IRO register to the public content index.

REQUIREMENT In the revised drafting conventions, a Disclosure Requirement consists of one or more distinct datapoints. Mandatory DR language is signalled by formulations such as “shall disclose”, “shall report”, “shall describe” or “shall explain”, subject to information materiality. Application Requirements are mandatory and have the same authority as the main-body requirements; they support application and may also provide presentation options.

Source anchor: Revised ESRS 1, paragraphs 17-18.

A datapoint is best treated operationally as the smallest information request that can be assigned, evidenced, reviewed and located. One paragraph can therefore produce several matrix rows: a value, unit, methodology, source, estimate limitation, scope statement and comparative explanation may each need a distinct owner or evidence item.

REQUIREMENT The materiality filter is applied to information, not only to topics. Except for permitted supplementary information, the undertaking shall not report prescribed information that is not material and shall not include immaterial entity-specific information. A matrix should therefore record the information-materiality decision and rationale rather than treating every extracted datapoint as automatically reportable.

Source anchor: Revised ESRS 1, paragraphs 23-24.

Lock the source set. Record the exact ESRS version, adoption or legal status, source document and extraction date.

Extract the DRs and mandatory ARs. Keep the original paragraph reference and a controlled paraphrase of the information request.

Connect the approved IRO register. Link each material topic or sub-topic to ESRS 2, GDR, topical DRs and entity-specific requirements.

Apply information materiality. Record “report”, “not material”, “not applicable”, “phase-in”, “relief” or another controlled status with rationale and approval.

Decompose each reportable requirement into assignable datapoints. Preserve conditions and exceptions in the same row or a linked field.

Assign owners and evidence. Identify source systems, documents, calculations, estimates, proxies, methodologies and retention locations.

Design controls and assurance traceability. Link prepare/review controls, reconciliations, issue logs and evidence-request status.

Map drafting and final locations. Record cross-references, incorporation by reference, supplementary information and precise final pages or paragraphs.

Freeze, reconcile and generate the public index. Re-run completeness, location, version and cross-reference checks after final pagination.

REQUIREMENT IRO-2 requires the undertaking to list the Disclosure Requirements with which it has complied and indicate where the related disclosures are located. The list can be tabular and may identify page or paragraph locations. Information incorporated by reference is separately identified. Supplementary information included in the sustainability statement should be distinguished so that users can tell what is reported to meet ESRS and what is additional.

Source anchor: Revised ESRS 2, IRO-2 paragraph 37(d) and AR 29.

The content index should be generated from the final controlled matrix. Hand-built page references are vulnerable to late layout changes, broken links and unreviewed cross-references.

Figure 2. Internal ESRS disclosure matrix, public ESRS content index and GRI Content Index compared.

REQUIREMENT Both ESRS and GRI use an index to help readers navigate reported information, but the reporting mechanisms differ. Under GRI 1: Foundation 2021, the GRI Content Index supports reporting in accordance with or with reference to the GRI Standards and includes the applicable statement of use, GRI 1 used, material topics, reported disclosures and locations, applicable Sector Standard information, and reasons for omission where relevant.

Source anchor: GRI 1: Foundation 2021, Requirement 7 and Appendices 1-2.

The Revised ESRS IRO-2 content index is a list of ESRS DRs complied with and their locations, with related treatment of incorporated-by-reference and supplementary information. An internal ESRS disclosure matrix is broader still and is not a public compliance statement. One dataset can support all three tools, but fields, claims and review criteria remain separate.

ESRS 2 General Disclosures

ESRS Policies, Actions, Metrics and Targets

How to Identify Impacts, Risks and Opportunities Under ESRS