Not Applicable vs Unavailable vs Omitted: How to Classify Voluntary Standard Datapoints

Learn how to classify required, conditional, voluntary, unavailable and protected-information datapoints without turning blank cells into unsupported reporting conclusions.

A single disclosure can contain several categories. B3 is a clear example: for an undertaking with more than 10 employees, total energy consumption is essential; the renewable/non-renewable and electricity/fuels breakdown is conditional on obtaining the necessary information; and the whole datapoint is voluntary for an undertaking with 10 employees or fewer. Classifying “B3” as a single yes/no item would therefore lose the logic needed to prepare the report and test the claim.

The same issue arises in the Comprehensive Module. Some paragraphs use shall after an “if” condition; others use may; some subpoints are explicitly voluntary for undertakings with 10 employees or fewer; and sector-specific information is considered only when relevant. The correct unit of classification is the smallest paragraph or subpoint that carries its own requirement, condition or option.

Is the item in the reporting scope? Confirm Option A, Option B, any selected additional Comprehensive disclosure under paragraph 25, and any separate user-specific information outside the Standard claim.

Is the item explicitly voluntary? Check “may” wording, sector-specific consideration, the square-bracket rule for undertakings with 10 employees or fewer, and module selection.

Does an “if applicable” or other stated condition exist? Test the exact factual or legal circumstance and document the result.

Does paragraph 22 apply? Test the stated protected-information grounds, identify each omitted datapoint in B1 and establish annual reassessment.

Can the item be reported faithfully and verifiably? Use measured information or a supportable estimate where appropriate. If not, record an unavailable-data gap and assess the compliance claim.

What must appear in the output? Report the value/narrative, state not selected or not applicable where useful, identify paragraph 22 omissions as required, and avoid silently blank fields.

Figure 1. Classify the smallest paragraph or subpoint that has its own requirement, option or condition.

B1 offers Option A (Basic Module only) and Option B (Basic and Comprehensive Modules). It states that a module must be complied with in its entirety, subject to the if-applicable principle. This means the undertaking cannot select Option B and then treat difficult essential Comprehensive datapoints as “not selected” merely because it prefers not to report them.

Paragraph 25 creates a different route: after completing B1-B11, an undertaking may add disclosures selected from the Comprehensive Module. That does not turn the report into Option B. A carefully labelled Option A report may therefore include selected C disclosures while reserving the Option B compliance statement for a report that completes the Comprehensive Module according to its categories and conditions.

The 2026 Standard requires B1 to identify the selected option, make the explicit compliance statement and identify disclosures omitted under paragraph 22. It does not prescribe the exact Disclosure Index shown below. A controlled index is recommended implementation practice because it lets the team demonstrate completeness, retain paragraph-level judgements and reconcile the report to the B1 claim.

Illustrative Disclosure Index entries

Figure 2. The Disclosure Index should show the classification, wording, claim consequence and evidence for every unreported datapoint.

The June 2026 EFRAG Digital Template explanatory note states that an empty value cell or a cell containing only a dash is not considered reported and will not be included in the generated XBRL report. That is a technical conversion rule, not a substantive conclusion that the datapoint is not applicable, voluntary or validly omitted. The same note explains validation statuses such as OK, MISSING VALUE, VALUE INCONSISTENCY, ERROR and INVALID URL. These messages can help find incomplete technical entries, but they do not replace the paragraph-level judgement, evidence review or B1 compliance assessment.

Organisation. Meadow Foods Ltd is a hypothetical 42-employee food manufacturer preparing Option A with one selected Comprehensive disclosure on climate targets.

Datapoints. It reports total energy and the full breakdown. It has a production process that significantly consumes water, so B6 paragraph 37 applies. Water discharge is not measured and no supportable estimate has yet been approved. One site lies near a protected wetland. Its target-year production assumptions are considered commercially sensitive, but management has not established that paragraph 22 applies.

Classification. B6 water consumption is unavailable/open gap, not not applicable, because the production-process condition is met. B5 is applicable and reportable because the site is near a BSA. The target itself is a selected additional disclosure; the commercially sensitive assumption cannot be silently removed. The team must either support a paragraph 22 omission for the precise protected datapoint, report proportionate information that does not reveal the secret while still meeting the disclosure, or adjust the added disclosure and output description before release.

Outcome. The Disclosure Index sends the water gap to remediation, records B5 as reported, and keeps the target assumption under legal/commercial review. The B1 Option A claim is withheld until the essential water-consumption datapoint is resolved or a technically supportable route is established.

The most important classification rule is simple: no data does not make a datapoint not applicable. Applicability comes from the circumstances written into the Standard. Voluntary non-selection comes from the module and datapoint architecture. Paragraph 22 omission comes from protected-information grounds. Unavailability is what remains when an essential or applicable item cannot be supported. A paragraph-level Disclosure Index makes those differences visible and allows management to align the B1 claim, the published report, the evidence register and any digital output.