Version and legal reference: DR (EU) 2026/1560 (OJ L, 2026/1560, 21.9.2026)
Appendix C
Background information for financial market participants that are users of the information produced using this Standard (reconciliation with other EU regulations)
This appendix is relevant for users of the sustainability report. The table below illustrates the Sustainable Finance Datapoints that are present in different modules of this Standard that satisfy the requests of multiple user types (banks, investors, large undertakings).
The column ‘DR number and Title’ identifies the disclosures present in the different modules (i.e. Basic Module, and Comprehensive Module) that are Sustainable Finance datapoints. The column SFDR Table 1 and/or EBA Pillar 3 and/or Benchmark Regulation illustrates how these disclosures relate to these regulations that are relevant for users of the sustainability report (banks, other investors).
| Topic: Environment / Social /Governance | DR number and Title | SFDR Table 1 and/or EBA Pillar 3 and/or Benchmark Regulation | |||||||||||||||||||
| Basic Module | |||||||||||||||||||||
| General information | B1 – Basis for preparation The undertaking shall disclose:
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| Environment | B3 – Energy and greenhouse gas emissions The undertaking shall disclose its total energy consumption in MWh, with a breakdown as per the table below, if it can obtain the necessary information to provide such a breakdown: | ||||||||||||||||||||
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| Renewable energy | Non-renewable energy | Total | ||||||||||||||||||
| Electricity (as reflected in utility billings) |
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| Fuels |
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| Environment | B3 – Energy and greenhouse gas emissions The undertaking shall disclose its estimated absolute gross greenhouse gas (GHG) emissions generated during the reporting period in metric tonnes of CO2 equivalent (tCO2eq) considering the content of the GHG Protocol Corporate Accounting and Reporting Standard (2004), including:
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| Environment | B4 – Pollution of air, water and soil If the undertaking is already required by law or other national regulations to report to competent authorities its emissions of pollutants, or if it voluntarily reports on them according to an Environmental Management System, it shall disclose the emissions of pollutants to air, water and soil in its own operations. If this information is already publicly available, the undertaking may alternatively refer to the document where it is reported, for example, by providing the relevant URL link or embedding a hyperlink. | ||||||||||||||||||||
| Environment | B5 – Biodiversity If the undertaking has sites or locations in or near a biodiversity-sensitive area (BSA), it shall disclose them, and the name of the BSA. | ||||||||||||||||||||
| Environment | B7 – Resource use, circular economy and waste management The undertaking shall disclose:
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| Social | B9 – Workforce – Health and safety The undertaking shall disclose the following information regarding its employees:
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| Social | B10 – Workforce – Remuneration, collective bargaining and training The undertaking shall disclose:
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| Governance | B11 – Convictions and fines for corruption and bribery In case of convictions and fines in the reporting period, the undertaking shall disclose the number of convictions, and the total amount of fines incurred for the violation of anti-corruption and anti-bribery laws. | ||||||||||||||||||||
| Comprehensive Module | |||||||||||||||||||||
| Environment | Consideration when reporting on GHG emissions under B3 (Basic Module) When reporting its Scope 1 and Scope 2 emissions, if the undertaking discloses entity-specific information on its Scope 3 emissions, it shall present it together with the information specified under B3 – Energy and greenhouse gas emissions. | Benchmark (Regulation (EU) 2016/1011, Articles 5(1), 6 and 8 (1).16) | |||||||||||||||||||
| Environment | C3 – GHG reduction targets and climate transition If the undertaking has established GHG emission reduction targets, it shall disclose its targets in absolute values for Scope 1 and Scope 2 emissions. In line with paragraphs 49 to 52 above and if it has set Scope 3 reduction targets, the undertaking shall also provide targets for significant Scope 3 emissions. In particular, it shall provide:
If the undertaking that operates in high climate impact sectors (High climate impact sectors are those listed in NACE Sections A to H and Section M as defined in the Annex to Delegated Regulation (EU) 2023/137.17) has adopted a transition plan for climate change mitigation, it may provide information about it, including an explanation of how it is contributing to reduce GHG emissions. In case the undertaking operates in high-climate impact sectors and does not have a transition plan for climate change mitigation in place, it shall indicate whether and, if so, when it will adopt such a transition plan. | ||||||||||||||||||||
| Environment | C4 – Climate risks If the undertaking has identified climate-related hazards and climate-related transition events, creating climate-related risks for the undertaking, it shall:
The undertaking may disclose the potential adverse effects of climate risks that may affect its financial performance or business operations in the short, medium or long term, indicating whether it assesses the risks to be high, medium, low. | ||||||||||||||||||||
| Social | C6 – Additional own workforce information – Human rights policies and processes The undertaking shall disclose an answer to the following questions:
Does the undertaking have a complaints-handling mechanism for its own workforce? (YES/NO) | ||||||||||||||||||||
| Social | C7 – Human rights incidents The undertaking shall disclose an answer to the following questions:
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| Governance | C8 – Revenues from certain activities If the undertaking is active in one or more of the following sectors, it shall disclose related revenues derived from activities in:
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| Benchmark (Commission Delegated Regulation (EU) 2020/1818 Article 12(1).36) | ||||||||||||||||||||
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| Governance | C9 – Gender diversity ratio in governance body If the undertaking has a governance body in place, the undertaking shall disclose the related gender diversity ratio. | ||||||||||||||||||||
| (1) This disclosure requirement is consistent with the requirements included in Commission Implementing Regulation (EU) 2022/2453 of 30 November 2022 amending the implementing technical standards laid down in Implementing Regulation (EU) 2021/637 as regards the disclosure of environmental, social and governance risks (OJ L 324, 19.12.2022, p. 1, ELI: http:/ (2) Commission Delegated Regulation (EU) 2022/1288, mandatory indicator #5 in Table 1 of Annex I (‘Share of non-renewable energy consumption and production’). (3) Commission Delegated Regulation (EU) 2022/1288 supplementing Regulation (EU) 2019/2088 (SFDR), mandatory indicators #1 and #2 in Table 1 of Annex I (‘GHG emissions’; Carbon footprint’). (4) Articles 5(1), 6 and 8(1) of Regulation (EU) 2016/1011 of the European Parliament and of the Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and Regulation (EU) No 596/2014 (OJ L 171, 29.6.2016, p. 1, ELI: http:/ (5) This information supports the information needs of financial market participants subject to Commission Delegated Regulation (EU) 2022/1288 supplementing Regulation (EU) 2019/2088 (SFDR) because it is derived from (a) an additional indicator related to principal adverse impacts as set out by indicator #2 in Table 2 of Annex I to that Delegated Regulation with regard to disclosure rules on sustainable investments (‘Emissions of air pollutants’); (b) indicator #8 in Table 1 of Annex I (‘Emissions to water); (c) indicator #1 in Table 2 of Annex I (‘Emissions of inorganic pollutants’); and (d) indicator #3 in Table 2 of Annex I (‘Emissions of ozone-depleting substances’). (6) Commission Delegated Regulation (EU) 2022/1288 supplementing Regulation (EU) 2019/2088 (SFDR), mandatory indicator #7 in Table 1 of Annex I (‘Activities negatively affecting biodiversity-sensitive areas’). (7) This information supports the information needs of financial market participants subject to Commission Delegated Regulation (EU) 2022/1288 supplementing Regulation (EU) 2019/2088 (SFDR) because it is derived from a mandatory indicator related to principal adverse impacts as set out by indicator #9 in Table 1 of Annex I to that Delegated Regulation with regard to disclosure rules on sustainable investments (‘Hazardous waste and radioactive waste ratio’). (8) This information supports the information needs of financial market participants subject to Commission Delegated Regulation (EU) 2022/1288 supplementing Regulation (EU) 2019/2088 (SFDR), as reflecting an additional indicator related to principal adverse impacts as set out by indicator #2 in Table 3 of Annex I to that Delegated Regulation with regard to disclosure rules on sustainable investments (‘Rate of accidents’). (9) This information supports the needs of benchmark administrators to disclose ESG factors subject to Commission Delegated Regulation (EU) 2020/1816 of 17 July 2020 supplementing Regulation (EU) 2016/1011 of the European Parliament and of the Council as regards the explanation in the benchmark statement of how environmental, social and governance factors are reflected in each benchmark provided and published (OJ L 406, 3.12.2020, p. 1, ELI: http:/ (10) Directive (EU) 2023/970 of the European Parliament and of the Council of 10 May 2023. (11) Commission Delegated Regulation (EU) 2022/1288 supplementing Regulation (EU) 2019/2088 (SFDR), mandatory indicator #12 in Table 1 of Annex I (‘Unadjusted gender pay gap’). (12) Commission Delegated Regulation (EU) 2020/1816, indicator ‘Weighted average gender pay gap’ in Sections 1 and 2 of Annex II. (13) Commission Delegated Regulation (EU) 2020/1816, indicator ‘Numbers of convictions and amount of fines for violations of anti-corruption and anti-bribery laws’ in Sections 1 and 2 of Annex II to Delegated Regulation (EU) 2020/1816. (14) This information supports the information needs of financial market participants subject to Commission Delegated Regulation (EU) 2022/1288 supplementing Regulation (EU) 2019/2088 (SFDR), as reflecting an additional indicator related to principal adverse impacts as set out by indicator # 17 Table 3 of Annex I to that Delegated Regulation (‘Numbers of convictions and amount of fines for violations of anti-corruption and anti-bribery laws by investee companies’). (15) Commission Delegated Regulation (EU) 2022/1288 supplementing Regulation (EU) 2019/2088 (SFDR), mandatory indicators #1 and #2 in Table 1 of Annex I (‘GHG emissions’; Carbon footprint’). (16) Regulation (EU) 2016/1011, Articles 5(1), 6 and 8 (1). (17) High climate impact sectors are those listed in NACE Sections A to H and Section M as defined in the Annex to Delegated Regulation (EU) 2023/137. (18) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 (SFDR) because it is derived from an additional indicator related to principal adverse impacts as set out by indicator #4 in Table 2 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosure rules on sustainable investments (‘Investments in companies without carbon emission reduction initiatives’). (19) This information is aligned with Article 6 of Commission Delegated Regulation (EU) 2020/1818 of 17 July 2020. (20) This information is aligned with Article 449a of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and amending Regulation (EU) No 648/2012 (OJ L 176, 27.6.2013, p. 1, ELI: http:/ (21) This information is aligned with Article 2(1) of Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing the framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 (OJ L 243, 9.7.2021, p. 1, ELI: http:/ (22) Commission Delegated Regulation (EU) 2020/1816 Annex II: Environmental factors to be considered by underlying assets of the benchmark. (23) EBA Pillar 3: ITS – Template 5: Banking book – Climate change physical risk: Exposures subject to physical risk; and EBA Pillar 3: ITS – Template 2: Banking book – Indicators of potential climate change transition risk: Loans collateralised by immovable property – Energy efficiency of the collateral. (24) This information supports the needs of benchmark administrators to disclose ESG factors subject to Delegated Regulation (EU) 2020/1816 as set out by indicator ‘Exposure of the benchmark portfolio to companies without due diligence policies on issues addressed by the fundamental International Labour Organisation Conventions 1 to 8’ in Sections 1 and 2 of Annex II to that Delegated Regulation. (25) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from a mandatory indicator related to principal adverse impacts as set out by indicator #11 in Table 1 of Annex I (‘Share of investments in investee companies without policies to monitor compliance with the UNGC principles or OECD Guidelines for Multinational Enterprises or grievance /complaints handling mechanisms to address violations of the UNGC principles or OECD Guidelines for Multinational Enterprises’) and by indicator #5 in Table 3 of Annex I (‘Share of investments in investee companies without any grievance/complaints handling mechanism related to employee matters’) and by indicator #9 in Table 3 of Annex I (‘Share of investments in entities without a human rights policy’) of Commission Delegated Regulation (EU) 2022/1288 with regard to disclosure rules on sustainable investments. (26) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from a mandatory and additional indicator related to principal adverse impacts as set out by indicator #10 in Table 1 of Annex I and by indicator #14 in Table 3 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosure rules on sustainable investments (‘Violations of UNGC principles and OECD Guidelines for Multinational Enterprises’ and ‘Number of identified cases of severe human rights issues and incidents’). (27) This information supports the information needs of benchmark administrators to disclose ESG factors subject to Delegated Regulation (EU) 2020/1816 as set out by indicator ‘Number of benchmark constituents subject to social violations (absolute number and relative divided by all benchmark constituents), as referred to in international treaties and conventions, United Nations principles and, where applicable, national law’ in Sections 1 and 2 of Annex II. (28) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts, as set out by indicator #14 in Table 1 of Annex I to Commission Delegated Regulation (EU) 2022/1288, and consistent with Commission Delegated Regulation (EU) 2025/1775. (29) Commission Delegated Regulation (EU) 2020/1818 Article 12(1): ‘Administrators of EU-Paris aligned Benchmarks shall exclude all of the following companies from those benchmarks: companies involved in any activities related to prohibited weapons;’ and Delegated Regulation (EU) 2020/1816 Annex II, Sections 1, 2 and 5: ‘Weighted average percentage of benchmark constituents in the controversial weapons sector’. (30) This information supports the needs of benchmark administrators to disclose ESG factors subject to Regulation (EU) 2020/1818 as set out by paragraph (b) of Article 12.1. (31) EBA Pillar 3: Template 1: Banking book – Climate change transition risk: Companies in the manufacturing of tobacco products excluded from EU-Paris aligned Benchmarks in accordance with point (b) of Article 12(1) and in accordance with Article 12(2) of Commission Delegated Regulation (EU) 2020/1818. (32) This information supports the needs of benchmark administrators to disclose ESG factors subject to Commission Delegated Regulation (EU) 2020/1818 as set out by Article 12(1) paragraph b) of that Regulation and Section 5 of Annex II to Delegated Regulation (EU) 2020/1816: ‘Weighted average percentage of benchmark constituents in the tobacco sector.’ (33) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts set out by indicator #4 in Table 1 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments (‘Exposure to companies active in the fossil fuel sector’). (34) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts set out by indicator #4 in Table 1 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments (‘Exposure to companies active in the fossil fuel sector’). (35) EBA Pillar 3: Template 1: Banking book – Climate change transition risk: Companies in Mining and quarrying excluded from EU-Paris aligned Benchmarks in accordance with Article 12(1), points (d) to (g), and in accordance with Article 12(2) of Commission Delegated Regulation (EU) 2020/1818. (36) Commission Delegated Regulation (EU) 2020/1818 Article 12(1). (37) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts, as set out by indicator #9 in Table 2 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments (‘Investments in companies producing chemicals’). (38) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 of the European Parliament and of the Council because it is derived from an additional indicator related to principal adverse impacts set out by indicator #9 in Table 2 of Annex I to Commission Delegated Regulation (EU) 2022/1288 with regard to disclosures rules on sustainable investments (‘Investments in companies producing chemicals’). (39) EBA Pillar 3: Template 1: Banking book – Climate change transition risk: Companies in Mining and quarrying excluded from EU-Paris aligned Benchmarks in accordance with of Article 12(1), points (d) to (g), and Article 12(2) of Commission Delegated Regulation (EU) 2020/1818. (40) This information supports the information needs of financial market participants subject to Regulation (EU) 2019/2088 because it is derived from an additional indicator related to principal adverse impacts set out by indicator #13 in Table 1 of Annex I to Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to disclosures rules on sustainable investments (‘Board gender diversity’). (41) This information supports the information needs of benchmark administrators to disclose ESG factors subject to Commission Delegated Regulation (EU) 2020/1816 as set out by indicator ‘Weighted average ratio of female to male board members’ in Sections 1 and 2 of Annex II to that Delegated Regulation. | |||||||||||||||||||||