ESRS E2 - Pollution

ESRS E2 - Pollution is one of the European Sustainability Reporting Standards (ESRS) developed by EFRAG under the Corporate Sustainability Reporting Directive (CSRD). It sets out how companies should disclose the impacts, risks and opportunities related to pollution arising from their activities and value chain, when pollution is identified as a material topic.

Pollution under ESRS E2 covers emissions of harmful substances to air, water and soil, substances of concern and of very high concern, and microplastics. The standard asks companies to describe their policies, actions and targets and to report quantitative metrics on the pollutants they release.

When does ESRS E2 apply?

ESRS E2 is not mandatory for every company. Like all topical ESRS, it applies only where the topic is material according to the company's double materiality analysis, which considers both impact materiality (effects on people and the environment) and financial materiality (effects on the company). If pollution is not material, the company explains that conclusion instead of reporting the full standard.

ESRS E2 and the carbon footprint

Greenhouse gases are reported primarily under ESRS E1 (Climate change), but ESRS E2 is closely connected to a company's wider environmental footprint. Measuring pollutants requires the same robust data infrastructure used to quantify the carbon footprint. Companies typically quantify greenhouse gas emissions across the three scopes defined by the GHG Protocol:

• Scope 1: direct emissions from owned or controlled sources, such as fuel combustion.
• Scope 2: indirect emissions from purchased energy.
• Scope 3: other indirect emissions across the value chain.

Key requirements of ESRS E2

1. Identification of pollution sources

Companies identify the pollution sources linked to their own operations and value chain, including air emissions, water and soil discharges, and substances of concern.

2. Measurement and quantification

Pollutants must be quantified using recognised methodologies, for example the GHG Protocol for greenhouse gases or European Environment Agency guidance for other pollutants.

3. Management and mitigation

Beyond disclosure, companies set out policies, actions and targets to prevent and reduce pollution, which may involve cleaner technologies and process improvements.

4. Transparency and communication

Information must be clear, comparable and auditable, and integrated into the company's sustainability statement for stakeholders.

The 2026 ESRS revision

The ESRS are being simplified following the EU Omnibus process. In late 2025 EFRAG submitted a revised set of standards that cuts mandatory datapoints by around 60% and removes voluntary datapoints; the European Commission opened a public consultation on this "ESRS 2.0" in spring 2026. The revised standards are expected to apply from financial years beginning on or after 1 January 2027, with voluntary early application possible. Until the revised set is formally adopted, the 2023 ESRS remain the legal reference. ESRS E2 is retained in the revised set, with adjustments to its metrics on substances of concern.

Why ESRS E2 matters

Beyond compliance, addressing pollution proactively helps companies reduce regulatory and reputational risk, identify inefficiencies, meet investor ESG expectations and foster innovation. ESRS E2 aligns with the EU European Green Deal and with the Sustainable Development Goals, particularly SDG 12 and SDG 13.

At Manglai we help companies measure their carbon footprint and prepare their sustainability reporting in line with the CSRD and the ESRS. Discover how Manglai can help you.