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Early ESRS: 3 bottlenecks before comparability

ESRS is not stalling on ambition. It is stalling on execution: evidence-based materiality, datapoint scoping, and value chain detail are the hard parts, not the labels themselves^[1]^[2]^[3].

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Double materiality has to be transparent and evidence-based, but EFRAG says the practical challenge is getting usable data and expert input early enough, plus balancing judgment with supportable evidence^[4]^[5]^[6].

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Scoping datapoints is the next bottleneck: companies must sort material vs non-material datapoints and apply phase-in relief where allowed. EFRAG says the datapoint list is a practical aid, not a full answer to datapoint-level materiality^[7]^[8]^[9].

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Value chain maps also need refinement. EFRAG says broad upstream, downstream, and own-operations labels are not enough; undertakings need a materiality-driven map showing where impacts, risks, and opportunities actually sit^[10]^[11]^[12].

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Bottom line: early ESRS may first deliver high-level comparability, while datapoint-level comparability stays uneven because it still depends on materiality judgments, phase-ins, and disclosure practice^[13]^[14]^[15].

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