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[[cite:1]][[cite:2]][[cite:3]].

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[[cite:4]][[cite:5]][[cite:6]].

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[[cite:7]][[cite:8]][[cite:9]].

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[[cite:10]][[cite:11]][[cite:12]].