ESA Joint Committee · sfdr-39 Final

PAI 6 (Table 2): The term ‘water usage’ is not defined in the RTS and is not a common term within the CDP nomenclature (water withdrawal, water discharge, water consumption and water recycled/reused).

Regulation
SFDR
Answered
2025-08-04
Answer provided by
ESAs (EBA, ESMA, EIOPA)
⚠

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Question

PAI 6 (Table 2): The term ‘water usage’ is not defined in the RTS and is not a common term within the CDP nomenclature (water withdrawal, water discharge, water consumption and water recycled/reused).

Answer

PAI indicator 6 in Table 2 of Annex I of the SFDR Delegated Regulation refers to “water usage and recycling”. It has two metrics. For definitions of “water consumption”, “water intensity”, and “water (recycled and reused)”, see the following definitions in Table 2 of Annex II in the Commission Delegated Regulation (EU) 2023/2772: • “Water consumption”: The amount of water drawn into the boundaries of the undertaking (or facility) and not discharged back to the water environment or a third party over the course of the reporting period. • “Water intensity”: A metric providing the relationship between a volumetric aspect of water and a unit of activity (products, sales, etc.) created (in the context of PAI indicator 6 in Table 2, the unit of activity is set out in the SFDR Delegated Regulation, i.e. investee company’s €M revenue); and • “Water (recycled and reused)”: Water and wastewater (treated or untreated) that has been used more than once before being discharged from the undertaking’s or shared facilities’ boundary, so that water demand is reduced. This may be in the same process (recycled) or in a different process within the same facility (own or shared with other undertakings) or in another of the undertaking’s facilities (reused). Furthermore, the following ESRS disclosures may be useful for this indicator: • The first metric (“Average amount of water consumed by the investee companies (in cubic meters) per million EUR of revenue of investee companies”) can be considered relevant for the reporting under “water intensity” in Annex I, ESRS E3 on Water and marine resources, paragraph 29 of Commission Delegated Regulation (EU) 2023/2772. • For the purpose of the second metric ("Weighted average percentage of water recycled and reused by investee companies"), "water recycled and reused" can be considered relevant for the reporting under "water recycled and reused" in Annex I, ESRS E3 on Water and marine resources, paragraph 28 (c) of Commission Delegated Regulation (EU) 2023/2772.

This Q&A is published by ESA Joint Committee (EBA, ESMA, EIOPA) and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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