Tagging, Extensions and a Late Correction After Board Approval

The proposed approach does not meet the digital tagging requirements.

• Block-tagging is for narrative. Each disclosure requirement's narrative - policy, targets, actions, due diligence, metrics context - should be tagged as a block so a machine reader can locate that disclosure. Tagging 58 pages as one block prevents a user from identifying individual disclosures.
• Detail-tagging is required for quantitative datapoints that have a defined element: all 96, not only the four climate tables. Social and governance datapoints (workforce headcount, gender pay gap, fines, board diversity) are detail-tagged too.
• Technical care. Negative values, dimensions, units and periods must be attached correctly - emissions in tonnes CO2e, percentages as decimals, the correct reporting period.
• Reconcile to the approved text. Every tagged value must equal the value in the approved statement, including where footnotes carry meaning.

Practical fix: build a tagging matrix mapping each ESRS datapoint in the statement to its element, then test the instance document with a viewer and a validation tool before filing. The auditor's silence on digital tagging in the engagement letter does not remove the obligation - the filed report must still be correct, and responsibility sits with the directors who approve it.

Extensions are the exception, not a convenience.

A company-specific element may be used only where no element in the applicable taxonomy adequately represents the disclosed item. "Close enough but differently worded" is not the test: the taxonomy's labels and definitions govern, and preparers routinely find that their own phrasing maps to a standard element once they search by definition rather than by label.

The likely answer here is that an intensity metric of emissions per unit of output maps to an existing ESRS intensity datapoint, or can be expressed with an existing element plus a defined unit. Check before extending.

If an extension is genuinely needed:

• Anchor it to the closest existing element rather than inventing a free-standing concept.
• Define it precisely, including the numerator, denominator and unit.
• Document why no standard element fits; that note is what a regulator or reviewer will ask for.
• Use it consistently in future reporting periods, and keep the mapping on file.
• Govern it: the audit committee should see the list of extensions used and the justification for each, because extensions reduce comparability for users and attract scrutiny.

A 1.8% change to Scope 1 after approval is a process problem before it is a number problem.

1. Confirm the correction. Meter reconciliation is a valid source. Document the before and after values, the site, the period affected, and why the original figure was wrong.
2. Re-run the tagging on the corrected statement, rather than manually patching the instance document. The tagged value must derive from the final approved text.
3. Assess materiality. 1.8% of Scope 1 may be immaterial to the statement and to any target baseline, but check whether it crosses a rounding, trend or disclosed-percentage threshold.
4. Route the change through approval. A post-approval change needs a documented approval path - chair's sign-off or a reconvened audit committee - and the assurance provider must be told, since a change after their fieldwork may require additional procedures or affect their conclusion.
5. Close the underlying control gap. The offshore vendor's work was never reviewed. Institute a four-eyes reconciliation between the statement and the instance document, freeze the version before filing, and build enough slack before 30 April that a late correction cannot threaten the deadline.