ESRS E5 for Steel & Metals Companies: 2026 Compliance Guide
- →Steel & Metals companies in ESRS E5 scope must report on ESRS modules E1, E2, E4, S1, S3, G1. Average sector readiness is only 43%.
- →Key compliance risks: Direct process emissions (Scope 1) and CBAM compliance.
- →CBAM also applies to this sector — embedded carbon reporting required from 2026.
Which ESRS E5 requirements apply to Steel & Metals?
Steel producers, aluminium smelters, mining companies and metal processors.
For ESRS E5 compliance, Steel & Metals companies must report on the following ESRS topical standards where material: E1, E2, E4, S1, S3, G1. The double materiality assessment will determine which of these modules require full disclosure.
Average compliance readiness across the Steel & Metals sector is currently 43% — significantly below the threshold needed for a clean assurance opinion. Most companies in this sector have work to do before their reporting deadline.
Key ESG risks for Steel & Metals companies
ESRS E5 requires Steel & Metals companies to disclose impacts, risks and opportunities across all material topics. The most commonly material topics for this sector are:
Direct process emissions (Scope 1)
CBAM compliance
Mining impacts (E4)
Community (S3)
Steel & Metals companies that fail their double materiality assessment risk under-reporting material topics. Auditors pay particular attention to this sector's direct process emissions (scope 1).
Scope 3 emissions for Steel & Metals
Scope 3 emissions are typically the largest part of a Steel & Metals company's carbon footprint. The most material Scope 3 categories for this sector are categories 1, 2, 4, 11 under the GHG Protocol.
For ESRS E5 compliance under ESRS E1-5, you must:
1. Screen all 15 Scope 3 categories 2. Report on material categories with documented methodology 3. Set Scope 3 reduction targets for material categories 4. Obtain third-party assurance over your Scope 3 data
ESGMaster automates Scope 3 calculation for Steel & Metals companies using DEFRA 2026 emission factors.
Start with a spend-based Scope 3 screening across all 15 categories. This identifies which categories are material without requiring detailed activity data — you can then focus detailed calculation effort where it matters most.
ESRS E5 compliance roadmap for Steel & Metals
Phase 1 — Assess (Months 1–3) Determine your ESRS E5 scope status, complete a double materiality assessment, and run a gap analysis against ESRS E1, E2, E4, S1, S3, G1.
Phase 2 — Collect (Months 4–9) Build data collection processes for all material ESRS metrics. For Steel & Metals, focus on direct process emissions (scope 1) data first — it is typically the hardest to collect and the most scrutinised by auditors.
Phase 3 — Report (Months 10–12) Draft your ESRS E5 report, engage third-party assurance, implement XBRL tagging, and file with your national authority.
ESGMaster compresses this timeline by automating Phases 1 and 2 — delivering your gap analysis in 8 seconds and your draft report in hours.
ESRS modules for Steel & Metals — materiality guide
| ESRS Module | Topic | Typical materiality for Steel & Metals | Key data required |
|---|---|---|---|
| E1 | Climate change | High | Scope 1, 2, 3 GHG emissions |
| E2 | Pollution | High | Pollutant emissions, waste |
| E4 | Biodiversity | High | Land use, biodiversity impacts |
| S1 | Own workforce | High | Headcount, pay gap, turnover |
| S3 | Affected communities | High | Community engagement, impacts |
| G1 | Business conduct | High | Anti-corruption, lobbying |
Frequently asked questions
Does ESRS E5 apply to Steel & Metals companies?
Yes, if your Steel & Metals company meets the ESRS E5 size thresholds: 1,000+ employees AND €450M+ net turnover (post-Omnibus). Even companies below these thresholds face ESRS E5-equivalent data requests from their large customers.
Which ESRS modules must Steel & Metals companies report on?
Based on typical Steel & Metals business models, the most commonly material ESRS modules are E1, E2, E4, S1, S3, G1. However, you must conduct your own double materiality assessment — the final list depends on your specific operations and value chain.
What Scope 3 categories matter most for Steel & Metals?
The most material Scope 3 categories for Steel & Metals companies are categories 1, 2, 4, 11 under the GHG Protocol. Category 1 is typically the largest source of emissions in this sector.
How long does ESRS E5 compliance take for a Steel & Metals company?
From zero to first ESRS E5 report typically takes 12–18 months for Steel & Metals companies. The biggest time bottlenecks are Scope 3 data collection and third-party assurance provider engagement. ESGMaster reduces the data collection phase to weeks rather than months.
What does ESRS E5 compliance cost for a Steel & Metals company?
Consultant-led ESRS E5 compliance for Steel & Metals companies typically costs €100,000–€400,000 in year one, depending on complexity and number of subsidiaries. AI-powered platforms like ESGMaster reduce first-year costs by 60–80%.