NFRD status metadata

This page provides details on Upright's NFRD status metadata

About

The European Non-Financial Reporting Directive (2014/95/EU) requires certain EU companies to produce non-financial (sustainability) reporting.

Along with its impact metrics, Upright provides metadata on whether a company falls within the scope of NFRD. This information is relevant, for example, for the aggregation of certain taxonomy metrics in accordance with the EU taxonomy regulation.

Criteria for determining NFRD obligation

The NFRD specifies EU-wide baseline criteria on which companies are in the scope of the NFRD, but member nations are allowed to extend the criteria to cover more companies.

Upright determines the NFRD status of a company considering both EU-wide baseline criteria and national rules. The image below illustrates the criteria Upright uses for determining NFRD status.

Summary of criteria Upright uses for determining NFRD status. The national thresholds have been sourced from the European Financial Reporting Advisory Group's (EFRAG)'s assesment report.

Limitations

The automated criteria Upright uses for determining NFRD status have the following limitations:

• National criteria in some EU member states define that state-owned companies are within the scope of NFRD regardless of them meeting some of the usual criteria. Such special rules may not be taken into account in all cases. These should however be a rare occurrence, as most state-owned companies are sufficiently large to also meet the usual criteria.

• In some EU member states, the criteria that relate to employee counts and turnover are stated such that they ought to be exceeded for two consecutive accounting periods. For simplicity, Upright considers only the latest figures when applying the criteria.

• In most EU member states, the actual criteria related to financials are stated in such a way that 2 out of three 3 thresholds related to employee counts, turnover, and the size of the company's balance sheet must be exceeded. Upright only considers two of those criteria (employee counts and turnover), and requires that both thresholds must be met. We consider this a justified simplification, as companies that would meet all other criteria expect the criteria either for employee counts and turnover are expected to be a rare occurence.

Upright works around these limitations by manually correcting the NFRD status of any identified problem cases.

NFRD obligation metadata in the Upright API

The NFRD obligation is indicated in a field named NFRD_obligation, available from the metrics/regulatory and metrics/all endpoints in the Upright API.