🧾 ESRS S4 – Consumers and End‑Users: Core Requirements for CSRD Reporting

ESRS S4 – Consumers and End‑Users is the dedicated European Sustainability Reporting Standard that governs how undertakings report on their impacts, risks and opportunities relating to users of their products and services.

While ESRS S1–S3 focus on own workforce, workers in the value chain and affected communities, ESRS S4 concentrates on downstream relationships with consumers and end‑users.

It explains what companies must disclose under the Corporate Sustainability Reporting Directive (CSRD) when consumer‑related matters are assessed as material.

This article summarises the scope, structure and main disclosure requirements of ESRS S4, and how businesses can approach implementation in practice.

📜 Scope and Sustainability Matters under ESRS S4

ESRS S4 aims to give stakeholders a clear view of:

• The significant positive and negative impacts of products and services on consumers and end‑users.
• Actions taken to prevent, mitigate or remedy those impacts.
• Related risks and opportunities for the undertaking, including financial effects.

The standard covers three main sustainability areas:

• Information‑related impacts
• Protection of privacy and personal data.
• Freedom of expression.
• Access to complete and quality information about products and services.

• Personal safety of consumers and end‑users
• Health and safety when using products or services.
• Physical security, including digital security where relevant.
• Specific protection of children.

• Social inclusion of consumers and end‑users
• Non‑discrimination.
• Access to essential products and services.
• Responsible marketing and avoidance of misleading or harmful practices.

Undertakings must assess these topics across their own operations and downstream value chain, including distributors, platforms and service providers.

Interaction with ESRS 2 and International Frameworks

ESRS S4 is closely linked to:

• ESRS 1 (general requirements) and ESRS 2 (general disclosures on governance, strategy and impact‑risk‑opportunity management).
• Other social standards ESRS S1–S3, where consumer issues overlap with workforce or community impacts.

The standard references several key international instruments, including:

• ILO Declaration on Fundamental Principles and Rights at Work.
• International Bill of Human Rights.
• OECD Guidelines for Multinational Enterprises.
• United Nations Global Compact principles.
• United Nations Guiding Principles on Business and Human Rights.

Disclosures under ESRS S4 should show how the undertaking’s approach to consumers and end‑users aligns with these frameworks.

For undertakings or groups with an average of 750 employees or fewer, ESRS S4 disclosures may be omitted during the first two years of sustainability reporting, provided the simplified option in ESRS 2 is followed.

🧩 General Disclosures: Consumers and End‑Users in Strategy and Business Model

Linked to ESRS 2 SBM‑3, companies must explain:

• Whether all relevant consumer and end‑user groups that are likely to be materially affected through operations and the value chain are within the scope of assessment.
• Whether material negative impacts are systemic (for example, across markets) or linked to specific incidents or business relationships.
• Material risks and opportunities arising from impacts and dependencies on consumers and end‑users, including where these relate to specific groups such as children or vulnerable users.

This information connects ESRS S4 with overall strategy and business model disclosures.

🛡️ Policies and Human Rights Commitments (ESRS S4‑1)

Under ESRS S4‑1, undertakings disclose:

• The key content, scope and communication of policies that address material impacts, risks and opportunities related to consumers and end‑users.
• Whether those policies apply to all consumers and end‑users, or to defined segments (for example, users of digital services or at‑risk groups).
• How policies align with internationally recognised standards, especially the United Nations Guiding Principles on Business and Human Rights.
• Any reported cases in the downstream value chain where these standards have not been respected.

Companies must also describe human rights policy commitments relevant to consumers and end‑users and how compliance with global instruments is monitored.

🗣️ Engagement with Consumers and End‑Users (ESRS S4‑2)

ESRS S4‑2 requires transparency on how consumer perspectives inform decisions on impacts.

Disclosures cover:

• Which parties are engaged: affected consumers, affected end‑users, their legitimate representatives, credible proxies (such as consumer organisations) and vulnerable or marginalised groups.
• At which stages engagement occurs, such as defining mitigation measures or assessing effectiveness.
• The type of engagement (information, consultation, participation) and frequency (ongoing, periodic or triggered by incidents or legal obligations).
• The functions and senior roles that hold operational responsibility for engagement, and how results influence policies and actions.
• How the undertaking evaluates the effectiveness of engagement, including any agreements or changes that follow.

📣 Remediation and Complaint Channels (ESRS S4‑3)

Under ESRS S4‑3, undertakings explain their arrangements for remedy and raising concerns:

• Processes for providing or contributing to remedy when negative impacts on consumers and end‑users occur, and how effectiveness is assessed.
• The existence and characteristics of channels such as grievance mechanisms, hotlines, digital portals or dialogue forums, including any third‑party mechanisms (for example, operated by authorities or industry initiatives).
• How business partners support or are required to support the availability of such channels.
• How issues raised are tracked, monitored and resolved, and how the involvement of intended users helps ensure channel effectiveness.
• How consumer awareness of, and trust in, these mechanisms is assessed, and whether policies exist to protect individuals from retaliation.

If appropriate channels do not exist, this absence must be clearly stated.

🔧 Actions, Resources, Metrics and Targets (ESRS S4‑4 and S4‑5)

ESRS S4‑4 focuses on concrete actions and resources:

• Processes used to determine which actions are needed in response to specific actual or potential impacts.
• Measures addressing material negative impacts, including adjustments to product design, marketing, sales or data‑use practices.
• Collaborative or industry‑wide initiatives where joint action is necessary.
• Steps taken to provide or enable remedy and additional initiatives to improve social outcomes for consumers and end‑users.
• How the effectiveness of these actions is tracked in practice, and how severe human rights issues and incidents are addressed.

Under ESRS S4‑5 and ESRS 2 MDR‑M, undertakings disclose:

• Targets related to material consumer and end‑user topics, performance against those targets, trends and significant changes, and how progress is monitored and reviewed.
• Metrics used to evaluate performance and effectiveness regarding consumer‑related impacts, risks and opportunities.
• Whether any metrics are validated by an external body other than the assurance provider, and which body, where relevant.

🤝 How ComplyMarket Supports ESRS S4 Implementation

ESRS S4 requires companies to connect policies, engagement processes, remediation mechanisms and quantitative indicators into a coherent disclosure framework.

ComplyMarket supports this process by providing:

• Structured mapping of ESRS S4 requirements against existing consumer protection, product safety and data‑protection practices.
• Guidance on policy and governance updates so that human rights commitments, marketing rules and complaint handling are aligned with ESRS S4‑1.
• Support for stakeholder‑engagement and grievance mechanisms, helping undertakings design channels that meet ESRS S4‑2 and S4‑3 expectations, including protection against retaliation.
• Assistance in defining actions, metrics and targets, ensuring consistency between S4‑4, S4‑5 and the cross‑cutting ESRS 2 metrics and targets requirements.
• Documentation support so that narrative explanations and underlying evidence are prepared for assurance and CSRD reporting.

With a structured, compliance‑driven approach, ComplyMarket helps organisations turn ESRS S4 obligations on consumers and end‑users into clear, reliable sustainability disclosures.