The roll-out of the CSRD and its underlying reporting standards, the ESRS, has brought the issue of consumers and end-users into sharp focus for many businesses. ESRS S4, titled ‘Consumers and End-users,’ is the standard under which companies operating in the B2C market must disclose how their products and services impact the people who use them.

This article explains what ESRS S4 requires, when it applies, and how companies should approach it.

What is ESRS S4?

ESRS S4 is the CSRD standard covering impacts, risks, and opportunities related to consumers and end-users — the people who purchase or use a company’s products or services. The standard is organized around four areas of potential impact:

• Information-related impacts: Including product safety information, marketing practices, and data privacy
• Personal safety: Risks from product use, including physical safety and health impacts
• Social inclusion: Access to products and services, and fair pricing
• Responsible business practices: Including anti-competitive behavior, responsible sales practices, and handling of consumer complaints

When does ESRS S4 apply?

Like all topical ESRS standards, S4 applies only where the topic is material under your double materiality assessment. For companies in B2C markets with significant direct consumer relationships, S4 is likely to be material. For pure B2B companies with no direct consumer exposure, it may not be material.

The Omnibus I Directive simplified many S4 requirements, moving several data points from mandatory to conditional. For companies still in CSRD scope, the relevant S4 obligations are determined by the materiality assessment combined with the amended ESRS framework.

For a full overview of the amended ESRS, see our guide to the amended ESRS under Omnibus.

Key ESRS S4 disclosures

Policies and processes (S4-1)

Companies must disclose their policies related to consumers and end-users, including consumer health and safety policies, data privacy practices, and approaches to marketing and responsible selling.

Engagement with consumers (S4-2)

Disclosure of how the company engages with consumers on sustainability matters, including mechanisms for feedback and complaint handling.

Processes to remediate negative impacts (S4-3)

Description of how the company addresses negative impacts on consumers that have been identified, including any remediation channels.

Targets and metrics (S4-4 and S4-5)

Quantitative metrics related to consumer impacts, including product safety incidents, data privacy breaches, and any targets set for improvement.

How to approach ESRS S4

1. Start with the DMA: Determine whether consumer and end-user impacts are material for your business. For most consumer-facing businesses, they will be.
2. Review existing policies: Map your current consumer protection, data privacy, and product safety policies against S4 requirements.
3. Identify gaps: Where policies or processes don’t currently meet S4 disclosure requirements, build the documentation needed.
4. Engage your legal and compliance teams: S4 overlaps significantly with consumer protection law and data protection regulation (GDPR). These teams will have much of the relevant information.
5. Build incident tracking: S4-4 metrics require tracking product safety incidents and data privacy breaches systematically.

How Coolset supports ESRS S4

Coolset’s CSRD platform includes structured data collection for ESRS S4 as part of the full reporting workflow. The platform reflects the updated requirements under the amended ESRS post-Omnibus. Book a demo to see how it works.