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ESRS 2: General Disclosures · 2026-5010-final

Disclosure Requirement BP-2

Disclosures in Relation to Specific Circumstances

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official EFRAG source.

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Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by EFRAG

To prepare this disclosure

10datapoints↓ 6claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain any specific circumstances that affect how it has prepared its sustainability information. In practice, that means saying whether the reporting boundary, methods, assumptions, estimates, or data quality are different because of unusual conditions, and making clear what those differences mean for the reported information.

The practical focus is on transparency about coverage and comparability. An organisation should help readers understand whether the information covers the whole business or only part of it, and whether any sites, entities, activities, or data points are excluded, estimated, or treated differently. The aim is to show where the reporting is complete, where it is limited, and why.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Have you decided which sustainability topics you will cover here, and which ones you will leave out? For each topic you are covering, have you fixed the exact label you will use and how it connects to your wider business plan? Have you agreed what policies, actions, targets and measures sit under each topic, so the story is complete and in the right place? Are the figures and descriptions taken from a source you can trace back, and are they based on the same cut-off date and calculation basis throughout? Have you checked whether each topic is treated as relevant in your assessment, and whether it is also judged to be material? If you are leaving any topic out, have you already settled the reason and recorded which items are omitted?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Omitted disclosures List every disclosure requirement that is not included in the report, with enough detail to identify each missing item and where it would have appeared. Disclosure checklist, reporting index, draft-to-final gap log, sign-off notes. Reporting lead / sustainability reporting team

Omission reasons For each omitted disclosure, record the specific reason it was left out and whether that reason applies to the whole item or only part of it. Draft commentary, issue log, legal or technical review notes, approval trail. Reporting lead with legal / subject-matter review

Assessment done State whether the topic was assessed, using a clear yes or no based on the completed assessment record for the reporting period. Materiality or topic-assessment workbook, workshop outputs, approval memo. Sustainability / materiality lead

Material topic flag State whether the topic was judged material, using a clear yes or no that matches the final materiality decision for the period. Final materiality matrix, governance approval, reporting boundary paper. Sustainability / materiality lead

Topic title Enter the name used internally for the topic, in the form that will be shown in the report and linked to the related disclosures. Reporting index, topic map, approved disclosure list. Sustainability reporting team

Strategy connection Describe how the topic connects to the organisation’s strategy, using the approved strategic framing and the same period covered by the report. Strategy deck, board paper, annual plan, approved narrative draft. Strategy team with sustainability reporting

Policy coverage Set out the policies that apply to the topic, naming the relevant policy documents and the parts that govern the topic. Policy register, approved policy documents, control library. Policy owner / compliance team

Action summary Capture the actions being taken on the topic, including the main workstreams, implementation status and who owns delivery. Action tracker, project plan, management updates, committee papers. Operational owner / programme manager

Target details Record each target linked to the topic, including the target statement, timeframe and the measure used to judge progress. Target register, board-approved objectives, KPI tracker. Performance management / sustainability team

Metric set List the metrics used for the topic, with the exact measure names and the reporting period they relate to. KPI dashboard, data dictionary, source-system extracts, reporting pack. Data owner / performance reporting team

＋ Show BP-2 sub-elements (LRA working checklist)

How to prepare it

1Start by deciding which sustainability topics you have actually assessed, and mark each one clearly as covered or not covered. Keep a simple record of the topic name and the yes/no outcome so the scope is easy to follow.

2For every topic you treat as covered, set out what you are counting as part of that topic. Use the same boundary consistently when you later gather the supporting material, so the figures and narrative all refer to the same scope.

3Gather the underlying support for each covered topic before drafting the disclosure. Pull together the evidence that backs the strategy connection, the policies in place, the actions taken, the targets set, and the measures used to track progress.

4Assemble the disclosure in a structured way for each topic: topic name, how it links to the business approach, the relevant policies, the actions underway, the targets, and the metrics. Where a topic is not covered, note that outcome separately.

5If you leave out any required topic, explain why it is missing and record the omission clearly. Also note any changes in approach, scope, or presentation so a reviewer can see what was excluded and why.

6Before finalising, check your draft against the official source to confirm the topic list, the covered or uncovered status, the scope, and the supporting details all match. Use that review to catch any gaps, inconsistencies, or unsupported statements.

Request the data

Request the basis and evidence for topic coverage and reporting choices

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

Which topics were assessed, which were treated as material, and what supporting strategy, policy, action, target, metric, and omission evidence sits behind those reporting choices?

Use your organisation’s own labels first, then map them to the reporting fields. For example, if your teams talk about priority themes, control topics, programmes, KPIs, or exceptions, use those terms in the request and only translate them into the reporting structure at the end. Keep the ask practical and evidence-led, and check the source material before sign-off.

Weak request

Please provide the ESRS 2:BP-2 disclosures, including all assessed topics, material topics, strategy links, policies, actions, targets, metrics, and omitted disclosures.

Why it fails: This uses framework language only, which makes it harder for the owner to recognise the records they hold. It also bundles too many ideas together without telling the team what internal documents, systems, or decision notes to pull. The result is slower, less complete evidence collection.

Better request

Please send the topic review pack for [reporting period] in [business area]: the internal topic list, which topics were reviewed, which were treated as priority, the strategy or plan reference for each, the policy/control reference, the main actions, any targets or KPIs, the measures tracked, and any items not included with the reason. Include source links, owner, approver, and approval date. Use your own team terms first, then we will map them into the reporting pack. Please adapt this to your organisation and check the source material before sign-off.

Formal email template

Subject: Request for topic review evidence and reporting basis for [reporting period]

Dear [name/team],

We are preparing the sustainability reporting pack for [reporting period] and need your help with the evidence behind the topic review and related reporting choices for [business area / topic set].

Please share, for each topic you own or contributed to:
- the topic name used internally
- whether it was reviewed and whether it was treated as a priority topic
- the link to the relevant strategy or business plan
- the policy, standard, or control reference
- the main actions or programmes in place
- any targets or KPIs used
- the metrics or measures tracked
- any topics or details that were not included in the report, with the reason

Please send the source files or links, plus a short note on where the information came from and who approved it. If your team uses different terms, please use those first and we will map them into the reporting pack.

A possible LRA training template only — please adapt this to your organisation and check the source material before sign-off.

Many thanks,
[preparer name]
[role]
[contact details]

Short Teams / Slack version

Hi [name], could you send the evidence for the topic review and reporting basis for [reporting period] in [business area]? We need the internal topic names, which ones were reviewed and treated as priority, the strategy/policy/action/target/KPI links, and any items left out plus the reason. Please share the source links/files and who approved them. Use your team’s own terms first — we’ll map them afterwards. Please adapt this to your organisation and check the source material before sign-off. धन्यवाद / Thanks, [name]

Industry examples

Manufacturing

Context. The sustainability team needs evidence from operations, HSE, and strategy owners for a plant network review.

Adapted request. Please share the plant-level topic review pack for [reporting period]: the topics your team assessed, which ones were treated as priority, the link to the site or group strategy, the relevant operating procedures or controls, the main improvement actions, any site targets or KPIs, the measures tracked, and any topics or details not included with the reason. Use your site’s own terms first, then we will map them into the reporting pack.

Example response. A table listing each site topic, review status, priority flag, strategy reference, procedure/control reference, action reference, target/KPI reference, metric, omission note, source link, owner, approver, and approval date.

Financial services

Context. The reporting team is collecting evidence from risk, compliance, product, and sustainability leads for a group-wide review.

Adapted request. Please send the group topic review evidence for [reporting period]: the internal issue list, which items were reviewed, which were treated as priority, the strategy or risk appetite reference, the policy or control reference, the main actions, any targets or KPIs, the measures tracked, and any items not included with the reason. Please use your team’s own wording first, then we will map it into the reporting pack.

Example response. A spreadsheet with each issue, review outcome, priority status, strategy/risk reference, policy/control reference, action reference, target/KPI reference, metric, omission reason, source system, owner, approver, and approval date.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

Describe the basis used to decide which topics were reviewed, how materiality was judged, what counts as an omission, and how each topic was linked to strategy, policies, actions, targets and metrics.

Context note

Explain what the figures show about the organisation’s reporting coverage: which topics were assessed, which were treated as material, which were connected to the business strategy, and where the disclosure is more complete or more limited.

Fluctuation statement

If the pattern changes from one topic to another, note whether that reflects differences in materiality decisions, missing disclosures, or uneven availability of supporting information rather than a change in the underlying issue itself.

Content index entry

BP-2 Disclosures in Relation to Specific Circumstances — [location / page] / [notes]

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Preparation tools & forms

Professional preparation tools for BP-2 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

Free · Community members

01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Go deeper · BP-2

Learn to prepare this disclosure end-to-end

This guide covers one Disclosure Requirement. The ESRS / CSRD Reporting course walks the full European workflow — double materiality, datapoints, evidence and assurance — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

Explore the ESRS / CSRD course →

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

We have a clear note where we explain any parts of the wider sustainability report that we left out because we used the relevant phase-in reliefs.An assurer will check whether the omitted items are actually covered by the relief relied on, and whether the note is specific enough to show what was left out and why.Draft report with the omission note; internal mapping of omitted items to the relief applied; sign-off papers showing the basis for the omission decision.

We recorded whether the topics linked to the omitted areas were considered in the materiality review, and whether they came out as material.An assurer will probe whether the materiality process really covered those topics and whether the conclusion is supported by the assessment evidence.Materiality assessment workbook; workshop outputs or scoring sheets; decision log showing the conclusion for each topic linked to the omitted areas.

We placed the note about omitted items in the main narrative or in the content index, rather than leaving it in an unconnected file.An assurer will check whether the location makes the omission easy to find and whether the report cross-references are complete and consistent.Published report layout; content index; cross-reference table; final proof showing where the omission note appears.

We put the material-topic note either in the main report section or next to the related topic disclosures.An assurer will test whether readers can find the information without ambiguity and whether the placement matches the way the rest of the report is organised.Final report proof; section structure or navigation map; cross-references from the topic pages to the note.

For each material phase-in topic, we set out the main way the business model and strategy respond to the related impacts.An assurer will look for a real link between the topic and the strategy narrative, and will check that the description is not generic or overstated.Strategy papers; board or management papers linking topics to business model choices; draft text showing the topic-by-topic linkage.

We included a short description of the policies that relate to the material phase-in topics.An assurer will check whether the policy descriptions are actually relevant to the topics named and whether they are more than a label or heading.Policy documents; policy register; mapping between each topic and the policy text used in the report.

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes or records evidencing the relevant engagement or consultation

Common reporting gaps

The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.

Common gaps

Mistakes to avoid when collecting the data

Wrong owner

The request goes to the sustainability team by default, even though the needed facts sit with the business lead who actually runs the topic, policy, action, target or metric in day-to-day operations.

Framework language only

The data call is written in reporting jargon, so the operational team cannot map it to the names and labels they use in their own systems and files.

No boundary set

People collect figures from mixed parts of the group without first fixing which entities, sites, activities or periods belong in the pack.

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Where judgement is often needed

Decide what sits inside the reporting perimeter after a buy-in or sale

If the group has changed through an acquisition or disposal, explain the cut-off date and whether the figures include the new or exited business for the full period, part of it, or not at all.

Handle country-by-country labels where local meanings do not match

Where the same business term is used differently in different places, state which local definition you used and how you kept the reporting line consistent across the group.

Set a clear rule for people or operations near the boundary

For staff, sites, customers, suppliers, or other activities close to the edge of scope, explain the rule used to include or exclude them and why that rule was chosen.

＋ Show 6 more

Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Food processing

*Illustrative only: this is a synthetic example disclosure.* We reviewed the sustainability matters we had already assessed and identified one area as not material for this reporting cycle. - The topic assessed was water use across our own sites and key suppliers; we marked it as not material after our review. - Because it was not material, we did not carry forward the related detailed requirements on governance, strategy, actions, targets or metrics, and we explained that the decision was based on the outcome of the materiality review.

This example shows how a company can explain that a topic was considered but then excluded from detailed reporting because it did not meet the materiality threshold. It is intentionally synthetic and uses generic language only.

Illustrative (synthetic) example — Software services

*Illustrative only: this is a synthetic example disclosure.* We completed our review of the topics in scope and found one area to be material, so we described how it connects to our business model and management approach. - The topic assessed was employee wellbeing; we treated it as material and linked it to our strategy because retention and productivity affect our operating model. - We then set out the relevant policies, the actions under way, the targets we are tracking, and the metrics we use to monitor progress, all in line with the outcome of that review.

This example shows a material topic being carried through into the narrative on strategy, policies, actions, targets and metrics. It is intentionally synthetic and uses generic language only.

Company reportsReal published reports

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How companies report BP-2 in practice

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

LANXESS Aktiengesellschaft

Chemicals · Germany · 2025

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LANXESS Aktiengesellschaft’s 2025 Corporate Sustainability Report provides unclear information related to impacts on value chain workers, referencing section “S2-4 – Taking action on material impacts on value chain workers, and approaches” on page 97, but without a clear disclosure of the specific datapoint. The report mentions assessment criteria for impacts on page 9 and refers to processes for identifying and assessing material impacts on page 16, though these do not directly clarify the disclosure in question. Notably, no quotable evidence explicitly addressing the disclosure was found elsewhere in the report.

REN - Redes Energéticas Nacionais, SGPS, S.A.

Water Utilities · Portugal · 2025

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REN's Integrated Report 2025 provides some related context on processes to identify and assess material pollution-related impacts, risks, and opportunities (p.635), as well as on strategy and materiality related to cybersecurity (p.139), but these disclosures are not clearly detailed. Several key sustainability topics, including management of material risks and crises, economic performance, significant environmental impacts, indirect economic impacts, and worker health promotion, are explicitly noted as omitted or not found in the report (pp.650-659). Overall, the report contains limited and unclear information on these sustainability disclosures.

Snam S.p.A.

Gas Utilities · Italy · 2025

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Snam S.p.A.'s 2025 Annual Report includes some coverage of material topics related to sustainability, with a specific mention of greenhouse gas-related material topics on page 481. There is related context on impacts, risks, and opportunities and their interaction with strategy on page 459, though this is not a clear disclosure. Other relevant sections, such as those on biodiversity and ecosystems (pages 463 and 488), provide some context but lack explicit, clear disclosures, and several expected datapoints are not found in the report.

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Scenarios to work through

A group has assessed a climate-related topic as relevant, but the draft report only names the topic and describes the main actions. It leaves out the link to the business plan, the policy position, the target, and the metric used to track progress.

QShould the preparer treat those missing items as acceptable, or should they be added before sign-off?

Reveal model answer →

A preparer has marked a biodiversity topic as not material after the latest review, but the working papers still show that the topic was considered and the conclusion was reached by the sustainability team, not the board. The draft report gives the conclusion but does not explain how that decision was made.

QWhat should the preparer check before finalising the disclosure about that topic?

Reveal model answer →

A company has two relevant topics in the same reporting period. For one of them, the draft includes the topic name, the strategy connection, policies, actions, targets and metrics. For the other, the draft includes the topic name and strategy connection only, because the team says the policy and target are still being developed.

QHow should the preparer decide whether the second topic can be presented with fewer details?

Reveal model answer →

During drafting, the reporting team realises that one environmental topic was assessed, found relevant, and linked to a target, but the metric used to monitor progress was not agreed in time for publication. The team wants to publish the rest of the section and leave the metric out without comment.

QWhat is the right judgement on whether the metric can simply be omitted?

Reveal model answer →

Framework references