Disclosure focus
This disclosure asks an organisation to explain the main actions it is taking, or plans to take, to address biodiversity and ecosystem-related impacts, risks and opportunities, and to show the resources it is putting behind those actions. In practice, that means describing the measures, programmes, investments, staffing or other support that are relevant to the issue, rather than only stating broad commitments or policies.
The practical focus is on whether the response is credible and sufficiently covered across the business. Reporters should make clear where actions apply, how far they extend across operations, value chain or specific sites, and whether the organisation is concentrating on a few flagship locations or applying measures more widely. The aim is to show the scale, scope and seriousness of the response, not just isolated examples.
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.
Preparation
Key datapoints to prepare
＋ Show E4-3 sub-elements (LRA working checklist)
Record the actions already carried out.
List the conservation steps taken.
Show what resources were set aside.
Describe the restoration work completed.
State the planned or actual timing.
Set out the area affected.
Give the amount of financing in euros.
Explain what the offset is meant to achieve.
Set out the criteria used to judge quality.
Name the standards applied.
Identify the ecosystem type involved.
Provide evidence that consent was obtained.
State whether free, prior and informed consent was used.
List the stakeholders involved in engagement.
How to prepare it
1Set the reporting boundary first: identify which biodiversity-related actions, offsetting activities, and any linked stakeholder engagement sit inside the disclosure, and keep the scope consistent across all fields.
2Define the categories you will use before collecting data: separate direct actions from conservation work, restoration work, offset purpose, and the consent-related items so each datapoint has one clear home.
3Gather source evidence for each item: pull together project records, budgets, area maps, habitat or ecosystem descriptions, quality checks, applied standards, and any documents showing whether consent was sought and how engagement was handled.
4Compile the disclosure content in the required form: enter the action details, timing, resources, financing amount in euros, impacted area, ecosystem type, quality criteria, standards used, and the narrative or yes/no items where the datapoint calls for them.
5Record any exclusions, assumptions, or changes in method: explain what was left out, why it was left out, and whether the way you measured or described the information changed from the prior period or from one project to another.
6Check the final draft against the official source before sign-off: confirm every required field is covered, the wording matches the underlying evidence, and the figures and narratives are internally consistent and complete.
Request the data
Request the actions and resource evidence from EHS / Sustainability / Land & Nature
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What nature-related actions, funding and supporting evidence can we show for the reporting period, including any offsetting work and any stakeholder consent records where relevant?
Use your organisation’s own labels first, then map them to the reporting categories. For example, ask for project, habitat, restoration, offset, land, biodiversity, permit, consultation or consent records if those are the terms your teams already use. Keep the request in business language and check the source material before sign-off.
Weak request
Please provide the ESRS E4:E4-3 actions and resources data, including all datapoints under paragraphs 13 and 14 and the AR6 items.
Why it fails: This uses framework language that many operational teams will not recognise, so it is harder to route, harder to complete accurately, and more likely to miss the underlying project records, budgets and consent evidence. It also does not tell the owner which internal files or business terms to use.
Better request
Please send the project, habitat and funding records for [reporting period] for [project/site]. Use your own names for the work, then include what was done, what is planned, when it happened, how much money or resource was set aside or spent, what area or habitat was affected, what checks or standards were used, and any consultation or consent records. A completed table plus source files is ideal.
Industry examples
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
Explain how the figures were compiled, including what counts as an action, how conservation and restoration work were distinguished, how offset cases were identified, how the affected area and funding were measured, which quality checks and external rules were used, and how stakeholder engagement and consent evidence were recorded.
Context note
Describe what the numbers indicate about the organisation’s approach to nature-related impacts and responses, including the balance between direct action and offsetting, the types of ecosystems involved, the scale of resources committed, and the extent of engagement with affected stakeholders.
Fluctuation statement
If the figures changed from one period to the next, explain whether that was driven by new projects, completion of earlier work, changes in the area covered, revised funding, different ecosystem types, or stronger evidence and engagement processes.
Content index entry
E4-3 Actions & Resources — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for E4-3 — 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.
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
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 wrong team, so the person answering cannot speak to the project actions, funding, timing or evidence from their own records.
Framework language only
The question is asked in reporting jargon rather than the business terms used on site, and the respondent cannot map it back to the actual work package or budget line.
Scope not pinned down
No one states which projects, sites, habitats or offset activities are in scope, so different teams pull different populations into the same file.
Wrong time basis
The data pull uses a different period or cut-off from the one used for the report, so the figures do not line up with the reporting year.
Mixed counting basis
Area, spend and activity counts are gathered on different bases without a clear rule, which makes the totals impossible to compare or reconcile.
Source labels lost
The original names from contracts, trackers or approval papers are stripped out, so the team cannot trace each field back to the source record.
Separate groups merged
Actions, restoration work and offset-related items are bundled together even though they should stay separate, which hides what each item actually covers.
Evidence trail missing
The file holds the numbers but not the supporting metadata, reviewer notes or sign-off history, so no one can show how the data was checked before use.
Where judgement is often needed
What counts as an action already in place versus still being planned
Separate work that has actually started from work that is only approved or under design, and explain the cut-off date you used so readers can see why each item sits in the list.
How to handle buys, sales, and other boundary shifts during the year
If sites, projects, or land areas moved in or out of the group during the period, state whether you used opening, closing, or average coverage and describe any restatement or exclusion approach you applied.
Which local naming or classification system to use for habitats and restoration work
Where countries or business units use different labels for the same land type or intervention, map them to one internal description and disclose the translation rule so the same activity is not counted twice or split inconsistently.
Whether to include marginal or partially covered areas
For locations that are only partly within the operational footprint or only partly affected by the work, set a clear inclusion rule and say how you treated the edge cases, including any threshold for counting them.
Choosing between measured figures and management estimates
Use direct measurements where they exist, rely on estimates where they do not, and explain the basis, source, and any material assumptions behind the numbers you report.
How to present timing when work spans more than one reporting period
If an action starts in one period and finishes in another, disclose whether you show the full programme, only the part completed in the year, or the amount committed for future years, and keep that approach consistent.
How to convert and round resource figures
When costs are tracked in different currencies or systems, state the exchange approach and rounding rule used, and make sure the totals still reconcile to the underlying records.
How to aggregate location data when privacy or sensitivity limits detail
If site-level information could identify people, communities, or sensitive places, combine the data to a higher level and explain the aggregation level and any information you have withheld.
How to describe offset-related work versus direct on-site action
If the programme includes both direct measures and offset-type activity, distinguish the purpose of each item and explain which land area, ecosystem type, and quality checks you used for the offset portion.
How to show consent or engagement evidence without over-disclosing personal data
Where engagement records include personal or sensitive information, summarise the stakeholder group, the type of evidence held, and the consent status in a way that protects privacy while still showing the basis for the disclosure.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food processing
During the year, we carried out habitat protection work across our own sites and nearby land, with 3 conservation actions and 2 restoration actions completed, and a further 2 conservation actions and 1 restoration action scheduled for the next 18 months. We assigned €1.8 million of internal resources to this programme, and where we used offsetting, it was only to address residual impacts from one wetland project: €0.6 million supported 12.0 hectares of freshwater marsh, with the area assessed against recognised habitat-condition checks and a third-party biodiversity standard. - For the offset project, we applied free, prior and informed consent with local communities, engaged 4 stakeholder groups, and kept signed meeting records, attendance lists and consent letters as evidence.
Synthetic, illustrative disclosure only; figures and process details are invented for training purposes and should be replaced with entity-specific facts.
Illustrative (synthetic) example — Renewable power
We delivered a mix of nature-positive measures around our operating areas, including 5 conservation actions and 4 restoration actions finished in the period, with 3 more conservation actions and 2 more restoration actions set for the following year. We committed €2.4 million of our own funds to this work, and our offset activity was limited to balancing residual effects from a transmission-line project: €0.9 million covered 18.5 hectares of coastal grassland, using site-condition benchmarks and a verified habitat standard. - In that offset case, we used free, prior and informed consent, worked with 6 stakeholder groups, and retained consultation notes, signed consent forms and local authority correspondence as proof.
Synthetic, illustrative disclosure only; figures and process details are invented for training purposes and should be replaced with entity-specific facts.
How companies report E4-3 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
ÖBB Holding / Rail Cargo Group
Ground Transportation — Railroads · Austria · 2024
ÖBB Holding / Rail Cargo Group’s 2024 Annual Report includes a clear target to create 30 biodiversity islands by 2030 within the ÖBB Infrastruktur sub-group, indicating an active biodiversity initiative (p.142). The report also references biodiversity-sensitive areas and the consideration of protected assets in construction planning, though without headline values or detailed metrics (p.139). However, there is limited disclosure on stakeholder involvement in target formulation and no comprehensive data on biodiversity actions beyond these points, with several expected datapoints not found or unclear in the report (p.141).
Acciona, S.A.
Electric Utilities / IPP / Energy Traders · Spain · 2025
Acciona’s 2025 Sustainability Report provides partial coverage of biodiversity-related disclosures, including references to biodiversity action plans and steps taken to preserve or restore biodiversity (p.156, p.162, p.434). The report mentions integration of biodiversity criteria and compliance with international standards, as well as transparency in environmental reporting and stakeholder dialogue (p.169). However, clear headline values or specific quantitative targets related to biodiversity are not explicitly disclosed, and some narrative items remain unclear or not found in the report.
Iberdrola, S.A.
Electric Utilities / IPP / Energy Traders · Spain · 2025
Iberdrola's 2025 Sustainability Report includes some narrative related to climate change actions referenced on page 67, although it does not clearly disclose the specific datapoint. The report provides more detailed coverage on biodiversity and ecosystems, including policies (p.66), actions and resources (p.56), and long-term conservation targets extending over 30 years (p.69), as well as a Biodiversity Plan addressing transition risks (p.66). However, several expected narrative items are not found or remain unclear, with no quotable evidence present for many datapoints.
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Scenarios to work through
A site team has finished a wetland repair project and a separate habitat-protection programme. The draft note also mentions a tree-planting offset, but the team has not yet separated what was done to avoid harm from what was done to make up for residual impact.
QHow should you split the description so the reader can see the practical steps taken, the nature of the protection work, and any separate offset activity without blending them together?
Reveal model answer →Hide answer ↑Set out the work in distinct parts: first, the actions already carried out; second, the protection measures used to safeguard the affected natural area; third, any restoration work aimed at bringing conditions back; and, if relevant, a separate note on offset activity. Keep each part clearly labelled in plain business language so the reader can tell prevention, repair and offsetting apart.
Why this matters · Separate direct action, protection work, restoration and offsetting so each purpose is clear.
A preparer has a list of biodiversity projects, but only one line says when the work started. The project manager says the rest can be left without dates because the narrative already explains the sequence.
QWhat timing detail should you include so the account shows when the measures began and how they are expected to unfold?
Reveal model answer →Hide answer ↑Add a clear timeline for the measures, including when implementation started and the expected timing of the remaining steps or completion. The point is to let the reader understand the pace of delivery, not just the existence of the projects.
Why this matters · A useful action summary shows timing, not just the existence of activities.
The finance team has approved a budget for habitat work, but the draft report only says the company is 'supporting biodiversity' and gives no amount. The sustainability lead is unsure whether the spend should be shown as a broad estimate or tied to the specific measures described.
QWhat should you do with the funding information so the reader can see the scale of support behind the actions?
Reveal model answer →Hide answer ↑State the resources set aside for the measures in a way that matches the actions described, rather than leaving it as a general statement of support. If the report includes a monetary figure, make sure it is linked to the relevant biodiversity work and is presented consistently with the rest of the narrative.
Why this matters · Readers need the resources behind the plan, not just a general commitment.
A restoration project is being used to compensate for damage in a coastal habitat. The team has a technical note on the area affected, the habitat type, the quality checks used, and the external method followed, but the draft report mixes these into one paragraph and does not say whether local communities were involved or whether consent was obtained where relevant.
QHow should you present the offset-related details so the purpose, location, habitat type, quality basis, method and any community-consent information are all traceable?
Reveal model answer →Hide answer ↑Describe the offset activity as a separate item and explain what it is meant to address. Then identify the area involved, the kind of ecosystem there, the quality criteria used to judge the work, and the method or framework followed. If people with rights or interests were engaged, say who they were and whether consent evidence exists where that is part of the process.
Why this matters · Offset information should be traceable from purpose through method, location and any consent trail.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
What do I need to gather for E4-3 before I start drafting the disclosure?+−
Use the page’s datapoint list as your starting checklist: implemented actions, conservation measures, restoration actions, delivery timeline, resources committed, offset objective and funding, affected area, ecosystem type, offset quality checks, applied standards, FPIC used, engaged groups, and consent records. The page also has a step-by-step preparation section to help you turn that list into a workable process.
How do I scope E4-3 actions, conservation measures and restoration actions so I do not miss anything?+−
The page is designed to help you organise the disclosure around the actions you have implemented and the related measures, timeline and resources. Use the step-by-step preparation section and the datapoint list together so your scope is consistent and you can explain what is included in the draft.
What evidence should I collect for E4-3 to make the disclosure assurance-ready?+−
The page includes an evidence pack with five items for assurance readiness, plus six assurance claims to verify using a claim/risk/evidence approach. That combination is meant to help you build a file that supports the draft and makes review easier.
Which E4-3 data points are most likely to need an owner in my team?+−
The page’s datapoint list covers both operational and governance-style information, so it is useful to assign owners for actions, funding, affected area, ecosystem type, quality checks, and consent-related records. The workbook is intended to help you organise that ownership and track what is still missing.
How do I use the E4-3 Prep & Assurance workbook to build the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is meant to support preparation and assurance readiness. Use it alongside the page’s step-by-step guidance, evidence pack and common gaps list to structure the draft and track completion.
What should I put in the E4-3 narrative if I only have partial data?+−
The page includes draft-output support such as narrative starters and a content-index line, which can help you turn available data into a clear first draft. It also flags common reporting gaps, so you can be explicit about what is known, what is still being collected and where evidence is incomplete.
How do I handle FPIC, engaged groups and consent records in E4-3?+−
These are listed as datapoints to prepare, so the page expects you to gather them where they are relevant to your disclosure. Use the evidence pack and assurance claims to check that the records you include are traceable and support the story you are telling.
What does the E4-3 page say about offset objective, offset funding and offset quality checks?+−
Those items are all part of the datapoint list, so the page is prompting you to capture both the purpose of any offsetting and the controls around it. The assurance section then helps you test whether the supporting evidence is strong enough for review.
How can I avoid the common mistakes when preparing an E4-3 disclosure?+−
The page has a section on common reporting gaps and mistakes, which is there to help you spot weak points before you finalise the draft. A practical approach is to cross-check your data against the datapoint list, the assurance claims and the evidence pack before you write the narrative.
Are there example E4-3 disclosures I can use as a model for my draft?+−
Yes. The page includes synthetic illustrative example disclosures, including a quantitative table, so you can see how the information may be presented in practice without treating it as a real company example.
Where can I find real company reports that mention E4-3-type biodiversity and ecosystem disclosures?+−
The page has a 'From company reports' table that links to real published reports at the pages where the topic is disclosed. It is useful for seeing how organisations present similar information, but it is not presented as an official source or a one-to-one framework mapping.
More questions this page can help with
E4-3 biodiversity and ecosystems disclosure checklist for implemented actions and conservation measuresE4-3 restoration actions and delivery timeline data points to collectE4-3 resources committed and offset funding evidence packE4-3 affected area and ecosystem type how to documentE4-3 FPIC used engaged groups consent records what evidence to keepE4-3 assurance claims claim risk evidence examplesE4-3 common reporting gaps and mistakes to avoidE4-3 Prep & Assurance workbook how to useE4-3 printable Library Card PDF what is it forE4-3 synthetic illustrative example disclosure tableE4-3 draft output narrative starters and content-index lineE4-3 company reports biodiversity ecosystems examples
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