Disclosure focus
This disclosure asks an organisation to explain the actions it is taking, and the resources it is using, in relation to the sustainability matters it has identified as material. In practice, the report should show what is being done, where it is being done, and what support is being put behind it, rather than simply listing policies or intentions.
The practical focus is on giving a clear picture of coverage and effort across the business. That means explaining whether actions apply across the whole organisation, selected business units, specific sites, or parts of the value chain, and whether the resources involved are limited to a few flagship initiatives or spread more broadly. The aim is to help readers understand how seriously the material matters are being addressed in day-to-day operations.
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 GDR-A sub-elements (LRA working checklist)
Give the action a clear working title.
Describe what has already been done.
Set out the results you expect to achieve.
List the steps you plan to take next.
State which part of the business or activity it covers.
Specify the period over which it will run.
Show the amount allocated for the current year.
Explain any funding conditions or links that affect it.
Provide the expected funding range for later periods.
If relevant, identify any non-cash inputs being used.
Name the financial statement line items connected to it.
Identify the kind of resources involved.
How to prepare it
1Start by setting the boundary for the disclosure: decide which activity, project, or initiative you are describing, and make that choice explicit so the reader knows what is in and out of scope.
2Define the terms you will use before drafting the entry. Clarify what you will count as the named action, the period it covers, the work already completed, the work still planned, and the results you expect to see.
3Gather the support for each part of the disclosure. Pull together the records, approvals, plans, budgets, and other source material that back the description of the action and the resource information.
4Prepare the actual disclosure text and figures. State the action in plain language, then set out what has been done, what remains to be done, the expected result, the kinds of resources involved, the amount used in the current year, the range planned for later periods, the linked financial statement line items, any reliance on funding, and any non-financial resources used.
5Record any exclusions, changes, or assumptions that affect the numbers or narrative. If something was left out, reclassified, or adjusted, explain it clearly so the reader can understand the basis of the disclosure.
6Check the draft against the official source before sign-off. Confirm that the wording, scope, timing, resource references, and supporting detail still match the underlying requirement and that nothing material has been missed or overstated.
Request the data
Request the action plan and resource data from Finance / FP&A
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What actions are being taken or planned on the material sustainability topics, and what resources are being committed now and next year to support them?
Use your organisation’s own planning and budgeting language first, then map it to the sustainability reporting categories. For example, ask for project names, workstreams, cost centres, capex/opex, headcount, and funding notes in the terms your teams already use. Check the official source before sign-off.
Weak request
Please provide the ESRS 2:GDR-A actions and resources disclosure data for all material sustainability matters, including the action name, scope, timeframe, actions taken, planned actions, expected outcomes, type of resources, current-year allocation, future allocation range, related financial statement line items, funding dependencies, and non-financial resources.
Why it fails: It uses framework language that many teams do not use day to day, so the owner may not know which plans, budgets, or trackers to pull from. It also bundles too many concepts without telling them how to express the information in their own operational terms, which makes the request harder to action and harder to verify.
Better request
Please send the current and planned initiatives for [business area / topic] for [reporting period], using your normal project, budget, and forecast terms. For each initiative, include what it covers, what has already been done, what is planned next, the expected result, the resource type, this year’s allocation, the expected range for next year, any linked finance lines, any funding assumptions, and any non-cash support. Attach the budget extract, forecast, or project summary you used.
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 each action was identified, how its scope and timing were defined, and how resource figures were compiled, including any non-cash support and links to the relevant accounting lines.
Context note
Set out what the action list is intended to achieve, how the current and future resource figures relate to delivery, and how the expected outcomes show the practical purpose of the plan.
Fluctuation statement
If the current allocation, future funding range, or support mix changes materially, explain whether this reflects timing, revised delivery plans, changed dependencies, or a different resource approach.
Content index entry
GDR-A Actions and Resources in Relation to Material Sustainability Matters — [location / page] / [notes]
Download Centre
Preparation tools & forms
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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 a policy lead or reporting contact instead of the team that actually runs the action or controls the budget, so the answer comes back second-hand and incomplete.
Framework language only
People ask for the data using disclosure labels rather than the organisation’s own project, programme, or cost-centre terms, which makes the source team unable to map the request cleanly.
No clear boundary
The collector does not state which business units, sites, or subsidiaries are in scope, so teams send mixed figures that cover different parts of the group.
Wrong period basis
The data pull uses a different cut-off or reporting window from the one being used for the report, so the figures do not line up with the same time period.
Mixed counting basis
Headcount, spend, and other measures are gathered on different bases without being separated, so the final pack blends unlike numbers that should stay distinct.
Source labels lost
Original file names, system tags, or local category names are stripped out during consolidation, making it hard to trace each figure back to where it came from.
Populations merged
Data for actions already under way, actions still planned, and expected results are combined into one pool even though they need separate treatment in the source pack.
Missing evidence trail
The collector saves the numbers but not the supporting notes, extracts, or approval record, so no one can show how the figure was built or checked.
No sign-off chain
The draft is passed on without a named reviewer or approval step from the people who own the source data, leaving no clear record that the figures were checked before use.
Where judgement is often needed
What counts as the action itself
Use a plain business label for each initiative, and if several workstreams sit under one programme, explain the grouping so readers can see what is included and what is left out.
Which parts of the business are in scope
State the operating units, sites, countries or activities covered by each action, and explain any exclusions where the same issue is handled differently in another part of the group.
How to handle boundary shifts after deals
If an acquisition, disposal or reorganisation changes the perimeter during the period, disclose the basis used for the period view and explain any restatement or non-restatement choice.
Whether timing is based on approval, start or delivery
Pick one timing basis for each action and use it consistently, then explain if the date shown reflects approval, launch, spend, completion or another internal milestone.
How to separate completed work from planned work
Distinguish what has already been done from what is still scheduled, and make clear whether the plan covers committed steps only or also broader intentions.
What counts as a resource and how it is measured
Describe the resource type in operational terms, then explain whether the amount shown is a measured figure, a management estimate or a range, including the basis used.
How to link spend to the financial statements
Where the action is tied to a line in the accounts, identify the relevant line item and explain any allocation method used when the spend is shared across several purposes.
How to treat future funding that is uncertain
If later funding depends on approvals, grants, partner support or other conditions, say what is firm, what is contingent and what assumptions sit behind the range.
How to aggregate sensitive workforce or community data
When privacy, safety or small numbers prevent a detailed split, present the data at a higher level and explain the aggregation rule so the reader understands the limitation.
How to round figures and ranges
Choose a rounding approach that does not distort the picture, apply it consistently across the disclosure, and note it where it could affect how the numbers are read.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — manufacturing
During the year, we ran a plant-efficiency programme across our two main sites, with work focused on energy use, water handling and waste reduction; the plan runs from Q2 2026 to Q4 2028 and is expected to cut operating emissions and disposal costs while improving process reliability. - We spent 12.0 million in the current year, made up of 9.0 million cash spend and 3.0 million staff time and internal support; the cash element sat mainly in property, plant and equipment additions and operating expenses, while the people element was not separately capitalised. - For the next three years, we expect to commit between 28.0 million and 34.0 million in total, with 18.0 million to 22.0 million likely to be capital spend and 10.0 million to 12.0 million likely to be operating spend; this is partly dependent on grant support of up to 6.0 million, and we also rely on internal engineering teams and existing production data systems rather than any external non-financial support.
Synthetic, internally consistent example for practitioner review only.
Illustrative (synthetic) example — retail
We are carrying out a store-network waste and packaging redesign across 180 outlets, with the work scheduled from January 2026 to December 2027 and aimed at lowering material use, reducing disposal charges and improving customer-facing sorting systems. - In the current year, we allocated 4.8 million, comprising 3.6 million for supplier and fit-out costs and 1.2 million for internal project teams; the spend was recognised mainly through operating costs, with a smaller share in leasehold improvements. - Over the next two years, we expect to allocate between 9.5 million and 11.0 million in total, including 6.5 million to 7.5 million of cash spend and 3.0 million to 3.5 million of internal labour and systems work; delivery depends in part on a possible local authority rebate of up to 1.5 million, and we are also using store manager training and our existing inventory platform as non-financial inputs.
Synthetic, internally consistent example for practitioner review only.
How companies report GDR-A in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Amadeus IT Group, S.A.
Hotels, Restaurants, Leisure, Tourism Services · Spain · 2025
Amadeus IT Group’s 2025 Non-Financial Report provides a covered disclosure on actions and resources related to material sustainability matters, including Artificial Intelligence on page 207. The report also references mitigation and energy efficiency in the context of supporting more efficient travel through technology on page 88, though this is not a clear or specific disclosure. Several related datapoints, such as those under GDR A.45.3 to A.46.6, are not found or clearly addressed in the report.
Mowi ASA
Food Production — Animal Source · Norway · 2024
Mowi ASA’s 2024 Integrated Annual Report provides a specific figure for financial resources allocated to its climate action plan, estimating operational expenditures at 13 million euros (p.72). The report includes related context on actions and resources concerning climate change policies and water and marine resources, though these disclosures lack clarity and specificity (p.64). Several datapoints related to resource allocation and actions remain unaddressed or unclear, with no explicit information found for multiple required disclosures.
Fluidra, S.A.
Electrical Equipment and Machinery · Spain · 2025
Fluidra's 2025 Integrated Annual Report provides partial coverage of its climate-related disclosures, notably mentioning actions and resources related to climate change mitigation and adaptation policies on pages 280 and 296. The report references Scope 3 greenhouse gas emissions and transition plans, as well as targets connected to climate change, but does not present clear headline values or fully detailed disclosures for these datapoints (p.280, p.296). Several expected disclosures, including specific quantitative data and comprehensive policy details, are not found or remain unclear in the report.
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Scenarios to work through
A preparer is drafting the section for a material water-risk topic. The team has one project already underway, one project approved for next year, and a target that the business expects to reach if both go ahead.
QHow should the preparer decide what to include so the write-up covers the action itself, where it applies, when it happens, what has already started, what is still planned, and the outcome the company expects?
Reveal model answer →Hide answer ↑The preparer should describe each material-topic response in practical terms: name the action clearly, explain which part of the business or value chain it covers, state the timing, separate work already in progress from work still to start, and set out the result the company expects from those steps. If the action is only planned, it should not be presented as already delivered; if an outcome is expected, that expectation should be linked to the action and timeframe described.
Why this matters · Keep the action story complete and time-based: what it is, where it applies, when it happens, what has been done, what is still planned, and what result is expected.
A finance team has agreed this year’s spend on a biodiversity programme, but the sustainability team also wants to mention a possible increase in funding next year if a grant is approved. The draft currently gives only one total figure and no explanation of what it covers.
QWhat should the preparer do to show the resources used now, the likely range for later funding, and any link to the financial statements or outside funding that affects the plan?
Reveal model answer →Hide answer ↑The preparer should identify the kind of resources being used, show the amount allocated in the current year, and, where future spending is still uncertain, present a sensible range rather than a single fixed figure. They should also explain which financial statement line items are connected to the spend and whether the plan depends on external funding or other financing conditions. If non-financial resources are part of the response, those should be described as well.
Why this matters · Resource reporting should cover both money and other inputs, and it should make clear what is spent now, what may be spent later, and what the funding link is.
A company has launched a supplier-training programme to reduce labour-rights risks. The draft says the programme is ‘under way’ and lists a budget, but it does not say whether the budget is staff time, cash, software, or external support, and it does not mention any future funding uncertainty.
QHow should the preparer decide whether the resource description is complete enough for the disclosure?
Reveal model answer →Hide answer ↑The preparer should check that the resource description is specific enough for a reader to understand the inputs behind the action. That means naming the type of resources used, not just giving a budget total: for example, cash spend, employee time, systems, or outside services. If the action depends on future money or other support, that dependency should be stated; if there are no such dependencies, the draft should not imply one. The current-year allocation should be clear, and any non-financial inputs should be included if they matter to delivery.
Why this matters · A useful resource note explains the form of support, not just the amount of money.
A preparer is combining several climate-related measures into one paragraph because they all sit under the same material topic. One measure has already started, one is approved but not yet started, and one is only a proposal with no funding decision. The paragraph also mentions a target outcome but does not tie it to each measure.
QWhat is the right way to decide whether the paragraph gives a fair picture of actions taken versus actions still only intended, and whether the expected result is linked closely enough to the measures described?
Reveal model answer →Hide answer ↑The preparer should separate what has already been put into practice from what is merely intended or proposed. Each measure should be described in a way that shows its own status, timing, and scope, rather than blending all three into one undifferentiated statement. The expected result should be connected to the relevant measures so a reader can see which action is meant to drive which outcome. If a proposal has no funding decision, it should be presented as a plan or possibility, not as an implemented action.
Why this matters · Do not blur delivered work, approved future work, and early-stage ideas; keep the status of each action and its expected effect distinct.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
General Basis for Preparation of Sustainability Statements → Guide ✓Disclosures in Relation to Specific Circumstances → Guide ✓Metrics in Relation to Material Sustainability Matters → Guide ✓Policies Adopted to Manage Material Sustainability Matters → Guide ✓Targets in Relation to Material Sustainability Matters → Guide ✓Role of the Administrative, Management and Supervisory Bodies → Guide ✓Show all 14 related disclosures →
FAQ
Questions this page answers
How do I use the GDR-A page to draft the disclosure from scratch?+−
Start with the plain-language explainer, then work through the datapoints to prepare, the step-by-step preparation section, and the draft-output ideas. The page is designed to help you turn source data into a first draft, not to replace your own reporting judgement.
What data do I need to collect for GDR-A before I start writing?+−
The page lists the datapoints to prepare: action name, coverage, timing, completed steps, next steps, expected results, resource type, this year spend, future spend range, linked accounts lines, funding conditions, and other support used. Use that list as your collection checklist so you can build the disclosure without missing key fields.
How should I set the scope and methodology for the GDR-A disclosure?+−
Use the page’s step-by-step preparation guidance to decide what action or actions you are describing and which datapoints apply to each one. Keep the scope consistent across the narrative, the table, and the evidence pack so the draft reads as one coherent disclosure.
Who should own the GDR-A data and sign-off process?+−
The page is useful for assigning ownership across sustainability, HR, finance, or other data owners because it shows which datapoints need to be gathered and evidenced. In practice, each field should have a named owner who can confirm the source and explain any judgement used.
What should go into the GDR-A evidence pack for assurance readiness?+−
The page includes an evidence pack with five items and six assurance claims to verify, so you can assemble support around the claim, the risk, and the evidence. Use those sections to make sure the pack is complete enough for a reviewer to trace the numbers and narrative back to source material.
What are the six assurance claims I need to check for GDR-A?+−
The page says there are six assurance claims to verify, organised around claim, risk, and evidence. Use that structure to test whether each reported point is supported, whether there is a realistic risk of error, and whether the evidence pack answers it clearly.
What are the common mistakes to avoid when reporting GDR-A?+−
The page lists common reporting gaps and mistakes, which are there to help you spot weak drafting, missing data, or inconsistent treatment before sign-off. A practical use is to compare your draft against those gaps and fix anything that would make the disclosure harder to assure.
How do I use the GDR-A workbook download in practice?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to help you organise the disclosure work and evidence. Use it alongside the page’s datapoint list and assurance sections to track what is complete, what is missing, and what still needs review.
What is the printable Library Card for GDR-A used for?+−
The printable Library Card in PDF format is a quick reference version of the page content. It is useful for workshops, data-owner check-ins, or assurance preparation when you want the key fields and checks in a compact format.
How can I turn the GDR-A data into a draft narrative and table?+−
The page’s draft-output section gives visualisation ideas, narrative starters, and a content-index line to help you shape the final write-up. Use those prompts to convert the collected datapoints into a clear draft, then check it against the example disclosures for format and completeness.
More questions this page can help with
GDR-A action name and action coverage: what should I capture in the draft?GDR-A action timing: how do I present completed steps and next steps clearly?GDR-A resource type, this year spend and future spend range: how should I structure the numbers?GDR-A linked accounts lines: what evidence do I need to support them?GDR-A funding conditions and other support used: how do I describe these without overcomplicating the disclosure?How do I use the GDR-A synthetic illustrative example disclosures without copying them?What should an assurance reviewer look for in a GDR-A evidence pack?How do I avoid the most common GDR-A reporting gaps before sign-off?Can I use the GDR-A page to brief HR or finance data owners on what to provide?Where do I find the GDR-A workbook and printable reference card?Does the GDR-A page provide real company report examples I can compare against?Is there a one-to-one ESRS or IFRS mapping for GDR-A on the page?
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