Disclosure focus
This disclosure asks an organisation to explain how it engages with affected consumers and end-users, and how those people can raise concerns or complaints. In practice, the report should show whether the organisation has ways to listen, respond and follow up across the parts of the business where consumers are affected, not just at a few visible or flagship locations.
The practical focus is on whether these channels are available, usable and relevant in the places and services where impacts can happen, and whether the organisation uses the feedback to identify and address issues. A good explanation should make clear the scope of coverage, how people can access the mechanism, and how the organisation handles and tracks what comes in.
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 S4-2 sub-elements (LRA working checklist)
State whether the complaint route can be used by the relevant people and groups.
List the ways people can reach the complaint route.
Confirm whether a formal complaints process exists.
Set out the measures used to track performance.
Show the share of matters that were closed out.
State how quickly matters are answered.
List the matters that were dealt with.
Describe the way issues are put right.
List the channels used to engage, such as support and surveys.
Describe the methods used to engage.
Identify any groups that may need extra care or support.
How to prepare it
1Map the reporting boundary first. Confirm which customer groups, products, services, and locations sit inside the scope for this disclosure, so you know whose feedback, complaints, and follow-up actions need to be captured.
2Set the definitions you will use for the report. Decide what counts as an engagement route, a complaint route, a vulnerable group, a case that has been handled, and the measures you will use for performance tracking, so the team applies the same rules throughout.
3Gather the source records behind each required item. Pull together the lists of engagement routes, the details showing which groups were identified as more exposed or less able to participate, and the records for complaint handling, response timing, closure, and any remedy provided.
4Build the disclosure content from those records. Prepare the narrative on how the company engages with customers, how the complaint route works, whether it is available, how accessible it is, how issues are resolved, and the figures or summaries for the key performance measures.
5Record any gaps, exclusions, or changes in method. If a route, case, group, or metric is left out, or if the way you measured or classified something changed from the prior period, note that clearly so readers can understand the basis of the disclosure.
6Check the draft against the official source before sign-off. Make sure every required item is covered, the wording matches the underlying evidence, and the final version still reflects the source material after any internal edits or consolidation.
Request the data
Request the complaints, feedback and engagement log from Operations
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What channels do we use to hear from affected people, how do we handle issues raised, and what evidence shows the process is working in practice?
Use your organisation’s own terms first, then map them to the disclosure. For example, if you call these routes ‘customer contacts’, ‘case management’, ‘whistleblowing’, ‘community feedback’ or ‘service recovery’, use those labels in the request and only translate them afterwards for reporting.
Weak request
Please provide the ESRS S4-2 engagement and grievance mechanism evidence, including stakeholder engagement channels, vulnerable groups, accessibility, KPIs, remediation approach and cases addressed.
Why it fails: This uses framework language that many operational teams do not use day to day, so it can be hard to answer consistently. It also does not say which systems, labels, time period, or business areas to pull from, so the response may be incomplete or not comparable.
Better request
Please send the complaints, feedback and case-handling records for [period] from [system/team]. We need the routes people use to contact us, whether there is a formal complaints route, how those routes are made accessible, the measures you track on response and closure, how issues are fixed, and the main case types. Please use your own team labels and add a short mapping note to the reporting categories.
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 which people-related channels were counted, how the organisation defined a complaint route, what was included in accessibility and response measures, and the basis used to identify vulnerable groups and cases handled through remedy processes.
Context note
Set out what the figures show about how people can raise issues, how the organisation engages with them, and how effectively concerns are being handled and put right.
Fluctuation statement
If the figures moved from the previous period, link the change to shifts in channel availability, engagement activity, case volumes, response speed, resolution performance, or the number of matters taken through remediation.
Content index entry
S4-2 Engagement & Grievance Mechanisms — [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 the wrong team, so the data is chased from people who do not run the support line, survey process, or case-handling log.
Framework language used
The data call is written in reporting jargon instead of the organisation’s own terms, so staff cannot map it to the actual helpdesk, feedback route, or case register.
Scope not fixed
No one states which business units, sites, or service lines are in scope, so different teams send different slices of the same activity.
Boundary drift
The collector mixes internal channels with third-party or legacy routes without saying which population belongs in the count, so the dataset is not comparable.
Wrong period basis
People pull figures from different cut-off dates or reporting windows, so the channel list, case counts, and timing measures do not line up.
Mixed counting basis
One team reports unique cases while another reports contacts or actions, and the final file combines them as if they were the same measure.
Source labels lost
The original names from the intake form, tracker, or case system are stripped out, so later reviewers cannot trace each figure back to its source record.
Evidence metadata missing
The file is saved without the date, owner, version, or system reference, so no one can tell which extract was used or whether it was current.
No sign-off trail
The numbers are passed on without a named reviewer or approval step, so there is no clear record of who checked the data before it moved into drafting.
Where judgement is often needed
What counts as a live route for concerns
List only the routes people can actually use in the reporting period, and explain any local hotlines, web forms, union routes or site-level channels that are available in some places but not others.
Whether a route is a complaint channel or just a feedback route
If a route can receive concerns but is not set up to handle complaints end to end, say so plainly and describe how you separate it from the formal case-handling route.
How to handle different local names for the same process
Where country teams use different labels for similar ways of raising issues, map them to one internal description and disclose the local differences so readers can see what is comparable and what is not.
Which people are included when the boundary shifts
When acquisitions, disposals or reorganisations change the group of people covered, state the cut-off used and explain whether the figures reflect the opening, closing or average scope for the period.
How to treat people just outside the formal scope
If some workers, contractors, agency staff, supply-chain workers or community members can use the route even though they sit near the boundary, explain whether they are included in the channel description and in the case counts.
Choosing the basis for response and closure timing
Pick one timing basis for first reply, resolution and closure, apply it consistently, and disclose the rule used where a case spans month-end, year-end or multiple teams.
Using estimates where case records are incomplete
If the case log does not fully support a metric, use a clearly stated estimate method, identify the data gaps, and separate estimated figures from directly counted ones.
How to present rates and percentages
State the denominator behind any rate, share or percentage, and explain any rounding so readers can reconcile the headline figure with the underlying case totals.
How much detail to show when privacy limits the data
Where small numbers or sensitive case details could identify people, group the information to a safer level and say that the presentation has been reduced for confidentiality reasons.
Whether to combine or separate linked routes and outcomes
If one concern can move between a local route, a central case team and a remedy process, explain whether you count it once or in several places and how you avoid double counting.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food retail
We ran a mix of direct conversations, short staff surveys and targeted outreach to people in higher-risk situations, and we used those inputs to shape our approach with affected communities. In the year, we identified 3 vulnerable groups and used 4 engagement routes: store-based help desks, a phone line, an online form and community partner sessions. - We had a formal complaints route in place, with 5 access points available; 4 were designed to be easy to use for people with different needs, and 1 required extra support. - We logged 120 complaints, resolved 102 of them during the period, and closed them in an average of 18 days. - Where harm was confirmed, we used case-by-case remedies such as refunds, service fixes, apology letters and follow-up checks; 27 cases were handled through that process.
This synthetic example shows how to describe the channels used to hear from affected people, who was prioritised as more exposed to harm, and how feedback was gathered. It also illustrates reporting on the complaint route, how usable it was, the number of cases, the share resolved, the average turnaround, and the kinds of remedy applied.
Illustrative (synthetic) example — Healthcare services
We combined patient forums, anonymous pulse surveys and meetings with carers to understand concerns and to keep contact open with people most likely to face barriers. We identified 2 vulnerable groups and used 3 engagement methods: clinic drop-ins, a digital survey and a partner-led listening session. - Our complaint system offered 4 ways to raise an issue; all 4 were accessible, and the route was available throughout the reporting period. - We received 84 complaints, settled 63 within the period, and took an average of 11 days to respond and close them. - For confirmed cases, we used practical redress such as treatment rebooking, fee waivers, service corrections and direct follow-up; 19 cases were dealt with in this way.
This synthetic example shows a different sector using a smaller set of outreach methods and a different complaint profile. It covers the same disclosure points: who was engaged, which groups were seen as more exposed, how feedback was collected, what complaint options existed, how accessible they were, and how many cases were remedied.
How companies report S4-2 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
SNCF Group
Ground Transportation — Railroads · France · 2025
SNCF Group's 2025 Full-Year Financial Report provides partial context on stakeholder communication and engagement, noting efforts to facilitate use of communication channels such as simplified numbers and posters (p.205) and a human, participatory approach to direct communication with stakeholders (p.194). The report also references a complaint service aligned with the SDGs, though no specific headline values are given (p.202). However, clear and comprehensive disclosures on this topic are largely missing or unclear, with several datapoints not found or only vaguely referenced without detailed information.
Acciona, S.A.
Electric Utilities / IPP / Energy Traders · Spain · 2025
Acciona’s 2025 Sustainability Report partially addresses complaint management by describing systematic tracking of complaint processes and the availability of complaint channels for stakeholders (p.315, p.52). The report notes a resolution time of 279 days with some cases closed and others with defined actions (p.314). However, there is no clear headline value or comprehensive narrative on complaint management outcomes, and several expected details or methodologies are not found or remain unclear in the report.
Telecom Italia S.p.A.
Telecommunication Services · Italy · 2025
Telecom Italia S.p.A.’s 2025 Annual Report provides evidence of internal channels for workers to raise concerns and indicates that the company monitors and manages these processes (p.204). The report also offers partial context on engagement planning, detailing the definition of objectives, scope, responsibilities, and stakeholder profiles for each initiative (p.131), as well as some information on accessibility and reliability of assistance services aligned with the Group’s model and local regulations (p.243). However, no clear headline values or comprehensive narrative on the overall effectiveness or outcomes of these disclosures are found, and several expected datapoints remain absent or unclear.
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Scenarios to work through
A service team has a staff helpline, an online form, and quarterly listening sessions. A preparer is drafting the disclosure and notices that the form is only available in one language, while some workers mainly use another language at work.
QHow should the organisation describe the channels and accessibility so the account is complete and not misleading?
Reveal model answer →Hide answer ↑List the actual ways people can raise issues or give feedback, then explain who can use them and any practical limits. If one route is not equally usable for some groups, say so plainly and describe the steps taken to make access workable, rather than implying every route works the same for everyone.
Why this matters · Describe the real routes in use and be clear about any access barriers or adaptations.
A grievance log shows 40 cases opened in the year, 28 closed, and 12 still open at year-end. The draft narrative says the process is effective because most matters were handled, but it does not mention how long people waited for a first reply.
QWhat should the preparer do when reporting performance measures for handling complaints and concerns?
Reveal model answer →Hide answer ↑Use the figures that show how the process is working in practice, including how many matters were dealt with, how many remain unresolved, and how quickly people received a first response. The narrative should match the numbers and avoid overstating performance when some cases are still open or response times are slow.
Why this matters · Pair the process description with balanced performance information, not just the positive result.
The company has a formal complaint route for workers and contractors, plus a separate community hotline for nearby residents. During the year, a case involving a contractor’s safety concern was handled through the worker route because the hotline team redirected it internally.
QHow should the preparer explain the complaint process and the cases handled through it?
Reveal model answer →Hide answer ↑Describe the different routes that people can use, then explain which kinds of concerns each route is meant to handle and how cases are routed in practice. The account should include the matters actually dealt with through the system, even if they arrived through a different entry point and were then passed to the right team.
Why this matters · Show both the design of the process and the types of cases it actually handled.
A preparer is writing the section on engagement with affected people. The company held six focus groups, ran an employee survey, and met with a small group of workers who may face extra barriers to speaking up, but the draft only says it “consulted stakeholders regularly.”
QWhat level of detail should be given about engagement methods and any groups that needed special attention?
Reveal model answer →Hide answer ↑Name the main ways the organisation engaged people, such as surveys, group discussions, or direct meetings, and identify any groups that were treated as more likely to be overlooked or less able to participate. The explanation should show how those groups were reached and why those methods were chosen, rather than using a vague summary.
Why this matters · Be specific about how engagement happened and how harder-to-reach groups were included.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
How do I prepare disclosure S4-2 using the step-by-step guidance on this page?+−
Use the page’s plain-language explainer, then work through the step-by-step preparation section to identify the datapoints you need, the evidence pack, and the draft-output options. It is designed to help you assemble a practical first draft rather than to act as an official source.
What datapoints do I need to collect for S4-2 on consumers and end-users?+−
The page lists the datapoints to prepare, including reporting routes, complaint route, access arrangements, complaint metrics, resolved case rate, reply timing, fixing approach, remedied matters, stakeholder contact methods, at-risk groups, and engagement approach. Use that list as your collection checklist.
How should I define the scope and methodology for S4-2 before drafting the disclosure?+−
The page is set up to help you decide what to include by walking through the preparation steps and the datapoints to prepare. It does not give a formal methodology, so use the page to structure your internal approach and document the choices you make.
Who should own the S4-2 data collection and sign-off process?+−
The page is useful for assigning ownership because it separates preparation, evidence, and assurance readiness. In practice, you would use it to allocate each datapoint and evidence item to the relevant business owner, then confirm who reviews the final draft.
What evidence do I need to build an assurance-ready S4-2 pack?+−
The page includes an evidence pack with five items and six assurance claims to verify, each framed around claim, risk, and evidence. Use those sections to assemble a pack that shows where the data came from and how it was checked.
What are the common mistakes to avoid when drafting S4-2?+−
The page lists common reporting gaps and mistakes, so it is intended to help you spot missing datapoints, weak evidence, or unclear drafting before sign-off. Use that section as a pre-submission quality check.
How do I use the Prep & Assurance workbook for S4-2?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is meant to support the preparation and assurance-readiness process. Use it alongside the page’s datapoints, assurance claims, and evidence pack to organise your draft.
What can I use the printable Library Card PDF for when preparing S4-2?+−
The Download Centre also provides a printable Library Card in PDF format. It is there as a quick reference while you work through the page’s preparation steps, evidence pack, and draft-output section.
Are there example disclosures I can use as a model for S4-2?+−
Yes. The page includes synthetic illustrative example disclosures, including a quantitative table, which you can use to see how the information might be presented in draft form.
How do I turn S4-2 data into a draft narrative and content-index line?+−
The draft-output section gives visualisation ideas, narrative starters, and a content-index line to help you convert collected data into report-ready wording. Use those prompts to shape the narrative after you have completed the datapoints and evidence checks.
More questions this page can help with
S4-2 consumers and end-users disclosure checklist for complaint route, access arrangements and reply timingHow to evidence complaint metrics and resolved case rate for S4-2S4-2 engagement approach and stakeholder contact methods what data should I collectHow to use the S4-2 evidence pack and assurance claims before sign-offWhat are the S4-2 reporting gaps and mistakes to check before draftingS4-2 workbook download how to complete the prep and assurance fileS4-2 synthetic example disclosure how should I adapt it to my companyHow to write the S4-2 draft-output narrative starters into a report paragraphS4-2 content-index line example for consumers and end-users disclosureWhere can I find real company reports linked from the S4-2 pageHow do I document at-risk groups for S4-2 using the page guidanceWhat should an assurance reviewer look for in the S4-2 claim risk evidence table
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