Disclosure LibraryPractitioner guidance for every reporting disclosure
All disclosures Courses
Home→ Disclosure Library→ ESRS→ ESRS 2→ IRO-2
ESRS 2: General Disclosures · 2026-5010-final
Disclosure Requirement IRO-2

Disclosure Requirements in ESRS Covered by the Undertaking's Sustainability Statement

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.

Dr Ross Kurinko, Sustainability Reporting Trainer
Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by EFRAG
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to explain how it has identified and assessed the impacts, risks and opportunities that matter for its sustainability reporting. In practice, it is about showing the basis for what has been included in the statement: what the organisation looked at, how it judged significance, and how that process led to the topics and matters reported elsewhere in the sustainability statement.

The practical focus is on the scope and consistency of the assessment, not just on a few headline sites or activities. An organisation should be able to describe whether its approach covers the whole business and value chain where relevant, or only selected operations, and why that approach is appropriate. The key point is to make clear how the assessment was carried out so readers can understand the coverage, boundaries and logic behind the reporting.

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

Datapoint What to capture Evidence hint Owner
Material impacts A plain summary of the significant effects the business has identified on people, the environment, or the economy, using the organisation’s own assessment and wording. Materiality assessment papers, impact register, board or committee papers approving the conclusion. Sustainability reporting / ESG team
Material risks A plain summary of the significant downside exposures the business has identified, based on its own assessment of what could affect performance or position. Risk register, climate or sustainability risk assessment, risk committee papers. Risk management
Material opportunities A plain summary of the significant upside areas the business has identified, based on its own assessment of where value or benefit could arise. Opportunity register, strategy papers, investment cases, management review papers. Strategy / sustainability team
Business and value chain link A clear statement of whether the matter sits in the organisation’s own activities, in its wider supply or customer chain, or across both, using the same boundary logic as the assessment. Boundary methodology, value chain mapping, materiality assessment support papers. Sustainability reporting / ESG team
Why not material A short explanation of why the climate topic was concluded not to be material, including the basis used for that conclusion and the main factors considered. Materiality assessment memo, climate screening paper, board or committee approval. Sustainability reporting / ESG team
Impact changes Any change in the significant effects already identified, including new effects, removed effects, or a change in how important they are judged to be. Updated materiality review, incident logs, stakeholder feedback, management papers. Sustainability reporting / ESG team
Risk changes Any change in the significant downside exposures already identified, including new risks, removed risks, or a change in their assessed importance. Updated risk register, risk committee papers, scenario analysis updates. Risk management
Opportunity changes Any change in the significant upside areas already identified, including new opportunities, removed opportunities, or a change in their assessed importance. Updated strategy papers, pipeline reviews, investment committee papers. Strategy / sustainability team
Required disclosures list A list of the disclosure items that apply, so the report can show which required topics are being addressed. Disclosure checklist, reporting matrix, drafting tracker. Financial reporting / sustainability reporting
Where disclosed The exact place in the report where each required item can be found, such as the section, note, or page reference. Final report index, cross-reference schedule, page map. Financial reporting
Linked by reference A yes/no flag showing whether the item is brought in from another document rather than repeated in full in the report. Cross-reference schedule, drafting instructions, final report sign-off pack. Financial reporting
Extra disclosures list A list of any additional disclosure items included beyond the core set, so reviewers can see what supplementary material has been added. Reporting checklist, drafting tracker, final disclosure index. Financial reporting / sustainability reporting
High-risk operations The types of operations that face a higher level of exposure, using the organisation’s own risk assessment and operational categories. Risk assessment, site or asset register, operational risk review. Operations / risk management
High-risk locations The countries or other places where the organisation’s activities face a higher level of exposure, based on the risk assessment used for reporting. Country risk assessment, site register, geopolitical or operational risk review. Operations / risk management
Cross-reference table A mapping that shows where each required item is covered in the report, so reviewers can trace the disclosure set end to end. Disclosure matrix, drafting tracker, final report contents list. Financial reporting
Report location The place in the sustainability statement where the linked information appears, using the final published structure and page or section references. Final sustainability statement, contents page, page map. Financial reporting
Not material flag A yes/no indication that the topic is not material, based on the organisation’s final assessment for the reporting period. Materiality assessment conclusion, approval memo, reporting checklist. Sustainability reporting / ESG team
＋ Show IRO-2 sub-elements (LRA working checklist)

How to prepare it

1Set the boundary first: decide which parts of the business and which parts of the wider value chain you are covering, then separate the three result types you need to report — adverse effects, downside exposures, and upside possibilities. If climate is not judged material, prepare the short rationale for that conclusion as part of the same scoping work.
2Define the terms you will use in a consistent way before drafting: what counts as an impact, a risk, an opportunity, and what counts as being linked to your own activities or to the value chain. Keep the definitions practical so the team applies them the same way across the disclosure.
3Gather the underlying support for each item: source papers, assessments, registers, workshop outputs, management papers, and any other records that show how the conclusion was reached. Use the evidence to identify where the most exposed operations sit and which countries or regions carry the higher exposure.
4Build the disclosure content from that evidence. Prepare the narrative for the material items, and where the disclosure asks for lists or references, compile the relevant standards, the place where each one is reported, whether it is brought in by reference, and any extra disclosures that sit alongside the main statement.
5Record anything that changed during the period and explain it clearly. Cover shifts in the adverse effects, downside exposures, and upside possibilities, and note any exclusions, boundary changes, or other adjustments that affect how the current year compares with the prior view.
6Check the draft against the official source and the reporting map before sign-off. Confirm that every required item is covered, that the cross-reference table points to the right location in the sustainability statement, and that any indication of non-materiality is supported by the final wording and evidence.
Request the data

Request the disclosure map and evidence pack from Sustainability Reporting

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

Which sustainability topics are covered in our statement, where are they shown, and what supporting references prove the mapping and any exclusions?

Use your organisation’s own labels for topics, reports, systems and governance forums first, then map them to the reporting framework wording. Keep the ask in business language rather than framework terms where possible, and check the source material before sign-off.

Weak request

Please provide the ESRS 2:IRO-2 disclosures, including material impacts, risks, opportunities, disclosure requirements, supplementary disclosures, and appendix linkage.

Why it fails: It uses framework language only, which makes it harder for the business owner to recognise what is being asked. It also bundles several different checks into one vague request, so the owner may not know which tracker, report, or evidence set to return.

Better request

Please send the current disclosure map for our sustainability statement: which topics are covered, where each one appears, what source evidence supports the mapping, what changed since last year, which sites or countries are higher risk, and which topics are not included with the reason why. If you already keep this in a tracker, send that version and note the owner, source system, and latest update date.

Formal email template
Subject: Request for the disclosure map and supporting references for [reporting period]

Hi [name/team],

We are preparing the sustainability statement for [reporting period] and need the current mapping of our sustainability topics, together with the supporting references behind each item.

Please share, for each topic in scope:
- the internal topic name you use
- whether it is covered in the statement, linked from another report, or not included
- where it appears in the statement or linked material
- the supporting source or evidence used for that mapping
- any note explaining why a topic is not included
- any changes from the prior period in the way impacts, risks, or opportunities are described
- any operations, sites, or countries flagged as higher risk
- the cross-reference table that ties the topics to the statement sections

If you already have this in a tracker or control file, please send that version and note the latest update date, owner, and source system.

Please adapt this to your organisation’s own terms and check the source material before sign-off.

Thanks,
[preparer name]
Short Teams / Slack version
Hi [name/team] — could you send the current topic map and supporting references for [reporting period]? Please include what’s covered, what’s linked, what’s excluded, where each item sits in the statement, and any notes on changes or higher-risk sites/countries. If there’s a tracker already, that works too. Please use your own internal terms and check the source material before sign-off. Thanks, [name]
Industry examples
Manufacturing

Context. A multi-site producer with plants, warehouses, and a central ESG reporting team.

Adapted request. Please share the current topic map for FY2025 across our plants, warehouses, and head office, including which topics are covered in the statement, where each one appears, the source file or tracker behind it, any changes since last year, and any sites or countries flagged as higher risk.

Example response. A tracker listing each internal topic, the statement section or linked report, the evidence file name, the owner, the update date, a note on changes from FY2024, and a list of higher-risk plants and countries.

Financial services

Context. A group with business lines, regional offices, and a central sustainability reporting function.

Adapted request. Please send the disclosure map for FY2025 covering our business lines and regions, showing which topics are included in the statement, where they are disclosed, what evidence supports the mapping, any exclusions with reasons, and any changes in risk or opportunity wording since the prior period.

Example response. A cross-reference table with each topic, the relevant section or annex, the linked source document, the internal owner, the exclusion rationale where relevant, and a note on any changes from the previous reporting cycle.

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

Set out the basis used to identify and define the significant matters, explain how the reporting boundary was applied across the business and value chain, and note which disclosures were used or linked to support the conclusion.

Context note

Explain what the figures and lists mean in practice by linking them to the organisation’s main areas of exposure, the parts of the business or value chain they affect, and the locations where those exposures are most concentrated.

Fluctuation statement

Describe any notable movement by pointing to the underlying business, operational or external drivers, and clarify whether the change reflects a shift in the underlying assessment, the reporting scope, or the underlying conditions.

Content index entry
IRO-2 Disclosure Requirements in ESRS Covered by the Undertaking's Sustainability Statement — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for IRO-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 · IRO-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.

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
We have set out a short explanation of the main positive and negative effects we judged to be material, and we link each one to the relevant subject area.The assurer will check that the summary is not vague, that it really covers both favourable and adverse effects, and that each item is tied to the right topic rather than being a general narrative.Materiality assessment papers; issue mapping; drafting notes showing how each effect was classified; cross-reference from the statement to the relevant topic section; review comments confirming the wording matches the underlying assessment.
We have placed the explanation of the main effects together with the related policies, actions, measures and goals so the reader can follow one joined-up story without repeated text.The assurer will probe whether the same point is being repeated in several places, whether the links between narrative and metrics are consistent, and whether the presentation really supports a single coherent account.Draft structure or content map; cross-references between narrative, policies, actions, metrics and targets; version history showing duplication was removed; sign-off notes from preparers and reviewers.
We have described the main effects in a way that shows how they influence, or may influence, people or the environment, rather than just naming the issue.The assurer will test whether the description explains the nature of the effect and its direction, or whether it is only a label with no practical meaning.Impact assessment worksheets; supporting analysis of affected stakeholders or environmental receptors; source documents used to draft the description; reviewer notes checking that the wording reflects the assessment evidence.
We have set out the main risks and opportunities in brief, and we have linked each one to the subject it belongs to.The assurer will check that risks and opportunities are both covered where relevant, that they are not mixed up, and that the topic linkage is clear and accurate.Risk and opportunity register; topic mapping; board or management papers used in the assessment; draft disclosure showing each item tagged to a subject area; approval trail.
We have included the dependencies that matter for understanding the risks and opportunities, so the reader can see what they rely on.The assurer will look for missing upstream or downstream dependencies, weak explanation of reliance, or a claim that cannot be traced back to the assessment.Dependency analysis; value chain mapping; workshop outputs; source data or assumptions used to identify dependencies; internal review notes confirming completeness.
We have explained where the relevant effects, risks and opportunities sit in our own activities and in the wider chain of activities around us.The assurer will test whether the locations and boundaries are clear, whether the coverage of own activities and the wider chain is consistent, and whether any exclusions are justified.Boundary-setting memo; operational and value chain maps; site or business-unit listings; scoping decisions; evidence showing how locations were assigned to each item.

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, wrong desk
Sending the request to a policy lead or report writer instead of the team that actually holds the underlying records means the data comes back second-hand and incomplete.
Framework words, not business terms
Asking people to answer in ESRS language rather than the organisation’s own operational labels leads to mismatched extracts and confusion over what to pull.
No clear boundary
Failing to state which entities, sites, activities or value-chain links are in scope causes teams to mix in data from outside the intended population.
＋ Show 6 more

Where judgement is often needed

Boundary shifts after buying or selling a business
Set the reporting perimeter using the group structure in place for the period, explain any step-up or step-out from acquisitions or disposals, and make clear whether the figures include only the time the business was under your control.
Different local meanings for the same issue
Where countries use different legal or operational definitions, choose one consistent basis for the group, state the rule you applied, and note any local exceptions that affect the picture.
People or sites close to the inclusion line
Decide in advance how you will treat cases that sit just inside or just outside the scope, apply that rule consistently, and disclose the threshold or practical test used.
＋ Show 5 more
Examples

Illustrative examples

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

Illustrative (synthetic) example — Food processing

We explain that our material matters include water stress in our own sites and in upstream farming, labour conditions in the supply chain, and product safety in use; we also note a possible upside from lower-emission packaging and energy efficiency. We have not concluded that climate is immaterial, because climate-related effects are already part of our current impacts, exposures and transition plans. - Since the last reporting cycle, we have seen a rise in supplier audit findings, a wider spread of heat-related downtime at two plants, and a larger set of efficiency projects that could improve margins. - The matters covered by our reporting package are the environmental, social and governance topics in the core report, with the detailed location given in the sustainability statement; we have used cross-references for the labour and water sections, and not for the climate note. - For the areas we flag as more exposed, the main operating types are fresh-produce intake, cold storage and primary processing, with the highest exposure in Spain, Morocco and southern Italy.

Synthetic example for training only; figures and locations are illustrative and internally consistent.

Illustrative (synthetic) example — Specialty chemicals

Our material topics include process safety, air emissions, and worker exposure in our own plants, plus transport and contractor controls in the wider chain; we also identify a commercial upside from low-carbon product lines. We do not treat climate as immaterial, because weather disruption, energy-price swings and customer demand shifts already affect our operations and plans. - Compared with the prior year, we recorded fewer lost-time incidents, more near-miss reports, and a larger share of sales from lower-carbon products. - The supplementary topics we report alongside the main statement are the health-and-safety, emissions and supply-chain sections, with the exact signposting shown in the report index; we use reference links for the safety and emissions sections, but not for the climate discussion. - The higher-risk operating types are batch blending, bulk storage and road distribution, and the main exposed geographies are the Gulf Coast of the United States, northern Germany and the Netherlands.

Synthetic example for training only; figures and locations are illustrative and internally consistent.

Company reportsReal published reports
Compare side by side →Get it free

How companies report IRO-2 in practice

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

Assicurazioni Generali S.p.A.
Banks / Diverse Financials / Insurance · Italy · 2024
Open report →
Assicurazioni Generali S.p.A.'s 2024 Annual Integrated Report partially addresses disclosure IRO 2.37, with a reported value found for IRO 2.37 e.1 on page 105 and supporting context related to material impacts, risks, and opportunities on page 104. However, the report does not clearly disclose datapoints IRO 2.37 a.1 and a.2, providing only related context or partial information without headline values (p.104). Several other datapoints, including IRO 2.37 a.3, a.4, b.1, c.1-c.3, d.1-d.3, and f.1-f.2, are not found or clearly addressed in the report.
DHL Group
Air Freight Transportation and Logistics · Germany · 2025
Open report →
DHL Group’s 2025 Annual Report includes references to material impacts, risks, and opportunities linked to their sustainability policies and actions, notably on pages 72, 97, 124, and 127, indicating some contextual coverage of these topics. However, the report does not provide clear or specific disclosures for most detailed datapoints under IRO 2.37, with many elements not found or only unclearly addressed. This suggests that while the company acknowledges material sustainability factors broadly, detailed or explicit reporting on individual required datapoints is largely missing or unclear.
Intesa Sanpaolo S.p.A.
Banks / Diverse Financials / Insurance · Italy · 2024
Open report →
Intesa Sanpaolo S.p.A.'s 2024 Annual Report includes a reference to a materiality assessment of impacts, risks, and opportunities related to consumers and end-users under ESRS S4, noted on page 269, though it does not provide a clear or detailed disclosure of the specific datapoint IRO 2.37 a.1. Other datapoints related to this disclosure are not found or clearly addressed in the report. The report also mentions materiality assessments for workers in the value chain, affected communities, resource use, and climate-related impacts, but these do not clarify the missing specific datapoints for this disclosure.
✓ LRA AI Assistant · Human-in-the-loop
Dr Ross Kurinko
Ask Study Studio AI assistant about this disclosure
Get practical answers for your reporting context. Your first two answers are free — join LRA Community for free to continue without a limit.
TryHow do I prepare IRO-2?What data do I need to collect?Where can I see a real-report example?What mistakes should I avoid?
2 free answers
Check your understanding

Scenarios to work through

A preparer has mapped the year-end sustainability statement and finds that one topic standard is covered only through a short note in a separate report, while another topic is described in the main statement with a cross-reference to a detailed annex. The team is unsure whether the reader can tell where each topic sits and whether any topic has been left out.

QHow should the preparer present the list of topic-level disclosures and their locations so the statement is clear about what is included and where it appears?
Reveal model answer →

During drafting, the climate team concludes that climate is not a material topic for the period, but the evidence file only says 'low exposure' and does not explain the judgement path. The sustainability lead asks whether that brief note is enough to support the conclusion.

QWhat level of explanation should the preparer provide when climate is judged not material?
Reveal model answer →

A business unit reports that a new supplier region has increased labour and water-related exposure in the supply chain, while a separate product line has created a fresh growth path in a low-carbon market. The reporting team is deciding whether these are simply current-year updates or whether they belong in the section that tracks shifts in the undertaking’s material matters.

QWhich kinds of year-on-year movements should the preparer describe in the statement?
Reveal model answer →

The reporting pack includes a table showing which topic standards are covered, but the team is unsure whether it also needs to say which extra disclosures were added because they were needed to explain the business properly. In one case, the extra material comes from a risk area in a high-exposure country and from a plant type with elevated operational risk.

QWhat should the preparer include when the statement goes beyond the standard topic disclosures?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

ESRS
IRO-2
within ESRS 2: General Disclosures
Open official source →
Primary
Related & explore
Go deeper · IRO-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.

FAQ

Questions this page answers

IRO-2 (ESRS 2) disclosure: what should I use the plain-language explainer for when drafting this page?+
What data points do I need to gather for IRO-2 (ESRS 2) before I can draft the disclosure?+
How do I use the step-by-step 'how to prepare' section for IRO-2 (ESRS 2)?+
Who should own the IRO-2 (ESRS 2) inputs in practice, and how should I assign responsibilities?+
What should I include in the evidence pack for IRO-2 (ESRS 2) to make it assurance-ready?+
What are the six assurance claims I need to verify for IRO-2 (ESRS 2)?+
What are the common reporting gaps or mistakes on IRO-2 (ESRS 2), and how do I avoid them?+
How do I use the synthetic illustrative example disclosures for IRO-2 (ESRS 2) without copying them into my report?+
What is the best way to use the draft-output section for IRO-2 (ESRS 2) to turn data into a report-ready draft?+
How do I use the Prep & Assurance workbook and printable Library Card for IRO-2 (ESRS 2)?+
Where can I find real company report examples for IRO-2 (ESRS 2) on the page?+
More questions this page can help with
IRO-2 (ESRS 2) checklist: what should I gather before drafting the disclosure?How do I build an evidence pack for IRO-2 (ESRS 2) that is ready for assurance review?What should go into the cross-reference table for IRO-2 (ESRS 2)?How do I decide whether to mark something as not material in IRO-2 (ESRS 2)?What does 'linked by reference' mean on the IRO-2 (ESRS 2) page in practice?How should I capture changes in impacts, risks and opportunities for IRO-2 (ESRS 2)?What are the high-risk operations and high-risk locations datapoints for IRO-2 (ESRS 2)?How do I use the narrative starters on the IRO-2 (ESRS 2) draft-output section?What is the report location field used for in IRO-2 (ESRS 2)?How do I avoid common mistakes when preparing IRO-2 (ESRS 2)?Can I use the synthetic example table on IRO-2 (ESRS 2) to structure my own quantitative disclosure?What should an HR or data owner provide for IRO-2 (ESRS 2) preparation?
How this library is built 312 published reports indexed 63171 pages with page-level citations 272 practitioner guides