Disclosure focus
This disclosure asks an organisation to explain which stakeholder groups it has considered and what their interests, concerns and views are in relation to the sustainability matters that are material to the business. In practice, the report should show that stakeholder input is not just acknowledged in general terms, but has been used to understand what matters most to different groups and how those views have informed the organisation’s assessment and reporting.
The practical focus is on breadth and relevance: the organisation should cover the stakeholder groups and parts of the business that are actually affected, rather than relying only on a few well-known or flagship sites. The aim is to show how the organisation has identified and reflected stakeholder perspectives across its operations, value chain and material topics in a way that is proportionate to its footprint and impacts.
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 SBM-2 sub-elements (LRA working checklist)
Set out the ways the organisation engages with stakeholders.
Explain how the board receives updates and information.
Describe the main interests and views raised by stakeholders.
Identify the stakeholder groups that matter most.
How to prepare it
1Set the reporting boundary first: decide which stakeholder groups you will cover, and make sure the scope is consistent across the whole response.
2Agree what counts as an engagement method, then list the ways the organisation has interacted with those groups during the period in a way that fits your internal records.
3Gather the underlying material for each group’s main concerns or views, using meeting notes, survey outputs, correspondence, or other source records that support the narrative.
4Draft the disclosure by pairing each stakeholder group with its engagement approach, the main interests or views raised, and the way the board or equivalent governing group is kept up to date.
5Record any exclusions, scope changes, or judgement calls so a reviewer can see what was left out, what changed, and why the final wording or figures are presented that way.
6Check the finished text against the official source and your evidence pack to confirm the content matches the required points and that nothing material has been missed or added.
Request the data
Request stakeholder engagement and board briefing evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What stakeholder groups did we engage, what did they tell us, and how was that fed up to the board or equivalent leadership group during the reporting period?
Use your organisation’s own labels first, then map them to the disclosure. For example, use your usual names for stakeholder groups, consultation channels, leadership packs, and board updates rather than framework terms.
Weak request
Please provide the stakeholder engagement evidence for SBM-2.
Why it fails: It uses framework language only, gives no clue which internal team should respond, and does not say what records, dates, channels, or leadership updates are needed. That makes it hard to find the right evidence and easy to return an incomplete pack.
Better request
Please send the stakeholder engagement log, consultation notes, and board or committee update pack for [reporting period], showing the groups we spoke to, how we heard from them, the main issues they raised, and where those points were summarised for [board / committee name]. Include the source file, date range, and owner for each record.
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
State which stakeholder groups were included, how they were grouped, and what counts as an engagement method, interest, or board briefing in this disclosure.
Context note
Explain what the stakeholder map shows about who the organisation listens to, how it gathers views, and how those views reach the board.
Fluctuation statement
If the mix of groups, engagement channels, or board reporting changed, note whether that reflects a shift in priorities, coverage, or the way input is escalated.
Content index entry
SBM-2 Interests and Views of Stakeholders — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for SBM-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.
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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 team asks the wrong business lead for the input, so the information comes from someone who does not run the stakeholder process or hold the source records.
Framework language first
People ask for answers in disclosure jargon instead of the organisation’s own terms, which makes the source data hard to map back to real meetings, surveys, or feedback logs.
Scope left vague
No one fixes which parts of the business, which stakeholder groups, or which activities are in scope, so the data set ends up mixing unlike populations.
Timing basis not set
The team does not agree the reporting period or cut-off point before collection starts, so some inputs relate to a different time window than others.
Counting basis mixed
One source is counted by individual people while another is counted by contacts, sessions, or responses, and the totals are then combined as if they were the same measure.
Source labels lost
Original tags from the survey, meeting note, or feedback register are stripped away, so later reviewers cannot tell where each figure or theme came from.
Separate groups merged
Inputs from different stakeholder groups are rolled together even though they should stay distinct, which hides who said what and weakens the final evidence trail.
Evidence details missing
The file set does not keep the date, owner, version, or source reference for each input, so the team cannot show how the data was assembled.
No sign-off trail
The collection pack is used without a clear review and approval record, so nobody can prove who checked the data before it moved into drafting.
Where judgement is often needed
Which stakeholder groups to include when the business footprint changes
If a purchase, sale, closure or new country changes who is affected, explain the cut-off you used for the period and whether the list of groups reflects the opening, closing or average footprint.
How to handle groups that sit just inside or just outside the reporting boundary
Where a population is partly covered, set out the rule used to include or exclude it and say how you treated people or organisations that were only indirectly affected.
Different local labels for the same type of stakeholder
When country teams use different names or legal categories for similar groups, map them to a common internal label and disclose the mapping so readers can see what was combined.
Choosing the basis for the engagement summary
If engagement happened through several channels or at different times, explain whether you summarised the latest view, the most frequent view, or a weighted view, and why that basis was chosen.
Deciding between direct feedback and management interpretation
State whether the reported interests and views come straight from stakeholder input or from management’s synthesis of that input, and describe any filtering or prioritising used.
Using estimates where full counts are not available
If you cannot measure every response or contact, say which figures are estimated, what data source or method was used, and how the estimate was checked against available records.
Rounding and small-number handling in the stakeholder summary
Explain the rounding rule used for counts or percentages and make sure the rounded figures still tell a consistent story across the groups and channels you describe.
Protecting privacy when the group is too small to show separately
Where naming a group could identify individuals, combine categories or remove detail, and disclose that the presentation has been aggregated to avoid exposing personal information.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food manufacturing
We keep the board updated through a standing pack for each meeting, plus ad hoc briefings when a material issue emerges. Our main external groups are employees, suppliers, customers, local communities, investors and regulators; we hear from them through site visits, surveys, grievance channels, supplier reviews, customer panels and community meetings. - The views we hear most often are about safe working conditions, product quality, timely payment, lower emissions, packaging reduction and clearer reporting. - In the last year, 1,240 employees took part in surveys or town halls, 86 suppliers joined review calls, 420 customers gave feedback through panels or complaints, and 18 community meetings were held; each of these feeds into the papers sent to directors and committee members before decisions are made.
Illustrative only: shows how a company can describe who it engages, how it does so, what those groups care about, and how that information reaches the board.
Illustrative (synthetic) example — Commercial property management
We use tenant forums, contractor meetings, investor calls, resident drop-ins and regulator check-ins to gather views from the groups most affected by our operations. Those groups include tenants, building users, contractors, investors, nearby residents and public authorities, and their main concerns are building safety, energy use, service quality, accessibility, rent affordability and complaint handling. - During the year, 64 tenant meetings were held, 27 contractor sessions took place, 12 investor updates were delivered, and 9 resident forums were run; the board receives a monthly summary plus escalation notes where issues need a decision. - Committee chairs also receive a short digest of recurring themes so that directors can see where expectations are changing and where management action is still needed.
Illustrative only: shows a different sector using different engagement channels while still covering the same four disclosure points.
How companies report SBM-2 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Sanoma Oyj
Education Services · Finland · 2025
Sanoma Oyj's Annual Report 2025 references SBM-2 and related standards multiple times, notably on pages 56, 67, 92, and 117, indicating some engagement with stakeholder interests and material impacts (p.56, p.67, p.92, p.117). However, no direct or quotable evidence specifically addressing SBM 2.1 through 2.4 disclosures was found in the report, and the methodology or narrative for SBM 2.2 remains unclear. Overall, while the report mentions relevant sections, it lacks explicit, detailed disclosure on the specific SBM 2 requirements.
Aena S.M.E., S.A.
Air Transportation — Airport Services · Spain · 2025
Aena S.M.E., S.A.'s 2025 Sustainability Report includes a reported value related to stakeholder engagement, noting the importance of community views, interests, and rights on page 237. The report also references a Code of Conduct for Third Parties on page 229, indicating some governance measures linked to the disclosure. However, there is no clear or quotable evidence found for specific methodology or narrative explanations (SBM 2.2), and related context on integration of sustainability performance in management bodies is unclear on page 318.
Nokian Tyres
Tires · Finland · 2025
Nokian Tyres’ Sustainability Statement 2025 includes a reported value related to SBM 2.sbm 2.3 on page 97, indicating some disclosure on the interests and views of stakeholders. The report also references material impacts, risks, and opportunities connected to SBM-2 on pages 97 and 98. However, there is no clear or quotable evidence found for SBM 2.sbm 2.1 or SBM 2.sbm 2.2, and the disclosure for SBM 2.sbm 2.4 is unclear despite related context on page 95.
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Scenarios to work through
A group of warehouse workers has raised concerns about shift patterns, while local residents near a distribution site have focused on traffic and noise. The reporting team has also heard from a lender that wants clearer climate transition information.
QWhich stakeholder groups should be described, and how do you decide which ones count as the main groups for this disclosure?
Reveal model answer →Hide answer ↑List the groups that matter most to the business’s sustainability impacts, risks and opportunities, rather than every contact the company has had. In this case, workers, nearby residents and the lender could all be relevant if their views shape the company’s understanding of material matters; the write-up should explain why these groups were selected as the main ones.
Why this matters · Focus on the stakeholder groups that are most relevant to the company’s material sustainability picture, and explain the basis for that choice.
A preparer has minutes from town-hall meetings, a supplier survey and a grievance log, but no single document that summarises all engagement activity. The board asks for a concise description of how the company has gathered stakeholder input during the year.
QHow should the engagement approach be described when the evidence comes from several channels rather than one formal process?
Reveal model answer →Hide answer ↑Describe the actual ways the company has listened and exchanged views, using the channels it really used, such as meetings, surveys, grievance handling or other direct contact. The explanation should show how those methods fit the stakeholder groups identified, without pretending there was one uniform process if there was not.
Why this matters · Set out the real engagement channels used for each relevant group, even when they are spread across different parts of the business.
During drafting, the sustainability team has a long list of comments from employees, investors and community groups. Some comments are operational requests, while others are broader concerns about safety, pay, emissions and local access to jobs.
QWhat should be included when summarising the main interests and views that stakeholders have expressed?
Reveal model answer →Hide answer ↑Select the points that are most important to understanding what those groups care about in relation to the company’s sustainability matters. The summary should capture the main themes, such as safety, pay, emissions or community access, and should not turn into a full transcript or an unfiltered list of every remark.
Why this matters · Report the main themes in stakeholder feedback, not every individual comment.
The sustainability report is being finalised, and the board pack contains a dashboard of stakeholder issues, a summary of engagement outcomes and a note on unresolved concerns. The chair wants to know how the board itself was kept up to date.
QHow should the company explain the way the board and its committees were kept informed about stakeholder interests and views?
Reveal model answer →Hide answer ↑Explain the route by which the top governance group received the information, such as regular papers, committee updates, escalation of key issues or briefing notes. The description should make clear how stakeholder input reached decision-makers and how often that happened where relevant, without overstating the level of detail if the board only received summaries.
Why this matters · Show the path from stakeholder input to the board and its committees, so readers can see how the information influenced oversight.
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 ✓Actions and Resources in Relation to Material Sustainability Matters →Metrics in Relation to Material Sustainability Matters → Guide ✓Policies Adopted to Manage Material Sustainability Matters → Guide ✓Targets in Relation to Material Sustainability Matters → Guide ✓Show all 14 related disclosures →
FAQ
Questions this page answers
How do I use the SBM-2 page to draft the disclosure from scratch?+−
Start with the plain-language explainer, then work through the step-by-step preparation section and the listed datapoints. The page also gives draft-output prompts, so you can turn the collected information into a first-pass narrative rather than starting from a blank page.
What data do I need to collect for SBM-2 before I write the disclosure?+−
The page says to prepare four datapoints: stakeholder groups, engagement approach, stakeholder concerns, and the board briefing route. Use those as your minimum data set before drafting.
How should I define the scope of stakeholder groups for SBM-2 on this page?+−
Use the page’s stakeholder-groups datapoint as the starting point and make sure the scope is clear enough to support the narrative and any evidence pack. The page does not give a fixed list, so you need to align the scope to your own reporting context and document it consistently.
What is the best way to document the stakeholder engagement approach for SBM-2?+−
Capture the approach in a way that shows how engagement was carried out and how it links to the concerns reported. The page’s preparation section and evidence pack are the main places to anchor that documentation.
Who should own the SBM-2 disclosure inputs in practice?+−
The page is useful for splitting ownership across ESG, HR, data owners and governance contacts because it names the key datapoints and the board briefing route. Assign each input to the person or team that can evidence it, then keep the ownership trail in the workbook.
What should I put in the evidence pack for SBM-2 assurance readiness?+−
The page includes an evidence pack with five items and five assurance claims to verify, so use those as the core of your file set. Build the pack around claim, risk and evidence so a reviewer can trace each statement back to support.
How do I use the five assurance claims on the SBM-2 page?+−
Treat them as a check-list for what a reviewer is likely to test: each claim should have a clear risk and supporting evidence. The page is designed to help you verify the disclosure before it goes into a draft or assurance process.
What are the common mistakes to avoid when preparing SBM-2?+−
The page lists common reporting gaps and mistakes, so use that section as a pre-submission review. It is especially helpful for spotting missing datapoints, weak evidence, or a narrative that does not line up with the underlying records.
How do I use the Prep & Assurance workbook for SBM-2?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to help you organise the preparation and assurance steps. Use it alongside the page’s datapoints, evidence pack and assurance claims to build a draft that is easier to review.
Can I use the SBM-2 page’s illustrative example to shape my own disclosure?+−
Yes, the page includes synthetic illustrative example disclosures, including a quantitative table where relevant. Use them as a formatting and drafting aid only, and make sure your own figures and narrative stay internally consistent.
How do I turn the SBM-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 the prepared data into a usable draft. Start with the narrative starters, then use the content-index line to show where the disclosure sits in your report.
More questions this page can help with
SBM-2 stakeholder groups: what should I collect before drafting?SBM-2 engagement approach: how do I write it in a way that is assurance-ready?SBM-2 stakeholder concerns: how do I capture them without overclaiming?SBM-2 board briefing route: what evidence should I keep?SBM-2 evidence pack: what are the five items and how do I organise them?SBM-2 Prep & Assurance workbook: how should a data owner use the xlsx file?SBM-2 printable Library Card PDF: when is it useful in the reporting process?SBM-2 draft output: how do I use the narrative starters and visualisation ideas?SBM-2 common reporting gaps: what should I check before sign-off?SBM-2 from company reports table: how do I use the linked examples without copying them?SBM-2 plain-language explainer: how do I use it to brief non-technical colleagues?SBM-2 assurance claims: how do I build a claim-risk-evidence matrix from the page?
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