Disclosure focus
Where a whole topical standard is omitted under paragraphs 125(a), 126(a) or 127(a), the undertaking states whether impacts, risks and opportunities related to that standard's topics were assessed as material. If one or more topics or sub-topics were assessed as material, the information required by BP-2 paragraph 9 is provided.
Where information under individual disclosure requirements is omitted under paragraphs 125(b)–(e), 126(b)–(e) or 127(b)–(e), the undertaking states that the information was omitted because the relevant phase-in provision was applied.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official European Commission source.
Prepare
What to collect before drafting
Tick each field as the evidence lands. Owners are the teams that usually hold the source files.
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Phase-in provision applied
Sustainability reporting / LegalIdentify the applicable ESRS 1 paragraph in the range 125–127.
Evidence Dated source records, governance papers and approval evidence supporting phase-in provision applied.
Watch for The published response for phase-in provision applied is incomplete or does not match the supporting records.
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Whole-standard omission
Sustainability reportingIdentify a topical standard omitted under paragraph 125(a), 126(a) or 127(a), where applicable.
Evidence Dated source records, governance papers and approval evidence supporting whole-standard omission.
Watch for The published response for whole-standard omission is incomplete or does not match the supporting records.
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Materiality assessment result
Sustainability reportingState whether impacts, risks and opportunities related to the omitted standard's topics were assessed as material.
Evidence Dated source records, governance papers and approval evidence supporting materiality assessment result.
Watch for The published response for materiality assessment result is incomplete or does not match the supporting records.
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Material topics or sub-topics
Sustainability reportingIdentify the material topics or sub-topics where one or more related impacts, risks or opportunities were assessed as material.
Evidence Dated source records, governance papers and approval evidence supporting material topics or sub-topics.
Watch for The published response for material topics or sub-topics is incomplete or does not match the supporting records.
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Business model and strategy
Sustainability reportingBriefly describe how the business model and strategy take account of impacts related to those material topics.
Evidence Dated source records, governance papers and approval evidence supporting business model and strategy.
Watch for The published response for business model and strategy is incomplete or does not match the supporting records.
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Targets and progress
Sustainability reportingDescribe time-bound targets related to the material topics and progress towards them, where required.
Evidence Dated source records, governance papers and approval evidence supporting targets and progress.
Watch for The published response for targets and progress is incomplete or does not match the supporting records.
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Policies and actions
Sustainability reportingDescribe policies and actions addressing the material topics, where required.
Evidence Dated source records, governance papers and approval evidence supporting policies and actions.
Watch for The published response for policies and actions is incomplete or does not match the supporting records.
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Metrics
Sustainability reportingReport the metrics required by BP-2 for the material topics, where applicable.
Evidence Dated source records, governance papers and approval evidence supporting metrics.
Watch for The published response for metrics is incomplete or does not match the supporting records.
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Other phased-in information omitted
Sustainability reportingFor provisions in paragraphs 125(b)–(e), 126(b)–(e) or 127(b)–(e), identify the information omitted as a result.
Evidence Dated source records, governance papers and approval evidence supporting other phased-in information omitted.
Watch for The published response for other phased-in information omitted is incomplete or does not match the supporting records.
Before you start
- Limit BP-2 to omissions caused by the phase-in provisions in ESRS 1 paragraphs 125–127.
- Separate whole-topical-standard omissions from omissions of information under individual disclosure requirements.
- Have the supporting records and the final response been reconciled?
How to prepare it
Request the data
Request the disclosure evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Provide the phase-in eligibility assessment, applicable ESRS 1 paragraph, materiality results for omitted topical standards and the BP-2 information required for any material topics.
Use the organisation's own role and document names, but preserve the defined ESRS terms and the scope described above.
Better request
Provide the phase-in eligibility assessment, applicable ESRS 1 paragraph, materiality results for omitted topical standards and the BP-2 information required for any material topics.
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
Verify eligibility for the specific phase-in provision before recording an omission and preserve the term material rather than relevant or priority.
Context note
If no phase-in provision in paragraphs 125–127 is used, BP-2 does not create a general omitted-disclosures schedule.
Download Centre
Preparation tools & forms
Download preparation tools for BP-2 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
Phase-in provision applied is reported accurately and completely.
Risk The response omits, misclassifies or overstates phase-in provision applied.
Evidence to check Dated source records, governance papers and approval evidence supporting phase-in provision applied.
Whole-standard omission is reported accurately and completely.
Risk The response omits, misclassifies or overstates whole-standard omission.
Evidence to check Dated source records, governance papers and approval evidence supporting whole-standard omission.
Materiality assessment result is reported accurately and completely.
Risk The response omits, misclassifies or overstates materiality assessment result.
Evidence to check Dated source records, governance papers and approval evidence supporting materiality assessment result.
Material topics or sub-topics is reported accurately and completely.
Risk The response omits, misclassifies or overstates material topics or sub-topics.
Evidence to check Dated source records, governance papers and approval evidence supporting material topics or sub-topics.
Business model and strategy is reported accurately and completely.
Risk The response omits, misclassifies or overstates business model and strategy.
Evidence to check Dated source records, governance papers and approval evidence supporting business model and strategy.
Targets and progress is reported accurately and completely.
Risk The response omits, misclassifies or overstates targets and progress.
Evidence to check Dated source records, governance papers and approval evidence supporting targets and progress.
Policies and actions is reported accurately and completely.
Risk The response omits, misclassifies or overstates policies and actions.
Evidence to check Dated source records, governance papers and approval evidence supporting policies and actions.
Metrics is reported accurately and completely.
Risk The response omits, misclassifies or overstates metrics.
Evidence to check Dated source records, governance papers and approval evidence supporting metrics.
Other phased-in information omitted is reported accurately and completely.
Risk The response omits, misclassifies or overstates other phased-in information omitted.
Evidence to check Dated source records, governance papers and approval evidence supporting other phased-in information omitted.
Evidence pack to prepare
Common reporting gaps
- Using the 2023 BP-2 title or content.
- Listing every absent disclosure requirement.
- Replacing material with relevant or priority.
- Failing to distinguish whole-standard and individual-information phase-ins.
- Using a phase-in without checking eligibility.
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Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
BP-2
within ESRS 2: General Disclosures
Guides that settle this question
Related & explore
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