Disclosure focus
The practical question is whether the target applies across the whole organisation or only to selected parts of it, such as particular countries, business units or flagship sites. It should be possible to understand the scope, the time horizon, and how the organisation knows whether it is on track, so readers can judge how embedded the target is in day-to-day management.
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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Target values
Strategy / sustainabilityRecord the numeric goal or end-state the organisation says it is aiming for, including the measure used and the intended level to be reached.
Evidence Approved target sheet, strategy paper, KPI dashboard, or board paper showing the stated goal and metric.
Watch for Target value does not reconcile to the approved KPI or board paper, so the reported figure uses a different measure or unit.
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Target coverage
Strategy / sustainabilityState exactly which part of the business, activity, geography, or portfolio the target applies to, and note any exclusions or partial coverage.
Evidence Target methodology note, scope statement, or internal memo defining the covered entities, sites, or operations.
Watch for Scope is mixed up with the wider group, so the target is reported for the wrong entity set or a missed sub-population.
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Starting point
Finance / sustainability reportingCapture the reference starting figure used to set the target, including the date or period it comes from and the metric definition behind it.
Evidence Baseline calculation file, prior-period report, or source-system extract used to establish the starting value.
Watch for Baseline and current-period figures are mixed, or the starting point does not reconcile to the source system used to set the target.
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Delivery date
Strategy / programme managementRecord the planned date or period by which the target is meant to be achieved, including any milestone years if the plan uses them.
Evidence Roadmap, target tracker, or approved plan showing the due year or milestone schedule.
Watch for Timeline is captured as a different period than the approved plan, so the due date or milestone year is misstated.
Before you start
- Have you pinned down exactly which parts of the business, activities, or locations this target covers, and which are left out?
- Is the starting point for the target fixed to one clearly identified year or period, so everyone is using the same reference point?
- Have you agreed the date or period by which progress will be judged, and is that timing written down in a way you can trace?
- Can you link the target figure back to a source record, model, or approved internal document without relying on memory or informal notes?
- Have you checked which internal definitions and measurement rules are being used, so the target is built on the same basis throughout?
How to prepare it
Request the data
Request the target register and supporting evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What targets has the organisation set, what do they cover, what starting point were they measured from, and by when are they meant to be reached?
Use your organisation’s own wording first, then map it to the reporting disclosure. Ask for the target register, board or committee papers, and any source files that show how the target wording, coverage, starting point and end date were agreed. Keep the request in business terms the team already uses, then translate it for reporting review.
Weak request
Please send the ESRS G1 targets, including scope, baseline and timeline.
Why it fails: This uses framework language only, so the owner may not know which internal records to pull. It also does not ask for the approval trail or the organisation’s own wording, which are needed to trace the target back to source documents.
Better request
Please send the current target register and the papers that show how each target was agreed. For each target, include the business wording, what it covers, the starting point used, and the date or milestone it is meant to reach, plus the document link or approval reference.
Formal email template
Subject: Request for target details and supporting documents Hello [name/team], We are preparing the sustainability reporting pack and need your help with the organisation’s target information for [reporting period]. Please send the current target register, plus any supporting papers or files that show: - the target wording in your own business terms - what parts of the business or activity it covers - the starting point used for comparison - the date or milestone by which it is meant to be reached - where the target was approved or agreed If there are several targets, please include each one separately and note any internal reference numbers or document links. A possible LRA training template is attached below for adaptation to your organisation. Please check the official source before sign-off. Many thanks, [preparer name]
Short Teams / Slack version
Hi [name] — could you share the target register and any supporting papers for [reporting period]? We need the target wording, what it covers, the starting point, the timing, and where it was agreed. Please use your team’s own terms and include any document links or reference numbers. Thanks.
Industry examples
Manufacturing
Context. A plant-level conduct or ethics target is tracked in a compliance log and approved through a management committee paper.
Adapted request. Please share the conduct target log and the committee paper for [reporting period]. For each target, include the plant or site covered, the starting point used, the milestone date, and the approval reference.
Example response. Target ID: CT-01; Target name: Supplier code rollout; Coverage / scope: All direct suppliers for three plants; Baseline year or starting point: 2025 supplier onboarding status; Baseline description: 42% of suppliers had signed the code; Target date / milestone: 31 Dec 2027; Status: In progress; Approval reference: Ops Committee 14/03/2026; Evidence link: SharePoint/Compliance/CT-01
Financial services
Context. A group-wide integrity or conduct target is maintained in a governance tracker and supported by board pack extracts.
Adapted request. Please send the governance tracker and board paper showing the current target wording, the business area it covers, the baseline used, and the planned completion date for [reporting period].
Example response. Target ID: GOV-04; Target name: Training completion milestone; Coverage / scope: UK and EU front-office teams; Baseline year or starting point: 2026 Q1 completion rate; Baseline description: 68% completed the module; Target date / milestone: 30 Sep 2027; Status: On track; Approval reference: Board pack 22/04/2026; Evidence link: GRC system record #88421
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 how the target was set, what activities or parts of the business it covers, which starting figure was used, and the date by which the aim is meant to be reached.
Context note
Explain what the target means in practice by linking the intended level to the starting point, the covered scope, and the planned timing.
Fluctuation statement
If the target, scope, baseline, or timing has changed, describe what moved, why it changed, and whether the revision affects the overall ambition or only the way it is measured.
Content index entry
G1-3 Targets — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for G1-3 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We set out the target’s numeric or qualitative end-point, the unit we use where relevant, and whether the figure is based on an absolute amount or a proportion.
Risk An assurer will test whether the stated target basis is clear, internally consistent, and not mixed up with a different metric or unit.
Evidence to check Target-setting paper; KPI dictionary or methodology note; approved target register; board or management approval pack; working papers showing how the unit and basis were chosen and checked against the published wording.
We explained which parts of the business the target covers, including any limits we applied to our own sites, upstream or downstream activities, and the countries or regions included.
Risk An assurer will probe whether the scope was defined consistently and whether any exclusions or geographic limits were applied deliberately rather than by omission.
Evidence to check Scope memo; boundary mapping; consolidation or coverage schedule; value-chain mapping; list of included entities, activities and locations; sign-off showing the scope decision was reviewed before publication.
We stated the time frame for the target and noted any staged steps or interim checkpoints we had set along the way.
Risk An assurer will check whether the end date and any stepping-stone dates are supported by source records and whether they match the version approved for disclosure.
Evidence to check Target timeline document; milestone tracker; project plan; approval minutes; version-controlled draft of the disclosure; evidence that the published dates agree to the underlying plan.
Where we had a starting point for the target, we disclosed the opening level and the year we used as the reference point for tracking change.
Risk An assurer will test whether the baseline was selected on a sound basis, whether the base year is clearly identified, and whether the starting value ties back to source data.
Evidence to check Baseline calculation file; source data extracts for the base year; methodology note explaining the baseline choice; audit trail from source records to the disclosed figure; review evidence showing the baseline was checked before issue.
If we did not have a measurable outcome target, we explained whether we still monitored progress and, if so, how we did that.
Risk An assurer will probe whether the statement is complete, whether the monitoring approach is real and operating, and whether the disclosure avoids implying a quantified target that does not exist.
Evidence to check Monitoring framework; internal reporting pack; meeting notes showing how progress was reviewed; any qualitative indicators used; evidence of management review confirming the wording before publication.
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.
Where drafts go wrong
Mistakes to avoid and where judgement is needed
The left column is what preparers get wrong while collecting; the right column is where you will have to make and explain a judgement.
Mistakes to avoid
- Wrong ownerThe request goes to the wrong team, so the target figure is pulled from someone who does not own the business plan or the underlying performance data.
- Framework language onlyThe question is asked in ESRS-style terms instead of the organisation’s own wording, and the person answering cannot map it to the right internal metric.
- No boundary setPeople collect a target without first agreeing which business units, sites, or activities are included, so later figures are not comparable.
- Wrong time basisThe team mixes a calendar-year target with a different reporting period, so the number does not line up with the period used elsewhere in the pack.
- Mixed counting basisOne source uses headcount, another uses full-time equivalent, and the collection step merges them without noticing the basis is different.
- Source labels lostThe original file names, system tags, or table headings are stripped away, so nobody can trace where the target value came from.
- Separate groups mergedTargets for different populations are combined into one total even though they should stay separate for the disclosure pack.
- No evidence trailThe team saves the number but not the supporting notes, extracts, or approval record, so the source and sign-off cannot be checked later.
Judgement needed
- Set the target boundary when the business changes shapeIf a takeover, sale or internal reorganisation changes the group you report on, choose a clear cut-off for what sits inside the target and explain whether the target is restated or left on the old basis.
- Handle country-by-country definitions with one internal ruleWhere local laws or operating practices define the same topic differently, pick one group-wide interpretation for the target, note any exceptions, and explain how you kept the comparison fair across markets.
- Decide who is in scope at the marginsFor workers, sites, suppliers or other populations that sit near the boundary, state the inclusion rule you used, why it was chosen, and whether any borderline cases were counted or left out.
- Fix the baseline date and keep it consistentChoose the starting point for the target using one date or period, explain why that point was selected, and say if later restatements were made because the underlying population changed.
- Be clear when the starting figure is estimatedIf the opening number is not fully measured, disclose which parts were estimated, the method used, and how you will replace or update the estimate when better data becomes available.
- Use one timing basis for the target clockState whether progress is tracked against a calendar year, financial year or another period, and explain any mismatch between the target timetable and the reporting cycle.
- Round numbers without hiding the underlying basisIf figures are rounded, say the rounding approach and make sure the published totals still align with the detailed records and the target story.
- Aggregate sensitive data before disclosureWhen privacy, competition or small sample sizes prevent person-level detail, combine the data to a level that protects individuals and explain the aggregation rule and any resulting limits on precision.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We set a 2030 ambition to cut the share of our own operations that is not yet covered by a formal anti-corruption training programme from 18% in our 2024 baseline to 0% by the end of 2030.
- The starting point is our 2024 internal review of 500 employees in scope, of whom 410 had completed the programme and 90 had not.
- The target applies only to our directly employed workforce in our manufacturing and distribution sites; contractors and joint ventures are outside this measure.
This example shows a quantified end-point, the starting measurement, the group covered by the measure, and the planned completion date.
We aim to raise the proportion of our client-facing staff who have completed our anti-bribery refresher from 72% in the 2025 baseline to 100% by 2028.
- Our baseline was measured across 250 relevant employees, with 180 already trained and 70 still to complete the refresher.
- The measure covers permanent and fixed-term staff in our advisory teams only; temporary agency workers and outsourced service providers are not included.
This example shows the intended end-state, the initial measurement, the people included in the measure, and the deadline for delivery.
Quality ladder
- Basic
We have a target to cut supplier-related incidents by 20%.
- Better
We have a target to cut supplier-related incidents by 20% across our direct suppliers, measured against our 2024 starting point.
- Best
We have a target to cut supplier-related incidents by 20% across our direct suppliers, measured against our 2024 starting point and due by 2027, and the recent rise in cases is linked to a wider supplier base after a business expansion.
Check your understanding
Scenarios to work through
A group has set a 2030 target to cut supplier-related bribery incidents in its high-risk procurement category. The draft note says the target is for the whole group, but it does not say whether it covers only direct suppliers or also agents and subcontractors.
A company wants to report a target to reduce confirmed corruption cases by 40% by 2028. The team has two possible starting points: the 2024 incident count, or the average from 2022–2024, and the papers in circulation use both figures.
A preparer is drafting a target to increase ethics training completion to 95% by 2027. The target was approved for employees in the sales and procurement teams only, but the draft wording says simply that it applies to ‘staff’.
The sustainability team has a target to reduce gifts-and-hospitality breaches by 30% from a 2025 baseline. The board paper says the aim is to reach that level ‘in the medium term’, while the project tracker shows a firm end date of December 2029.
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Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
G1-3
within ESRS G1: Business Conduct
Guides that settle this question
Related & explore
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FAQ
Questions this page answers
The page says to prepare four datapoints: target values, target coverage, starting point and delivery date. Use those as the minimum input set before you draft the narrative or table.
Use it as a working checklist to move from scoping to drafting, rather than as a policy statement. It is there to help you organise the disclosure, collect the right inputs and avoid missing key fields.
The page points you to define the target values, target coverage, starting point and delivery date clearly enough for a reviewer to follow the logic. Keep the method practical and consistent with the evidence you can show in the pack.
The page is designed for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can source the data and explain it. In practice, assign one accountable owner and make sure the evidence pack supports their sign-off.
The page includes an evidence pack with five items for assurance readiness, plus five assurance claims to verify. Use those together so each reported point can be traced back to supporting documents or records.
The page says there are five claims to verify, each with a claim, risk and evidence prompt. Use them as a review list to test whether the disclosure is complete, consistent and supported before it goes to assurance.
The page lists common reporting gaps and mistakes to help you spot weak points before submission. Use that section as a pre-filing check so you can fix missing data, unclear scope or unsupported statements early.
The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. Start with the table or visual, then use the narrative starters to turn the prepared datapoints into a concise draft.
Yes, but only as an illustrative guide. The example is synthetic, so use it to understand structure and presentation, then replace every figure and statement with your own company data and evidence.
The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook to organise inputs and checks, and the PDF as a quick reference while drafting or reviewing.
It links to real published reports at the pages where the topic is disclosed, so you can see how others present similar information. Use it for practical inspiration on layout and wording, not as a substitute for your own data or methodology.
More questions this page can help with