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ESRS G1: Business Conduct·Disclosure Requirement G1-5
Political Influence & Lobbying
Practical guidance for preparing this disclosure. Use this card to identify the information to prepare, verify claims and organise supporting evidence. For exact requirements, always refer to the official European Commission source.
Published passport
Review pending
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Under review
Editorial review in progress
Prepared from official source material and published report evidence. No named approver is recorded yet, so this page carries no byline.
Use it alongside the official European Commission source while that review is in progress.
Standard
ESRS G1: Business Conduct
Disclosure Requirement G1-5 · 2026-5010-final
Last reviewed
—
LRA educational guidance · Not issued or endorsed by European Commission
To prepare this disclosure
Disclosure focus
This disclosure asks an organisation to explain how it manages political influence and lobbying in practice. In plain terms, it is about whether the organisation has a clear approach to engaging with policymakers, trade bodies, and other political actors, and whether that approach is applied consistently rather than only in a few visible locations or through a single team.
The practical focus is on the organisation’s full footprint: the policies, controls, oversight, and reporting that cover lobbying and political engagement across the business, not just flagship sites or headquarters. It should be clear who is responsible, what activities are covered, and how the organisation makes sure its approach is followed wherever such engagement happens.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official European Commission source.
Before you start
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key information to prepare
| Preparation field | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Total contributions | The full amount contributed in the reporting period, using one consistent currency and the same cut-off as the rest of the report. | Finance ledger, payment schedules, donation records, and period-end reconciliation to the general ledger. | Finance / Treasury |
| Contributions by country | A country split of the contributions total, with each amount assigned to the correct jurisdiction on a consistent basis. | Grant or donation register with country coding, payment records, and a reconciliation back to the total contributions figure. | Finance / Sustainability reporting |
| Beneficiary type split | A breakdown of recipients by the kind of beneficiary they are, using the organisation’s agreed categories and covering the full population. | Beneficiary master list, programme records, and category definitions approved for reporting. | Sustainability / Community investment |
| Material topics | The subjects identified as relevant for the report, stated in plain language and aligned to the organisation’s current assessment. | Materiality assessment, stakeholder input summary, and the approved reporting topic list. | Sustainability / ESG reporting |
| Governance positions | The roles held by the people in scope, described by their actual position titles rather than generic labels. | Board or committee roster, appointment letters, and governance structure chart. | Company Secretariat / Governance |
| IRO linkage | A clear explanation of how each item connects to the organisation’s identified impacts, risks or opportunities, using the same mapping used in the assessment. | IRO register, assessment matrix, and cross-reference table used for report drafting. | Sustainability / Risk |
| Named individuals | The specific people identified for this disclosure, with names recorded exactly as held in the approved source list. | Approved personnel list, governance records, or nomination papers used for the disclosure. | Company Secretariat / HR |
| Prior roles | The roles those individuals held before their current position, using the same job history source and the same definition of prior role for all entries. | CVs, appointment files, HR history records, and board papers. | HR / Company Secretariat |
| Relevant period | The time window over which the disclosure applies, stated clearly so readers can see when the identified roles or events occurred. | Reporting timetable, appointment dates, and the cut-off date used for the disclosure. | Company Secretariat / Reporting |
＋ Show G1-5 sub-elements (LRA working checklist)
Break down the total amount of contributions by each country involved.
Show the full contribution amount for each country.
Classify the recipients by beneficiary type.
Explain how the engagement links to the organisation’s material impacts, risks and opportunities.
State the roles held by the people involved.
Set out the subject areas covered.
Name the individuals identified.
Describe the roles they held before.
Give the relevant time period.
How to prepare it
Set the reporting boundary first, then decide which contribution items fall inside it. Make sure you can separate the total amount from the country breakdown and the beneficiary category for each item you include.
Agree the classification rules before you start collecting data. Use the same internal definitions for the subject matter covered, the role held by the people involved, and how each item connects to the relevant impacts or risks.
Gather support for every reported item from source records. Keep the evidence needed to show the total figure, the country split, the beneficiary type, the topic, the position, the link to the related impacts or risks, the named individuals, their earlier roles, and the relevant time period.
Compile the disclosure in a way that matches the required fields. Present the numeric total and the related narrative details clearly, and make sure the wording is consistent across the full set of entries.
Record anything you have left out or adjusted, and explain why. If you have changed a classification, a grouping, or a time reference, note that change so the reader can understand the basis used.
Check the final draft against the official source before sign-off. Confirm that every required item is covered, the figures and descriptions align with the underlying records, and no required detail has been missed or misstated.
Request the data
Request the political contributions and lobbying register
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What payments, support, or advocacy activity did we record in the period, who or what did they relate to, and how do they connect to our material sustainability issues?
Use your organisation’s own terms first, then map them to the reporting fields. For example, if you track this through a gifts and hospitality log, public affairs tracker, government relations register, or policy engagement file, ask for that source rather than using framework labels in the first message.
Weak request
Please provide the ESRS G1-5 political influence and lobbying data, including all contributions, beneficiaries, topics, positions, IRO links, and individuals with previous roles.
Why it fails: It uses framework language that many teams do not track day to day, so the owner may not know which register, codes, or records to search. It also bundles several concepts without saying what source to pull, what period to cover, or how to identify the items in the organisation’s own records.
Better request
Please send the extract from your public affairs / legal register for [reporting period] covering any payments, support, memberships, sponsorships, or policy engagement activity in [boundary]. Include the amount or value, country, recipient type, topic, position taken, link to our material issues, named individuals, any prior public office/advisory/regulator roles, and the source reference for each line.
Formal email template
Subject: Request for political support and policy engagement data for [reporting period] Hi [name/team], We are preparing the sustainability report and need a clean extract from your [source record/system] covering [reporting period] for the [group / entity boundary]. Please share the entries for any payments, support, memberships, sponsorships, or policy engagement activity that were recorded in the period, together with the details below: - amount or value - country or jurisdiction - recipient or beneficiary type - policy topic or issue area - position taken or ask made - link to our material issues, if recorded - names of any individuals involved - any previous public office, advisory, or regulator roles held by those individuals - the date or timeframe of the activity - the source reference or system ID If the data sits in more than one place, please include the relevant extracts and note which field comes from which source. A possible LRA training template is attached; please adapt this to your organisation’s own terms and check the official source before sign-off. Many thanks, [preparer name] [team] [contact details]
Short Teams / Slack version
Hi [name] — could you send the [reporting period] extract from [source record/system] for any political support or policy engagement items in scope for [group/entity boundary]? Please include amount/value, country, recipient type, topic, position taken, link to our material issues, named individuals, any prior public office/advisory/regulator roles, dates, and source ID. Please use your own internal labels and I’ll map them for reporting. Thanks.
Industry examples
Manufacturing
Context. The company tracks trade association fees, local planning engagement, and policy submissions through a government relations log and finance coding.
Adapted request. Please send the [reporting period] extract from the government relations log and finance codes for any trade association fees, sponsorships, policy submissions, or other public affairs items in [boundary]. Include amount/value, country, recipient type, topic, position taken, link to our material issues, named individuals, any prior public office/advisory/regulator roles, and the source ID.
Example response. The owner returns a table with 14 lines: 6 trade association fees, 3 sponsorships, 4 policy submissions, and 1 meeting series. Each line includes value, country, recipient type, topic, position, material issue link, named individual, prior role, and source reference.
Financial services
Context. The firm records political donations, industry body memberships, and policy advocacy in a legal and external affairs register.
Adapted request. Please provide the [reporting period] extract from the legal and external affairs register for any donations, memberships, or policy advocacy activity in [boundary]. Include amount/value, jurisdiction, beneficiary type, topic, position taken, link to our material issues, named individuals, any prior public office/advisory/regulator roles, and the record reference.
Example response. The owner returns 5 records: 2 membership fees, 1 event sponsorship, and 2 policy submissions. The extract shows the jurisdiction, recipient category, policy topic, stance taken, named participants, prior roles, and the register reference for each item.
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 how the figures were compiled, including what counts as a contribution, how recipient types and countries were grouped, how topics and positions were matched to the related impacts, risks or opportunities, and how individuals were identified and the period used for that review.
Context note
Set out what the numbers indicate in practice: where support was directed, which recipient groups received it, what issues were covered, how the organisation responded on those issues, and how the individual-screening process was framed.
Fluctuation statement
If any figures changed materially, note whether the movement came from a shift in geography, a change in recipient mix, a different set of topics or positions, or a wider or narrower review period for identifying individuals.
Content index entry
G1-5 Political Influence & Lobbying — [location / page] / [notes]Download Centre
Preparation tools & forms
Professional preparation tools for G1-5 — 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.
Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| We checked that the named people were in post during the year and that any earlier public-sector roles we mentioned were recent enough to be relevant, with the comparison basis recorded in our working papers. | An assurer may test whether the roles were actually comparable, whether the dates support the ‘recent’ link, and whether the selection of appointees was complete and unbiased. | Board appointment records; CVs or biographies; HR or company secretariat files; a documented comparison note explaining why each prior public role was treated as relevant; approval papers for the final list. |
| We compiled the money figure from the underlying records for both cash and non-cash support, then reconciled the total to the source schedules before sign-off. | An assurer may probe whether all relevant items were captured, whether indirect support was included consistently, and whether the total ties back to the source data without omissions or double counting. | General ledger extracts; payment approvals; donation registers; in-kind valuation support; consolidation workbook; reconciliation to the reported total; management review evidence. |
| We split the reported amount by location using the country or region attached to each item in the source records, and we kept a mapping file showing how each entry was assigned. | An assurer may check whether the geographic split is based on a consistent rule, whether any items were allocated to the wrong place, and whether the subtotals add up to the overall figure. | Transaction-level listing with location fields; allocation rules; mapping spreadsheet; country/region subtotal reconciliation; exception log for any ambiguous cases. |
| We identified the recipient category from the supporting documentation for each item and used a consistent classification rule across the period. | An assurer may question whether the beneficiary type was described accurately, whether the same type was used consistently for similar items, and whether any mixed or unclear recipients were handled appropriately. | Recipient records; invoices or grant letters; classification guidance; review notes for borderline cases; sample trace from source document to reported category. |
| We prepared the narrative on public-policy engagement from the internal issue tracker and position papers, then checked that the topics we highlighted were the main ones for the period and linked them to the business issues we had already identified as important. | An assurer may test whether the selected topics were truly the main ones, whether the stated positions match the underlying advocacy material, and whether the link to the company’s important risks and opportunities is supported rather than asserted. | Policy tracker; lobbying or advocacy logs; position papers; issue prioritisation memo; materiality assessment or risk register cross-reference; review and approval trail. |
| We cross-checked the draft wording against the underlying advocacy records to make sure the positions were described consistently and that no significant topic was left out of the final summary. | An assurer may look for completeness, consistency between the narrative and source records, and evidence that the draft was reviewed by the people responsible for the advocacy activity. | Draft-to-source comparison mark-up; sign-off emails from policy leads; completeness checklist; meeting minutes showing review of the final wording. |
Evidence pack to prepare
Common reporting gaps
Figures are stated without the supporting narrative, or narrative without figures.
Scope is inconsistent between the text and the numbers.
The reporting boundary is left undefined.
Material changes since the previous period are not disclosed.
Estimates and measured values are not distinguished.
Source records for the figures are not identified.
Common gaps
Mistakes to avoid when collecting the data
Wrong ownerThe request goes to the policy team or legal team instead of the business area that actually tracks donations, memberships, and advocacy activity.
Framework language usedPeople ask for data using disclosure labels rather than the organisation’s own terms, so the source team cannot map the request to its records.
Scope not fixedThe team starts collecting figures without first agreeing which entities, activities, and locations sit inside the reporting boundary.
Wrong period basisThe data pull uses a different cut-off or timing rule from the reporting period, so the numbers do not line up with the rest of the pack.
Mixed counting basisAmounts, counts, and narrative fields are gathered on different bases and then merged, which makes the final dataset internally inconsistent.
Source labels lostOriginal file names, field names, or system codes are stripped out during consolidation, so the team can no longer trace each figure back to its source.
Populations mergedSeparate groups such as direct payments, in-kind support, and other political activity are combined into one bucket even though they need to stay distinct.
Evidence trail missingThe pack is assembled without retaining the underlying extracts, notes, and approval record, leaving no clear audit trail for review.
Where judgement is often needed
Set the group boundary for donations and lobbying spend after deals closeUse the reporting perimeter you have chosen for the rest of the report, then explain whether newly bought or sold entities are included for the full year or only from the date control changed.
Translate local political-payment labels into one group-wide categoryWhere countries use different legal or accounting labels, map them to a single internal definition for this disclosure and say which local items were grouped together or left out.
Decide whether indirect support counts as a contributionMake a clear call on items such as trade body fees, event sponsorships, in-kind support or third-party payments, and disclose the rule used to include or exclude them.
Choose the country basis for cross-border paymentsIf a payment touches more than one place, state whether you classify it by the payer’s location, the recipient’s location, the place of use, or another internal rule, and apply that rule consistently.
Separate named recipients from broad recipient groupsWhen naming the beneficiary would create a privacy or safety issue, aggregate the information at a higher level and explain the level used, while keeping the totals and country split intact.
Link policy positions to the issues they were meant to influenceFor each topic and position, describe the practical issue addressed and the related business concern, and explain any judgement used where the link to the wider risk or opportunity picture is indirect.
Identify the people covered by the lobbying registerState whether the list covers only staff formally assigned to public-policy work or also others who speak with officials as part of their role, and explain how you treated borderline cases.
Use a consistent cut-off date for the year’s lobbying activityPick one reporting date for the period covered, then disclose whether the list reflects activity up to year-end, a rolling register, or another cut-off, especially where records are updated after the period closes.
Decide how to handle estimates and rounding in the totalsIf some amounts are estimated or rounded, say which figures are measured and which are approximations, and make sure the country and beneficiary breakdowns still reconcile to the total within your chosen rounding approach.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Consumer goods
During the year, we made external payments of **€1.8 million** in total, split across **€1.1 million in Country A** and **€0.7 million in Country B**. By recipient type, **€1.2 million** went to public bodies, **€0.4 million** to trade associations, and **€0.2 million** to community organisations.
- For the policy area covered, the payments related to product safety, packaging regulation, and responsible sourcing.
- The people involved in approving or overseeing these payments were two executive directors, one finance lead, and one compliance manager; the finance lead had previously worked in public affairs, and the compliance manager had previously worked in regulatory affairs.
- The review period for these disclosures was the 12 months ended 31 December 2025, and the figures above are internally consistent and illustrative only.
This synthetic example shows how a company might describe total external payments, split them by geography and recipient type, and then explain the policy topics, the roles of the people involved, and any relevant prior roles and time period.
Illustrative (synthetic) example — Industrial equipment
We recorded **£920,000** of external payments in the reporting year, with **£552,000 in Country C** and **£368,000 in Country D**. Of that total, **£460,000** was paid to government agencies, **£276,000** to industry bodies, and **£184,000** to local charities.
- The matters linked to these payments were workplace safety, emissions controls, and supply-chain due diligence.
- The individuals who handled approval or oversight were one board member, two senior managers, and one legal counsel; the board member had previously served in government relations, and one senior manager had previously worked in procurement.
- These disclosures cover the 2025 financial year and are presented as a fully synthetic, internally consistent example.
This synthetic example shows a different reporter using the same disclosure logic: total external payments, country split, recipient categories, the topics connected to the payments, the relevant roles, and any earlier roles held by those people.
Company reports
How companies report G1-5 in practice
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
Iberdrola, S.A.
Electric Utilities / IPP / Energy Traders · Spain · 2025
Iberdrola's 2025 Sustainability Report provides a specific numeric value for its total contribution to the community, amounting to EUR 62.7 million as stated on page 107. There is partial narrative context on page 111 regarding the types of customers covered, indicating inclusivity across sectors and people, but no headline value is given. Notably, no other narrative items relevant to this disclosure are found elsewhere in the report.
EDP, S.A.
Electric Utilities / IPP / Energy Traders · Portugal · 2025
EDP, S.A.'s 2025 Integrated Annual Report states that the company makes no direct political contributions to political parties, candidates, or campaigns (p.195). The report also mentions lobbying expenses and membership fees to lobbying associations, but the disclosure of these figures and related topics is unclear (p.195). There is no quotable evidence found regarding numeric values or detailed narrative items on political contributions or lobbying beyond this, indicating limited transparency on these aspects.
Amadeus IT Group, S.A.
Hotels, Restaurants, Leisure, Tourism Services · Spain · 2025
Amadeus IT Group, S.A.'s 2025 Non-Financial Report provides some related context on political influence and lobbying activities (p.205) and mentions contributions to charities and non-governmental organizations (p.215), but these references do not constitute clear or detailed disclosures. The report also includes financial figures and operational data across various geographical areas (pp.26, 62, 166, 167), though these are not explicitly linked to the disclosure in question. Notably, no direct or numeric evidence specifically addressing the disclosure was found in the report.
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Scenarios to work through
Your group paid a trade association fee of 120,000 in one country and 30,000 in another. The finance team can see the payments, but the sustainability draft only mentions the total.
QHow should you present these amounts so the disclosure is usable for review?
Reveal model answer →Hide answer ↑
Break the figure down so readers can see the overall amount and how it sits by country, rather than leaving it as one combined sum. If the payment went to different kinds of recipient, also identify the type of recipient for each relevant amount. A possible LRA training template would be: 'Adapt this to your organisation and check the source records before sign-off.'
Why this matters · Keep the spending split clear enough for a reader to understand where the money went and who received it.
The public affairs team says the company supported a policy paper on carbon pricing and also joined a submission on labour rules. They want the report to say only that the company 'engaged on public policy'.
QWhat level of detail should you capture about the subjects covered and the company’s stance?
Reveal model answer →Hide answer ↑
Describe the subject areas in plain language and explain the position the company took on each one, not just that it took part in policy discussions. If the work was connected to a material risk or opportunity, make that link clear as well. A possible LRA training template would be: 'Adapt this to your organisation and check the source material before sign-off.'
Why this matters · Readers need to see both the policy subjects and the company’s actual line on them, plus any link to material impacts, risks or opportunities.
A director sits on the board of a sector body that lobbies on energy policy. The draft report names the director but does not say whether the person is there in a personal capacity or because of their company role, and it gives no time period.
QWhat should you confirm before finalising the description of that person’s involvement?
Reveal model answer →Hide answer ↑
State who the person is, note any earlier role that helps explain the appointment, and give the period during which they held that position. Keep the description tied to the company’s lobbying-related activity, not just the individual’s biography. A possible LRA training template would be: 'Adapt this to your organisation and check the source records before sign-off.'
Why this matters · When naming people involved in advocacy work, include enough context for the reader to understand who they are, why they are there, and when they served.
The legal team has a list of three senior staff who represented the company in policy meetings during the year. One joined from government six months before the reporting date, another moved from a regulator two years ago, and the third has no prior public-sector role.
QHow should you decide what to disclose about these individuals?
Reveal model answer →Hide answer ↑
Identify the people involved, then explain any previous public roles that are relevant to understanding their current lobbying-related work, and state the relevant time window for that information. Do not add unrelated career history. A possible LRA training template would be: 'Adapt this to your organisation and check the source file before sign-off.'
Why this matters · Disclose the people involved in advocacy work with the background and timing needed to make their role understandable.
Framework references
Relevant ESRS requirements and related disclosures
Available framework references and nearby disclosures relevant to preparing this requirement.
ESRS
G1-5
within ESRS G1: Business Conduct
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FAQ
Questions this page answers
For G1-5, what data do I need to gather before I start drafting the disclosure?+−
The page says to prepare a defined set of datapoints: total contributions, contributions by country, beneficiary type split, material topics, governance positions, IRO linkage, named individuals, prior roles and the relevant period. Use the step-by-step preparation section to turn that list into a working data request.
How do I set the scope and relevant period for a G1-5 disclosure using this page?+−
Use the page’s preparation section to confirm the reporting period and then keep the data aligned to that period across all datapoints. The page also flags relevant period as a specific datapoint to capture, so it should be set before drafting the narrative.
Who should own the G1-5 data collection in practice?+−
The page is designed for ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can source the underlying records and explain them. The workbook is intended to help assign and track those responsibilities.
What should I include in the evidence pack for G1-5 assurance readiness?+−
The page says there is an evidence pack with five items to support assurance readiness. Use it alongside the six assurance claims to make sure each claim has a clear claim, risk and evidence trail.
What are the six assurance claims I need to verify for G1-5?+−
The page says there are six assurance claims to check, each with a claim, risk and evidence angle. It does not list them in the summary here, so use the page’s assurance section and evidence pack to work through them systematically.
What are the most common mistakes people make when reporting G1-5?+−
The page includes a list of common reporting gaps and mistakes to help you avoid weak or incomplete disclosures. In practice, use that list as a pre-submission check against your draft and evidence pack.
How do I use the G1-5 workbook download to prepare the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the required datapoints, track ownership and evidence, and move from raw inputs to a draft disclosure.
What is the printable Library Card for G1-5 and when should I use it?+−
The Download Centre also includes a printable Library Card in .pdf format. It is there as a quick reference while you prepare the disclosure, check the required datapoints and review the assurance steps.
How do I turn the G1-5 data into a draft disclosure?+−
The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. Use those prompts to convert the prepared data into a clear first draft rather than starting from a blank page.
Can I use the synthetic example disclosure on G1-5 as a template for my own report?+−
Yes, as a worked illustration only. The page says the example is synthetic, so use it to understand structure and presentation, then replace it with your own internally consistent data.
More questions this page can help with
G1-5 ESRS Business Conduct practical checklist for ESG managersWhat datapoints are needed for a G1-5 business conduct disclosure?How do I collect contributions by country for G1-5?How should beneficiary type split be prepared for G1-5?How do I document governance positions and prior roles for G1-5?What is IRO linkage in the G1-5 disclosure page?How do I build an evidence pack for G1-5 assurance?What should be in a G1-5 assurance-ready file pack?How do I avoid common G1-5 reporting gaps?How do I use the Prep & Assurance workbook for G1-5?What does the G1-5 printable Library Card help with?Where can I find real company report examples for G1-5 topics?
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