Disclosure focus
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.
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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Total contributions
Finance / TreasuryThe full amount contributed in the reporting period, using one consistent currency and the same cut-off as the rest of the report.
Evidence Finance ledger, payment schedules, donation records, and period-end reconciliation to the general ledger.
Watch for Does not reconcile to the finance ledger or mixes payments from a different reporting period.
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Contributions by country
Finance / Sustainability reportingA country split of the contributions total, with each amount assigned to the correct jurisdiction on a consistent basis.
Evidence Grant or donation register with country coding, payment records, and a reconciliation back to the total contributions figure.
Watch for Country coding is not aligned to the source register, so amounts are allocated to the wrong jurisdiction.
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Beneficiary type split
Sustainability / Community investmentA breakdown of recipients by the kind of beneficiary they are, using the organisation’s agreed categories and covering the full population.
Evidence Beneficiary master list, programme records, and category definitions approved for reporting.
Watch for Beneficiary categories are not aligned to the reporting definitions, so similar recipients are grouped inconsistently.
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Material topics
Sustainability / ESG reportingThe subjects identified as relevant for the report, stated in plain language and aligned to the organisation’s current assessment.
Evidence Materiality assessment, stakeholder input summary, and the approved reporting topic list.
Watch for The topic list is taken from an outdated assessment and no longer matches the current materiality review.
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Governance positions
Company Secretariat / GovernanceThe roles held by the people in scope, described by their actual position titles rather than generic labels.
Evidence Board or committee roster, appointment letters, and governance structure chart.
Watch for Role titles are pulled from an old roster and do not match the current governance structure.
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IRO linkage
Sustainability / RiskA clear explanation of how each item connects to the organisation’s identified impacts, risks or opportunities, using the same mapping used in the assessment.
Evidence IRO register, assessment matrix, and cross-reference table used for report drafting.
Watch for The linkage is built from a different assessment version, so the reported mapping does not reconcile to the current IRO register.
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Named individuals
Company Secretariat / HRThe specific people identified for this disclosure, with names recorded exactly as held in the approved source list.
Evidence Approved personnel list, governance records, or nomination papers used for the disclosure.
Watch for A person is included who is not on the approved source list, so the named population does not reconcile to the governance record.
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Prior roles
HR / Company SecretariatThe roles those individuals held before their current position, using the same job history source and the same definition of prior role for all entries.
Evidence CVs, appointment files, HR history records, and board papers.
Watch for Previous roles are taken from mixed sources, so the job history does not reconcile to HR records.
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Relevant period
Company Secretariat / ReportingThe time window over which the disclosure applies, stated clearly so readers can see when the identified roles or events occurred.
Evidence Reporting timetable, appointment dates, and the cut-off date used for the disclosure.
Watch for The period is stated using a different cut-off from the underlying records, so the disclosure mixes current and earlier appointments.
Before you start
- Have you first decided which payments count here: only direct political donations, or any other support that should be treated the same way in your internal records?
- For the money figure, have you fixed the reporting period and currency basis you will use, and checked that the total can be traced back to a source record?
- Can you separate each amount by the country where it was made and by the kind of recipient, using labels your finance or public affairs teams already use?
- Have you agreed which policy areas or campaign topics belong in scope, and which public positions or statements you will link to them?
- For any people named, have you confirmed who they are, what former roles matter, and the time window you will use to describe that background?
How to prepare it
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
Download preparation tools for G1-5 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
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.
Risk 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.
Evidence to check 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.
Risk 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.
Evidence to check 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.
Risk 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.
Evidence to check 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.
Risk 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.
Evidence to check 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.
Risk 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.
Evidence to check 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.
Risk 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.
Evidence to check 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.
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 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.
Judgement 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
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
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.
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.
Quality ladder
- Basic
We reported total political contributions of 120.
- Better
We reported 120 in political contributions, split across France, Germany and the UK, with recipients covering trade groups and charities.
- Best
We reported 120 in political contributions for the year ended 31 December 2025, split across France, Germany and the UK, with recipients covering trade groups and charities; our public-policy positions covered climate, tax and labour, and we linked each position to the related impact, risk or opportunity because those were the areas where our advocacy work was most active.
Check your understanding
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.
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'.
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.
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.
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Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
G1-5
within ESRS G1: Business Conduct
Guides that settle this question
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FAQ
Questions this page answers
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.
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.
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.
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.
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.
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.
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.
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.
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.
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