ESRS 2 — Actions and Resources in Relation to Material…

Q: How do I use the GDR-A page to draft the disclosure from scratch?

Start with the plain-language explainer, then work through the datapoints to prepare, the step-by-step preparation section, and the draft-output ideas. The page is designed to help you turn source data into a first draft, not to replace your own reporting judgement.

Q: What data do I need to collect for GDR-A before I start writing?

The page lists the datapoints to prepare: action name, coverage, timing, completed steps, next steps, expected results, resource type, this year spend, future spend range, linked accounts lines, funding conditions, and other support used. Use that list as your collection checklist so you can build the disclosure without missing key fields.

Q: How should I set the scope and methodology for the GDR-A disclosure?

Use the page’s step-by-step preparation guidance to decide what action or actions you are describing and which datapoints apply to each one. Keep the scope consistent across the narrative, the table, and the evidence pack so the draft reads as one coherent disclosure.

Q: Who should own the GDR-A data and sign-off process?

The page is useful for assigning ownership across sustainability, HR, finance, or other data owners because it shows which datapoints need to be gathered and evidenced. In practice, each field should have a named owner who can confirm the source and explain any judgement used.

Q: What should go into the GDR-A evidence pack for assurance readiness?

The page includes an evidence pack with five items and six assurance claims to verify, so you can assemble support around the claim, the risk, and the evidence. Use those sections to make sure the pack is complete enough for a reviewer to trace the numbers and narrative back to source material.

Q: What are the six assurance claims I need to check for GDR-A?

The page says there are six assurance claims to verify, organised around claim, risk, and evidence. Use that structure to test whether each reported point is supported, whether there is a realistic risk of error, and whether the evidence pack answers it clearly.

Q: What are the common mistakes to avoid when reporting GDR-A?

The page lists common reporting gaps and mistakes, which are there to help you spot weak drafting, missing data, or inconsistent treatment before sign-off. A practical use is to compare your draft against those gaps and fix anything that would make the disclosure harder to assure.

Q: How do I use the GDR-A workbook download in practice?

The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to help you organise the disclosure work and evidence. Use it alongside the page’s datapoint list and assurance sections to track what is complete, what is missing, and what still needs review.

Q: What is the printable Library Card for GDR-A used for?

The printable Library Card in PDF format is a quick reference version of the page content. It is useful for workshops, data-owner check-ins, or assurance preparation when you want the key fields and checks in a compact format.

Q: How can I turn the GDR-A data into a draft narrative and table?

The page’s draft-output section gives visualisation ideas, narrative starters, and a content-index line to help you shape the final write-up. Use those prompts to convert the collected datapoints into a clear draft, then check it against the example disclosures for format and completeness.

Disclosure focus

The practical focus is on giving a clear picture of coverage and effort across the business. That means explaining whether actions apply across the whole organisation, selected business units, specific sites, or parts of the value chain, and whether the resources involved are limited to a few flagship initiatives or spread more broadly. The aim is to help readers understand how seriously the material matters are being addressed in day-to-day operations.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official European Commission source.

Request the data

Request the action plan and resource data from Finance / FP&A

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

What actions are being taken or planned on the material sustainability topics, and what resources are being committed now and next year to support them?

Use your organisation’s own planning and budgeting language first, then map it to the sustainability reporting categories. For example, ask for project names, workstreams, cost centres, capex/opex, headcount, and funding notes in the terms your teams already use. Check the official source before sign-off.

Weak request

Please provide the ESRS 2:GDR-A actions and resources disclosure data for all material sustainability matters, including the action name, scope, timeframe, actions taken, planned actions, expected outcomes, type of resources, current-year allocation, future allocation range, related financial statement line items, funding dependencies, and non-financial resources.

Why it fails: It uses framework language that many teams do not use day to day, so the owner may not know which plans, budgets, or trackers to pull from. It also bundles too many concepts without telling them how to express the information in their own operational terms, which makes the request harder to action and harder to verify.

Better request

Please send the current and planned initiatives for [business area / topic] for [reporting period], using your normal project, budget, and forecast terms. For each initiative, include what it covers, what has already been done, what is planned next, the expected result, the resource type, this year’s allocation, the expected range for next year, any linked finance lines, any funding assumptions, and any non-cash support. Attach the budget extract, forecast, or project summary you used.

Formal email template

Subject: Request for action and resource information for sustainability reporting

Dear [name/team],

We are preparing the sustainability report and need your help with the actions and resource information for [business area / programme / topic]. Please share the current and planned initiatives in your own planning terms, together with the related resource view.

Could you please provide, for [reporting period]:
- the initiative or workstream name;
- what it covers and where it applies;
- when it started, what is underway now, and what is planned next;
- the actions already taken;
- the actions planned;
- the outcome expected;
- the resource type involved;
- the amount allocated this year;
- the expected range for future allocation;
- the related finance line(s) or budget line(s);
- any funding dependencies or assumptions;
- any non-cash support used, if relevant.

Please send the information in a table, plus any supporting documents such as budget extracts, business cases, forecast files, or project summaries. If you use different internal terms, please use those and we will map them during reporting.

Please share by [date]. Check the official source before sign-off.

Kind regards,
[preparer name]

Short Teams / Slack version

Hi [name/team] — could you send the current and planned [programme/workstream/project] details for [reporting period], plus the resource view (budget, forecast, headcount, other support) and any linked finance lines? Please use your own internal terms and attach any supporting files. Thanks — [preparer name]

Industry examples

Manufacturing

Context. A plant-level energy efficiency programme with capex approval and contractor support.

Adapted request. Please share the plant energy programme details for [reporting period]: project name, site coverage, milestones completed, next steps, expected savings or operational result, capex and opex committed this year, forecast range for next year, linked finance codes, any grant or approval dependency, and any contractor or equipment support used.

Example response. Project: Boiler upgrade and compressed air optimisation; Scope: Plant 3; Timeframe: Started Q2, completion planned Q4; Actions taken: audit completed, equipment ordered; Planned actions: install controls, commission system; Expected outcome: lower energy use and reduced downtime; Resource type: capex, contractor days, internal engineering time; Current-year allocation: £1.2m; Future allocation range: £0.3m-£0.5m; Linked finance lines: CAPEX-4312, OPEX-2204; Funding dependency: final utility rebate confirmation; Non-cash support: internal maintenance team time.

Retail

Context. A supplier engagement and packaging reduction programme managed through procurement and operations.

Adapted request. Please send the packaging and supplier programme information for [reporting period] in your usual sourcing and project terms: initiative name, supplier or product scope, work completed, next actions, expected result, resource type, current spend, forecast range, linked budget lines, any dependency on supplier participation, and any in-kind support such as design or store rollout time.

Example response. Programme: Own-brand packaging redesign; Scope: chilled food suppliers in UK stores; Timeframe: Live since March, rollout through December; Actions taken: supplier brief issued, pilot completed; Planned actions: extend to remaining suppliers, update artwork; Expected outcome: lower packaging weight and improved recyclability; Resource type: external design fees, procurement time, store rollout labour; Current-year allocation: £480k; Future allocation range: £150k-£250k; Linked finance lines: PRC-1188, MKT-0441; Funding dependency: supplier sign-off on new pack specs; Non-cash support: category manager time and store operations support.

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 each action was identified, how its scope and timing were defined, and how resource figures were compiled, including any non-cash support and links to the relevant accounting lines.

Context note

Set out what the action list is intended to achieve, how the current and future resource figures relate to delivery, and how the expected outcomes show the practical purpose of the plan.

Fluctuation statement

If the current allocation, future funding range, or support mix changes materially, explain whether this reflects timing, revised delivery plans, changed dependencies, or a different resource approach.

Content index entry

GDR-A Actions and Resources in Relation to Material Sustainability Matters — [location / page] / [notes]

Download Centre

Preparation tools & forms

Download preparation tools for GDR-A with free verified email access for 24 hours. Source-report links remain public.

Free · Email access

01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Check

For each claim, check the evidence

We prepared the coverage figure from the underlying action log, then checked that each item included what was done in the year, what is still to come, and the timing attached to each part.
Risk An assurer may test whether the figure mixes completed work with future plans, or whether dates and status labels were applied consistently across the disclosed actions.
Evidence to check Action register or tracker; project plans and milestone dates; internal review notes showing how in-year and future items were separated; sign-off pack used before publication.
We grouped the environmental actions using our chosen avoid-reduce-restore style logic, and kept a short mapping note showing why each item sat in its category.
Risk An assurer may probe whether the grouping was applied consistently, whether any item was placed in the wrong bucket, or whether the basis for classification was documented.
Evidence to check Classification matrix or mapping table; working papers showing the rationale for each action; reviewer comments and resolution notes; version history of the draft disclosure.
We limited the disclosed actions to the scope we had agreed for the report, and recorded the boundary decisions where an activity was included, excluded, or only partly covered.
Risk An assurer may ask whether the scope was set too narrowly or too broadly, and whether exclusions were deliberate, approved, and traceable.
Evidence to check Scope memo; boundary and inclusion/exclusion log; management approvals; links between the disclosed actions and the underlying programme list.
We stated whether each action was delivered by us alone or together with other parties, and kept evidence of the roles each party played.
Risk An assurer may check whether collaboration claims are supported, whether partner involvement was overstated, or whether responsibility was unclear.
Evidence to check Partnership agreements, joint project plans, emails or meeting minutes showing shared delivery, and internal ownership records for each action.
We described the actions in a way that separates what happened this year from what is planned later, and we checked that the timeframes were internally consistent across the narrative and tables.
Risk An assurer may test whether the timing is coherent, whether future milestones are realistic, and whether the same dates appear consistently in all parts of the disclosure.
Evidence to check Programme timetable; board or committee papers approving the plan; draft-to-final comparison; cross-check of dates against the main report tables.
We linked each action to the policy aim it is meant to support, and kept a note explaining the expected result we were relying on.
Risk An assurer may probe whether the stated contribution is too vague, whether the expected result is plausible, and whether the link to the policy aim is evidenced rather than asserted.
Evidence to check Policy documents; business case or project rationale; outcome statements; internal approval papers showing the intended contribution.

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes or records evidencing the relevant engagement or consultation

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 a policy lead or reporting contact instead of the team that actually runs the action or controls the budget, so the answer comes back second-hand and incomplete.
Framework language onlyPeople ask for the data using disclosure labels rather than the organisation’s own project, programme, or cost-centre terms, which makes the source team unable to map the request cleanly.
No clear boundaryThe collector does not state which business units, sites, or subsidiaries are in scope, so teams send mixed figures that cover different parts of the group.
Wrong period basisThe data pull uses a different cut-off or reporting window from the one being used for the report, so the figures do not line up with the same time period.
Mixed counting basisHeadcount, spend, and other measures are gathered on different bases without being separated, so the final pack blends unlike numbers that should stay distinct.
Source labels lostOriginal file names, system tags, or local category names are stripped out during consolidation, making it hard to trace each figure back to where it came from.
Populations mergedData for actions already under way, actions still planned, and expected results are combined into one pool even though they need separate treatment in the source pack.
Missing evidence trailThe collector saves the numbers but not the supporting notes, extracts, or approval record, so no one can show how the figure was built or checked.
No sign-off chainThe draft is passed on without a named reviewer or approval step from the people who own the source data, leaving no clear record that the figures were checked before use.

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Judgement needed

What counts as the action itselfUse a plain business label for each initiative, and if several workstreams sit under one programme, explain the grouping so readers can see what is included and what is left out.
Which parts of the business are in scopeState the operating units, sites, countries or activities covered by each action, and explain any exclusions where the same issue is handled differently in another part of the group.
How to handle boundary shifts after dealsIf an acquisition, disposal or reorganisation changes the perimeter during the period, disclose the basis used for the period view and explain any restatement or non-restatement choice.
Whether timing is based on approval, start or deliveryPick one timing basis for each action and use it consistently, then explain if the date shown reflects approval, launch, spend, completion or another internal milestone.
How to separate completed work from planned workDistinguish what has already been done from what is still scheduled, and make clear whether the plan covers committed steps only or also broader intentions.
What counts as a resource and how it is measuredDescribe the resource type in operational terms, then explain whether the amount shown is a measured figure, a management estimate or a range, including the basis used.
How to link spend to the financial statementsWhere the action is tied to a line in the accounts, identify the relevant line item and explain any allocation method used when the spend is shared across several purposes.
How to treat future funding that is uncertainIf later funding depends on approvals, grants, partner support or other conditions, say what is firm, what is contingent and what assumptions sit behind the range.
How to aggregate sensitive workforce or community dataWhen privacy, safety or small numbers prevent a detailed split, present the data at a higher level and explain the aggregation rule so the reader understands the limitation.
How to round figures and rangesChoose a rounding approach that does not distort the picture, apply it consistently across the disclosure, and note it where it could affect how the numbers are read.

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Examples

How it reads on the page

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — manufacturing

During the year, we ran a plant-efficiency programme across our two main sites, with work focused on energy use, water handling and waste reduction; the plan runs from Q2 2026 to Q4 2028 and is expected to cut operating emissions and disposal costs while improving process reliability.
- We spent 12.0 million in the current year, made up of 9.0 million cash spend and 3.0 million staff time and internal support; the cash element sat mainly in property, plant and equipment additions and operating expenses, while the people element was not separately capitalised.
- For the next three years, we expect to commit between 28.0 million and 34.0 million in total, with 18.0 million to 22.0 million likely to be capital spend and 10.0 million to 12.0 million likely to be operating spend; this is partly dependent on grant support of up to 6.0 million, and we also rely on internal engineering teams and existing production data systems rather than any external non-financial support.

Synthetic, internally consistent example for practitioner review only.

Illustrative (synthetic) example — retail

We are carrying out a store-network waste and packaging redesign across 180 outlets, with the work scheduled from January 2026 to December 2027 and aimed at lowering material use, reducing disposal charges and improving customer-facing sorting systems.
- In the current year, we allocated 4.8 million, comprising 3.6 million for supplier and fit-out costs and 1.2 million for internal project teams; the spend was recognised mainly through operating costs, with a smaller share in leasehold improvements.
- Over the next two years, we expect to allocate between 9.5 million and 11.0 million in total, including 6.5 million to 7.5 million of cash spend and 3.0 million to 3.5 million of internal labour and systems work; delivery depends in part on a possible local authority rebate of up to 1.5 million, and we are also using store manager training and our existing inventory platform as non-financial inputs.

Synthetic, internally consistent example for practitioner review only.

Quality ladder

Basic
I allocated €1 million to our climate work this year.
Better
I allocated €1 million this year to our climate work, mainly for energy-efficiency upgrades and staff training, and I expect about €1.2 million next year.
Best
I allocated €1 million this year to our climate work across our owned sites and operations, with €0.7 million already spent and €0.3 million still committed, and I expect €1.0 million to €1.2 million next year because we are bringing forward some upgrades after supplier delays.

Check your understanding

Scenarios to work through

A preparer is drafting the section for a material water-risk topic. The team has one project already underway, one project approved for next year, and a target that the business expects to reach if both go ahead.

QHow should the preparer decide what to include so the write-up covers the action itself, where it applies, when it happens, what has already started, what is still planned, and the outcome the company expects?

Reveal model answer →

A finance team has agreed this year’s spend on a biodiversity programme, but the sustainability team also wants to mention a possible increase in funding next year if a grant is approved. The draft currently gives only one total figure and no explanation of what it covers.

QWhat should the preparer do to show the resources used now, the likely range for later funding, and any link to the financial statements or outside funding that affects the plan?

Reveal model answer →

A company has launched a supplier-training programme to reduce labour-rights risks. The draft says the programme is ‘under way’ and lists a budget, but it does not say whether the budget is staff time, cash, software, or external support, and it does not mention any future funding uncertainty.

QHow should the preparer decide whether the resource description is complete enough for the disclosure?

Reveal model answer →

A preparer is combining several climate-related measures into one paragraph because they all sit under the same material topic. One measure has already started, one is approved but not yet started, and one is only a proposal with no funding decision. The paragraph also mentions a target outcome but does not tie it to each measure.

QWhat is the right way to decide whether the paragraph gives a fair picture of actions taken versus actions still only intended, and whether the expected result is linked closely enough to the measures described?

Reveal model answer →

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Framework references

Relevant ESRS requirements and related disclosures

ESRS

GDR-A

within ESRS 2: General Disclosures

Open official source →

Guides that settle this question

ESRS 2 General Disclosures: basis of preparation, governance, strategy, business model, stakeholders, material IROs, content index and GDR →ESRS and CSDDD: Reporting, Due Diligence and Value Chain Responsibilities Compared →ESRS G1 Business Conduct: Ethics, Corruption, Whistleblowing, Suppliers and Payment Practices →ESRS vs GRI: Double Materiality, Impact Reporting and Practical Interoperability →

Related & explore

General Basis for Preparation of Sustainability Statements → Card Disclosures in Relation to Specific Circumstances → Card Metrics in Relation to Material Sustainability Matters → Card Policies Adopted to Manage Material Sustainability Matters → Card Targets in Relation to Material Sustainability Matters → Card Browse all disclosures →

More in ESRS 2 →Browse full catalogue →Search all disclosures →

FAQ

Questions this page answers

How do I use the GDR-A page to draft the disclosure from scratch?+

What data do I need to collect for GDR-A before I start writing?+

How should I set the scope and methodology for the GDR-A disclosure?+

Who should own the GDR-A data and sign-off process?+

What should go into the GDR-A evidence pack for assurance readiness?+

What are the six assurance claims I need to check for GDR-A?+

What are the common mistakes to avoid when reporting GDR-A?+

How do I use the GDR-A workbook download in practice?+

What is the printable Library Card for GDR-A used for?+

How can I turn the GDR-A data into a draft narrative and table?+

	Report A	Report B	Report C
Datapoint 1	✓ p.213	unclear	✓ p.87
Datapoint 2	✓ p.214	—	✓ p.90

Actions and Resources in Relation to Material Sustainability Matters

What to collect before drafting

Action name

Action coverage

Action timing

Completed steps

Next steps

Expected results

Resource type

This year spend

Future spend range

Linked accounts lines

Funding conditions

Other support used

How to prepare it

Request the action plan and resource data from Finance / FP&A

Notes that turn data into a disclosure

Preparation tools & forms

For each claim, check the evidence

We prepared the coverage figure from the underlying action log, then checked that each item included what was done in the year, what is still to come, and the timing attached to each part.

We grouped the environmental actions using our chosen avoid-reduce-restore style logic, and kept a short mapping note showing why each item sat in its category.

We limited the disclosed actions to the scope we had agreed for the report, and recorded the boundary decisions where an activity was included, excluded, or only partly covered.

We stated whether each action was delivered by us alone or together with other parties, and kept evidence of the roles each party played.

We described the actions in a way that separates what happened this year from what is planned later, and we checked that the timeframes were internally consistent across the narrative and tables.

We linked each action to the policy aim it is meant to support, and kept a note explaining the expected result we were relying on.

Mistakes to avoid and where judgement is needed

Mistakes to avoid

Judgement needed

How it reads on the page

Scenarios to work through

Ask the Knowledge Hub AI Assistant about this disclosure

Check your text

Relevant ESRS requirements and related disclosures

Questions this page answers

Secure your enrolment

Actions and Resources in Relation to Material Sustainability Matters

What to collect before drafting

Action name

Action coverage

Action timing

Completed steps

Next steps

Expected results

Resource type

This year spend

Future spend range

Linked accounts lines

Funding conditions

Other support used

How to prepare it

Request the action plan and resource data from Finance / FP&A

Notes that turn data into a disclosure

Preparation tools & forms

For each claim, check the evidence

We prepared the coverage figure from the underlying action log, then checked that each item included what was done in the year, what is still to come, and the timing attached to each part.

We grouped the environmental actions using our chosen avoid-reduce-restore style logic, and kept a short mapping note showing why each item sat in its category.

We limited the disclosed actions to the scope we had agreed for the report, and recorded the boundary decisions where an activity was included, excluded, or only partly covered.

We stated whether each action was delivered by us alone or together with other parties, and kept evidence of the roles each party played.

We described the actions in a way that separates what happened this year from what is planned later, and we checked that the timeframes were internally consistent across the narrative and tables.

We linked each action to the policy aim it is meant to support, and kept a note explaining the expected result we were relying on.

Mistakes to avoid and where judgement is needed

Mistakes to avoid

Judgement needed

How it reads on the page

Scenarios to work through

Ask the Knowledge Hub AI Assistant about this disclosure

Check your text

Relevant ESRS requirements and related disclosures

Questions this page answers

Get in touch