Disclosure focus
The practical emphasis is on whether the targets are organisation-wide or limited to particular parts of the business, such as specific operations, regions, products or sites. It also helps readers understand the scope and ambition of the targets, so they can see whether the organisation is covering its full material footprint or only selected activities.
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 level
Sustainability / strategyState the intended end point or level the organisation is aiming to reach.
Evidence Target-setting paper, board-approved plan, or KPI register.
Watch for Target level is recorded as a vague ambition rather than a measurable end point.
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Target assumptions
Sustainability / strategySet out the key assumptions used when the target was designed, including any conditions the target depends on.
Evidence Target model, planning memo, or assumptions log.
Watch for Assumptions are omitted, so the target cannot be traced back to the planning basis used to set it.
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Target legal basis
Legal / complianceNote any law, regulation, permit, or other formal rule that underpins the target, if one exists.
Evidence Legal register, compliance memo, or cited statute/permit reference.
Watch for The target is linked to the wrong legal source or to no legal basis at all.
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Scenario basis
Strategy / climate planningIdentify the scenario or planning case used to frame the target, including the named scenario if one was used.
Evidence Scenario analysis, transition plan, or modelling pack.
Watch for The scenario basis is mixed up with a different planning case or not tied to the model actually used.
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Policy fit
Sustainability / policyExplain how the target sits alongside the organisation’s own policies and commitments.
Evidence Policy map, internal policy register, or alignment note.
Watch for The target is described as aligned to a policy that does not actually cover the same subject or ambition.
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Scientific support
Sustainability / technical teamDescribe the scientific or technical basis used to justify environmental targets.
Evidence Technical paper, external science reference, or methodology note.
Watch for The target is presented as science-based without a documented scientific basis behind it.
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Target type
Sustainability / reportingSpecify whether the target is set as a fixed amount or as a proportion, rate, or other relative measure.
Evidence Target register, KPI definition, or reporting template.
Watch for Absolute and relative measures are mixed, so the target type does not match the metric used.
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Measurement unit
Sustainability / reportingRecord the unit used to express the target value, such as tonnes, percentage, or currency.
Evidence KPI dictionary, target register, or calculation sheet.
Watch for The unit is missing or does not match the source metric, so the value cannot be interpreted correctly.
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Target boundary
Finance / sustainability reportingDefine which parts of the business, activities, or locations are included in the target.
Evidence Boundary statement, consolidation memo, or scope definition.
Watch for The boundary is not aligned to the reporting perimeter, so included entities or activities are left out.
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Starting point
Sustainability / data teamCapture the starting value used for the target comparison, with the same metric and boundary as the target itself.
Evidence Baseline calculation, prior KPI report, or source data extract.
Watch for The starting point is taken from a different metric or boundary, so the comparison is not like-for-like.
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Base year
Sustainability / reportingState the reference year used as the anchor for the target.
Evidence Target register, board paper, or reporting calendar.
Watch for The base year is confused with the first reporting year or another reference period.
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End year
Sustainability / strategyState the year by which the target is meant to be achieved.
Evidence Target register, roadmap, or board-approved plan.
Watch for The end year is entered as a review date or milestone year instead of the final target date.
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Interim checkpoints
Sustainability / strategyList any intermediate milestones or step-down targets on the way to the final target.
Evidence Roadmap, target trajectory, or milestone tracker.
Watch for Interim checkpoints are omitted or placed on the wrong years, so the path to the final target is unclear.
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Target method
Sustainability / analyticsDescribe the method used to set the target, including how the target was calculated or derived.
Evidence Methodology note, calculation workbook, or target-setting memo.
Watch for The calculation method is not documented, so the reported target cannot be reproduced from the source inputs.
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Progress tracking
Sustainability / performance managementExplain how progress is monitored when no formal target has been set, including the approach used to follow change over time.
Evidence Management dashboard, KPI tracker, or monitoring framework.
Watch for The tracking approach is described as target-based even though no target exists, so the monitoring method is mischaracterised.
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Effectiveness measures
Sustainability / performance managementList the indicators used to judge whether the action is working, and show how they are used to assess effectiveness.
Evidence KPI dashboard, monitoring report, or programme evaluation note.
Watch for The indicators measure activity rather than effectiveness, so the chosen measures do not show whether the action is working.
Before you start
- Have you settled which business areas, activities, and impacts this target covers, and which are out of scope?
- Have you fixed the measurement basis: is this an absolute figure or a ratio, what unit will you use, and what baseline and base year sit behind it?
- Have you pinned down the timing: which end year is being used, and are there any interim waypoints to include?
- Can every number be traced back to a source you can explain, including the method used to calculate it and any assumptions behind it?
- Have you checked whether the target rests on any legal basis, scenario view, policy link, or scientific rationale, and if so, which one applies?
- If there is no target yet, have you decided how you will track progress instead, and which indicators will show whether action is working?
How to prepare it
Request the data
Request the target register and tracking evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What targets, milestones, and tracking methods are we using for each material sustainability topic, and what evidence supports them?
Use your organisation’s own terms first, then map them to the reporting fields. For example, ask for the target register, KPI pack, or performance dashboard rather than using framework labels in the first message. This is a possible LRA training template only; adapt it to your organisation and check the source material before sign-off.
Weak request
Please provide the ESRS 2:GDR-T information for all material sustainability matters, including target value, baseline, methodology, assumptions, scenario basis, policy alignment, and tracking approach.
Why it fails: It uses framework language that many internal owners will not recognise, and it bundles too many concepts without telling the recipient what practical records to send. It also does not point them to the internal artefacts they actually hold, such as the target register, KPI pack, or dashboard.
Better request
Please send the current target register and progress pack for [topic], including the target level, whether it is absolute or relative, the unit, boundary, baseline, base year, target year, milestones, measurement method, and any assumptions, policy links, scenario inputs, or scientific references used. If there is no formal target, send the measures used to track performance instead. Please include the source file, owner, and approval date.
Formal email template
Subject: Request for target and progress evidence for [material topic / workstream] Dear [name], I am preparing the sustainability reporting pack and need the current evidence for [material topic / workstream]. Please share the latest target register, milestone plan, and any tracking material that shows how progress is being measured. To help us map this correctly, please include: - the target value or level currently in use - whether it is an absolute or relative measure - the unit used internally - the boundary covered - the baseline and base year - the target year - any interim milestones - the method used to calculate or monitor progress - any assumptions, scenario inputs, policy links, or scientific references used when the target was set - if there is no formal target for this topic, the measures used to track performance instead Please also include the source file or system, the owner, the approval date, and any notes on changes since the last review. This is a possible LRA training template only; please adapt it to your organisation’s own language and check the source material before sign-off. Many thanks, [preparer name]
Short Teams / Slack version
Hi [name] — I’m pulling together the sustainability pack for [period]. Could you send the latest target tracker / KPI pack for [topic], plus the baseline, milestones, measurement method, and any notes on assumptions or policy links? If there isn’t a formal target, please send the measures you use to track progress instead. Please include the source file and owner. Thanks.
Industry examples
Manufacturing
Context. The business has an energy reduction programme across owned plants and a separate safety improvement plan.
Adapted request. Please send the latest plant-level target tracker for the energy programme and the safety improvement plan, including the target level, unit, baseline, base year, target year, interim milestones, and the method used to roll up site results. If either programme has no formal target, send the KPI dashboard used to monitor progress instead. Please include the source file, owner, and approval date.
Example response. A site tracker showing: energy use reduction target of 12% by FY2028 versus FY2023 baseline; quarterly milestones for FY2025–FY2027; monthly meter-based reporting; and a note that the safety plan is tracked through incident-rate KPIs rather than a formal target.
Retail
Context. The business tracks supplier standards and packaging reduction through separate operational scorecards.
Adapted request. Please send the current scorecards for supplier standards and packaging reduction, including the target level, whether it is an absolute or relative measure, the unit, baseline, base year, target year, milestones, and the method used to monitor progress. If a scorecard has no formal target, please send the indicators used to track performance instead. Include the source system and the owner.
Example response. A procurement scorecard showing: 90% of strategic suppliers assessed by FY2026, baseline FY2024 at 62%; packaging reduction tracked as grams per unit sold with quarterly milestones; and a note that one supplier programme is monitored through audit completion rates rather than a formal target.
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 target was defined, including the measurement basis, the unit used, the scope covered, the starting year, the end year, any interim checkpoints, and the approach used to set it.
Context note
Describe what the target means in practice by linking the stated level to the business area covered, the comparison year, and the basis used to support the target.
Fluctuation statement
If the target or its milestones changed, explain what drove the change, such as a revised assumption set, updated scenario work, a different policy position, new scientific input, or a change in legal grounding.
Content index entry
GDR-T Targets in Relation to Material Sustainability Matters — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for GDR-T with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
I have set out the figure in a way that shows the intended level to be reached, and I have stated the unit used to measure it.
Risk The assurer may test whether the stated figure is internally consistent, whether the unit matches the metric, and whether the wording could be read as vague or incomplete.
Evidence to check Target schedule or KPI register; draft and final report wording; calculation sheet showing the unit applied; sign-off notes confirming the figure and unit were reviewed together.
I have explained the approach used to define the figure, including the main assumptions that materially affected it.
Risk The assurer may probe whether the method was chosen consistently, whether key assumptions were documented at the time, and whether any assumption could materially change the result.
Evidence to check Methodology paper; assumption log; model inputs and version history; approval papers showing the basis used to set the figure.
I have stated whether the figure is set because a rule or legal duty requires it.
Risk The assurer may check whether the statement is clear, current, and supported by a legal assessment rather than a general policy statement.
Evidence to check Legal review memo; compliance register; board or committee paper noting the basis for the figure; draft disclosure showing the required/not required conclusion.
I have described the scenario choices, the main information sources used, and how closely the result aligns with relevant public policy aims.
Risk The assurer may test whether the chosen scenarios are identifiable, whether the data sources are traceable, and whether the stated policy alignment is supportable.
Evidence to check Scenario selection paper; source list and data lineage records; internal assessment of policy alignment; working papers showing how the scenarios were compared.
I have explained the scenario basis, the key datasets behind it, and the extent to which the result fits with policy goals at national, EU, or wider international level.
Risk The assurer may probe whether the policy comparison is overstated, whether the datasets are reliable, and whether the basis used is consistent across the disclosure.
Evidence to check Scenario analysis pack; data source register; cross-checks against external policy references; review notes confirming the level of compatibility stated.
I have linked each measurable target to the relevant policy aims and actions, and I have shown that it is outcome-focused and time-bound.
Risk The assurer may test whether the target is genuinely measurable, whether the link to actions is clear, and whether the target is specific enough to assess progress.
Evidence to check Target-setting paper; policy-to-target mapping; action plan or roadmap; approval minutes showing the target was framed as an outcome measure.
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 owner, wrong languageTeams often ask the policy lead or a framework specialist instead of the business owner who actually tracks the target in the organisation’s own terms.
- Scope left vaguePeople sometimes collect a target figure without pinning down which sites, entities, activities or time periods sit inside the boundary.
- Baseline and current year mixed upThe data pack can combine the starting point, the reference year and the latest update, so the target path no longer ties back cleanly.
- Absolute and intensity data blendedCollectors may merge headcount-based, output-based or total-volume figures into one file even though they need to stay on separate counting bases.
- Units not fixed earlyA target is sometimes gathered in mixed units, which makes later comparison impossible because the same measure is recorded in different forms.
- Source labels stripped outOriginal system names, report titles or spreadsheet tabs are often removed, so no one can trace where each number came from.
- Different populations mergedData for separate business lines, regions or target types is sometimes rolled together even though each should be kept distinct.
- No evidence trailThe team may capture the number but forget the supporting files, date stamps and reviewer sign-off needed to show how it was assembled.
- Timing basis not alignedInputs are sometimes pulled from different cut-off dates or reporting cycles, so the target data does not reflect one consistent period.
- Method notes missingCollectors may record the headline target but leave out the assumptions, calculation approach, policy link, scenario basis or scientific basis that explain how it was set.
Judgement needed
- Setting the starting point after a business changeIf a purchase, sale, or reorganisation changes the group you are measuring, choose a baseline that matches the new operating perimeter and explain what changed, when it changed, and whether earlier figures were restated or left as originally reported.
- Using one group definition across different countriesWhere local reporting populations or legal entities are not identical in every country, pick a consistent organisational boundary for the target and explain any exclusions, local carve-outs, or country-specific adjustments.
- Deciding who sits just inside or just outside the targetFor people, sites, products, suppliers, or other units near the edge of the target scope, state the inclusion rule you applied and disclose any material exclusions so readers can see how the coverage was drawn.
- Choosing the measurement basis for the targetIf the target can be expressed in more than one way, make clear whether you used an absolute figure or a scaled measure, and explain why that basis best fits the change you are trying to drive.
- Fixing the date used for the baseline and progress checksState the date or period used for the starting point and for each progress update, and explain any lag between the operational event and the figure reported so users can compare like with like.
- Mixing estimates with directly observed dataWhen some inputs are modelled, sampled, or otherwise estimated rather than directly counted, identify which parts are estimated, the main assumptions behind them, and how you checked that the approach is reasonable.
- Rounding and small-number effectsIf rounding changes the apparent result or makes a small population look materially different, explain the rounding rule used and, where helpful, show the unrounded basis in working papers or supporting notes.
- Protecting privacy when the target covers sensitive groupsIf disclosing the target at a detailed level could expose personal or commercially sensitive information, aggregate the figures to a safer level and explain the aggregation rule and any limits it creates for interpretation.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We set a 2035 emissions goal for our own operations and purchased electricity, using 2024 as the starting point and a 2029 checkpoint on the way. The target is a 42% cut from the 2024 baseline of 1,000,000 tCO2e to 580,000 tCO2e by 2035; this is an absolute target, measured in tCO2e, and it covers our consolidated group boundary, including majority-controlled subsidiaries.
- The target design is aligned to our climate policy and uses a 1.5°C pathway as the scenario reference.
- We rely on a science-based pathway for the environmental target, and the approach assumes stable grid emission factors, no major portfolio acquisitions, and continued access to current abatement technologies.
- There is no specific legal requirement driving this target; our method uses emissions inventory data, operational forecasts, and the same boundary used in our annual reporting, with 2029 set as the interim milestone at 760,000 tCO2e.
Illustrative only: this example shows how to describe the target level, baseline, base year, target year, interim checkpoint, unit, scope, absolute/relative framing, policy link, scenario reference, scientific basis, assumptions, legal basis, and method in plain language.
We have set a water-use goal for our direct manufacturing sites, starting from a 2023 baseline and aiming for 2030, with a 2026 checkpoint in between. The plan is to reduce water withdrawal by 18% from 2,500,000 m3 to 2,050,000 m3, so the target is relative rather than absolute, and it applies only to sites we operate and control.
- The target sits alongside our resource-efficiency policy and is framed against a high-water-stress scenario for the regions where we operate.
- Because this is an environmental target, we use a science-led approach based on site-level water balances, production forecasts, and local catchment stress data; the main assumptions are steady production mix, no plant closures, and no material change in water recycling rates.
- We do not rely on a legal obligation for this target, and our interim step is 2,250,000 m3 by 2026.
Illustrative only: this example shows how to describe a non-emissions environmental target using the same required elements in different wording, including the target level, baseline, dates, interim step, unit, boundary, relative framing, policy link, scenario reference, scientific basis, assumptions, legal basis, and method.
Quality ladder
- Basic
I have set a 2030 target of 40% for our own operations.
- Better
I have set a 2030 target of 40% for our own operations, measured against a 2024 starting point using our internal tracking method.
- Best
I have set a 2030 target of 40% for our own operations, measured against a 2024 starting point across our wholly owned sites using our internal tracking method, and the latest update moved only slightly because one site was added to the scope.
Check your understanding
Scenarios to work through
A preparer is drafting a climate target for a group with operations in three countries. The draft says emissions will fall by 30% by 2030, but it does not say whether that is measured against the whole group or only one business line, and the team has not yet written down the base year or the starting figure.
A sustainability team has set a water-use reduction goal for a manufacturing site. The draft includes the target number and year, but the team has not explained the assumptions behind the plan, whether any law underpins the target, or whether it was built from a future-pathway scenario or from the company’s own policy commitments.
A company has no formal target for reducing waste yet, but it still wants to show investors how it is managing the issue. The draft lists monthly waste volumes and recycling rates, but it does not explain why those measures were chosen or how they help judge whether the approach is working.
A group has set a biodiversity target that depends on a future land-use pathway and a public policy commitment. The draft mentions the target year and a few milestones, but it does not explain the assumptions behind the pathway or how the target connects to the company’s wider policy position.
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Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
GDR-T
within ESRS 2: General Disclosures
Guides that settle this question
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FAQ
Questions this page answers
Start with the page’s datapoints to prepare: target level, assumptions, legal basis, scenario basis, policy fit, scientific support, target type, measurement unit, boundary, starting point, base year, end year, interim checkpoints, target method, progress tracking and effectiveness measures. The page also gives a step-by-step preparation flow, so you can turn those inputs into a draft in a structured way.
Use the page’s datapoints for target boundary, target level, target type and measurement unit to define what the target covers and how it is expressed. The page is designed to help you make those choices explicit before drafting.
The page includes an evidence pack with five items for assurance readiness, plus six assurance claims to verify using a claim/risk/evidence approach. Use those sections to build a file that shows how the target was set, tracked and supported.
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it alongside the page’s step-by-step preparation section to organise the datapoints, evidence and draft output in one place.
The page lists common reporting gaps and mistakes, so it is meant to help you spot missing target details, weak support and incomplete tracking before you finalise the draft. Use that section as a pre-submission check.
The page asks you to prepare target assumptions, scenario basis, policy fit and scientific support, so these should be captured clearly and consistently in the draft and evidence pack. That helps a reviewer see why the target was chosen and how it is being tracked.
The page provides a five-item evidence pack specifically for assurance readiness. Use it to assemble the core documents and records that support the target, the method and the progress reported.
The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. That gives you a practical way to convert the prepared datapoints into a readable disclosure draft.
Yes, the page includes synthetic illustrative example disclosures, including a quantitative table, to show how the information can be presented. Treat them as examples only and adapt them to your own data and scope.
The page has a ‘From company reports’ table that links to real published reports at the pages where the topic is disclosed. Use it to see how others have presented similar information in practice.
More questions this page can help with