Disclosure focus
The practical focus is on the scope and consistency of the assessment, not just on a few headline sites or activities. An organisation should be able to describe whether its approach covers the whole business and value chain where relevant, or only selected operations, and why that approach is appropriate. The key point is to make clear how the assessment was carried out so readers can understand the coverage, boundaries and logic behind the reporting.
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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Material impacts
Sustainability reporting / ESG teamA plain summary of the significant effects the business has identified on people, the environment, or the economy, using the organisation’s own assessment and wording.
Evidence Materiality assessment papers, impact register, board or committee papers approving the conclusion.
Watch for The impact list does not reconcile to the materiality assessment and omits a significant effect that was escalated in review.
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Material risks
Risk managementA plain summary of the significant downside exposures the business has identified, based on its own assessment of what could affect performance or position.
Evidence Risk register, climate or sustainability risk assessment, risk committee papers.
Watch for The risk list does not reconcile to the risk register and mixes in issues that were not assessed as material.
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Material opportunities
Strategy / sustainability teamA plain summary of the significant upside areas the business has identified, based on its own assessment of where value or benefit could arise.
Evidence Opportunity register, strategy papers, investment cases, management review papers.
Watch for The opportunity list does not reconcile to the strategy or pipeline and misses a material opportunity that was approved internally.
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Business and value chain link
Sustainability reporting / ESG teamA clear statement of whether the matter sits in the organisation’s own activities, in its wider supply or customer chain, or across both, using the same boundary logic as the assessment.
Evidence Boundary methodology, value chain mapping, materiality assessment support papers.
Watch for The boundary is misclassified, with own-operations issues treated as value-chain issues or vice versa.
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Why not material
Sustainability reporting / ESG teamA short explanation of why the climate topic was concluded not to be material, including the basis used for that conclusion and the main factors considered.
Evidence Materiality assessment memo, climate screening paper, board or committee approval.
Watch for The justification does not match the documented assessment and the conclusion is unsupported by the underlying screening.
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Impact changes
Sustainability reporting / ESG teamAny change in the significant effects already identified, including new effects, removed effects, or a change in how important they are judged to be.
Evidence Updated materiality review, incident logs, stakeholder feedback, management papers.
Watch for The update misses a newly emerged impact or keeps an impact that was no longer in scope for the period.
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Risk changes
Risk managementAny change in the significant downside exposures already identified, including new risks, removed risks, or a change in their assessed importance.
Evidence Updated risk register, risk committee papers, scenario analysis updates.
Watch for The update does not reconcile to the latest risk register and leaves out a risk that was newly escalated.
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Opportunity changes
Strategy / sustainability teamAny change in the significant upside areas already identified, including new opportunities, removed opportunities, or a change in their assessed importance.
Evidence Updated strategy papers, pipeline reviews, investment committee papers.
Watch for The update does not reconcile to the latest strategy review and includes an opportunity that was no longer active.
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Required disclosures list
Financial reporting / sustainability reportingA list of the disclosure items that apply, so the report can show which required topics are being addressed.
Evidence Disclosure checklist, reporting matrix, drafting tracker.
Watch for The list is incomplete and a required disclosure is omitted from the reporting checklist.
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Where disclosed
Financial reportingThe exact place in the report where each required item can be found, such as the section, note, or page reference.
Evidence Final report index, cross-reference schedule, page map.
Watch for The location points to the wrong section or page and does not match the final published report.
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Linked by reference
Financial reportingA yes/no flag showing whether the item is brought in from another document rather than repeated in full in the report.
Evidence Cross-reference schedule, drafting instructions, final report sign-off pack.
Watch for The flag is set incorrectly and the report says a disclosure is linked when the underlying source is not actually incorporated.
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Extra disclosures list
Financial reporting / sustainability reportingA list of any additional disclosure items included beyond the core set, so reviewers can see what supplementary material has been added.
Evidence Reporting checklist, drafting tracker, final disclosure index.
Watch for The supplementary list does not match the final report and a non-core disclosure is left off the schedule.
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High-risk operations
Operations / risk managementThe types of operations that face a higher level of exposure, using the organisation’s own risk assessment and operational categories.
Evidence Risk assessment, site or asset register, operational risk review.
Watch for The operation types are misclassified and a high-exposure activity is left out because the source register was not reconciled.
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High-risk locations
Operations / risk managementThe countries or other places where the organisation’s activities face a higher level of exposure, based on the risk assessment used for reporting.
Evidence Country risk assessment, site register, geopolitical or operational risk review.
Watch for The geography list does not reconcile to the risk assessment and a high-risk country or region is omitted.
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Cross-reference table
Financial reportingA mapping that shows where each required item is covered in the report, so reviewers can trace the disclosure set end to end.
Evidence Disclosure matrix, drafting tracker, final report contents list.
Watch for The cross-reference table does not match the final report and points to outdated draft locations.
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Report location
Financial reportingThe place in the sustainability statement where the linked information appears, using the final published structure and page or section references.
Evidence Final sustainability statement, contents page, page map.
Watch for The stated location is a draft reference and does not match the published sustainability statement.
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Not material flag
Sustainability reporting / ESG teamA yes/no indication that the topic is not material, based on the organisation’s final assessment for the reporting period.
Evidence Materiality assessment conclusion, approval memo, reporting checklist.
Watch for The flag is set to not material even though the assessment file shows the topic was material for the period.
Before you start
- Have you already settled which impacts, risks and opportunities are actually in scope for this statement, including anything tied to your own activities or the wider chain around them?
- For any item you plan to include, have you fixed the basis and cut-off period you will use so the figures and descriptions line up with the same reporting window?
- Can every number or statement you plan to use be traced back to a source you can point to, with a clear path from the draft back to the underlying record?
- Have you agreed the business definitions you will use for the key labels, so the same term means the same thing across the whole pack?
- If you are leaving climate out as not significant, have you already written down the reason in a way that matches your own assessment trail?
- Have you checked which topics changed during the period, and which report sections you will point to or list as covered elsewhere, including any areas you will mark as not significant?
How to prepare it
Request the data
Request the disclosure map and evidence pack from Sustainability Reporting
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Which sustainability topics are covered in our statement, where are they shown, and what supporting references prove the mapping and any exclusions?
Use your organisation’s own labels for topics, reports, systems and governance forums first, then map them to the reporting framework wording. Keep the ask in business language rather than framework terms where possible, and check the source material before sign-off.
Weak request
Please provide the ESRS 2:IRO-2 disclosures, including material impacts, risks, opportunities, disclosure requirements, supplementary disclosures, and appendix linkage.
Why it fails: It uses framework language only, which makes it harder for the business owner to recognise what is being asked. It also bundles several different checks into one vague request, so the owner may not know which tracker, report, or evidence set to return.
Better request
Please send the current disclosure map for our sustainability statement: which topics are covered, where each one appears, what source evidence supports the mapping, what changed since last year, which sites or countries are higher risk, and which topics are not included with the reason why. If you already keep this in a tracker, send that version and note the owner, source system, and latest update date.
Formal email template
Subject: Request for the disclosure map and supporting references for [reporting period] Hi [name/team], We are preparing the sustainability statement for [reporting period] and need the current mapping of our sustainability topics, together with the supporting references behind each item. Please share, for each topic in scope: - the internal topic name you use - whether it is covered in the statement, linked from another report, or not included - where it appears in the statement or linked material - the supporting source or evidence used for that mapping - any note explaining why a topic is not included - any changes from the prior period in the way impacts, risks, or opportunities are described - any operations, sites, or countries flagged as higher risk - the cross-reference table that ties the topics to the statement sections If you already have this in a tracker or control file, please send that version and note the latest update date, owner, and source system. Please adapt this to your organisation’s own terms and check the source material before sign-off. Thanks, [preparer name]
Short Teams / Slack version
Hi [name/team] — could you send the current topic map and supporting references for [reporting period]? Please include what’s covered, what’s linked, what’s excluded, where each item sits in the statement, and any notes on changes or higher-risk sites/countries. If there’s a tracker already, that works too. Please use your own internal terms and check the source material before sign-off. Thanks, [name]
Industry examples
Manufacturing
Context. A multi-site producer with plants, warehouses, and a central ESG reporting team.
Adapted request. Please share the current topic map for FY2025 across our plants, warehouses, and head office, including which topics are covered in the statement, where each one appears, the source file or tracker behind it, any changes since last year, and any sites or countries flagged as higher risk.
Example response. A tracker listing each internal topic, the statement section or linked report, the evidence file name, the owner, the update date, a note on changes from FY2024, and a list of higher-risk plants and countries.
Financial services
Context. A group with business lines, regional offices, and a central sustainability reporting function.
Adapted request. Please send the disclosure map for FY2025 covering our business lines and regions, showing which topics are included in the statement, where they are disclosed, what evidence supports the mapping, any exclusions with reasons, and any changes in risk or opportunity wording since the prior period.
Example response. A cross-reference table with each topic, the relevant section or annex, the linked source document, the internal owner, the exclusion rationale where relevant, and a note on any changes from the previous reporting cycle.
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
Set out the basis used to identify and define the significant matters, explain how the reporting boundary was applied across the business and value chain, and note which disclosures were used or linked to support the conclusion.
Context note
Explain what the figures and lists mean in practice by linking them to the organisation’s main areas of exposure, the parts of the business or value chain they affect, and the locations where those exposures are most concentrated.
Fluctuation statement
Describe any notable movement by pointing to the underlying business, operational or external drivers, and clarify whether the change reflects a shift in the underlying assessment, the reporting scope, or the underlying conditions.
Content index entry
IRO-2 Disclosure Requirements in ESRS Covered by the Undertaking's Sustainability Statement — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for IRO-2 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We have set out a short explanation of the main positive and negative effects we judged to be material, and we link each one to the relevant subject area.
Risk The assurer will check that the summary is not vague, that it really covers both favourable and adverse effects, and that each item is tied to the right topic rather than being a general narrative.
Evidence to check Materiality assessment papers; issue mapping; drafting notes showing how each effect was classified; cross-reference from the statement to the relevant topic section; review comments confirming the wording matches the underlying assessment.
We have placed the explanation of the main effects together with the related policies, actions, measures and goals so the reader can follow one joined-up story without repeated text.
Risk The assurer will probe whether the same point is being repeated in several places, whether the links between narrative and metrics are consistent, and whether the presentation really supports a single coherent account.
Evidence to check Draft structure or content map; cross-references between narrative, policies, actions, metrics and targets; version history showing duplication was removed; sign-off notes from preparers and reviewers.
We have described the main effects in a way that shows how they influence, or may influence, people or the environment, rather than just naming the issue.
Risk The assurer will test whether the description explains the nature of the effect and its direction, or whether it is only a label with no practical meaning.
Evidence to check Impact assessment worksheets; supporting analysis of affected stakeholders or environmental receptors; source documents used to draft the description; reviewer notes checking that the wording reflects the assessment evidence.
We have set out the main risks and opportunities in brief, and we have linked each one to the subject it belongs to.
Risk The assurer will check that risks and opportunities are both covered where relevant, that they are not mixed up, and that the topic linkage is clear and accurate.
Evidence to check Risk and opportunity register; topic mapping; board or management papers used in the assessment; draft disclosure showing each item tagged to a subject area; approval trail.
We have included the dependencies that matter for understanding the risks and opportunities, so the reader can see what they rely on.
Risk The assurer will look for missing upstream or downstream dependencies, weak explanation of reliance, or a claim that cannot be traced back to the assessment.
Evidence to check Dependency analysis; value chain mapping; workshop outputs; source data or assumptions used to identify dependencies; internal review notes confirming completeness.
We have explained where the relevant effects, risks and opportunities sit in our own activities and in the wider chain of activities around us.
Risk The assurer will test whether the locations and boundaries are clear, whether the coverage of own activities and the wider chain is consistent, and whether any exclusions are justified.
Evidence to check Boundary-setting memo; operational and value chain maps; site or business-unit listings; scoping decisions; evidence showing how locations were assigned to each item.
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 deskSending the request to a policy lead or report writer instead of the team that actually holds the underlying records means the data comes back second-hand and incomplete.
- Framework words, not business termsAsking people to answer in ESRS language rather than the organisation’s own operational labels leads to mismatched extracts and confusion over what to pull.
- No clear boundaryFailing to state which entities, sites, activities or value-chain links are in scope causes teams to mix in data from outside the intended population.
- Period basis left vagueNot fixing the reporting window and cut-off point up front lets different teams use different dates, so the figures do not line up.
- Mixed counting rulesCombining headcount, cases, sites or other measures without separating the basis used for each one produces totals that cannot be reconciled.
- Source labels stripped outCopying figures without keeping the original file names, system tags or record labels makes it hard to trace each number back to its source.
- Separate groups merged too earlyPutting together populations that should stay distinct, such as different business lines or geographies, hides the differences that the disclosure needs to show.
- No evidence trailCollecting the data without saving the supporting files, timestamps and reviewer notes leaves no clear audit trail for later checks.
- No sign-off recordLetting the dataset move forward without a named reviewer and approval step means no one can show who checked it or when.
Judgement needed
- Boundary shifts after buying or selling a businessSet the reporting perimeter using the group structure in place for the period, explain any step-up or step-out from acquisitions or disposals, and make clear whether the figures include only the time the business was under your control.
- Different local meanings for the same issueWhere countries use different legal or operational definitions, choose one consistent basis for the group, state the rule you applied, and note any local exceptions that affect the picture.
- People or sites close to the inclusion lineDecide in advance how you will treat cases that sit just inside or just outside the scope, apply that rule consistently, and disclose the threshold or practical test used.
- Current-period cut-off for events and dataUse one clear cut-off date or reporting period for all items, explain any lagged information or later corrections, and show whether the same timing basis was used across the statement.
- Measured figures versus estimatesIf direct measurement is not available, use a reasonable estimate, say where estimation was needed, and distinguish estimated amounts from values taken from source records.
- Rounding and presentation choicesApply one rounding approach across the statement, disclose the level of precision used, and make sure rounded subtotals still reconcile to the totals you present.
- Protecting personal or sensitive informationWhen detailed location or workforce data could identify individuals or small groups, aggregate the information to a safer level, explain the aggregation rule, and keep the disclosure meaningful.
- Changes in the list of covered topicsIf the set of covered disclosure topics changes from the prior year, explain what was added, removed, or moved, and link each change to the relevant part of the statement.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We explain that our material matters include water stress in our own sites and in upstream farming, labour conditions in the supply chain, and product safety in use; we also note a possible upside from lower-emission packaging and energy efficiency. We have not concluded that climate is immaterial, because climate-related effects are already part of our current impacts, exposures and transition plans.
- Since the last reporting cycle, we have seen a rise in supplier audit findings, a wider spread of heat-related downtime at two plants, and a larger set of efficiency projects that could improve margins.
- The matters covered by our reporting package are the environmental, social and governance topics in the core report, with the detailed location given in the sustainability statement; we have used cross-references for the labour and water sections, and not for the climate note.
- For the areas we flag as more exposed, the main operating types are fresh-produce intake, cold storage and primary processing, with the highest exposure in Spain, Morocco and southern Italy.
Synthetic example for training only; figures and locations are illustrative and internally consistent.
Our material topics include process safety, air emissions, and worker exposure in our own plants, plus transport and contractor controls in the wider chain; we also identify a commercial upside from low-carbon product lines. We do not treat climate as immaterial, because weather disruption, energy-price swings and customer demand shifts already affect our operations and plans.
- Compared with the prior year, we recorded fewer lost-time incidents, more near-miss reports, and a larger share of sales from lower-carbon products.
- The supplementary topics we report alongside the main statement are the health-and-safety, emissions and supply-chain sections, with the exact signposting shown in the report index; we use reference links for the safety and emissions sections, but not for the climate discussion.
- The higher-risk operating types are batch blending, bulk storage and road distribution, and the main exposed geographies are the Gulf Coast of the United States, northern Germany and the Netherlands.
Synthetic example for training only; figures and locations are illustrative and internally consistent.
Quality ladder
- Basic
I have identified the sustainability topics we report on, including impacts, risks and opportunities.
- Better
I have listed the topics we cover, shown where each one is reported in our statement, and noted which items we have brought in by cross-reference.
- Best
I have mapped the topics we cover across our statement, identified the parts we include by cross-reference, and explained that the items we left out were not material for the period because our review found no significant effect, exposure or upside to report.
Check your understanding
Scenarios to work through
A preparer has mapped the year-end sustainability statement and finds that one topic standard is covered only through a short note in a separate report, while another topic is described in the main statement with a cross-reference to a detailed annex. The team is unsure whether the reader can tell where each topic sits and whether any topic has been left out.
During drafting, the climate team concludes that climate is not a material topic for the period, but the evidence file only says 'low exposure' and does not explain the judgement path. The sustainability lead asks whether that brief note is enough to support the conclusion.
A business unit reports that a new supplier region has increased labour and water-related exposure in the supply chain, while a separate product line has created a fresh growth path in a low-carbon market. The reporting team is deciding whether these are simply current-year updates or whether they belong in the section that tracks shifts in the undertaking’s material matters.
The reporting pack includes a table showing which topic standards are covered, but the team is unsure whether it also needs to say which extra disclosures were added because they were needed to explain the business properly. In one case, the extra material comes from a risk area in a high-exposure country and from a plant type with elevated operational risk.
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Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
IRO-2
within ESRS 2: General Disclosures
Guides that settle this question
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FAQ
Questions this page answers
Use it to understand the disclosure at a practical level before you start collecting data or writing the narrative. It is designed to help you prepare the disclosure, not to act as an official source.
The page lists the datapoints to prepare, including material impacts, risks and opportunities, business and value chain links, changes over time, required disclosures, where the information is disclosed, linked-by-reference items, extra disclosures, high-risk operations and locations, the cross-reference table, report location, and the not material flag.
Follow it as a working sequence for building the disclosure, from scoping the topic through to drafting the output. It is there to help a sustainability, HR or data owner turn source information into a usable draft.
The page is aimed at sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can provide the underlying data and evidence. Use the page to coordinate who prepares the inputs, who checks them, and who signs off the draft.
The page includes an evidence pack with five items to support assurance readiness. Use it to assemble the documents and records that back up the claims, the data, and the final disclosure.
The page says there are six assurance claims to verify, each with a claim, risk and evidence angle. Use them as a checklist to test whether the disclosure is supported and whether the evidence pack is complete.
The page lists common reporting gaps and mistakes so you can spot weak points before finalising the draft. Use that section to check for missing data, unclear scope, weak links between the narrative and evidence, and incomplete cross-references.
They are there to show how a disclosure can be structured and how the narrative and data table can work together. Treat them as examples only and adapt the approach to your own facts and evidence.
Use the visualisation ideas, narrative starters and content-index line to convert your prepared data into a first draft. The section is designed to help you move from source information to a clear report structure.
The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use them to organise the preparation work, track evidence, and support review before the disclosure is finalised.
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 other companies have presented similar information in practice.
More questions this page can help with