Disclosure focus
The practical emphasis is on whether the response is broad enough to cover the parts of the business where the workforce is affected, rather than being limited to a few visible or flagship sites. An organisation should be able to show how actions are prioritised, where they apply, and whether the resources are sufficient to deliver them across relevant operations, functions or locations. The aim is to give a clear picture of implementation, not just commitment.
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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Actions carried out
Sustainability / issue ownerA plain summary of the steps the organisation has already put in place in response to the issue, focusing on what was actually done rather than plans.
Evidence Action logs, project updates, management papers, implementation trackers, or signed-off workplans.
Watch for The narrative is written from the plan rather than the implemented actions, so it does not match the delivery records.
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Prevention and mitigation
Risk / controls ownerThe measures used to stop the issue happening, or to reduce its effect where it cannot be avoided, described in practical business terms.
Evidence Risk treatment plans, control registers, remediation trackers, operating procedures, and approval notes.
Watch for Prevention steps are mixed up with general policy statements, so the reported measures do not reconcile to the control register.
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Community programmes
Community investment / social impactThe community-facing initiatives the organisation runs or supports, with enough detail to show what the programme is and who it is for.
Evidence Programme briefs, community investment records, partnership agreements, grant files, and delivery reports.
Watch for A local project is reported as a community programme even though it sits outside the defined community portfolio.
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Impact category
Sustainability / impact assessmentThe kind of impact being described, stated in a way that clearly distinguishes the main issue from other possible impact types.
Evidence Impact assessment, incident review, stakeholder complaint log, or issue classification note.
Watch for The impact is put in the wrong category, so the label does not align with the underlying assessment.
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Response actions
Issue owner / operationsThe concrete steps taken to address the impact, including operational changes, engagement, remediation, or other follow-up actions.
Evidence Corrective action tracker, meeting minutes, remediation plan, and evidence of completion.
Watch for Planned follow-up is reported as completed action, so the narrative does not reconcile to the action tracker.
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Business trade-offs
Strategy / executive sponsorAny practical balancing decisions made between the impact issue and business needs, such as land use, operations, cost, or continuity.
Evidence Decision papers, executive approvals, project options analysis, and board or committee papers.
Watch for The trade-off is described without the actual decision basis, so the reported balance does not match the approval paper.
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Performance measures
Performance reporting / analyticsThe key measures used to track performance on the issue, with the metric names and values kept consistent with internal reporting.
Evidence KPI dashboard, management report, scorecard, or source system extracts.
Watch for The KPI is taken from a different definition than the management dashboard, so the figure does not reconcile to the source report.
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Outcome measures
Monitoring / evaluationThe indicators used to show what changed as a result of the organisation’s actions, rather than just what was done.
Evidence Outcome tracking report, evaluation notes, survey results, or impact review.
Watch for Activity counts are reported as outcomes, so the measure captures output rather than the actual result.
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Review cadence
Reporting / monitoring leadHow often the organisation checks or updates the relevant measures, stated as the actual monitoring interval used in practice.
Evidence Monitoring schedule, reporting calendar, control timetable, or review plan.
Watch for The stated cadence does not match the real review cycle, so the frequency is a period error.
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Incident count
Incident management / operationsThe total number of relevant incidents recorded for the reporting period, counted once per incident using the agreed incident definition.
Evidence Incident register, case management system, complaints log, or security/operations records.
Watch for The count is taken from a partial log or a different period, so it does not reconcile to the incident register.
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Incident type
Incident management / legalA short description of what kind of incident occurred, using the organisation’s own classification for land, rights, protest-related, or similar events.
Evidence Incident forms, case notes, investigation records, and classification guidance.
Watch for The incident is assigned the wrong type, so the category does not match the case file.
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Incident seriousness
Incident management / riskThe assessed level of seriousness for the incident, using the organisation’s agreed severity scale and the facts of the case.
Evidence Severity assessment, investigation report, escalation record, and risk matrix.
Watch for The severity rating is applied using a different scale or threshold, so the level does not align with the investigation outcome.
Before you start
- Have you decided which land-related actions, prevention steps, mitigation measures and community programmes you will include, and which ones sit outside this disclosure?
- For each action, have you fixed the time basis and reporting period you will use so the figures and descriptions line up with the same cut-off?
- Can every number and statement be traced back to a source record, owner or system, or is any part still only estimated or anecdotal?
- Have you agreed the working definitions you will use for the kinds of impact, incident and severity you are describing so the team applies them consistently?
- Have you settled which performance measures, outcome signals and review cadence you will report, and whether they are the ones actually used in operations?
How to prepare it
Request the data
Request the community actions and tracking evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What actions, programmes, measures, indicators and incident tracking do we have in place for our affected local communities, and how are we monitoring whether they are working?
Use your organisation’s own terms first, then map them to the disclosure items. For example, if you talk about neighbourhood engagement, site liaison, social investment, grievance handling or local impact tracking, use those labels in the request and only translate them afterwards for reporting. This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off.
Weak request
Please provide the ESRS S3:S3-3 actions and resources data, including all actions implemented, prevention and mitigation measures, community programmes, impact types, actions taken, trade-offs, KPIs, outcome indicators, monitoring frequency, and incidents.
Why it fails: It uses framework language that many operational teams will not recognise, so the owner may not know which records to pull. It also does not say which sites, systems, time period or internal labels to use, so the response is likely to be incomplete or inconsistent.
Better request
Please send the community engagement, local impact and incident-tracking records for [period] across [sites/boundary]. Include the actions already in place, any reduction measures, local programmes, the impact categories you use, the follow-up actions, any balancing decisions, the measures you track, how often you review them, and any land/community-rights/protest incidents. Use your own team labels and add the source system and file reference.
Formal email template
Subject: Request for community action and monitoring evidence for [reporting period] Hi [name/team], We are preparing the sustainability reporting pack and need your help with the evidence for our local community actions and tracking. Please send, for [reporting period] and [boundary / sites], the information you hold on: - actions already put in place to address local community impacts; - measures used to prevent or reduce those impacts; - any community programmes or local initiatives; - the main impact types you track; - the actions taken in response to those impacts; - any trade-offs or balancing decisions you recorded; - the indicators you use to track progress; - the outcome measures you review; - how often you review them; and - the number, type and seriousness of any incidents linked to land, community rights or protests. Please return the data in your own operational language where possible, with a short note explaining the terms you use internally. If you have multiple sources, please include the source system, owner, date extracted and any caveats. This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off. Thanks, [preparer name] [team] [contact details]
Short Teams / Slack version
Hi [name] — could you share the community actions and tracking evidence for [period] across [sites/boundary]? Please include what’s been done, any prevention/reduction measures, community programmes, the impact types you track, actions taken, any trade-offs noted, the KPIs/outcome measures, review frequency, and any incidents (count, type, seriousness). Use your team’s own labels and add the source file/system. Thanks.
Industry examples
Mining
Context. A site team tracks land access, local hiring commitments, grievance cases and community investment in separate logs.
Adapted request. Please share the site community log, grievance tracker and local investment register for [period] for [mine/site]. Include the actions already in place, any measures to reduce local impacts, community programmes, the impact types you record, follow-up actions, any land-use balancing notes, the indicators you monitor, review frequency, and any incidents linked to land access, community rights or protests.
Example response. A table with one row per action or incident, showing the site, internal category, action name, impact type, follow-up action, trade-off note, indicator, outcome measure, review cadence, incident count, incident type and seriousness, plus links to the source logs.
Food & agriculture
Context. An agribusiness team manages farmer engagement, water-use mitigation, local community projects and protest monitoring through regional operations.
Adapted request. Please send the regional community and farmer-engagement records for [period] across [regions/farms]. Include the measures already in place to reduce local impacts, community programmes, the impact types you track, actions taken, any land or water balancing decisions, the KPIs and outcome measures you review, how often you review them, and any incidents involving land, rights or protests.
Example response. A regional summary table with each programme or action, the internal label used, the affected community group, the mitigation step, the balancing note, the KPI, the outcome measure, the review frequency, and incident counts by type and seriousness, with source references to the regional tracker.
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 which definitions were used for each topic, how the figures were compiled from the underlying records, and what basis was used to classify actions, impacts, indicators, incidents and severity.
Context note
Set out what the numbers show about the organisation’s management of community-related impacts, including the scale of actions taken, the kinds of outcomes tracked, and the nature of any incidents recorded.
Fluctuation statement
If the figures moved materially, describe the operational or community factors behind the change, noting whether it reflects more activity, different impact types, altered monitoring, or a change in incident severity.
Content index entry
S3-3 Actions & Resources — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for S3-3 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We linked the incident count back to the related complaint routes and follow-up actions so a reviewer can trace each case through the reporting pack.
Risk The cross-links may be incomplete, inconsistent, or point to the wrong case set, making the incident figure hard to verify end-to-end.
Evidence to check ['Case register showing unique IDs used across the incident log, complaint records, and response-action tracker', 'A sample trace from one reported incident to the related channel record and action record', 'Draft report cross-reference map or index used before publication']
We used the same tracking notes and review outputs that management used to judge whether community-related actions were working, rather than relying on a separate narrative prepared only for the report.
Risk The statement may overstate how outcomes were assessed if there is no documented method, no follow-up evidence, or only anecdotal review.
Evidence to check ['Monitoring templates, KPI sheets, or review dashboards used to assess action progress', 'Meeting notes or management reviews showing how effectiveness was judged', 'Evidence of any changes made after review, such as revised actions or closure notes']
Where community measures had to be balanced against other operational pressures, we documented the trade-off and the basis for the chosen approach before finalising the disclosure.
Risk The report may present a neat explanation while the underlying decision trail is missing, inconsistent, or not approved.
Evidence to check ['Decision papers or emails showing the competing pressures considered and the chosen response', 'Approvals from relevant managers or governance forums', 'Version history showing how the wording on trade-offs was settled']
The figures and narrative were built from the action tracker and supporting records that the team uses to manage the material issues, with resource use captured in the same working papers.
Risk The disclosure may be based on partial records, outdated inputs, or unsupported estimates of actions and resources.
Evidence to check ['Action plan or tracker listing planned, underway, and completed measures', 'Budget, staffing, or supplier records supporting the resource claims', 'Reconciliation between source records and the final report tables or text']
We checked that the transition measures were described alongside the other community topics they affect, so the report shows how the topics connect rather than treating them in isolation.
Risk The narrative may miss important links between measures and related topics, or may imply a connection that is not supported by the underlying analysis.
Evidence to check ['Topic mapping or issue matrix showing linked community themes', 'Draft sections demonstrating how related topics were cross-referenced', 'Internal review comments confirming the connections were tested before sign-off']
For the incident figure, we relied on cases that had been confirmed through our review process and counted the types separately so the totals can be traced back to the underlying records.
Risk The count may include unverified cases, duplicate entries, or unclear categorisation, which would weaken the assurance trail.
Evidence to check ['Confirmed incident log with status fields showing verification outcome', 'Classification rules used to assign incident types', 'Reconciliation of the reported totals to the underlying case list']
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 owner askedThe request goes to a team that only sees part of the work, so the record misses actions, budgets, or monitoring details held elsewhere.
- Framework terms used too earlyPeople are asked for answers in disclosure language instead of the business terms they use day to day, which leads to mismatched or unusable source data.
- Scope not pinned downThe team never agrees which sites, communities, projects, or time period belong in the pull, so different contributors send different populations.
- Wrong timing basisData is gathered using a different reporting window or cut-off date from the one used in the rest of the pack, so the figures do not line up.
- Counting bases mixedOne source counts programmes, another counts activities, and another counts cases, but the collector merges them as if they were the same measure.
- Source labels lostOriginal system names, file titles, or local category labels are stripped out during collection, making it hard to trace what each item actually came from.
- Separate groups mergedImpacts, actions, or indicators that should stay in distinct buckets are combined into one list, which hides differences that matter for the disclosure.
- Evidence trail incompleteThe pack is assembled without the underlying files, dates, and reviewer sign-off, so no one can show how the numbers or descriptions were checked.
Judgement needed
- What counts after a buy-in or sale-outUse the reporting cut-off you have set for the period, then explain whether newly added or removed sites, teams, or communities are included only from the date control changed or for the full period.
- When local labels do not line upWhere the same issue is described differently in different countries, map each local label to one internal category and disclose the mapping rule so readers can see how like-for-like grouping was done.
- People or places near the boundary of scopeDecide in advance how you will treat groups that are partly affected, indirectly linked, or only occasionally touched by the activity, and state the inclusion rule you used.
- Choosing the timing basis for actions and resultsIf implementation, monitoring, and outcome data are captured on different dates, pick one timing basis for the narrative and say which date or period drives the figures.
- Measured figures versus estimatesIf some values come from site records and others from assumptions or sampling, identify which parts are estimated, describe the method used, and keep the split clear in the explanation.
- Rounding small numbers without losing the storyApply one rounding rule across the disclosure, note it if it affects totals or percentages, and make sure the rounded figures still reconcile to the underlying counts.
- Protecting privacy when the group is too smallWhere naming a community, household, or individual could expose personal data, combine the information to a higher level and explain the aggregation rule used.
- Counting the same action across several workstreamsIf one initiative supports prevention, mitigation, and community programmes at the same time, decide whether to report it once or in each relevant bucket and explain the approach so it is not double counted.
- Separating operational actions from wider programmesWhen a measure serves both day-to-day site management and a broader community effort, describe the main purpose you assigned to it and why that classification was chosen.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We are providing this as a synthetic example only. During the year, we put in place land-use controls, supplier checks, and local engagement measures to reduce pressure on nearby communities, and we also ran community support programmes covering water access and grievance handling.
- The main issue was a change in land access linked to a new site expansion; we paused one parcel, redesigned access routes, and offered compensation and livelihood support where needed.
- We tracked the work through monthly site reviews and quarterly community reporting, using indicators such as hectares affected, households reached, complaints closed, and restoration progress; the latest review showed 18 hectares affected, 12 hectares restored, 240 households engaged, and 36 complaints received, of which 33 were closed.
- We recorded 4 incidents in total: 2 related to land access, 1 involving community rights concerns, and 1 protest at a site gate; all were assessed as medium severity, with no fatalities or permanent displacement.
Synthetic illustration for practitioner learning only; not legal or compliance advice.
This is a synthetic example for illustration only. We implemented mitigation steps for a transmission corridor by narrowing the footprint, adjusting tower locations, and strengthening consultation with nearby residents and land users, while also funding local skills and access programmes.
- The issue involved land take and temporary access restrictions; we chose a slightly longer route to avoid sensitive areas, accepted higher build costs, and kept a record of the trade-off between land protection and project economics.
- Our indicators were reviewed every two months and included land disturbed, compensation paid, meetings held, and restoration completion; at the latest check, 9 hectares were disturbed, 7 hectares were restored, 14 meetings were held, and 95% of agreed compensation had been paid.
- We logged 3 incidents: 1 land access dispute, 1 complaint about community consultation, and 1 peaceful protest; each was rated low severity, and all were resolved without escalation.
Synthetic illustration for practitioner learning only; not legal or compliance advice.
Quality ladder
- Basic
We logged 3 incidents.
- Better
We logged 3 incidents, split between land access, community rights and local protest issues, and we tracked them monthly using our internal case log.
- Best
We logged 3 incidents this year, covering land access, community rights and local protest issues; we reviewed them monthly against our case log, and the rise from 1 last year mainly reflects better reporting rather than more harm.
Check your understanding
Scenarios to work through
A farming supplier has started a grievance hotline, a land-access mediation process, and a community skills fund after complaints from nearby residents. The draft note also mentions a new road project, but it is not clear whether that is part of the response or just a separate capital plan.
A site team has introduced extra site checks, revised contractor rules, and a local dialogue forum after tensions with an indigenous community over access to customary land. Management wants to say the actions were taken, but not mention that the new rules slowed operations and increased transport costs.
A preparer has data showing that a community training programme reached 120 people this quarter, while a land-restoration project covered 45 hectares. The team also tracks complaint resolution time and attendance at stakeholder meetings, but no one has agreed how often these figures are reviewed.
A company has recorded two separate incidents this year: one protest at a project gate and one complaint about restricted access to grazing land. The draft says both were “minor issues” because no one was injured, but the community says the access restriction affected livelihoods for several weeks.
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Peer comparison uses examples on this card, not prevalence in the report corpus.
Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
S3-3
within ESRS S3: Affected Communities
Guides that settle this question
Related & explore
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FAQ
Questions this page answers
Use the page’s plain-language explainer, then work through the step-by-step preparation section to gather the listed datapoints, build the evidence pack and shape a draft. The page is designed to help you turn source material into a disclosure-ready narrative rather than to act as an official standard.
The page says to prepare actions carried out, prevention and mitigation, community programmes, impact category, response actions, business trade-offs, performance measures, outcome measures, review cadence, incident count, incident type and incident seriousness. Use that list as your collection checklist before drafting.
The page does not give a formal methodology, but it does give a step-by-step preparation flow and a set of datapoints to organise your scope around. In practice, use those items to define what you are covering, what evidence you need and how often the information is reviewed.
The page is written for sustainability/ESG managers, HR or data owners and assurance reviewers, so ownership should sit with the people who can source the underlying data and sign off the evidence. Use the workbook and evidence pack to make responsibilities clear before drafting.
The page says there are six assurance claims to verify, each with a claim, risk and evidence prompt. Use that section to check the draft against the supporting documents before it goes to review.
The page includes an evidence pack with five items to support assurance readiness. Build it alongside the draft so the underlying records are easy to trace, check and hand over to reviewers.
The page lists common reporting gaps and mistakes to help you spot weak or incomplete drafting. Use that section as a pre-submission check so the narrative, data and evidence line up.
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the preparation steps, track the required datapoints and assemble the assurance evidence before turning it into a draft.
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 evidence pack and review the draft output.
The page includes synthetic illustrative example disclosures, including a quantitative table where relevant. Use them as a drafting aid to see how the information can be presented, but treat them as examples only.
The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. Use those prompts to convert your collected data into a structured draft that is easier to review and assurance-check.
More questions this page can help with