Disclosure focus
The practical focus is breadth and realism, not just a description of a few visible sites or initiatives. An organisation should think about coverage across its operations, products, services, suppliers and other upstream and downstream activities, and explain whether the picture it presents reflects the whole business or only selected areas.
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.
-
Main offerings
Commercial / strategyList the organisation’s main goods and services in plain business terms, covering what it actually sells or delivers in the reporting period.
Evidence Product catalogue, service line descriptions, sales materials, management reporting, legal entity or business unit summaries.
Watch for Product and service names drift from the sales catalogue or management pack, so the disclosure does not match what the business actually offers.
-
Value chain position
Strategy / operationsState where the organisation sits in the chain from inputs to end use, using an ordinary description of its role in relation to suppliers, operations and customers.
Evidence Operating model, supply chain maps, business model narrative, procurement and sales process documentation.
Watch for The role is described at the wrong point in the chain, so the position does not align with the operating model or supply chain map.
-
Upstream activities
Procurement / supply chainSummarise the main activities that happen before the organisation’s own operations, including the key stages and counterparties it depends on.
Evidence Supplier maps, procurement records, inbound logistics summaries, value chain analysis.
Watch for Upstream stages are left out or grouped too broadly, so the account misses the supplier-side activities the business depends on.
-
Downstream activities
Commercial / supply chainSummarise the main activities that happen after the organisation’s own operations, including how products or services move on to customers or end users.
Evidence Distribution maps, customer journey materials, channel reports, after-sales or service delivery documentation.
Watch for Downstream channels or end-use steps are omitted, so the description stops at the company boundary instead of following the product or service onward.
-
Key offerings
Finance / commercialIdentify the products or services that are most important to the business, based on scale, strategic importance or impact on the reporting period.
Evidence Revenue analysis, segment reporting, management accounts, product profitability or volume reports.
Watch for The wrong items are treated as key because the selection does not reconcile to revenue, volume or segment reporting.
-
Main customer groups
Sales / marketingName the customer groups or markets that matter most to the business, using the organisation’s own commercial segmentation.
Evidence CRM segmentation, sales reports, market plans, customer concentration analysis.
Watch for Customer groups are described using a different segmentation than the sales or CRM system, so the market split does not reconcile.
-
Period changes
Finance / strategyDescribe any material changes during the reporting period in the business mix, products, services, markets or operating setup that affect the disclosure.
Evidence Board papers, management updates, restructuring announcements, acquisition or disposal records, product launch logs.
Watch for The disclosure uses the year-end picture only and misses in-period changes, so the narrative is out of step with what changed during the year.
-
Sustainability link
Sustainability / strategyExplain how the business model connects to the organisation’s sustainability aims, showing the practical link between what it does and the objectives it says it is pursuing.
Evidence Strategy documents, sustainability plan, target tracker, board or committee papers, KPI dashboards.
Watch for The link is stated at a high level but not tied to the actual business model, so the objectives do not match the activities being reported.
-
Industry classification
Finance / reportingRecord the sector or industry category the organisation uses for reporting, based on the classification applied in its own reporting or external filings.
Evidence Statutory filings, investor materials, internal reporting taxonomy, sector codes used in systems.
Watch for The sector code is taken from a different classification set than the one used in filings or internal reporting, so the category does not match the source system.
-
Core internal activities
Operations / business unitsList the important activities carried out inside the organisation that are central to how it makes money or delivers its services.
Evidence Operating model, process maps, business unit descriptions, internal control narratives, management reporting.
Watch for A major internal activity is missed because the list is built from one function’s view, so the operational picture is incomplete.
-
Significance basis
Finance / strategyShow why the identified activity is significant, either by giving the share of revenue it represents or by explaining the business reason it is material.
Evidence Revenue split by activity, segment reporting, management commentary, significance memo or board paper.
Watch for Revenue share is calculated from the wrong denominator or the narrative reason is not supported, so the basis for significance does not hold up.
-
Fossil fuel flag
Finance / sustainabilityConfirm whether the organisation has fossil fuel-related activity and record the yes/no answer used for reporting.
Evidence Business line inventory, revenue mapping, legal entity activity list, management sign-off.
Watch for The yes/no answer is based on a broad business description rather than the actual activity list, so the flag is set against the wrong scope.
-
Chemicals flag
Finance / sustainabilityConfirm whether the organisation has chemicals-related activity and record the yes/no answer used for reporting.
Evidence Product and business line inventory, revenue mapping, legal entity activity list, management sign-off.
Watch for The flag is driven by a product label that does not match the underlying activity classification, so the category is misapplied.
-
Weapons flag
Legal / complianceConfirm whether the organisation has activity linked to controversial weapons and record the yes/no answer used for reporting.
Evidence Business line inventory, sanctions or restricted activity screening, legal entity activity list, management sign-off.
Watch for The answer is taken from a partial screening list and misses a relevant business line, so the prohibited-activity check is incomplete.
-
Tobacco flag
Finance / sustainabilityConfirm whether the organisation has tobacco-related activity and record the yes/no answer used for reporting.
Evidence Product and business line inventory, revenue mapping, legal entity activity list, management sign-off.
Watch for The flag is set using a brand or customer description rather than the underlying activity, so the tobacco classification is not aligned to the source records.
-
Related revenue
FinanceCapture the revenue linked to the flagged activity, using the same scope and period as the yes/no assessment and the organisation’s reported revenue basis.
Evidence General ledger, segment revenue schedule, product revenue mapping, management reconciliation.
Watch for The revenue figure is pulled from a different period or scope than the flag, so the amount does not reconcile to the activity being disclosed.
Before you start
- Have you fixed which products and services sit inside this write-up, and which parts of the supply and delivery chain you will describe?
- Before drafting, have you agreed the business lines, customer groups and any in-period changes that matter for this section?
- Have you decided which operating segments count as significant, and whether you will explain that using turnover share or another clear business reason?
- For any yes/no flags on sensitive activities, have you checked the scope against your own definitions so the answer is based on the same rule set throughout?
- Have you confirmed the figures or statements come from a traceable source and cover the same reporting period and basis across the whole section?
How to prepare it
Request the data
Request the business model and value chain evidence from Strategy / Commercial
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What does the business do, where does it sit in the chain, what changed this period, and which activities or revenue streams are most material for sustainability reporting?
Use your own internal labels first, then map them to the reporting fields. For example, describe products, services, customer groups, operating segments, supply chain stages, and any restricted or sensitive lines in the language your teams already use.
Weak request
Please provide the ESRS 2:SBM-1 information on products, value chain position, upstream and downstream overview, significant products and markets, changes in the period, sector classification, internal activities, revenue share, and fossil fuel / chemicals / controversial weapons / tobacco flags.
Why it fails: It uses framework language that many business owners will not recognise, so it is harder to answer quickly and accurately. It also mixes several different asks into one long sentence, which makes it easy to miss the practical evidence needed to support the narrative.
Better request
Please send the business description pack for [reporting period] for [entity / business unit]. We need your own names for the main products and services, where they sit in the chain, the key upstream and downstream stages, the most important customer groups and markets, what changed this period, and the basis for any activity or revenue stream you treat as significant. If any line of business needs separate handling because of policy, legal, or reputational sensitivity, please flag it and include the source files.
Formal email template
Subject: Request for business model and value chain evidence for [reporting period] Hi [name], We are preparing the sustainability reporting pack and need your help with the business description and value chain evidence for [entity / business unit]. Please send, for [reporting period]: - a plain-language description of the main products and services; - where each sits in the chain from inputs to customer delivery; - the main upstream and downstream stages we rely on; - the most important products, services, customer groups, and markets; - any changes during the period that affect how the business should be described; - the internal basis for why any activity, product, or revenue stream is treated as significant; - any lines of business that need separate handling because of policy, legal, or reputational sensitivity. Please use your team’s own terminology first, and include any source files or links that support the description. A possible LRA training template is attached; please adapt this to your organisation and check the official source before sign-off. If easier, you can return the information in the table below or in your own format. Thanks, [preparer name]
Short Teams / Slack version
Hi [name] — could you share the business description pack for [reporting period] for [entity / business unit]? We need the main products/services, where they sit in the chain, the key upstream/downstream stages, the important customer groups/markets, any changes this period, and the basis for anything treated as significant. Please use your team’s own terms first and attach the source files. I’ve got a possible LRA training template if helpful — please adapt it to your organisation and check the official source before sign-off.
Industry examples
Manufacturing
Context. A diversified industrial group with direct sales, distributors, and outsourced assembly.
Adapted request. Please share the product and channel summary for [reporting period]: main product families, where each sits in the supply chain, key supplier stages, main customer channels, any launches or exits this period, and the basis for treating any product line as significant.
Example response. Product family A; sold through distributors; upstream includes metal parts and packaging; downstream includes installation and servicing; new variant launched in Q2; treated as significant because it represents 42% of revenue and is a core strategic line.
Financial services
Context. A lender with retail and SME lending, brokered distribution, and servicing operations.
Adapted request. Please provide the business line summary for [reporting period]: main lending and fee-based services, where they sit in the delivery chain, key origination and servicing stages, main customer groups, any changes in product mix, and the basis for any line treated as significant.
Example response. Retail mortgages, SME term lending, and servicing fees; origination via branches and brokers; servicing in-house; no new product launches, but broker channel expanded; SME lending treated as significant because it is a major revenue stream and a strategic growth area.
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
Start by explaining how the organisation defined its main business lines, which activities were treated as significant, how upstream and downstream parts of the business were identified, and on what basis any revenue share or significance judgement was made.
Context note
Explain what the figures mean in practice by linking the organisation’s products and services to its place in the value chain, the markets or customer groups they serve, and the business areas that matter most for sustainability strategy.
Fluctuation statement
If there were changes in the period, describe what shifted in the product or service mix, which markets or activities were affected, and whether those changes altered the organisation’s sustainability focus or significance assessment.
Content index entry
SBM-1 Strategy, Business Model and Value Chain — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for SBM-1 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We limited the coverage figure to the markets where the product or service is not allowed, and we kept a note of how that boundary was set.
Risk An assurer will test whether the boundary is complete and whether any excluded markets were left out without a clear reason.
Evidence to check Market list used for the cut-off, legal or policy basis for the restriction, internal scoping note, and sign-off showing who approved the boundary.
We described the business in plain terms by mapping what we sell, where inputs come from, where outputs go, and where we sit in the wider chain.
Risk The assurer may check whether the picture is too high-level, omits key links, or misstates the organisation’s role in the chain.
Evidence to check Business model summary, value-chain map, operating model papers, procurement and sales summaries, and management review notes.
For the revenue split, we separated the figure into coal, oil and gas lines using the same source records throughout.
Risk The assurer will probe whether the split is based on a consistent method and whether any revenue was misclassified or left in a catch-all bucket.
Evidence to check Revenue ledger extracts, segment mapping, calculation workbook, source invoices or contracts, and reconciliation to the general ledger.
We used the same business description across the related sections so the coverage stayed aligned from one part of the report to the next.
Risk The assurer may look for inconsistencies between sections, duplicated wording that hides differences, or a mismatch between narrative and data tables.
Evidence to check Cross-reference matrix, draft comparison file, version history, and final editorial review comments.
We checked that each section of the disclosure matched the underlying operating model before publication, rather than relying on a single team’s draft.
Risk The assurer will test whether the narrative reflects the actual structure of the business and whether any late changes were missed.
Evidence to check Operating model documents, review emails, change log, and approval trail from finance, sustainability and business owners.
We selected the main product and customer groupings using the same internal basis we use for management reporting, then noted any material changes during the period.
Risk The assurer may challenge whether the groupings are genuinely significant, whether the basis is applied consistently, and whether period-on-period changes are complete.
Evidence to check Management reporting packs, product and customer segmentation analysis, period comparison schedules, and evidence of any reclassification decisions.
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 ownerThe request goes to a team that knows the reporting framework but does not own the business facts, so the answer comes back generic and cannot be tied to the actual products, markets or operating lines.
- Framework language firstThe data call uses reporting jargon instead of the organisation’s own terms, which makes local teams map the wrong activities and miss the right source records.
- No clear boundaryPeople collect figures without agreeing which entities, business lines or activities are in scope, so the same item is counted in one place and left out in another.
- Wrong period basisThe team pulls information from a different reporting window or cut-off date, so the data does not match the period being reported.
- Mixed counting methodOne pack combines turnover, headcount and other measures without separating the basis for each, which makes the figures impossible to compare or trace.
- Source labels lostOriginal system names, file references or line-item labels are stripped out during consolidation, so no one can trace a number back to the first record.
- Separate populations mergedDistinct sets such as main products, key customer groups or different activity types are rolled into one bucket, which hides what should be kept apart.
- Weak evidence trailThe file set does not keep the supporting notes, extracts and approval history together, so reviewers cannot see who checked the data or when.
Judgement needed
- What sits inside the reporting perimeter after a dealIf a business has been bought or sold during the period, explain which operations are counted in the description of products, markets and supply links, and make clear the cut-off date or averaging basis used.
- How to handle different country labels for the same activityWhere local business descriptions or sector labels differ across countries, use one group-wide naming approach, state any mapping used, and explain any material exceptions.
- Whether a borderline activity is treated as part of the core offerFor activities that are close to the edge of the main business, state the judgement used to include or exclude them from the description of significant offerings or customer groups.
- How to describe links in the supply and customer chain when visibility is partialIf the organisation does not have full line-of-sight to every step before or after its own operations, explain the level of detail available and whether the picture is based on direct records, estimates or a mix of both.
- Which internal activities count as significantWhen deciding which in-house functions or processes are material enough to mention, explain the threshold or reasoning used and keep the same approach across the group unless a local difference is material.
- How to decide whether a business line is material enough to nameIf a product, service or market is close to the significance threshold, disclose the basis for treating it as significant or not, and show how that judgement links to the organisation’s own business model.
- How to present changes during the yearFor shifts in the business mix, customer base, operating footprint or supply links during the period, describe what changed, when it changed, and whether the figures or narrative reflect the opening state, closing state or the full-year average.
- How to deal with sensitive detail and small populationsWhere naming a market, customer group or activity could expose confidential information or where the population is very small, aggregate the data to a safer level and explain the grouping rule used.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We describe a business that makes packaged food ingredients and finished products, with our own operations in Europe and North America, plus a supply base for agricultural inputs, packaging and logistics, and customers that include retailers, food manufacturers and foodservice groups. In the period, our main lines were bakery ingredients and chilled meals; these were the largest parts of revenue, and we note that the mix shifted toward higher-margin convenience products, which we treat as more relevant to our sustainability aims because they depend on lower-waste packaging and more traceable sourcing.
- We classify ourselves in a food-processing sector grouping; the activities that matter most internally are procurement, manufacturing, cold-chain distribution and product development, and we regard them as significant because they account for 92% of revenue.
- We do not operate in fossil fuels, chemicals or controversial weapons.
This example shows how a reporter can summarise what it makes, where it sits in the chain, which products and customers matter most, what changed during the year, why those lines are sustainability-relevant, how it classifies itself, which internal activities are most important, and whether it is linked to the three specified sensitive areas.
We are an industrial equipment business that designs, assembles and services energy-efficient pumps and control systems, with component sourcing from specialist suppliers and sales to utilities, process industries and infrastructure operators. Our most important lines were pump systems and digital monitoring services; together they made up most of the year’s turnover, and we highlight them because they support energy efficiency, asset life extension and lower maintenance waste.
- We place ourselves in an industrial equipment sector grouping; the internal work we see as most significant is engineering, assembly, field service and software support, and we consider it significant because it generated 88% of revenue.
- We do not operate in fossil fuels, chemicals or controversial weapons.
This example shows a different kind of reporter using the same disclosure to explain its products, chain position, key markets, year-on-year mix changes, sustainability links, sector grouping, major internal functions, and the three sensitive-area flags.
Quality ladder
- Basic
I operate in consumer goods and report that 12% of my revenue comes from higher-risk activities.
- Better
I sell household products mainly to retailers in Europe, source most inputs from Asia, and say that 12% of my revenue comes from higher-risk activities because those lines are still material to my business mix.
- Best
I sell household products mainly to retailers in Europe, source most inputs from Asia, and report that 12% of my revenue came from higher-risk activities this year, with the share unchanged from last year because my core product mix and customer base stayed broadly stable.
Check your understanding
Scenarios to work through
A group sells packaged food through supermarkets and online subscriptions. During drafting, the team can describe the main offerings, but the supply chain map is split across procurement, logistics and sales, and no one has yet agreed which parts sit before the group and which sit after it.
A manufacturer has added a new product line in the year, which now accounts for 18% of turnover, while an older line still makes up 62%. The reporting team is unsure whether to mention only the largest line or also explain the newer line because it is growing quickly and is linked to the group’s sustainability plan.
A services group reports under a broad industry label, but its main activity is actually software implementation, with a smaller managed-support arm. The finance team wants to name only the broad sector label and leave out the internal activities because they think the sector code is enough.
A diversified group has a small chemicals unit, a larger consumer products arm, and no fossil fuel, weapons or tobacco operations. The drafting team is unsure whether they should still answer the industry-screening items and whether a zero answer needs any related turnover explanation.
Ask the Knowledge Hub AI Assistant about this disclosure
Get practical answers for your reporting context.
Check your text
Paste one or two paragraphs. The fragment is used for this check only and is not stored in your conversation.
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
SBM-1
within ESRS 2: General Disclosures
Guides that settle this question
Related & explore
More in ESRS 2 →Browse full catalogue →Search all disclosures →
FAQ
Questions this page answers
Use the page’s plain-language explainer, then work through the preparation steps to gather the listed datapoints and build a draft. The page is designed to help you turn source information into a disclosure, not to replace your own judgement or internal review.
The page lists the datapoints to prepare, including offerings, value chain position, upstream and downstream activities, customer groups, period changes, sustainability link, industry classification, core internal activities, significance basis, the four product flags, and related revenue. Use that list as your collection checklist so you can see what is already available and what still needs to be sourced.
The page gives a practical preparation route and a set of datapoints, but it does not prescribe a formal methodology. In practice, use the page to align the scope of the disclosure with the business information you can evidence, then document how you treated any period changes, classifications, and revenue links.
The page is set up for practitioner use, so ownership should sit with the people who can evidence each datapoint and explain it clearly. A sensible approach is to assign each item in the datapoint list to the most relevant internal owner and keep the evidence pack under one coordinated review.
The page includes an evidence pack with five items and also gives six assurance claims to verify. Use those together to assemble a file that shows the claim, the risk if it is wrong, and the evidence supporting it, so a reviewer can trace the disclosure back to source material.
The page has a section on common reporting gaps and mistakes, which is there to help you spot weak points before sign-off. Use it as a pre-submission check against your draft, especially where the disclosure depends on classification, revenue linkage, or period changes.
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the datapoints, track evidence, and move from source information to a draft disclosure in a structured way.
The Download Centre also provides a printable Library Card in .pdf format. It is there as a practical companion to the workbook, so you can keep the key points, checks, and drafting prompts to hand while preparing the disclosure.
The page includes a draft-output section with visualisation ideas, narrative starters, and a content-index line. Use those prompts to convert your collected data into a first draft, then check it against the evidence pack and the common gaps list.
Yes. It includes a 'From company reports' table that links to real published reports at the pages where the topic is disclosed, and it also shows synthetic illustrative examples. Use the real-report links for reference and the synthetic example to see how a disclosure can be structured.
More questions this page can help with