Disclosure focus
The practical focus is on breadth and relevance: the organisation should cover the stakeholder groups and parts of the business that are actually affected, rather than relying only on a few well-known or flagship sites. The aim is to show how the organisation has identified and reflected stakeholder perspectives across its operations, value chain and material topics in a way that is proportionate to its footprint and impacts.
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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Stakeholder groups
Sustainability / stakeholder engagementList the main external and internal groups the organisation treats as important for this topic, using the same grouping used in reporting and governance papers.
Evidence Stakeholder map, materiality papers, engagement plan, board or committee papers, strategy documents.
Watch for The group list does not reconcile to the stakeholder map used by strategy or materiality work, so a key population is left out or split differently.
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Engagement approach
Sustainability / stakeholder engagementDescribe the ways the organisation engages those groups, such as meetings, surveys, forums, consultations or other channels, and keep the description aligned to the actual process used.
Evidence Engagement logs, consultation records, survey plans and results, meeting minutes, stakeholder programme tracker.
Watch for The engagement method description does not match the actual channel log, so a channel is misclassified or a whole engagement route is missed.
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Stakeholder concerns
Sustainability / stakeholder engagementCapture the main issues, expectations or concerns raised by those groups, grouped in the same way the organisation records them for reporting and follow-up.
Evidence Survey outputs, consultation summaries, meeting notes, issue trackers, grievance or feedback logs.
Watch for The stated concerns use a different issue taxonomy from the source records, so categories are merged or split differently from the underlying feedback.
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Board briefing route
Company secretariat / governanceExplain how the board receives updates on stakeholder matters, including the route, frequency and source of the information it sees.
Evidence Board packs, committee papers, reporting calendar, governance reporting lines, minutes showing receipt of updates.
Watch for The reporting route does not reconcile to board and committee papers, so the update path or reporting frequency is described for the wrong governance body.
Before you start
- Have we already decided which outside groups count for this write-up, and which ones sit outside it?
- For each group, have we settled the way we will describe how we hear from them — for example, meetings, surveys, forums, or other channels?
- Have we agreed which concerns or viewpoints are the main ones to summarise, rather than every comment we have ever received?
- Do we know how the board or equivalent top group is kept in the loop on these matters, and who passes the information up?
- Can we point each statement back to a named internal source, so the wording is traceable before sign-off?
How to prepare it
Request the data
Request stakeholder engagement and board briefing evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What stakeholder groups did we engage, what did they tell us, and how was that fed up to the board or equivalent leadership group during the reporting period?
Use your organisation’s own labels first, then map them to the disclosure. For example, use your usual names for stakeholder groups, consultation channels, leadership packs, and board updates rather than framework terms.
Weak request
Please provide the stakeholder engagement evidence for SBM-2.
Why it fails: It uses framework language only, gives no clue which internal team should respond, and does not say what records, dates, channels, or leadership updates are needed. That makes it hard to find the right evidence and easy to return an incomplete pack.
Better request
Please send the stakeholder engagement log, consultation notes, and board or committee update pack for [reporting period], showing the groups we spoke to, how we heard from them, the main issues they raised, and where those points were summarised for [board / committee name]. Include the source file, date range, and owner for each record.
Formal email template
Subject: Request for stakeholder engagement and board update evidence for [reporting period] Hi [name/team], I’m pulling together the evidence pack for our sustainability reporting and need your help with the stakeholder engagement material for [reporting period]. Please could you share, or point me to, the records covering: - the main stakeholder groups we engaged during the period; - how we engaged them and through which channels; - the main issues, concerns, or views they raised; - how those points were summarised and taken up in updates to the board / [your internal leadership group name]. Please include the source documents or tracker extracts, plus any notes on the reporting boundary, dates, and who owns each record. If it helps, you can send this back in your usual format and I’ll map it for the disclosure. Please also flag anything confidential or sensitive so we can handle it appropriately. Thanks, [preparer name]
Short Teams / Slack version
Hi [name] — could you send over the stakeholder engagement log / board update pack for [reporting period]? I need the groups engaged, the channels used, the main points raised, and the note or deck that went to [board / committee name]. Please include the source file and dates. I’ll map it to the reporting pack.
Industry examples
Manufacturing
Context. A plant-based group with site-level employee forums, supplier reviews, and community liaison meetings near major facilities.
Adapted request. Please share the site engagement log and leadership update pack for [reporting period], covering employee reps, key suppliers, and local community contacts. I need the topics raised, the way each conversation happened, and the note that went to the executive team or board committee.
Example response. Attached: site engagement tracker export, supplier forum minutes, community meeting summary, and Q4 board pack slide. The tracker lists each group, date, topic, owner, and the route used to brief leadership.
Financial services
Context. A regulated business with investor relations calls, customer feedback channels, and periodic updates to the board risk committee.
Adapted request. Please provide the stakeholder feedback summary and committee paper for [reporting period], showing investor, customer, and employee inputs, the channels used to gather them, and the paper or slide deck sent to the board risk committee.
Example response. Attached: IR call notes, customer insight summary, employee pulse survey output, and risk committee paper. The pack shows the main themes, dates, source files, and the committee briefing route.
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
State which stakeholder groups were included, how they were grouped, and what counts as an engagement method, interest, or board briefing in this disclosure.
Context note
Explain what the stakeholder map shows about who the organisation listens to, how it gathers views, and how those views reach the board.
Fluctuation statement
If the mix of groups, engagement channels, or board reporting changed, note whether that reflects a shift in priorities, coverage, or the way input is escalated.
Content index entry
SBM-2 Interests and Views of Stakeholders — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for SBM-2 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We prepared the coverage figure from our own engagement records, using a short summary of the main ways we spoke with affected groups and the main groups involved in each relevant category.
Risk An assurer may question whether the summary is complete, whether the engagement methods were actually used, and whether the groups named match the underlying records.
Evidence to check Engagement logs, meeting notes, attendance lists, consultation summaries, stakeholder maps, and the internal working paper showing how the summary was compiled from source records.
For the disclosed operations, we selected the relevant stakeholder groups and engagement channels on a consistent basis, then checked that the summary reflects the actual mix of contacts rather than a selective or one-off account.
Risk The main risk is cherry-picking: the reporter may have left out less favourable engagement, omitted a relevant group, or described a broader process than the evidence supports.
Evidence to check Scope memo, inclusion/exclusion rationale, source files for each engagement channel, cross-checks between the draft disclosure and the underlying records, and sign-off notes from the preparer and reviewer.
We built the statement on stakeholder feedback already held in our files and used it to describe what key groups told us about the business model and strategy, without overstating how representative any single view was.
Risk An assurer will probe whether the reported views are genuinely supported by evidence, whether they are current, and whether the wording overstates consensus or certainty.
Evidence to check Survey outputs, interview notes, grievance or feedback records, workshop summaries, analysis papers, and evidence showing how the team distinguished recurring themes from isolated comments.
Before publication, we checked that the summary of stakeholder views was aligned with the latest internal analysis and with the material issues already identified for the reporting period.
Risk The concern is that the disclosure may be out of date, inconsistent with other sections, or based on an earlier draft after the underlying analysis changed.
Evidence to check Latest issue-analysis pack, version history, review comments, reconciliation between the disclosure and related sections, and approval evidence showing the final check before release.
We informed the board and relevant committees using briefing papers and meeting packs that set out the main stakeholder concerns, the related impacts and risks, and any points raised by worker representatives.
Risk An assurer may test whether the governance update was timely, whether it covered the right topics, and whether the board-level reporting is supported by actual papers and minutes.
Evidence to check Board and committee packs, minutes, presentation slides, management reports, escalation notes, and records showing when worker-representative input was included and how it was passed up the line.
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 team asks the wrong business lead for the input, so the information comes from someone who does not run the stakeholder process or hold the source records.
- Framework language firstPeople ask for answers in disclosure jargon instead of the organisation’s own terms, which makes the source data hard to map back to real meetings, surveys, or feedback logs.
- Scope left vagueNo one fixes which parts of the business, which stakeholder groups, or which activities are in scope, so the data set ends up mixing unlike populations.
- Timing basis not setThe team does not agree the reporting period or cut-off point before collection starts, so some inputs relate to a different time window than others.
- Counting basis mixedOne source is counted by individual people while another is counted by contacts, sessions, or responses, and the totals are then combined as if they were the same measure.
- Source labels lostOriginal tags from the survey, meeting note, or feedback register are stripped away, so later reviewers cannot tell where each figure or theme came from.
- Separate groups mergedInputs from different stakeholder groups are rolled together even though they should stay distinct, which hides who said what and weakens the final evidence trail.
- Evidence details missingThe file set does not keep the date, owner, version, or source reference for each input, so the team cannot show how the data was assembled.
- No sign-off trailThe collection pack is used without a clear review and approval record, so nobody can prove who checked the data before it moved into drafting.
Judgement needed
- Which stakeholder groups to include when the business footprint changesIf a purchase, sale, closure or new country changes who is affected, explain the cut-off you used for the period and whether the list of groups reflects the opening, closing or average footprint.
- How to handle groups that sit just inside or just outside the reporting boundaryWhere a population is partly covered, set out the rule used to include or exclude it and say how you treated people or organisations that were only indirectly affected.
- Different local labels for the same type of stakeholderWhen country teams use different names or legal categories for similar groups, map them to a common internal label and disclose the mapping so readers can see what was combined.
- Choosing the basis for the engagement summaryIf engagement happened through several channels or at different times, explain whether you summarised the latest view, the most frequent view, or a weighted view, and why that basis was chosen.
- Deciding between direct feedback and management interpretationState whether the reported interests and views come straight from stakeholder input or from management’s synthesis of that input, and describe any filtering or prioritising used.
- Using estimates where full counts are not availableIf you cannot measure every response or contact, say which figures are estimated, what data source or method was used, and how the estimate was checked against available records.
- Rounding and small-number handling in the stakeholder summaryExplain the rounding rule used for counts or percentages and make sure the rounded figures still tell a consistent story across the groups and channels you describe.
- Protecting privacy when the group is too small to show separatelyWhere naming a group could identify individuals, combine categories or remove detail, and disclose that the presentation has been aggregated to avoid exposing personal information.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We keep the board updated through a standing pack for each meeting, plus ad hoc briefings when a material issue emerges. Our main external groups are employees, suppliers, customers, local communities, investors and regulators; we hear from them through site visits, surveys, grievance channels, supplier reviews, customer panels and community meetings.
- The views we hear most often are about safe working conditions, product quality, timely payment, lower emissions, packaging reduction and clearer reporting.
- In the last year, 1,240 employees took part in surveys or town halls, 86 suppliers joined review calls, 420 customers gave feedback through panels or complaints, and 18 community meetings were held; each of these feeds into the papers sent to directors and committee members before decisions are made.
Illustrative only: shows how a company can describe who it engages, how it does so, what those groups care about, and how that information reaches the board.
We use tenant forums, contractor meetings, investor calls, resident drop-ins and regulator check-ins to gather views from the groups most affected by our operations. Those groups include tenants, building users, contractors, investors, nearby residents and public authorities, and their main concerns are building safety, energy use, service quality, accessibility, rent affordability and complaint handling.
- During the year, 64 tenant meetings were held, 27 contractor sessions took place, 12 investor updates were delivered, and 9 resident forums were run; the board receives a monthly summary plus escalation notes where issues need a decision.
- Committee chairs also receive a short digest of recurring themes so that directors can see where expectations are changing and where management action is still needed.
Illustrative only: shows a different sector using different engagement channels while still covering the same four disclosure points.
Quality ladder
- Basic
I summarised four stakeholder groups, their main concerns, how we heard them, and how the board was briefed.
- Better
I grouped our stakeholders into four main sets, noted the main points they raised, described the ways we gathered those views, and explained that the board and its committees received the updates through regular reports and meetings.
- Best
I covered four stakeholder groups across the year, set out the channels we used to collect their views, explained the main themes they raised, and noted that the board and committee members were kept informed through scheduled papers and discussions, with a recent shift in feedback linked to a change in our operating model.
Check your understanding
Scenarios to work through
A group of warehouse workers has raised concerns about shift patterns, while local residents near a distribution site have focused on traffic and noise. The reporting team has also heard from a lender that wants clearer climate transition information.
A preparer has minutes from town-hall meetings, a supplier survey and a grievance log, but no single document that summarises all engagement activity. The board asks for a concise description of how the company has gathered stakeholder input during the year.
During drafting, the sustainability team has a long list of comments from employees, investors and community groups. Some comments are operational requests, while others are broader concerns about safety, pay, emissions and local access to jobs.
The sustainability report is being finalised, and the board pack contains a dashboard of stakeholder issues, a summary of engagement outcomes and a note on unresolved concerns. The chair wants to know how the board itself was kept up to date.
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Advice, not assurance
Framework references
Relevant ESRS requirements and related disclosures
ESRS
SBM-2
within ESRS 2: General Disclosures
Guides that settle this question
Related & explore
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FAQ
Questions this page answers
Start with the plain-language explainer, then work through the step-by-step preparation section and the listed datapoints. The page also gives draft-output prompts, so you can turn the collected information into a first-pass narrative rather than starting from a blank page.
The page says to prepare four datapoints: stakeholder groups, engagement approach, stakeholder concerns, and the board briefing route. Use those as your minimum data set before drafting.
Use the page’s stakeholder-groups datapoint as the starting point and make sure the scope is clear enough to support the narrative and any evidence pack. The page does not give a fixed list, so you need to align the scope to your own reporting context and document it consistently.
Capture the approach in a way that shows how engagement was carried out and how it links to the concerns reported. The page’s preparation section and evidence pack are the main places to anchor that documentation.
The page is useful for splitting ownership across ESG, HR, data owners and governance contacts because it names the key datapoints and the board briefing route. Assign each input to the person or team that can evidence it, then keep the ownership trail in the workbook.
The page includes an evidence pack with five items and five assurance claims to verify, so use those as the core of your file set. Build the pack around claim, risk and evidence so a reviewer can trace each statement back to support.
Treat them as a check-list for what a reviewer is likely to test: each claim should have a clear risk and supporting evidence. The page is designed to help you verify the disclosure before it goes into a draft or assurance process.
The page lists common reporting gaps and mistakes, so use that section as a pre-submission review. It is especially helpful for spotting missing datapoints, weak evidence, or a narrative that does not line up with the underlying records.
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to help you organise the preparation and assurance steps. Use it alongside the page’s datapoints, evidence pack and assurance claims to build a draft that is easier to review.
Yes, the page includes synthetic illustrative example disclosures, including a quantitative table where relevant. Use them as a formatting and drafting aid only, and make sure your own figures and narrative stay internally consistent.
The draft-output section gives visualisation ideas, narrative starters and a content-index line to help you convert the prepared data into a usable draft. Start with the narrative starters, then use the content-index line to show where the disclosure sits in your report.
More questions this page can help with