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London Reporting Academy ESRS 2 · General Disclosures · Disclosure Requirement SBM-3

Applicable from FY2027

This revised ESRS edition applies from reporting year 2027. For reporting years 2024–2026, use the ESRS 2023 edition.

Material Impacts, Risks and Opportunities and Their Interaction with Strategy and Business Model

SBM-3 · mandatory · narrative disclosure

This disclosure asks an organisation to explain which material sustainability impacts, risks and opportunities matter most to its business model and strategy, and how those matters connect to the way the organisation creates, delivers and preserves value. In practice, it is about showing the link between what is material and the organisation’s strategic choices, rather than listing issues in isolation.

Disclosure focus

The practical focus is on whether the organisation has considered its full business, not just a few headline sites or activities. It should describe how the material matters are reflected across operations, value chain and decision-making, and where there are differences in relevance by geography, business line or site type. The aim is to show the breadth of coverage and the real strategic implications, in a way that is clear and specific to the organisation.

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.

  • Interaction with strategy

    Strategy / sustainability team

    Describe how the issue links with the organisation’s strategy, including the practical way it affects or is affected by that strategy.

    Evidence Strategy papers, board packs, risk registers, business planning notes.

    Watch for The description is written as a generic narrative and does not tie back to the approved strategy or the source business plan.

  • Strategic response

    Strategy / executive management

    Set out the organisation’s chosen strategic response to the issue, in plain terms that show the direction of travel and the main actions at a high level.

    Evidence Strategy refresh papers, executive committee papers, transformation roadmap.

    Watch for The response is mixed up with operational actions and does not match the agreed strategic response in the planning documents.

  • Planned response

    Business planning / programme management

    Capture the actions the organisation plans to take in response to the issue, including the intended measures and implementation approach.

    Evidence Action plans, programme plans, project trackers, management approvals.

    Watch for Planned actions are omitted or described at the wrong level, so the disclosure does not reconcile to the approved action plan.

  • Revenue effect

    Finance / commercial team

    Explain the expected effect on income, including the main revenue streams that may change and the direction of that change.

    Evidence Budget models, revenue forecasts, commercial plans, finance review papers.

    Watch for Revenue is reported on a different basis from the forecast model, or gross and net revenue are mixed.

  • Cost effect

    Finance / procurement / operations

    Explain the expected effect on costs, including the main cost categories that may rise or fall and the direction of that change.

    Evidence Budget and forecast files, cost centre reports, procurement plans, finance commentary.

    Watch for Cost impacts are taken from a different period or category set than the budget, so the figures do not reconcile to the management accounts.

  • Balance sheet effect

    Finance / treasury / accounting

    Describe the expected effect on assets and liabilities, including which balance sheet items may change and how.

    Evidence Forecast balance sheet, impairment papers, provisioning memos, treasury papers.

    Watch for Asset and liability impacts are captured at the wrong reporting date or mapped to the wrong balance sheet line item.

  • Cash movement effect

    Treasury / finance

    Explain the expected effect on cash movements, including the main inflows or outflows and when they are expected to arise.

    Evidence Cash flow forecast, treasury model, capex plan, working capital analysis.

    Watch for Cash flow is confused with profit impact, or the timing of the cash movement does not match the treasury forecast.

  • Expected financial change

    Finance / strategy

    State the financial changes the organisation expects from the issue, covering the relevant measures of performance, position and cash.

    Evidence Integrated forecast, scenario outputs, finance papers, board reporting.

    Watch for The expected changes are described qualitatively but do not reconcile to the underlying forecast assumptions or model outputs.

  • Assessment periods

    Strategy / risk / finance

    Set out the time periods used for the assessment, making clear which horizons were considered and how they were grouped.

    Evidence Scenario pack, planning assumptions, board papers, risk assessment notes.

    Watch for The time horizons are inconsistent across documents, so short-, medium- and long-term effects are mixed together.

  • Planning basis

    Strategy / risk / finance

    Explain the basis used for the assessment, including the scenario or planning approach and the assumptions behind it.

    Evidence Scenario analysis pack, planning assumptions log, sensitivity analysis, governance approvals.

    Watch for The disclosure refers to one planning basis while the analysis was built on another, so the scenario basis does not match the model.

  • Why not quantified

    Finance / sustainability reporting

    Record why the effect could not be measured in numbers, including the specific barrier to quantification.

    Evidence Methodology note, finance memo, data gap log, management review comments.

    Watch for The reason given is generic and does not identify the actual data gap, method limit or estimation constraint.

  • Qualitative financial effect

    Finance / strategy / risk

    Describe, in words, how the issue is expected to affect the organisation’s finances when a numeric estimate is not available.

    Evidence Management commentary, risk assessment, scenario notes, business impact analysis.

    Watch for The qualitative description is too vague and does not explain the specific financial mechanism or direction of effect.

  • Affected statement lines

    Finance / accounting

    List the financial statement line items that are likely to be affected by the issue, using the organisation’s reporting categories.

    Evidence Chart of accounts mapping, financial statement draft, accounting memo, audit trail.

    Watch for The line items named do not match the reporting structure used in the financial statements, or a relevant line item is missed.

  • Resilience assessment

    Strategy / risk / sustainability

    Describe how the organisation’s business model and strategy hold up under the issue, including the main conclusions from the resilience review.

    Evidence Resilience assessment, scenario analysis, board papers, strategy review documents.

    Watch for The resilience narrative is not aligned to the actual assessment results, or it omits the main weakness identified in the review.

  • Assessment method

    Strategy / risk / finance

    Explain the method used to test resilience, including the analytical approach, inputs and any key assumptions.

    Evidence Methodology paper, scenario model, assumptions log, validation notes.

    Watch for The method described in the disclosure does not match the one actually used in the analysis, so the basis of the conclusion is wrong.

  • Assessment periods used

    Strategy / risk / finance

    State the time periods applied in the resilience assessment, showing the horizons actually tested.

    Evidence Scenario analysis outputs, planning timetable, board materials, assumptions schedule.

    Watch for The periods reported do not match the periods tested in the model, so the assessment horizon is misstated.

Before you start

  • Which impacts, risks, and opportunities are we actually covering here, and which parts of the business sit outside this write-up?
  • For any figures we mention, have we fixed the period, the planning basis, and the time bands we are using?
  • Can every number or statement be traced back to a source we can point to and explain?
  • Have we agreed the business definitions we will use for the effects on sales, spend, assets or liabilities, and cash movement?
  • If we cannot put a figure on something, have we settled why not and what qualitative explanation we will give instead?
  • Have we chosen the method we will use to test how robust the business is, and the time bands for that review?
+ Show SBM-3 sub-elements (LRA working checklist)

How to prepare it

Set the boundaries for the write-up first: decide which business areas, activities, and time periods you are covering, and make sure the scope matches the matters you are reporting on.
Translate each required item into your own reporting definitions: agree what you will treat as the interaction with the business model, the strategic reply, the planned follow-up, the financial effects, the expected changes, and the resilience assessment so the team uses one consistent meaning throughout.
Gather the support behind each statement before drafting: pull together the internal papers, forecasts, planning materials, scenario work, and other source records needed to back the narrative and any figures.
Build the disclosure in the required mix of text and numbers: explain the interaction and strategic response, set out the planned response, show the revenue, cost, balance-sheet and cash-flow effects where relevant, and include the expected financial changes, timing, and planning basis.
If you cannot quantify something, say so plainly and explain why: describe the effect in words, identify the financial statement line items that are likely to be affected, and state the reason the item is not presented as a number.
Record any exclusions, changes in approach, and the basis for the resilience assessment, then check the final wording back against the official source to confirm nothing important has been missed or altered.

Request the data

Request the strategy-and-financial impact evidence

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

How do the main sustainability-related issues connect to the business model, what actions are being taken, and what financial effects or planning assumptions support that story?

Use your organisation’s own labels first, then map them to the reporting categories. For example, if you talk about business drivers, investment cases, budget pressures, forecast assumptions, or balance sheet items internally, keep that language in the request and only translate it later for reporting.

Weak request

Please provide the ESRS 2:SBM-3 evidence for material impacts, risks and opportunities, including interaction with strategy and business model, financial effects, resilience, and any non-quantified items.

Why it fails: It uses framework language that many internal owners will not recognise, so they may not know which pack, model, or decision paper to send. It also does not point to the business issue, the source file, the planning basis, or the specific financial outputs needed.

Better request

Please send the latest internal pack for [internal issue name] that shows how it affects the business model or plan, what response is underway or planned, and any revenue, cost, asset, liability, or cash impacts. Include the scenario or planning basis, the time view used, and any items that were not quantified with the reason and the line items likely affected.

Formal email template
Subject: Request for strategy and financial impact evidence for [reporting period]

Dear [name/team],

We are preparing the sustainability reporting pack and need your help with the business impacts linked to [internal issue name].

Please share the material you use internally that explains:
- how this issue affects the business model or operating plan;
- what response is already underway or planned;
- any financial effects you have identified, including revenue, cost, asset, liability, or cash impacts;
- the planning basis, time view, and any scenario or assumption set used;
- any cases where the effect could not be quantified, together with the reason and the related line items that may be affected.

Please send the source file or extract, plus a short note on the boundary, period, and owner for the information. If there are multiple versions, please indicate which one is the latest approved or management-reviewed version.

Please adapt this to your organisation’s own terminology and check the official source before sign-off.

Kind regards,
[preparer name]
[team]
[contact details]
Short Teams / Slack version
Hi [name/team] — could you send the latest internal pack for [internal issue name] covering: business impact, current/planned response, any revenue/cost/asset/liability/cash effects, the planning basis, and any qualitative-only items with the reason they were not quantified? Please include the period, boundary, source file, and owner. Please adapt this to your organisation’s own terminology and check the official source before sign-off. Thanks, [name]

Industry examples

Manufacturing

Context. A plant team tracks energy cost exposure, equipment downtime risk, and capex for process changes in monthly operations and budget packs.

Adapted request. Please share the latest operations and finance pack for [internal issue name] showing how it affects plant output, cost base, and investment plan, plus any revenue, cost, asset, liability, or cash impacts. Include the budget or scenario basis, the time view, and any items left qualitative with the reason.

Example response. A workbook with plant-level assumptions, a capex note, a forecast bridge, and a short narrative on why one risk was not quantified because the estimate range was too wide.

Retail

Context. A trading and planning team monitors supplier disruption, product mix changes, margin pressure, and stock impacts through forecast and trading updates.

Adapted request. Please send the latest trading and planning pack for [internal issue name] showing how it affects sales, margin, stock, and cash, together with the response plan and any scenario assumptions used. If any effect was not quantified, please explain why and note the line items likely affected.

Example response. A monthly trading pack with sales and margin sensitivities, stock write-down assumptions, a scenario summary, and a note that one supplier risk was described qualitatively because the timing of disruption was uncertain.

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 how the figures were prepared, including what each measure covers, the basis used for any estimates or scenarios, the time periods applied, and the reason where an effect is described without a number.

Context note

Explain what the reported amounts and descriptions mean for the business, linking the interaction, the response taken, the expected financial effects, and the parts of the accounts that may be affected.

Fluctuation statement

If the numbers or expectations change, point to shifts in the underlying issue, the response plan, the time horizon, or the planning assumptions used to estimate the effect.

Content index entry

SBM-3 Material Impacts, Risks and Opportunities and Their Interaction with Strategy and Business Model — [location / page] / [notes]

Download Centre

Preparation tools & forms

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Check

For each claim, check the evidence

  • We based the coverage figure on the same boundary we used for the rest of the report, and we can show why any sites, entities or activities were left out.

    Risk Assurer checks whether the boundary is consistent, whether exclusions were deliberate rather than accidental, and whether the figure could be overstated or understated by missing parts of the business.

    Evidence to check Boundary memo; list of included and excluded entities/sites/activities; consolidation or reporting scope workpapers; management sign-off on scope decisions; reconciliation of the coverage figure to underlying population data.

  • We explained how the disclosed operations link back to our business model and strategy, and we kept working papers showing the basis for that mapping.

    Risk Assurer probes whether the narrative is supported by evidence, whether the link to strategy is genuine, and whether material items were omitted because they were not traced through the business model.

    Evidence to check Strategy papers; business model diagrams; materiality assessment outputs; mapping of impacts, risks and opportunities to business activities and value chain stages; board or management papers approving the linkage.

  • We set out the actions already taken and the actions planned to deal with the identified matters, and we retained the decision papers behind those choices.

    Risk Assurer checks whether the response described is real, current and approved, and whether the report overstates progress or omits planned actions that are still needed.

    Evidence to check Action plans; investment or change programme approvals; project status reports; governance minutes; implementation trackers; evidence of completed and planned measures.

  • We described the current financial effect using the figures we could support, and where we did not quantify it we kept the reasons and the related line-item references.

    Risk Assurer probes whether the numbers tie to finance records, whether any unquantified items were properly justified, and whether the affected statement lines were identified correctly.

    Evidence to check Finance extracts; calculation sheets; management estimates; audit trail to ledger or reporting packs; rationale for any non-quantified items; mapping to financial statement line items.

  • We prepared the forward-looking effect view using our planning assumptions and scenario work, and we can show the time bands and the basis used for each estimate.

    Risk Assurer checks whether the outlook is grounded in approved assumptions, whether the time horizons are consistent, and whether the estimates are too speculative or selectively presented.

    Evidence to check Budget and forecast packs; scenario analysis files; planning assumptions; sensitivity analyses; time-horizon definitions; governance approval of the modelling basis.

  • Where we did not put a number on an effect, we recorded why, what it means in practice, and which financial statement lines could be touched.

    Risk Assurer probes whether the non-quantification is justified, whether the qualitative description is specific enough, and whether the linked financial lines are complete and accurate.

    Evidence to check Non-quantification rationale; internal review notes; qualitative impact summaries; mapping to affected line items; evidence that quantification was considered and rejected for stated reasons.

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 does not hold the underlying records, so the answer is built from second-hand knowledge instead of the operational source.
  • Framework language onlyPeople ask for the data using reporting jargon rather than the business’s own terms, and the right team cannot map the request to its records.
  • Scope left vagueNo one states which part of the business, which activities, or which locations are in scope, so different teams collect different slices of the same topic.
  • Wrong period basisThe team pulls figures from a different reporting window or cut-off date, so the dataset does not match the period being reported.
+ Show 4 more

Judgement needed

  • Acquisitions, disposals, and perimeter shiftsUse the reporting boundary that matches the period you are explaining, and if a buy-in, sale, or reorganisation changes the group of entities covered, say when the change happened and whether the figures include the old or new perimeter.
  • Different local definitions for the same topicWhere countries or business units use different operational definitions, pick one basis for the group narrative, explain the main differences, and show any material split or reconciliation needed to avoid mixing unlike data.
  • People or activities near the edge of scopeDecide consistently whether to include borderline workers, sites, products, or customers, then disclose the inclusion rule and any exclusions so readers can see how close-to-the-line cases were handled.
  • Current period, opening position, or forward-looking viewState clearly whether the effect is being shown using the latest period, a starting point, or a future expectation, and keep the basis the same across the linked narrative and figures unless you explain the change.
+ Show 6 more

Examples

How it reads on the page

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — industrial equipment manufacturing

We explain that a shift in customer demand toward lower-emission products is already changing how we sell, design and source components, so the board and its committees have approved a product redesign programme and a supplier-screening plan for the next two years. In this scenario, we expect a €120 million revenue effect, €18 million of extra operating spend, a €9 million balance-sheet effect and a €6 million cash effect, with the main lines likely touched being revenue, cost of sales, inventories, trade payables and operating cash flow.
- Our forward view is based on a three-scenario planning exercise covering the next 12, 24 and 60 months, using internal demand forecasts and transition assumptions; we expect the largest changes in the medium term, with a smaller effect in the short term and a more material shift by year five.
- We have not put numbers on some parts of the effect because the timing and size are still too uncertain; those unquantified items are described qualitatively as possible margin pressure, higher working-capital needs and occasional asset write-down risk, and they may affect revenue, operating profit, inventories, receivables and cash flow.
- We judge the business model to be resilient because the planned redesign, supplier changes and pricing actions should allow us to keep serving core customers even if the transition is slower or faster than expected.

Synthetic, illustrative only; figures are internally consistent and intended to show how a reporter might describe the interaction, response, quantified effects, unquantified effects and resilience in plain language.

Illustrative (synthetic) example — food and beverage processing

We describe how hotter summers and water constraints are already influencing sourcing, production scheduling and product mix, and our management team has set a response plan covering water efficiency, recipe reformulation and selective price changes. On the basis of a climate-stress test and internal planning assumptions, we expect a €75 million revenue effect, €11 million of added costs, a €4 million asset and liability effect and a €3 million cash effect, with the most likely affected lines being sales, production costs, property and equipment, provisions and operating cash flow.
- Our outlook uses a two-path planning basis over the short, medium and longer term, and we expect the financial effect to build gradually rather than arrive all at once.
- We have left some items unquantified because the evidence is not yet strong enough to support a reliable estimate; qualitatively, those items could mean lower volumes in peak periods, higher utility and logistics spend, and possible impairment pressure on certain sites, affecting sales, operating expenses, fixed assets, provisions and cash generation.
- Even so, we consider the group reasonably robust because the response plan gives us options to shift sourcing, adjust production and protect supply to key customers if conditions worsen.

Synthetic, illustrative only; figures are internally consistent and intended to show a second plausible reporter with a different sector and a different pattern of effects.

Quality ladder

  • Basic

    I have identified 6 material business issues.

  • Better

    I have identified 6 material business issues, split across 2 impact areas, 2 risk areas and 2 opportunity areas, based on our latest review.

  • Best

    I have identified 6 material business issues across our operations and value chain, covering 2 near-term and 4 longer-term items, using our latest planning review, and the increase from last year reflects two newly assessed supply-chain risks and one delayed opportunity because market timing shifted.

Check your understanding

Scenarios to work through

A manufacturer has identified a major transition risk from tighter product standards. The board has approved a shift toward lower-emission product lines, but the finance team has not yet linked that shift to any forecast changes.

QWhat should the preparer do when describing how this issue connects to the business model and strategy?
Reveal model answer →

A services group expects a new customer requirement to reduce revenue in one region over the next two years, while also increasing compliance spend and contract assets. Management has a rough estimate for revenue and costs, but not for the balance sheet effect.

QHow should the preparer decide what to include about the financial consequences?
Reveal model answer →

A retailer has run an internal planning exercise using three climate pathways and a five-year budget cycle. The exercise shows that one pathway would materially affect store refurbishment timing, but the team is unsure whether to present the analysis as a resilience assessment or as a general planning input.

QWhat is the right judgement on how to explain the basis for the analysis?
Reveal model answer →

A mining group has identified a long-term water-stress risk that could affect production, but the impact is too uncertain to quantify reliably today. The team can describe likely operational effects and knows the issue may affect impairment testing and provisions.

QWhat should the preparer do when the effect cannot be measured with confidence?
Reveal model answer →
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FAQ

Questions this page answers

How do I use the SBM-3 page to draft the disclosure from scratch?+
What data do I need to collect for SBM-3 before I start writing?+
How should I decide the scope and methodology for SBM-3?+
Who should own the SBM-3 disclosure and the underlying data?+
What evidence pack do I need to make SBM-3 assurance-ready?+
What are the common mistakes to avoid when preparing SBM-3?+
How do I use the synthetic example disclosures on the SBM-3 page?+
What should I put in the narrative if I cannot quantify a financial effect for SBM-3?+
How do I use the workbook and printable Library Card for SBM-3?+
What does the 'From company reports' table help me do for SBM-3?+
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