Disclosure GuidesThe questions that hold a report up, settled

London Reporting Academy·Disclosure guides

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Expert-written answers to the questions that slow reporting teams down. Each one opens with the conclusion, shows the requirement it rests on, explains the conditions and the judgement involved, and links to the disclosure cards the decision affects.

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Answers from the published guides · 275 disclosure cards · 1,211 indexed reports

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EU VS·Explainer·Data and evidence

EU Voluntary Sustainability Report Template: Structure, Disclosure Index and Evidence Pack

A strong EU Voluntary Sustainability Report should be built as three connected outputs: an approved report or counterparty-facing document, a controlled disclosure index and response pack, and a restricted evidence room. The report should identify the undertaking, reporting period, perimeter, Option A or Option B basis, paragraph 22 omissions and applicable B/C disclosures; explain methodologies, boundaries, estimates, changes and limitations; and use a disclosure index that points to precise locations.

Helps you decideEU Voluntary Sustainability Report Template: Structure, Disclosure Index and Evidence Pack

Reviewed 11 Aug 2026 9 min Read the guide →

EU VS·Decision guide·Data and evidence

Free EU Voluntary Sustainability Reporting Template: Basic and Comprehensive Modules

A useful EU Voluntary Sustainability Reporting template should not be a single blank report. It should be a small controlled package: a Word report skeleton for the Basic and Comprehensive Modules, an Excel applicability matrix, an evidence register, a data dictionary and a request-response log.

Helps you decideFree EU Voluntary Sustainability Reporting Template: Basic and Comprehensive Modules

Reviewed 11 Aug 2026 5 min Read the guide →

EU VS·Decision guide·Data and evidence

C4 Climate Risks: Physical and Transition Risk Without an Overbuilt Scenario Model

A useful first C4 disclosure is specific, traceable and proportionate - not necessarily model-heavy. Identify the hazard or transition event, the exposed site, activity or value-chain node, the reason it is sensitive, the relevant time horizon, the potential operational or financial channel, and the action or control.

Helps you decidehow far to take scenario work in a first climate risk disclosure, and what a risk statement must name to stay traceable

Reviewed 10 Aug 2026 14 min Read the guide →

EU VS·Decision guide·Metrics and methodologies

C3 Climate Targets and Scope 3: When Quantification Is Appropriate

Begin with a category screening, not with a request for a single Scope 3 total. Quantify the categories that are significant and for which a reasonable estimate can be supported; explain the methods and limitations.

Helps you decidewhich Scope 3 categories are ready to quantify and publish, and whether your climate ambition qualifies as an established target

Reviewed 10 Aug 2026 15 min Read the guide →

EU VS·Decision guide·Reporting boundaries

C1 Business Model and Value Chain: How to Write a Useful Comprehensive Disclosure

C1 should let a reader understand what the undertaking offers, where it operates, which relationship categories enable the business model and how sustainability-related strategy connects to those facts. It is not a request for a complete supplier or customer list.

Helps you decideWhich aspects of the business model are significant enough to describe, and at what level of aggregation?

Reviewed 10 Aug 2026 12 min Read the guide →

EU VS·Comparison·Reporting boundaries

EU Voluntary Standard 2026 vs VSME

The 2026 EU Voluntary Standard is not a wholly new architecture: it is based on the VSME standard endorsed by Commission Recommendation (EU) 2025/1710 and retains the Basic B1-B11 and Comprehensive C1-C9 modules. The main changes are its proposed legal form and role, the wider intended population up to 1,000 employees, a statutory value-chain cap defined through a separate Annex II, specific reliefs for undertakings with 10 employees or fewer, alignment with the revised ESRS and targeted datapoint changes.

Helps you decideWhich source is current, what changed in architecture and datapoints, and how to transition without losing evidence or overstating legal status.

Reviewed 11 Aug 2026 11 min Read the guide →

EU VS·Decision guide·Reporting boundaries

EUVS KH 29 Workforce Disclosures

B8-B10 use employees - individuals in an employment relationship with the undertaking - as the core population. B8 reports employees in headcount or FTE by temporary/permanent contract, gender and country of employment contract when the undertaking operates in more than one country.

Helps you decideWho counts as an employee, which denominator applies, how country rules are handled and whether publication needs privacy controls.

Reviewed 11 Aug 2026 11 min Read the guide →

EU VS·Comparison·Data and evidence

Basic vs Comprehensive Module

Choose the Basic Module when the organisation needs a reliable core report, is building its first repeatable data cycle or mainly answers proportionate customer and management questions. Choose Basic plus Comprehensive when banks, investors or corporate clients need additional information on strategy, policies, Scope 3, GHG targets, transition, climate risks, workforce depth, human rights, sensitive activities or governance diversity - and the organisation can complete and evidence the full Comprehensive Module.

Helps you decideWhich module best fits company size, information users, data maturity, climate needs and upgrade plans.

Reviewed 11 Aug 2026 12 min Read the guide →

EU VS·Decision guide·Data and evidence

Report or Dataset First? How SMEs Should Implement Voluntary Sustainability Reporting

For most SMEs, the controlled dataset should come first and the designed report should be treated as one output. The 2026 Voluntary Standard is intended to serve counterparties, banks and investors as well as internal management, and it allows the report to be public or counterparty-focused.

Helps you decideDecide why a controlled dataset normally comes before graphic report design.

Reviewed 11 Aug 2026 15 min Read the guide →

EU VS·Comparison·Omissions and claims

Not Applicable vs Unavailable vs Omitted: How to Classify Voluntary Standard Datapoints

Classify each paragraph or subpoint by starting with the selected reporting option and the wording of the disclosure - not with whether the data happens to be available. Not applicable means an express circumstance in the Standard is absent.

Helps you decideUse four distinct classifications instead of treating every blank as not applicable.

Reviewed 11 Aug 2026 14 min Read the guide →

EU VS·Decision guide·Reporting boundaries

Convictions and Fines Under B11: What Must an Undertaking Report?

B11 is triggered by confirmed legal outcomes in the reporting period: the undertaking reports the number of convictions and the total amount of fines incurred for violations of anti-corruption and anti-bribery laws. Allegations, whistleblowing reports, internal findings and open investigations are not themselves B11 convictions or fines.

Helps you decideWhether an event is a qualifying conviction or fine, in which period and boundary, and how it is aggregated and worded.

Reviewed 11 Aug 2026 11 min Read the guide →

EU VS·Decision guide·Reporting boundaries

B1 and B2 Explained: Company Profile, Practices, Policies and Future Initiatives

B1 establishes who is reporting, on what basis and for which organisational perimeter; B2 then states whether the undertaking has specific sustainability practices, policies, future initiatives being implemented and targets. The two disclosures should not be merged into a promotional profile.

Helps you decideWhat belongs in the company profile, and which maturity label is supported for each sustainability item.

Reviewed 11 Aug 2026 12 min Read the guide →

EU VS·Decision guide·Data and evidence

Evidence Register for the EU Voluntary Standard: What to Keep Behind Every Datapoint

Every reported datapoint should have a controlled evidence record showing what was reported, which paragraph or subpoint it relates to, where the source came from, who owns it, which period and boundary it covers, how it was calculated or judged, who reviewed it, whether the evidence is confidential and whether the datapoint is approved for release. The 2026 Voluntary Standard does not prescribe a named “evidence register”, but it requires information to be faithful and verifiable.

Helps you decideDefine the minimum evidence record behind each metric and narrative statement.

Reviewed 11 Aug 2026 15 min Read the guide →

EU VS·Decision guide·Reporting boundaries

EUVS KH 28 Environmental B Disclosures

B4-B7 do not share one universal applicability test. B4 covers own-operation pollutant emissions that the undertaking must report to authorities under EU or national law, or voluntarily reports under an environmental management system.

Helps you decideWhich disclosure applies, at which locations, using which source records and units.

Reviewed 11 Aug 2026 10 min Read the guide →

EU VS·Decision guide·Metrics and methodologies

Energy and GHG Disclosures Under the EU Voluntary Standard: Scope 1, Scope 2 and Evidence

B3 requires total energy consumption in MWh and, where the necessary information can be obtained, a renewable/non-renewable split for electricity and fuels. It also requires estimated absolute gross Scope 1 emissions and location-based Scope 2 emissions in tCO2e, considering the GHG Protocol Corporate Standard.

Helps you decideHow to construct the energy register, select factors, treat supplier attributes and document estimates.

Reviewed 11 Aug 2026 11 min Read the guide →

EU VS·Decision guide·Data and evidence

Missing Data and Estimates Under the EU Voluntary Standard: What Is Allowed?

The 2026 EU Voluntary Standard allows or anticipates estimates in some areas - most clearly for Scope 1 and location-based Scope 2 greenhouse-gas emissions - but it does not provide a general “data unavailable” exemption for every essential and applicable datapoint. A missing value must first be tested against the selected module, an explicit voluntary category, an “if applicable” condition and the limited omission permission in paragraph 22.

Helps you decideUnderstand why estimation is sometimes acceptable but unavailability is not a general omission reason.

Reviewed 11 Aug 2026 15 min Read the guide →

EU VS·Decision guide·Reporting boundaries

EU Voluntary Sustainability Reporting Standard 2026 Explained

The 2026 EU Voluntary Sustainability Reporting Standard is a Commission-adopted framework designed to help undertakings outside mandatory sustainability reporting provide proportionate, standardised information to business counterparties, banks and investors and improve their own management. It retains a Basic Module (B1-B11) and a Comprehensive Module (C1-C9), with the Basic Module required before the Comprehensive Module.

Helps you decideWhether to use the Standard, which module to select, what boundary and reporting channel to adopt, and how to respond to value-chain information requests.

Reviewed 11 Aug 2026 12 min Read the guide →

EU VS·Decision guide·Assurance and controls

Does an EU Voluntary Sustainability Report Need External Assurance?

No. The 2026 EU Voluntary Standard does not impose a general obligation on an undertaking to obtain external assurance; the delegated act expressly states that undertakings applying the Standard are not obliged to seek assurance for the information they report. The information must nevertheless be relevant, faithful, comparable, understandable and verifiable, so a proportionate internal review and controlled evidence trail remain important.

Helps you decideUnderstand why external assurance is not a general requirement of the Standard.

Reviewed 11 Aug 2026 14 min Read the guide →

EU VS·Decision guide·New standards and transition

Is the EU Voluntary Sustainability Reporting Standard Mandatory?

No. The EU Voluntary Sustainability Reporting Standard is voluntary for the undertaking preparing information; it does not itself create a general duty to prepare or publish a sustainability report. A separate law may make a company a mandatory reporter, and a customer, bank or tender may create a commercial expectation or contractual request.

Helps you decideWhether the undertaking has a legal duty to report, a commercial reason to respond, a statutory right to decline above-cap information or a voluntary choice to use the Standard.

Reviewed 11 Aug 2026 11 min Read the guide →

EU VS·Decision guide·Reporting boundaries

Who Can Use the EU Voluntary Sustainability Reporting Standard?

The clearest eligible user is an undertaking that is not subject to mandatory sustainability reporting under Articles 19a or 29a and that does not exceed an average of 1,000 employees in the preceding financial year. Annex I expressly includes self-employed persons, non-incorporated undertakings and listed micro-undertakings.

Helps you decideWhether the Standard is an appropriate reporting basis, at which entity or group level, and whether value-chain protections apply.

Reviewed 11 Aug 2026 11 min Read the guide →

EU VS·Explainer·Reporting boundaries

C6 and C7 Human Rights Disclosures: Complaints, Confirmed Incidents and Remediation

C6 and C7 serve different purposes. C6 asks whether the undertaking has an own-workforce code or human-rights policy, which specified issues it covers, and whether an own-workforce complaints-handling mechanism exists.

Helps you decideWhat is a mechanism, what is an intake item, and what qualifies as a confirmed incident for reporting.

Reviewed 11 Aug 2026 11 min Read the guide →

EU VS·Decision guide·Omissions and claims

Must an EU Voluntary Sustainability Report Be Public?

No. The voluntary standard says that the report’s primary function is to inform actual or potential business counterparties and that the undertaking may decide to make it public. If it does so, it may use a separate section of its management report, where one exists, or a separate document.

Helps you decidewhether to publish the report at all, which delivery channel each reader gets, and what may stay confidential without going silent about it

Reviewed 10 Aug 2026 14 min Read the guide →

EU VS·Decision guide·Omissions and claims

Can You Add Selected Comprehensive Disclosures to a Basic Module Report?

Yes. Paragraph 25 of the Commission-adopted 2026 Voluntary Standard permits an undertaking, after completing B1-B11, to report selected disclosures from the Comprehensive Module. The safest reporting basis is to retain the Option A statement for the completed Basic Module, label the selected C disclosures as supplementary, explain the basis in B1 and show them separately in the disclosure index.

Helps you decideCan You Add Selected Comprehensive Disclosures to a Basic Module Report?

Reviewed 11 Aug 2026 8 min Read the guide →

EU VS·Comparison·Omissions and claims

Option A vs Option B Under the EU Voluntary Standard: Requirements and Reporting Claims

Option A means applying the Basic Module only; Option B means applying both the Basic and Comprehensive Modules. B1 requires the undertaking to identify the selected option and make an explicit statement of compliance using that option.

Helps you decideOption A vs Option B Under the EU Voluntary Standard: Requirements and Reporting Claims

Reviewed 11 Aug 2026 8 min Read the guide →

EU VS·Comparison·Framework interoperability

EU Voluntary Standard vs GRI: Which Framework Fits an SME?

The best fit depends on the reporting objective. The EU Voluntary Standard is designed as a proportionate, modular information set for undertakings outside mandatory CSRD reporting, with a Basic Module and a Comprehensive Module that can support lender, customer, investor and value-chain requests.

Helps you decideWhether the immediate need is a proportionate counterparty dataset, a public impact report, future ESRS readiness, or a controlled combination.

Reviewed 11 Aug 2026 13 min Read the guide →

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  1. 01
    Answer

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  2. 02
    Basis

    The official source and edition are named, and kept clearly apart from our reading of them.

  3. 03
    Judgement

    The points the standard leaves open are marked, with what a defensible position looks like.

  4. 04
    Action

    The answer links to the disclosures and evidence it affects, so a decision turns into fields to fill.

  • Practitioner-written, then technically reviewed
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