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

Disclosure guides

Reporting boundaries

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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·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·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·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·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·Explainer·Reporting boundaries

C9 Gender Diversity Ratio: Calculation, Population and Reporting Controls

C9 applies if the undertaking has a governance body in place. The current Commission-adopted text requires the related gender diversity ratio but does not set out a detailed calculation method.

Helps you decideWhich body and active members form the ratio population, and which calculation convention is used.

Reviewed 11 Aug 2026 10 min Read the guide →

EU VS·Explainer·Reporting boundaries

C8 Sector Exposure and Related Revenue: How to Determine the Correct Boundary

C8 begins with the undertaking’s own activities. If the undertaking is active in prohibited weapons, tobacco cultivation or production, fossil fuels, or chemicals production falling within Division 20.2, it discloses the related revenues derived from those activities; fossil-fuel revenue is disaggregated between coal, oil and gas.

Helps you decideWhether the undertaking itself is active in a listed sector and which revenue is derived from that activity.

Reviewed 11 Aug 2026 10 min Read the guide →

EU VS·Decision guide·Reporting boundaries

How to Prepare a Report Under the EU Voluntary Standard: Step-by-Step Guide

Prepare the report as a controlled reporting project, not as a questionnaire-filling exercise. First identify the users, requests and intended publication channel; confirm that the Voluntary Standard is an appropriate basis; select Option A (Basic Module only) or Option B (Basic and Comprehensive Modules); and build a disclosure-level applicability matrix.

Helps you decideWhich users and requests the report will serve, whether Option A or Option B is appropriate, and what controlled evidence is required before release.

Reviewed 10 Aug 2026 13 min Read the guide →

EU VS·Decision guide·Reporting boundaries

Does the EU Value Chain Cap Apply to Banks, Customers and Procurement Platforms?

The value chain cap follows purpose and legal role, not the label of the requester or the datapoint alone. A bank or customer can be subject to the cap when it is a CSRD reporting undertaking and seeks information from a protected undertaking for its sustainability reporting.

Helps you decideWhich requester/purpose combinations fall within the statutory cap and which require separate legal or commercial analysis.

Reviewed 10 Aug 2026 10 min Read the guide →

EU VS·Decision guide·Reporting boundaries

Protected Undertaking Test: Does the EU Value Chain Cap Apply to Your Company?

A company is a protected undertaking only if the specific responding undertaking is in the value chain of a CSRD reporting undertaking and does not exceed an average of 1,000 employees during the preceding financial year on its balance sheet date. The status should be documented for the correct legal entity through a dated self-declaration supported by the employee calculation, accounts or payroll evidence, value-chain relationship and reporting period.

Helps you decideWhether the respondent meets both the employee and value-chain criteria, and which Annex II employee band applies.

Reviewed 10 Aug 2026 10 min Read the guide →

EU VS·Decision guide·Reporting boundaries

EU Value Chain Cap Explained: What Large Companies May Ask Smaller Suppliers to Report

The value chain cap is a purpose-specific upper limit, not a general ban on ESG questions and not a duty for suppliers to report. A request is potentially within the cap only where a CSRD reporting undertaking seeks information for its sustainability reporting, the respondent is a protected undertaking in its value chain, the datapoint is listed in Annex II for the respondent's employee band, and the information is necessary.

Helps you decideWhether each request line is within the Annex II ceiling, above it, or outside the cap because the purpose or parties differ.

Reviewed 10 Aug 2026 11 min Read the guide →

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You should be able to stop reading after the first paragraph and still have what you came for. Everything below it exists so you can defend the answer to a reviewer.

  1. 01
    Answer

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  2. 02
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  3. 03
    Judgement

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

  4. 04
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    The answer links to the disclosures and evidence it affects, so a decision turns into fields to fill.

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