Short answer
The answer, before the reasoning
GDR-P, GDR-A, GDR-M and GDR-T form a connected disclosure grammar for material IROs. GDR-P explains policy objectives, scope and exclusions.
GDR-A explains key actions, timeframes, expected outcomes and significant resources. GDR-M explains the metric, unit, method, sources, estimates, limitations, value-chain proxies and progress. GDR-T explains measurable outcome-oriented targets, scope, baseline, milestones, methods and alignment. If there is no policy, action or target, the absence is disclosed. If there is no measurable outcome target, the undertaking explains whether and how effectiveness is tracked. Common PATM can be disclosed once with clear scope and cross-references.
2026 REVISED ESRS · HOW-TO / TECHNICAL GUIDE
ESRS Policies, Actions, Metrics and Targets: How GDR-P, GDR-A, GDR-M and GDR-T Work
A repeatable disclosure logic for each material topic, including no-policy and no-target situations
ANSWER · EXPLAIN · APPLY · EVIDENCE · CONNECT · PUBLISH
© 2026 London Reporting Academy. Educational technical guidance.
In practice
| Article / package ID | LRA-ESRS2-002 |
|---|---|
| Version | 1.0 |
| Technical review date | 2 August 2026 |
| Source basis | Commission-adopted 2026 Revised ESRS |
Technical status
TECHNICAL STATUS
Commission-adopted 2026 Revised ESRS (C(2026) 5010 final, 3 July 2026). As at 2 August 2026, the delegated act has not yet entered into force. It becomes legally effective only after completion of the scrutiny period and publication in the Official Journal of the European Union. The revised standards apply to financial years beginning on or after 1 January 2027. Early application for financial year 2026 is permitted once the delegated act enters into force. Until early adoption is validly made, the 2023 ESRS as amended remain the legally applicable standards for current reporting. Preparers should state clearly which version they use. EFRAG had not issued revised Implementation Guidance or an updated revised-ESRS datapoint list by 28 July 2026.
Quick orientation
Quick orientation
- Applies to
- Every material topic or sub-topic and material entity-specific matter.
- Primary decision
- How to structure policy, action, metric and target disclosures around the IRO.
- Key source
- Revised ESRS 2, paragraphs 38-52 and AR 30-47.
- Common confusion
- Treating policy, action, metric and target as four independent checklists or equating a no-target situation with no disclosure.
1. The purpose of the GDR-PATM model
REQUIREMENT GDR-P, GDR-A, GDR-M and GDR-T create a consistent disclosure logic for the way an undertaking manages material impacts, risks and opportunities. They are applied when the undertaking reports under a topical standard and when it develops entity-specific information. The four requirements are connected: policies set direction, actions and resources implement the response, metrics measure performance, and targets define the intended outcome and time horizon.
Source anchor: Revised ESRS 2, paragraphs 38-40.
REQUIREMENT The model is not a request to repeat the same corporate policy statement under every topic. The undertaking may disclose common policies, actions, metrics or targets once and cross-refer, provided that the scope and affected IROs are clear. Detail should be proportionate to the severity of the impact, magnitude of the risk or opportunity, and importance for strategy and business model.
Source anchor: Revised ESRS 2, AR 30-33.
Figure 1. GDR-PATM as a connected management and disclosure loop.
Rule
Canonical drafting rule
Begin with the material IRO, not with the document called “policy”. Then show the management response and the evidence chain. This prevents generic PATM disclosures that have no visible connection to the materiality assessment.
2. Common requirements before P, A, M and T
REQUIREMENT Information about policies, actions, metrics and targets should enable users to understand the level at which the undertaking manages the material IRO. If a policy, action, metric or target covers only part of a topic - for example only own operations, one geography or one worker group - that partial scope must be visible in the disclosure.
Source anchor: Revised ESRS 2, paragraph 38.
REQUIREMENT If the undertaking has no policy, no action or no target for a topic related to material IROs, it discloses that fact. The standard does not create an equivalent general “no metric” statement: topical metrics and material entity-specific metrics still have to be assessed and disclosed where required.
Source anchor: Revised ESRS 2, paragraphs 39, 48 and 52.
A practical PATM header should identify the IRO ID, topic or sub-topic, impact/risk/opportunity type, affected geography, own-operations or value-chain scope, reporting period and responsible owner. The header is implementation practice, but it greatly improves traceability.
3. GDR-P - Policies
REQUIREMENT GDR-P explains the policies adopted to prevent, mitigate, bring to an end, minimise or remediate material negative impacts, to manage material risks, and to pursue material opportunities or positive impacts.
Source anchor: Revised ESRS 2, paragraph 41.
The disclosure should not imply that a policy covers a whole value chain when the approved document applies only to employees or controlled sites. Equally, a group policy may be described once when it applies across topics, but the topic disclosure should explain the relevant objective and scope.
In practice
| Required element | What good disclosure makes clear | Typical evidence |
|---|---|---|
| Key content and objective | What the policy is designed to achieve and which material IROs it addresses; any changes during the period. | Approved policy; change log; board or management approval; IRO cross-reference. |
| Scope and exclusions | Own operations, upstream/downstream value chain, geographies and, if defined, affected stakeholder groups; any exclusions. | Applicability matrix; legal-entity and value-chain scope; exception approvals. |
| Third-party standards or initiatives | Which external standard or initiative the undertaking commits to respect through implementation of the policy. | Membership/commitment record; policy wording; implementation procedure. |
| Affected stakeholder interests for social topics | How stakeholder interests were considered when setting the policy, where such consideration occurred. | Consultation records; worker-representative input; community or consumer evidence. |
| Overarching human-rights policy | Whether there is an overarching policy committing to implement the UNGPs, ILO Declaration and OECD Guidelines, and which stakeholder groups it covers. | Human-rights policy; due-diligence procedure; coverage map. |
Rule
No-policy situation
The requirement is to disclose the absence. A concise explanation of why the policy is absent, who is considering the gap and any approved development plan may be useful, but such information should be clearly labelled as current status and planned action, not presented as an existing policy.
4. GDR-A - Actions and resources
REQUIREMENT GDR-A explains the key actions taken in the reporting year and planned for the future, their timeframe and scope, and their expected outcomes. Where relevant, it also explains how the actions contribute to the objectives of the related policy.
Source anchor: Revised ESRS 2, paragraphs 44-45.
REQUIREMENT Where significant financial resources have been or are expected to be allocated, the undertaking describes the type of current and future resources, any preconditions for implementation, the amount allocated in the reporting period with the related financial-statement line items or notes, and an indicative range of future financial resources.
Source anchor: Revised ESRS 2, paragraph 46.
REQUIREMENT Key actions may have started in an earlier period and continue to produce effects in the current period. They may also be collaborative, particularly for systemic impacts. Environmental actions may be classified using the mitigation hierarchy. These ARs help the undertaking describe the actual management response rather than a one-year list of projects.
Source anchor: Revised ESRS 2, AR 35-41.
In practice
| Action field | Drafting question | Control point |
|---|---|---|
| Action | What concrete activity has been taken, is underway or is approved and planned? | Exclude vague intentions that have no owner, decision or evidence. |
| Timeframe | When did the action start, when will it be completed and over which horizon should outcomes appear? | Align to target milestones and financial-resource periods. |
| Scope | Which operations, value-chain relationships, geographies, subsidiaries and stakeholder groups are covered? | Reconcile to policy scope and metric boundary. |
| Expected outcome | What change for people, environment or the undertaking is expected? | Do not claim effectiveness before outcome evidence exists. |
| Resources | What operational, capital or significant non-financial resources support the action? | Reconcile reported current amounts to finance records and explain preconditions. |
5. GDR-M - Metrics
REQUIREMENT The undertaking discloses the metrics required by topical standards for material IROs and the metrics needed on an entity-specific basis. Entity-specific metrics can include metrics used internally to evaluate performance or track the effectiveness of actions, provided they are relevant and faithfully represented.
Source anchor: Revised ESRS 2, paragraphs 47-49 and Revised ESRS 1, paragraph 11.
A metric table that contains only the number and unit is rarely sufficient. The evidence file should support the boundary, period, method, source systems, transformations, estimates, review and change from the prior year. Where a topic standard prescribes no metric - as may occur in some social standards - the undertaking still considers whether an entity-specific metric is necessary to explain the material IRO and management response.
In practice
| Metric disclosure | Minimum content |
|---|---|
| Value and unit | The reported metric and its unit of measurement. |
| Method and sources | Calculation methodology and source inputs. |
| Estimates and limitations | Estimation method, significant assumptions and limitations, where relevant. |
| Value-chain data | Reliance on indirect sources or proxies and planned data-quality improvements. |
| Context | Information needed to interpret the metric, including why a method or input was chosen. |
| Performance change | Significant change from previous periods, target progress and effects of major acquisitions or disposals. |
6. GDR-T - Targets
REQUIREMENT GDR-T applies to measurable, time-bound and outcome-oriented qualitative or quantitative targets related to material IROs. Each target is linked to policy objectives and actions and includes the target value or qualitative level, absolute or relative basis where defined, unit, scope, baseline and base year where defined, target year and milestones, methodologies and assumptions, legal basis, relevant scenarios and policy alignment, and whether environmental targets are based on conclusive scientific evidence.
Source anchor: Revised ESRS 2, paragraphs 50-51.
REQUIREMENT If the undertaking has not set a measurable outcome-oriented target, it explains whether and how it nevertheless tracks the effectiveness of its policies and actions. A roadmap milestone, management ambition or activity target should not be relabelled as an outcome target unless it meets the definition and the disclosed methodology supports the claim.
Source anchor: Revised ESRS 2, paragraph 52.
In practice
| Target element | Reviewer question |
|---|---|
| Outcome orientation | Does the target describe the expected result for people, the environment or the undertaking, rather than merely an activity? |
| Scope | Does the target boundary match the policy, action and metric boundaries, and are exclusions visible? |
| Baseline and milestones | Can progress be calculated consistently from an approved base year and interim milestones? |
| Method and assumptions | Are scenarios, data sources, definitions and significant assumptions documented? |
| Policy and science alignment | Is any claim of legal, national, EU, international or scientific alignment supported and precisely worded? |
| Progress | Is progress reported through GDR-M using the same metric, scope and calculation basis? |
7. The reusable drafting template
Figure 2. Reusable drafting template for one material IRO or a clearly defined group of IROs.
The template can be implemented as a controlled table in the disclosure matrix or drafting system. It should not force every topic into identical wording. The objective is consistent questions, not identical answers.
In practice
| Field | Reusable drafting prompt |
|---|---|
| IRO connection | Which approved material IRO or group of IROs does this PATM disclosure manage? |
| Scope | What is covered and excluded by own operations, value chain, geography, activity and stakeholder group? |
| Current status | What exists and operates in the reporting period? |
| Future status | What is approved and planned, with timeframe, preconditions and resources? |
| Evidence | Which document, system, calculation, consultation record or approval supports each claim? |
| Progress and limitation | What changed, what did not work, what is estimated and what will improve? |
Hypothetical scenario
Illustrative scenario - water-stressed manufacturing site
A manufacturer identifies a material negative water impact on a local basin and a related operating risk. Its existing environmental policy covers controlled sites but not upstream raw-material suppliers. The company should not describe the policy as covering the full value chain. GDR-P states the policy objective, the material impact and risk addressed, the controlled-site scope, the upstream exclusion and the basin geographies. GDR-A describes the site-efficiency programme, supplier-screening pilot, expected outcomes, completion dates and significant approved capital expenditure. It also explains that the supplier action depends on access to reliable basin-level data. GDR-M reports withdrawal and consumption metrics, the basin boundary, calculation method and the proportion estimated. It explains the supplier proxy and the approved data-quality plan. GDR-T describes the outcome-oriented reduction target, its baseline, scope, target year, milestones and scientific basis. Progress is reported through the same metric and boundary. If no measurable supplier outcome target has been set, the company states that fact and explains how it tracks effectiveness through supplier coverage, verified action plans and basin-risk indicators. The example is illustrative and must be adapted to actual facts and the relevant topical requirements.
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
In practice
9. Weak and stronger PATM disclosure
| WEAK DISCLOSURE | STRONGER DISCLOSURE |
|---|---|
| We have a comprehensive sustainability policy, implement many initiatives, monitor several KPIs and aim to improve performance continuously. | Illustrative wording: The Water Stewardship Policy applies to all controlled manufacturing sites and excludes upstream suppliers. It addresses the material impact of water withdrawal in the X basin and the related production-continuity risk. During 2026, the undertaking completed closed-loop cooling at two sites and approved GBP 8-10 million of additional capital expenditure for 2027-2028, subject to permitting. Basin-adjusted water consumption decreased 6% from the 2024 baseline; 18% of the value was estimated using metered production and approved intensity factors. The 2030 target is a 30% absolute reduction within the same site boundary. No measurable upstream outcome target has been set; supplier-programme effectiveness is tracked through verified action-plan coverage and data-quality milestones. |
In practice
10. Common mistakes
| Mistake | Correction |
|---|---|
| Starting from a policy library rather than the IRO register | Map each material IRO to the policy, action, metric and target actually used to manage it. |
| Claiming group-wide or value-chain coverage without checking approved scope | Disclose the real coverage and exclusions consistently across P, A, M and T. |
| Calling an intention an action | Separate approved, resourced actions from aspirations and early concepts. |
| Reporting expenditure without linking it to actions and financial statements | Identify the action, current amount, line item or note, future range and preconditions. |
| Publishing a metric without method or limitations | Disclose unit, method, sources, estimates, proxies, context and significant change. |
| Using an activity target as an outcome target | Explain the intended outcome; if no measurable outcome target exists, disclose how effectiveness is tracked. |
| Repeating boilerplate under every topic | Describe common PATM once, clarify scope and use controlled cross-references. |
| Reporting only positive progress | Include significant setbacks, changes, limitations and the effect of acquisitions or disposals where relevant. |
Rule
Myth vs reality
Myth: If there is no target, the topic cannot be reported. Reality: the absence of a target is itself disclosed, and the undertaking explains whether and how it tracks effectiveness. Metrics and other topic disclosures may still be required.
Readiness
11. PATM quality checklist
- Every PATM block references an approved material IRO or a clearly defined group of IROs.
- Policy objectives, scope, exclusions and changes are specific and evidenced.
- Actions are distinguished as taken, underway or planned and include timeframe and expected outcomes.
- Significant financial resources reconcile to finance records and future ranges are approved and appropriately caveated.
- Metrics include unit, method, sources, estimates, limitations, value-chain proxies, context and prior-period change.
- Targets are outcome-oriented, time-bound and linked to policy, actions, scope, baseline, milestones and methods.
- No-policy, no-action and no-target situations are disclosed accurately.
- Progress is reported using a metric that matches the target scope and baseline.
- Common disclosures are cross-referred without obscuring topic-specific information.
- Evidence owner, reviewer and approval are recorded for each material claim.
Related Knowledge Hub articles
ESRS 2 General Disclosures
ESRS Disclosure Matrix and Content Index
How to Identify Impacts, Risks and Opportunities Under ESRS
In practice
Related standards and mappings
| Relationship | Standard / disclosure |
|---|---|
| Direct or supporting | ESRS 2 GDR-P |
| Direct or supporting | ESRS 2 GDR-A |
| Direct or supporting | ESRS 2 GDR-M |
| Direct or supporting | ESRS 2 GDR-T |
| Direct or supporting | ESRS 1 entity-specific disclosures |
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