C2 Policies and Practices: How to Avoid Overstating Sustainability Maturity

Technical status note. The Commission adopted C(2026) 5011 final on 3 July 2026. As at 1 August 2026, the delegated act was under European Parliament and Council scrutiny and had not yet completed the process leading to application. Recheck the Official Journal version, entry into force and any corrections before publication or client use.

Use note. This material separates requirements in the 2026 Voluntary Standard from London Reporting Academy implementation practices and illustrative wording. It does not replace the official text, legal analysis or entity-specific review.

Sustainability information is often assembled from different sources: a website statement, an internal procedure, a supplier questionnaire, a project proposal, a board presentation and a target mentioned in a sales document. Those sources use similar language but represent different levels of maturity. When they are compressed into one paragraph, an organisation can appear to have formal policies, embedded processes and monitored targets even though the evidence shows only isolated activities or intentions.

This is not merely a drafting problem. Overstatement creates inconsistent answers across customer questionnaires, tender packs and lender requests. It also weakens governance because owners cannot tell which commitments are approved, which actions operate, which projects are still being developed and which claims need evidence of results. C2 is therefore most useful when it acts as a controlled maturity register in narrative form.

Figure 1. C2 maturity claims ladder: the evidence gate should match the reported status rather than the desired image of maturity.

B2 is the Basic Module inventory. If the undertaking has specific practices, policies or future initiatives for transitioning towards a more sustainable economy, it states that fact and identifies whether it has practices, sustainability policies, future initiatives or forward-looking plans being implemented, and targets used to monitor policy implementation. For policies, B2 also states whether they are publicly available.

C2 is the description layer. Where those items were already reported under B2, the undertaking briefly describes them. If a practice, policy or future initiative covers suppliers or clients, that coverage is mentioned. If targets were identified in B2, the targets are briefly described. The undertaking may also indicate the most senior person or body accountable for implementation when it has determined that accountability.

B2 answers “what categories exist?” and records policy public availability.

C2 answers “what is the item, what does it cover and what is its implementation status?”

Supplier and client coverage is not left implicit.

Targets disclosed in B2 are briefly described in C2.

Senior accountability is optional and should be reported only when it has been determined.

1. Actual practice

A practice is something the undertaking actually does. It may be simple and need not be part of a formal policy. Examples include monthly energy reviews, a supplier qualification check, segregated waste collection, flexible-working arrangements or product-safety testing. The minimum evidence is an identifiable process, an owner, a period in which it operated and records showing use. A one-off activity can be described as a one-off activity, but it should not be portrayed as an embedded practice.

2. Approved policy

The 2026 Standard defines a policy as a set or framework of general objectives and management principles used for decision-making. It implements strategy or management decisions, is under the responsibility of defined person or persons, specifies its perimeter, includes one or more objectives and is implemented through actions or action plans. A document titled “policy” that lacks approval, owner, perimeter or implementation route may not satisfy that description in substance.

3. Future initiative or forward-looking plan being implemented

A future initiative is forward-looking, but C2 should not become a list of ideas. The strongest evidence is an approved or otherwise authorised plan with a defined objective, owner, implementation status, milestones and resources or dependencies. “We are considering solar panels” is an aspiration. “A feasibility study was approved in September 2026, supplier quotations were obtained and an investment decision is scheduled for March 2027” is a future initiative being implemented.

4. Target

Appendix A defines targets as measurable, outcome-oriented and time-bound goals. A target should therefore identify the outcome, metric or unit, scope, baseline or starting point where relevant, target date, target value and owner. A direction of travel - “reduce waste” - may be an objective, but it is not yet a measurable target. C2 should not manufacture missing numbers or dates to make an ambition look complete.

B2 asks whether policies are publicly available. “Publicly available” should mean that an external user can access the current policy through a stable location, such as the undertaking’s website or a public document set. A policy stored on an intranet is not publicly available. A policy can still exist and be valid when it is internal. The report should state the status accurately rather than implying that non-public means absent or that public means effective.

Record the URL, document version and access date for public policies. Where only a summary is public, say so. Where publication is restricted because the document contains operational, security or personal information, describe the policy and state that the full document is internal, subject to the applicable confidentiality review.

Figure 2. From B2 inventory to C2 description: a controlled flow from classification and evidence to coverage, targets and accountability.

Illustrative scenario. Greenfield Foods has reduced electricity consumption through weekly shutdown checks for two years. It has an approved responsible-sourcing policy covering direct agricultural suppliers, but the policy is not public. It is implementing a packaging-lightweighting project with trials under way. Management has discussed a 30% waste-reduction ambition but has not approved a baseline, target year or target value. The website says the company is “committed to zero waste”.

The reporting team classifies the shutdown checks as an actual practice, the sourcing document as a policy, and the packaging project as a future initiative being implemented. It does not report the waste ambition as a target. The website wording is referred for correction because it suggests a measurable commitment that does not exist. C2 states that the sourcing policy covers direct suppliers and is not publicly available. The operations director is identified as the most senior accountable person only because the accountability has been formally assigned.

Adaptation warning. The example does not imply that every undertaking needs a formal written policy or the same evidence form. The description must reflect the actual governance and operating reality. Do not copy the “not publicly available” statement unless the policy exists and the public-access status has been checked.

Must a policy be publicly available?

No. B2 requires the undertaking to state whether its sustainability policies are publicly available. An internal policy can be reported as internal; the status should be accurate.

Can an unwritten practice be disclosed?

Yes, if it actually operates and can be described and evidenced. Do not call it a formal policy unless the substance meets the policy definition and the approval/governance basis is clear.

Can C2 include an initiative that starts after year-end?

Only with careful reporting-date wording. If implementation had not begun by year-end, it may be an aspiration or subsequent development rather than a future initiative being implemented during the reporting period.

Does C2 require evidence of effectiveness?

C2 requires brief descriptions of the reported items, not a universal effectiveness evaluation. If the disclosure claims that an item achieved, prevented or improved an outcome, that additional claim needs evidence.