Short answer
The answer, before the reasoning
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.
The evidence room should retain source records, calculations, approvals, legal confirmations and reviewer sign-off. Public availability is optional under the Standard, so the undertaking may use a public report, a controlled counterparty response or both - but the reporting basis must remain consistent.
One dataset, three controlled outputs: public report, counterparty response pack and evidence room.
Technical status
LEGAL-STATUS NOTE
The European Commission adopted C(2026) 5011 on 3 July 2026. At the source-check date, the Commission status page stated that the delegated act was not in force until publication in the Official Journal. Recheck the final EU number, scrutiny outcome, entry into force and any changed wording immediately before publication.
Start with the output architecture, not the Word document
The Voluntary Standard is designed primarily to inform actual or potential business counterparties. It allows, but does not require, public availability. This means the reporting team should decide at the beginning whether it needs a public sustainability report, a controlled response pack for specific counterparties, or both. The same approved data can support each output, but the documents have different access, confidentiality and version-control needs.
The third output - the evidence room - is not a publication. It contains source records, calculation files, policies, approvals, legal confirmations, assumptions and review evidence. Publishing those files by default can disclose confidential information and weaken controls. The report and response pack should point to approved evidence IDs, while access to the underlying files remains controlled.
In practice
Recommended report contents
| Section | Purpose | Typical content |
|---|---|---|
| 1. Cover and document control | Identify the report and current version. | Undertaking, reporting period, report title, version, authorisation date, contact point and legal-status note. |
| 2. Basis of preparation | Explain the formal reporting basis. | Option A or Option B, individual/consolidated basis, subsidiaries, employee test, perimeter, cross-references and paragraph 22 omissions. |
| 3. Entity profile | Give context for the metrics. | Legal form, NACE codes, total assets, turnover, employee count, primary countries, significant assets/sites, geolocations and certifications/labels. |
| 4. Practices, policies and initiatives | Explain existing management arrangements. | B2 and, where relevant, C2, including scope, owners, supplier/customer coverage and targets. |
| 5. Environmental disclosures | Present applicable metrics and methods. | B3-B7, Scope 3 consideration where relevant, C3-C4 if selected or under Option B. |
| 6. Social disclosures | Present workforce and human-rights information. | B8-B10 and, where selected or under Option B, C5-C7. |
| 7. Governance disclosures | Present applicable conduct and governance information. | B11, C8 and C9 where applicable. |
| 8. Methodology and limitations | Help users interpret data quality. | Definitions, boundaries, formulas, estimates, source systems, comparatives, changes and remediation plans. |
| 9. Disclosure index | Provide traceable navigation. | Module, disclosure, datapoint class, applicability, status, location, basis and omission note. |
| 10. Appendices | Add decision-useful supporting information. | Glossary, detailed calculation notes, selected C information, sector/entity-specific metrics and contact details. |
In practice
Three basis-statement patterns
| Reporting basis | Illustrative structure |
|---|---|
| Option A | “This report has been prepared in accordance with Option A of the EU Voluntary Sustainability Reporting Standard, comprising the Basic Module. It covers [entity/perimeter] for [period]. [No information / the following information] has been omitted under paragraph 22.” |
| Option B | “This report has been prepared in accordance with Option B of the EU Voluntary Sustainability Reporting Standard, comprising the Basic and Comprehensive Modules. It covers [entity/perimeter] for [period]. [Omission statement].” |
| Option A with selected C | “This report applies Option A. Selected supplementary information from [C disclosures] is included for [user purpose]. The undertaking does not state that it applies the Comprehensive Module in its entirety.” |
Rule
ADAPTATION WARNING
The wording above is illustrative. It is not an official clause and should be adapted to the final legal title, the undertaking’s perimeter, selected disclosures, omissions, cross-references and authorisation process.
Design the disclosure index as a control, not a decorative appendix
The index should be developed at the same time as the report. A row is not complete merely because a page number has been entered. The index should show what the datapoint is, how it is classified, whether it applies, what status it has, where the information is located and why any information is not reported. The controlled internal index may include more detail than the public index, such as evidence IDs, owner and reviewer.
In practice
| Index field | Purpose |
|---|---|
| Module and disclosure | Distinguish B from C and preserve the numbered source. |
| Datapoint / topic | Avoid treating a disclosure heading as though every field were one datapoint. |
| Datapoint class | Record essential, if applicable, voluntary/may, ≤10 relief or sector/entity-specific. |
| Applicability | Show the fact-based conclusion and distinguish not applicable from omitted. |
| Disclosure status | Reported, supplementary, not applicable, omitted or not selected. |
| Precise location | Page, section, URL or controlled response-pack field. |
| Basis / explanation | Method, limitation, selected-C purpose or omission reason. |
| Owner and reviewer | Create accountability and an annual update route. |
Methodology notes: the minimum information needed to understand a metric
Definition and unit of measure.
Reporting period and whether a comparative is provided.
Entity, site, workforce or value-chain boundary.
Source systems and records.
Calculation formula and unit conversions.
Estimates, assumptions and emission factors.
Exclusions and data gaps.
Changes in method, boundary or source compared with the previous year.
Data owner, preparer, reviewer and approval date.
For narrative disclosures, the same discipline applies. A policy description should identify the approved document, scope, owner and covered issues. A climate-risk statement should identify the hazard/event, exposure or sensitivity assessment, time horizon and adaptation action. A human-rights incident disclosure should define confirmed incidents, population, period and privacy controls.
In practice
Limitations and omissions need separate registers
| Record | When to use it | What to retain |
|---|---|---|
| General limitation | Data quality, estimate, incomplete system coverage or methodology maturity that does not meet paragraph 22. | Specific gap, affected metric, effect on interpretation, estimate/method and improvement action. |
| Not-applicable conclusion | The disclosure’s stated trigger does not apply. | Facts assessed, source evidence, rationale, owner and reviewer. |
| Paragraph 22 omission | Applicable information falls within one of the permitted protected categories. | Affected datapoint, permitted category, specialist support, B1 wording, approver and annual reassessment date. |
| Selected C not included | The undertaking uses Option A and did not choose that C disclosure. | User-need decision and confirmation that no Option B claim is made. |
Public report, controlled response pack and evidence room
Disclosure-to-evidence traceability: index, wording, calculation, source, owner review and technical approval form one chain.
In practice
| Output | Audience and access | Content — Key control |
|---|---|---|
| Public report | Any public user; stable web/PDF access. | Approved narrative, metrics, basis, index, methodology and proportionate limitations. — No restricted evidence or personal data; stable version and links. |
| Controlled response pack | Named bank, customer, investor or platform. | Structured B/C datapoints, cover note, index and response-specific mapping. — Use the same canonical data and reporting basis; record recipient, due date and version. |
| Evidence room | Internal team, authorised reviewer or assurance provider. | Source files, calculations, approvals, legal records, assumptions and review notes. — Access restrictions, retention, version control and traceability to the published claim. |
In practice
Evidence-register fields
| Field | What it controls |
|---|---|
| Evidence ID | Stable reference used in the index, calculation and review note. |
| Related disclosure / claim | The exact B/C datapoint or public statement supported. |
| Evidence type and description | Policy, extract, calculation, legal record, confirmation or approval. |
| Reporting period | Ensures the file supports the current report rather than a prior year. |
| Owner and source system | Identifies accountability and provenance. |
| File location and access level | Separates public, controlled and restricted material. |
| Review control | Recalculation, reconciliation, legal review, management confirmation or approval. |
| Reviewer and date | Shows who challenged and accepted the evidence. |
| Retention and update trigger | Ensures annual reuse does not rely on stale evidence. |
In practice
A practical production timetable
| Stage | Core actions | Output |
|---|---|---|
| 1. Scope and route | Confirm eligibility, users, period, perimeter, Option A/B and selected-C strategy. | Approved basis memo and project plan. |
| 2. Requirements and applicability | Build the B/C register; identify conditions, reliefs and possible omissions. | Controlled requirements and applicability matrix. |
| 3. Data and evidence | Issue data requests; calculate metrics; collect policies, legal and HR evidence. | Evidence register and calculation files. |
| 4. Drafting and index | Draft narrative and metrics; populate index and methodology notes together. | First complete report and index. |
| 5. Review and remediation | Run technical, finance, legal, HR, operational and editorial reviews. | Findings log and corrected package. |
| 6. Authorisation and release | Approve B1, final claim, omissions, cross-references and publication channels. | Signed report, response pack and controlled evidence room. |
| 7. Maintenance | Monitor counterparty requests, data changes and legal/standard updates. | Annual update queue and version history. |
Hypothetical example: public summary plus lender pack
The undertaking does not upload source invoices or employee files to the public website. It does not alter the target boundary in the lender pack without updating the canonical report record. When a customer asks for a different presentation, the response register records the request and maps it to the approved data rather than generating a new uncontrolled answer.
Hypothetical scenario
ILLUSTRATIVE SCENARIO
A 180-employee logistics undertaking prepares an Option A report and selected C3/C4 information. It publishes a concise PDF with the B disclosures, selected climate information, methodology notes and public index. A lender receives a controlled spreadsheet containing the same approved datapoints plus requested field mappings. The evidence room holds utility invoices, fuel data, emission factors, target approval, flood-risk analysis, HR extracts and review sign-off. All three outputs use the same period, perimeter and B1 wording.
Illustrative only. It shows how the decision is made, not wording that can be copied or relied on.
In practice
Common template errors
| Error | Why it matters | Correction |
|---|---|---|
| Starting from a blank narrative report | Requirements, evidence and index are added too late. | Start with the requirements matrix and output architecture. |
| One generic methodology note | Different metrics have different boundaries, estimates and systems. | Use a method ID for each metric family. |
| Publishing the evidence room | Confidential, personal or commercially sensitive records may be exposed. | Publish approved disclosures; control source-file access. |
| Different numbers in report and questionnaire | The undertaking loses a single source of truth. | Map every response to the canonical metric and version. |
| Index with only page references | Applicability, classification and omissions are invisible. | Add status, basis and explanation fields. |
| Treating the template as official | The structure may be useful but is not itself a source of requirements. | Anchor claims in the final Standard and show the template’s status. |
| No annual maintenance owner | Data and references become stale. | Assign owner, review date and update triggers for every register. |
Readiness
Report package readiness checklist
- The reporting route and perimeter are approved.
- The report structure reflects the selected B/C scope.
- B1 includes option, basis, omissions, subsidiaries and entity profile.
- The disclosure index has classification, applicability, status, location and basis fields.
- Methodology notes cover definitions, units, boundaries, estimates and changes.
- Limitations and paragraph 22 omissions are kept in separate controlled records.
- Every published claim links to an evidence ID and reviewer.
- Public report, response pack and evidence room have defined access controls.
- Cross-references are available at the same time and from the same document set.
- The report is coherent with financial statements and other public claims.
- The final package has technical and governance approval.
- Official Journal status and final legal numbering have been rechecked.
Download · XLSX
LRA_EU_Voluntary_Standard_Report_and_Evidence_Template.xlsx
749.7 KB
Sources
Primary sources
- · Commission Delegated Regulation C(2026) 5011 final (3 July 2026)
- · Annexes to C(2026) 5011 - Voluntary Standard and value-chain-cap list (3 July 2026)
- · Corporate Sustainability Reporting Directive - implementing and delegated acts (updated 3 July 2026)
- · Commission adopts revised sustainability reporting standards (3 July 2026)
- · Voluntary Standard - interactive text (2026)
- · Directive (EU) 2026/470 (Omnibus I) (24 February 2026)
- · GHG Protocol Corporate Standard (current source checked 1 August 2026)
- · GHG Protocol Corporate Value Chain (Scope 3) Standard (current source checked 1 August 2026)
Take it with you
The checklists as a working spreadsheet
Every checklist and table on this page, with empty status, owner and evidence columns for your team to fill in and keep.
✓ LRA AI Assistant · Human-in-the-loop
Ask about this guide
It answers from this page, and reaches into the linked disclosure cards when your question is about the standard itself. Your first two answers are free without signing in.
Go deeper · EU Voluntary Standard 2026
Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.
