Disclosure focus
This disclosure asks an organisation to explain any specific circumstances that affect how it has prepared its sustainability information. In practice, that means saying whether the reporting boundary, methods, assumptions, estimates, or data quality are different because of unusual conditions, and making clear what those differences mean for the reported information.
The practical focus is on transparency about coverage and comparability. An organisation should help readers understand whether the information covers the whole business or only part of it, and whether any sites, entities, activities, or data points are excluded, estimated, or treated differently. The aim is to show where the reporting is complete, where it is limited, and why.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show BP-2 sub-elements (LRA working checklist)
State whether the disclosure requirement is omitted.
Give the reason for leaving it out.
Indicate whether the topic is material.
Indicate whether the topic has been assessed.
Describe the actions taken.
Report the metrics used.
Set out the policies in place.
Explain how the topic connects to strategy.
State the targets in place.
Name the topic.
How to prepare it
1Start by deciding which sustainability topics you have actually assessed, and mark each one clearly as covered or not covered. Keep a simple record of the topic name and the yes/no outcome so the scope is easy to follow.
2For every topic you treat as covered, set out what you are counting as part of that topic. Use the same boundary consistently when you later gather the supporting material, so the figures and narrative all refer to the same scope.
3Gather the underlying support for each covered topic before drafting the disclosure. Pull together the evidence that backs the strategy connection, the policies in place, the actions taken, the targets set, and the measures used to track progress.
4Assemble the disclosure in a structured way for each topic: topic name, how it links to the business approach, the relevant policies, the actions underway, the targets, and the metrics. Where a topic is not covered, note that outcome separately.
5If you leave out any required topic, explain why it is missing and record the omission clearly. Also note any changes in approach, scope, or presentation so a reviewer can see what was excluded and why.
6Before finalising, check your draft against the official source to confirm the topic list, the covered or uncovered status, the scope, and the supporting details all match. Use that review to catch any gaps, inconsistencies, or unsupported statements.
Request the data
Request the basis and evidence for topic coverage and reporting choices
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Which topics were assessed, which were treated as material, and what supporting strategy, policy, action, target, metric, and omission evidence sits behind those reporting choices?
Use your organisation’s own labels first, then map them to the reporting fields. For example, if your teams talk about priority themes, control topics, programmes, KPIs, or exceptions, use those terms in the request and only translate them into the reporting structure at the end. Keep the ask practical and evidence-led, and check the source material before sign-off.
Weak request
Please provide the ESRS 2:BP-2 disclosures, including all assessed topics, material topics, strategy links, policies, actions, targets, metrics, and omitted disclosures.
Why it fails: This uses framework language only, which makes it harder for the owner to recognise the records they hold. It also bundles too many ideas together without telling the team what internal documents, systems, or decision notes to pull. The result is slower, less complete evidence collection.
Better request
Please send the topic review pack for [reporting period] in [business area]: the internal topic list, which topics were reviewed, which were treated as priority, the strategy or plan reference for each, the policy/control reference, the main actions, any targets or KPIs, the measures tracked, and any items not included with the reason. Include source links, owner, approver, and approval date. Use your own team terms first, then we will map them into the reporting pack. Please adapt this to your organisation and check the source material before sign-off.
Industry examples
Draft your disclosure
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
Describe the basis used to decide which topics were reviewed, how materiality was judged, what counts as an omission, and how each topic was linked to strategy, policies, actions, targets and metrics.
Context note
Explain what the figures show about the organisation’s reporting coverage: which topics were assessed, which were treated as material, which were connected to the business strategy, and where the disclosure is more complete or more limited.
Fluctuation statement
If the pattern changes from one topic to another, note whether that reflects differences in materiality decisions, missing disclosures, or uneven availability of supporting information rather than a change in the underlying issue itself.
Content index entry
BP-2 Disclosures in Relation to Specific Circumstances — [location / page] / [notes]
Download Centre
Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
The request goes to the sustainability team by default, even though the needed facts sit with the business lead who actually runs the topic, policy, action, target or metric in day-to-day operations.
Framework language only
The data call is written in reporting jargon, so the operational team cannot map it to the names and labels they use in their own systems and files.
No boundary set
People collect figures from mixed parts of the group without first fixing which entities, sites, activities or periods belong in the pack.
Wrong timing basis
The team pulls numbers from a different reporting window or cut-off date than the one used for the rest of the disclosure pack.
Mixed counting rules
Headcounts, totals and percentages are combined in one extract even though they were built on different counting methods and cannot be compared directly.
Source labels lost
Original file names, system codes or local category tags are stripped out, so the team can no longer trace each figure back to its source record.
Merged populations
Separate groups that should stay apart, such as different business units or issue areas, are rolled into one dataset and the distinctions disappear.
Weak evidence trail
The pack is assembled without saving the supporting notes, extracts and approval trail needed to show where each data point came from and who checked it.
Where judgement is often needed
Decide what sits inside the reporting perimeter after a buy-in or sale
If the group has changed through an acquisition or disposal, explain the cut-off date and whether the figures include the new or exited business for the full period, part of it, or not at all.
Handle country-by-country labels where local meanings do not match
Where the same business term is used differently in different places, state which local definition you used and how you kept the reporting line consistent across the group.
Set a clear rule for people or operations near the boundary
For staff, sites, customers, suppliers, or other activities close to the edge of scope, explain the rule used to include or exclude them and why that rule was chosen.
Choose the timing basis and say it openly
If you use a start date, end date, average period, snapshot date, or another timing basis, disclose that basis so readers can understand how the numbers were built.
Separate direct measurement from estimates
When some figures come from records and others from assumptions or models, identify which parts are estimated, describe the main method used, and note any material uncertainty.
Explain any rounding approach that affects totals
If figures are rounded, say the rounding rule used and make sure the rounded parts still reconcile sensibly to the reported total.
Protect personal data by grouping small counts
If individual-level detail would risk identifying people, combine the data into broader groups and explain the aggregation approach used to avoid disclosure of personal information.
State how you treated mixed-source data across systems
Where the same measure is pulled from different internal systems or local records, explain the consolidation rule used so readers can see how one group figure was formed.
Clarify whether omitted items were left out by design or because data was unavailable
If a topic, metric, or other item is not included, say whether it was excluded on purpose or because the information could not be obtained, and give the reason.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food processing
*Illustrative only: this is a synthetic example disclosure.* We reviewed the sustainability matters we had already assessed and identified one area as not material for this reporting cycle. - The topic assessed was water use across our own sites and key suppliers; we marked it as not material after our review. - Because it was not material, we did not carry forward the related detailed requirements on governance, strategy, actions, targets or metrics, and we explained that the decision was based on the outcome of the materiality review.
This example shows how a company can explain that a topic was considered but then excluded from detailed reporting because it did not meet the materiality threshold. It is intentionally synthetic and uses generic language only.
Illustrative (synthetic) example — Software services
*Illustrative only: this is a synthetic example disclosure.* We completed our review of the topics in scope and found one area to be material, so we described how it connects to our business model and management approach. - The topic assessed was employee wellbeing; we treated it as material and linked it to our strategy because retention and productivity affect our operating model. - We then set out the relevant policies, the actions under way, the targets we are tracking, and the metrics we use to monitor progress, all in line with the outcome of that review.
This example shows a material topic being carried through into the narrative on strategy, policies, actions, targets and metrics. It is intentionally synthetic and uses generic language only.
How companies report BP-2 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
LANXESS Aktiengesellschaft
Chemicals · Germany · 2025
LANXESS Aktiengesellschaft’s 2025 Corporate Sustainability Report provides unclear information related to impacts on value chain workers, referencing section “S2-4 – Taking action on material impacts on value chain workers, and approaches” on page 97, but without a clear disclosure of the specific datapoint. The report mentions assessment criteria for impacts on page 9 and refers to processes for identifying and assessing material impacts on page 16, though these do not directly clarify the disclosure in question. Notably, no quotable evidence explicitly addressing the disclosure was found elsewhere in the report.
REN - Redes Energéticas Nacionais, SGPS, S.A.
Water Utilities · Portugal · 2025
REN's Integrated Report 2025 provides some related context on processes to identify and assess material pollution-related impacts, risks, and opportunities (p.635), as well as on strategy and materiality related to cybersecurity (p.139), but these disclosures are not clearly detailed. Several key sustainability topics, including management of material risks and crises, economic performance, significant environmental impacts, indirect economic impacts, and worker health promotion, are explicitly noted as omitted or not found in the report (pp.650-659). Overall, the report contains limited and unclear information on these sustainability disclosures.
Snam S.p.A.
Gas Utilities · Italy · 2025
Snam S.p.A.'s 2025 Annual Report includes some coverage of material topics related to sustainability, with a specific mention of greenhouse gas-related material topics on page 481. There is related context on impacts, risks, and opportunities and their interaction with strategy on page 459, though this is not a clear disclosure. Other relevant sections, such as those on biodiversity and ecosystems (pages 463 and 488), provide some context but lack explicit, clear disclosures, and several expected datapoints are not found in the report.
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Scenarios to work through
A group has assessed a climate-related topic as relevant, but the draft report only names the topic and describes the main actions. It leaves out the link to the business plan, the policy position, the target, and the metric used to track progress.
QShould the preparer treat those missing items as acceptable, or should they be added before sign-off?
Reveal model answer →Hide answer ↑They should be added unless the team has a clear, documented reason for leaving any of them out. For a topic that has been assessed as relevant, the report should not stop at the label and actions alone; it should also explain how the topic connects to the business plan, what policy approach is in place, what target is being used, and which metric is being tracked. If any of those elements are not included, the omission and the reason for it need to be stated in a way that is specific and understandable.
Why this matters · When a topic is treated as relevant, the disclosure should be rounded out with the linked strategy, policy, action, target and metric information, or the omission should be explained.
A preparer has marked a biodiversity topic as not material after the latest review, but the working papers still show that the topic was considered and the conclusion was reached by the sustainability team, not the board. The draft report gives the conclusion but does not explain how that decision was made.
QWhat should the preparer check before finalising the disclosure about that topic?
Reveal model answer →Hide answer ↑They should make sure the report clearly shows both the assessment outcome and the reasoning behind it. If the topic was considered and then judged not material, the disclosure should not just state the outcome in isolation; it should also explain the basis for that conclusion so a reader can understand why the topic was left out of the main content. The explanation should match the actual decision trail used by the organisation.
Why this matters · A topic that is judged not material still needs a clear explanation of why it was left out.
A company has two relevant topics in the same reporting period. For one of them, the draft includes the topic name, the strategy connection, policies, actions, targets and metrics. For the other, the draft includes the topic name and strategy connection only, because the team says the policy and target are still being developed.
QHow should the preparer decide whether the second topic can be presented with fewer details?
Reveal model answer →Hide answer ↑The team should not assume that an incomplete package is fine just because work is still underway. If the topic is being reported as relevant, the disclosure should cover the full set of linked elements, unless there is a documented reason for leaving some parts out. If policy, actions, targets or metrics are not yet available, the report should say so plainly and explain the omission rather than presenting the topic as if the information were complete.
Why this matters · Relevance brings an expectation of a complete picture; if parts are missing, the gap and reason should be made explicit.
During drafting, the reporting team realises that one environmental topic was assessed, found relevant, and linked to a target, but the metric used to monitor progress was not agreed in time for publication. The team wants to publish the rest of the section and leave the metric out without comment.
QWhat is the right judgement on whether the metric can simply be omitted?
Reveal model answer →Hide answer ↑It should not be left out silently. If the metric is missing, the report should identify that omission and explain why it is absent. The rest of the topic can still be reported, but the reader should not be left guessing whether the metric was forgotten, unavailable, or deliberately excluded. The explanation should be clear enough for a reviewer to understand the reporting choice.
Why this matters · Missing information should be flagged and explained, not hidden in an otherwise complete topic narrative.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
General Basis for Preparation of Sustainability Statements → Guide ✓Actions and Resources in Relation to Material Sustainability Matters →Metrics in Relation to Material Sustainability Matters → Guide ✓Policies Adopted to Manage Material Sustainability Matters → Guide ✓Targets in Relation to Material Sustainability Matters → Guide ✓Role of the Administrative, Management and Supervisory Bodies → Guide ✓Show all 14 related disclosures →
FAQ
Questions this page answers
BP-2 ESRS 2: General Disclosures — what should I gather before I start drafting this disclosure page?+−
Start with the page’s datapoints to prepare: omitted disclosures, omission reasons, whether an assessment was done, the material topic flag, topic title, strategy connection, policy coverage, action summary, target details and the metric set. The page also gives a step-by-step preparation section, so you can use it to turn those inputs into a draft rather than starting from a blank page.
How do I use the BP-2 page to decide which disclosures are omitted and how to explain the omission?+−
Use the page’s preparation list to capture both the omitted disclosures and the reasons for omission, then carry that through into the draft narrative. The page is designed to help you record the decision clearly rather than leaving gaps unexplained.
What does the BP-2 page expect me to collect for the material topic and strategy link?+−
The page points you to the material topic flag, topic title and strategy connection as separate datapoints to prepare. In practice, that means you should be able to show which topic is being discussed and how it connects to the company’s strategy in the draft.
How should I use the BP-2 workbook to prepare the disclosure and assign ownership?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to support preparation and assurance readiness. Use it to organise the datapoints, track ownership and keep the evidence trail together while you build the draft.
What evidence should I keep ready for assurance on BP-2 ESRS 2: General Disclosures?+−
The page includes an evidence pack with five items for assurance readiness, alongside six assurance claims to verify. Use those together to build a file that shows the claim, the risk it addresses and the supporting evidence.
What are the common mistakes on the BP-2 page that I should avoid in the draft?+−
The page lists common reporting gaps and mistakes, so it is meant to help you spot weak or incomplete drafting before sign-off. A practical use is to check that the omission reasons, topic details, strategy link and metric set are all populated consistently.
How do I turn the BP-2 datapoints into a draft narrative and content index line?+−
The draft-output section gives visualisation ideas, narrative starters and a content-index line. That means you can use the page to move from collected datapoints into a first-pass narrative and a simple index entry for the report.
Are there example disclosures on the BP-2 page that I can use as a model?+−
Yes — the page shows synthetic illustrative example disclosures, including a quantitative table where relevant. They are there to help you see how the disclosure might look in practice, but they are examples only and should be adapted to your own data.
How do I use the BP-2 assurance claims, risk and evidence prompts in practice?+−
The page gives six assurance claims to verify, each framed around claim, risk and evidence. A practical approach is to test each claim against your source documents and make sure the evidence pack supports what you are saying in the draft.
Where can I find real published reports for BP-2 style disclosures?+−
The page includes a ‘From company reports’ table that links to real published reports at the pages where the topic is disclosed. You can use it as a reference point for seeing how others have presented similar information, without treating it as an official template.
More questions this page can help with
BP-2 ESRS 2: General Disclosures checklist for omitted disclosures and omission reasonsBP-2 evidence pack items for assurance readinessHow to use the BP-2 Prep & Assurance workbookBP-2 draft narrative starters and content index lineBP-2 common reporting gaps and mistakesBP-2 synthetic example disclosure tableBP-2 material topic flag and topic title dataBP-2 strategy connection and policy coverage inputsBP-2 action summary and target details preparationBP-2 metric set data collection guidanceBP-2 assurance claims claim risk evidenceBP-2 from company reports links
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