Disclosure focus
This disclosure asks an organisation to explain the metrics it uses to track each material sustainability matter, and to show that those metrics are relevant, reliable and used consistently over time. In practice, the report should make clear what is being measured, why those measures were chosen, how they link to the material topics identified, and whether the same approach is applied from one reporting period to the next.
The practical focus is on coverage and comparability: readers should be able to see whether the metrics cover the whole organisation, specific business units, sites or value-chain activities, and whether any important parts are excluded. If the organisation uses different measures for different operations or locations, it should explain the scope and any limitations so users can understand how complete the picture is.
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 GDR-M sub-elements (LRA working checklist)
Set out how the figure was worked out.
State the reported number clearly.
List the data sources and inputs relied on.
Give the measurement unit used.
Explain any assumptions made.
Describe how this period differs from the previous one.
Provide the surrounding context needed to interpret it.
Explain the estimation approach used, where relevant.
Note any limits or weaknesses in the information.
Show progress against the relevant targets.
How to prepare it
1Set the boundary first: decide which business areas, time period, and reporting population the measure covers, so the figure or narrative is tied to one clear scope.
2Define the metric in business terms: state the value being reported, the unit used to express it, and the calculation approach that turns the underlying data into the reported result.
3Gather the underlying records: pull together the source data, input files, and any supporting notes used to build the number or the written explanation.
4If judgement was needed, record it clearly: explain any estimation approach, the assumptions behind it, and the main limits that affect how much confidence users can place in the result.
5Add the context around the result: describe the circumstances that help a reader understand the figure or narrative, note any year-on-year change, and explain progress against any stated target where relevant.
6Document anything that affects comparability and then check the final wording against the official source to confirm the scope, definitions, evidence trail, and disclosures still match the requirement.
Request the data
Request the metric pack from Finance
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What figures, methods and supporting notes do we need to explain each material sustainability metric clearly and consistently?
Use your organisation’s own names for measures, reports and systems first, then map them to the reporting disclosure. Ask for the business terms people already use, not the framework label.
Weak request
Please provide the ESRS 2:GDR-M metrics, including the metric value, unit of measurement, calculation methodology, sources/inputs used, estimation method, assumptions, limitations, contextual information, change vs prior period, and progress toward targets.
Why it fails: It uses framework language that many internal owners will not recognise, so it is harder to action. It also reads like a compliance checklist rather than a practical request for the team’s own report, system output, and explanatory notes.
Better request
Please send the latest performance figures and the notes your team already uses to explain them for [period] and [scope]. Include the value, unit, how it was built, the source report or system, any estimates, assumptions, limits, context, movement since last period, and progress against target. Use your normal business terms first, then we will map them to the reporting pack.
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 produce the figure, including the calculation approach, the data sources or inputs relied on, and any estimation method applied.
Context note
Explain what the figure represents in practice by adding the relevant unit, the surrounding circumstances, and any other information needed to interpret it properly.
Fluctuation statement
If the figure moved versus the prior period, set out the main reasons for the change and note whether progress toward the target improved or slowed.
Content index entry
GDR-M Metrics in Relation to Material Sustainability Matters — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for GDR-M — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.
Free · Community members
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 team asks a policy lead or report drafter for the numbers, when the actual source sits with the operational manager who runs the process and can explain how the figures were built.
Framework language first
The request is sent using disclosure jargon instead of the business’s own terms, so the person holding the data cannot tell which internal report, register, or system extract is being asked for.
No boundary set
People pull figures from an undefined mix of entities, sites, or activities, so the dataset does not clearly show what is in scope and what has been left out.
Wrong time basis
The data is gathered for a different reporting window or cut-off than the one being used for the period under review, which makes the figures impossible to compare cleanly.
Mixed counting basis
One file combines values built on different measurement bases, such as headcount, full-time equivalent, or another internal unit, so the final total is not like-for-like.
Source labels lost
During consolidation, the original names from the source system or spreadsheet are stripped away, so no one can trace each figure back to the exact input it came from.
Separate groups merged
Distinct populations that should stay apart are rolled into one dataset, which hides differences that matter for later explanation and review.
No evidence trail
The collector saves the number but not the supporting notes, assumptions, or file references, so there is no clear record of how the figure was assembled or checked.
No sign-off record
The draft data is passed along without a named reviewer confirming it, leaving no audit trail showing who checked the numbers before they moved into reporting.
Where judgement is often needed
Set the reporting perimeter after a buy-in or sale
If a business has been added or sold during the period, explain which parts of the year are counted, which operations are included in the figure, and whether the prior period has been restated so readers can compare like with like.
Choose one country rule where local definitions differ
Where the same measure is defined differently across countries, pick one basis for the group figure, describe the local differences that were bridged, and state any country-specific exceptions that affect the total.
Decide how to treat people or assets near the boundary
For workers, sites, customers, suppliers, or other populations that sit close to the inclusion line, state the practical rule used to include or exclude them and explain any threshold, test, or judgement applied.
Fix the time basis for the number you report
State whether the figure is taken at period end, averaged over the year, or built from another timing basis, and explain why that timing gives the most useful picture for the matter being measured.
Separate measured data from estimated data
When complete records are not available, identify which parts come from direct records and which parts are estimated, describe the method used for the estimate, and note the main limits on confidence in the result.
Explain the assumptions behind any estimate
Set out the key assumptions that drive the calculation, including any proxy, scaling factor, or conversion used, so users can see how the number was built and how sensitive it may be to those choices.
State how missing or weak source data were handled
If source information is incomplete, inconsistent, or not independently checked, explain the fallback inputs used, the checks performed, and any areas where the figure is less robust than the rest of the metric.
Show how you rounded the number
Tell readers the rounding rule used for the metric and make sure the rounded figure still matches the underlying calculation logic, especially where small changes could affect trend analysis or target tracking.
Aggregate carefully where privacy limits detail
When individual-level disclosure is not possible, report the measure in grouped form, explain the aggregation rule used, and confirm that the grouping still gives a fair view without exposing personal data.
Explain any change from the last reporting cycle
If the method, scope, source data, or estimate approach has changed since the previous period, describe what changed, why it changed, and how that affects the current figure and any comparison with earlier years.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Manufacturing
We report a single group-wide figure for the year, expressed in tonnes of CO2e, and we derive it from metered fuel use, electricity bills, refrigerant logs and supplier activity data using our internal emissions model. For this period, the result is 18,400 tCO2e; the estimate relies on spend-based proxies for 12% of purchased goods where primary data were not yet available, assumes no material change in production mix during the final quarter, and is constrained by incomplete supplier coverage in two upstream categories. - Compared with the prior year, the figure is 4% lower, mainly because of lower grid electricity use and better refrigerant leakage control. - Against our reduction plan, we are 38% of the way to the 2030 target, based on the gap between the current result and the target pathway.
Illustrative only: shows how to present a quantified result, the unit, the calculation basis, the data sources, the estimation approach, the key assumptions, the main limits, the business context, the year-on-year movement and progress against a target in one narrative disclosure.
Illustrative (synthetic) example — Retail
We present one consolidated result for the reporting year in cubic metres, calculated from site meter readings, tanker delivery notes and wastewater invoices, then adjusted through our internal water-balance approach. The reported amount is 126,000 m3; where direct readings were missing, we estimated 9% of the total using seasonal occupancy patterns, assumed normal trading hours across the estate, and note that the figure is less precise for leased sites with shared utilities. - The year-on-year change is a 7% reduction, helped by fixture upgrades and lower wash-down demand. - This leaves us 52% of the way toward our 2028 water-intensity goal, measured against the remaining distance to the target.
Illustrative only: shows a plain-language narrative that covers the measured result, the unit, how the number was built, the inputs used, the estimation approach, the assumptions, the main constraints, the operating context, the movement from the prior period and the position against a target.
How companies report GDR-M in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
REN - Redes Energéticas Nacionais, SGPS, S.A.
Water Utilities · Portugal · 2025
REN's 2025 Integrated Report partially covers workforce health and safety metrics, mentioning the total recordable incident rate and fatality rate on page 668, though without clear disclosure of specific values (p.668). The report provides a partial context on work accidents and their impact on employees on page 141 but lacks headline values or detailed methodology (p.141). Notably, several related datapoints, including methodologies and narrative explanations for health and safety and other indicators, are missing or unclear throughout the report.
Indra Sistemas, S.A.
Software and Services · Spain · 2025
Indra Sistemas, S.A.'s Sustainability Report 2025 provides some methodological context on emissions calculation, mentioning Scope 1 emission sources on page 252 and referencing Scope 3 targets including indirect emissions from purchased goods on page 71. The report partially covers data sourcing for product information on page 85 and workforce metrics collection on page 268, with additional methodology details noted on page 92. However, clear headline values for emissions and comprehensive disclosures for several related datapoints are missing or unclear, with no quotable evidence found for multiple GDR M.49 indicators.
Sanoma Oyj
Education Services · Finland · 2025
Sanoma Oyj's 2025 Annual Report provides partial evidence on sustainable resource use, mentioning efforts to transition away from virgin resources and promote recycled materials (p.102). There is related context on greenhouse gas accounting using 100-year Global Warming Potential values, but no clear disclosure of emissions scope or methodology (p.97). Several datapoints, including specific emissions figures and detailed methodologies, are not found or remain unclear in the report.
✓ LRA AI Assistant · Human-in-the-loop
Ask Study Studio AI assistant about this disclosure
Get practical answers for your reporting context. Your first two answers are free — join LRA Community for free to continue without a limit.
TryHow do I prepare GDR-M?What data do I need to collect?Where can I see a real-report example?What mistakes should I avoid?
2 free answers
Check your understanding
Scenarios to work through
Your team has calculated water use for a material environmental topic using meter reads from owned sites, but the draft note only shows the final figure. A reviewer asks how the number was built and where the underlying data came from.
QWhat should you add so a reader can understand the figure and trace it back to its basis?
Reveal model answer →Hide answer ↑Set out the number itself, the unit you used, the way you worked it out, and the main data sources or inputs behind it. The point is to let a reader see both the result and the trail that led to it, rather than leaving only a headline figure with no explanation.
Why this matters · A metric is not complete unless the value, unit, method and source basis are all clear.
For a greenhouse-gas estimate, part of the data was unavailable for one site, so the team used a proxy based on floor area and utility spend. The draft note mentions the estimate but does not explain the shortcut or its weaknesses.
QHow should you present the estimate so users can judge how much confidence to place in it?
Reveal model answer →Hide answer ↑Explain the estimation approach, the assumptions you relied on, the limits of the approach, and any context needed to interpret the result. If the figure changed from the previous period because the estimate method changed, make that clear as well, so the reader can distinguish a real movement from a measurement effect.
Why this matters · When a figure is estimated, the method, assumptions, limits and context need to travel with it.
A social metric on training hours is reported this year in hours per employee, while last year it was shown as total hours. The team also has a target to raise average hours, but the draft only gives the current number.
QWhat extra explanation is needed before the disclosure is ready for review?
Reveal model answer →Hide answer ↑State the unit and make the basis of calculation clear, then explain any change in how the figure is presented compared with the prior period. If the metric links to a target, show how the current result sits against that target so the reader can see progress rather than a standalone number.
Why this matters · Keep the measurement basis stable and explain any shift, especially where the metric is used to track a target.
A biodiversity indicator combines supplier data, internal site records and a modelled estimate for missing locations. The draft note gives the total but leaves out the fact that some locations were estimated and why the team believes the figure is still useful.
QWhat should the preparer disclose to make the metric understandable and balanced?
Reveal model answer →Hide answer ↑Describe the inputs used, the estimation approach for the missing locations, the assumptions behind that approach, and the main limitations. Add any context needed to interpret the result, including whether the current period differs from the previous one and whether the figure shows movement toward a stated target.
Why this matters · A mixed-source metric needs enough context for users to understand both its strengths and its weaknesses.
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 ✓Disclosures in Relation to Specific Circumstances → Guide ✓Actions and Resources in Relation to Material Sustainability Matters →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
How do I use the GDR-M page to draft the disclosure from scratch?+−
Start with the plain-language explainer, then work through the step-by-step preparation section and the datapoints to prepare. The page is designed to help you turn source data into a draft disclosure, not to replace your internal reporting process.
What data do I need to gather for GDR-M before I start writing the disclosure?+−
The page points you to reported figure, measurement unit, calculation approach, input sources, estimation approach, key assumptions, known constraints, reporting context, period-on-period movement and target progress. Use that list as your collection checklist so you can build the disclosure from complete inputs.
How should I decide the scope and calculation approach for GDR-M?+−
Use the page’s preparation steps and the datapoints list to define what is being reported, how it is measured and how it is calculated. The page also prompts you to capture the reporting context, assumptions and known constraints so the scope is clear in the draft.
Who should own the GDR-M data and sign-off process?+−
The page does not assign roles for you, but it is set up for a sustainability/ESG manager, HR or data owner, and assurance reviewer to use together. In practice, you would assign ownership for the reported figure, the calculation method, the evidence pack and the final review.
What should I include in the evidence pack for GDR-M assurance?+−
The page includes an evidence pack with five items to support assurance readiness, alongside six assurance claims to verify. Use those sections to assemble the documents and checks that show the figure, method and assumptions are supported.
What are the common mistakes to avoid when preparing GDR-M?+−
The page lists common reporting gaps and mistakes so you can check for missing inputs, weak explanations or unsupported figures before drafting. It is best used as a pre-submission quality check rather than as a substitute for your own controls.
How do I use the GDR-M workbook download to prepare the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf. Use the workbook to organise the datapoints, evidence and assurance checks, and use the PDF as a quick reference while drafting.
Can I use the synthetic example disclosure on the GDR-M page as a template?+−
Yes, but only as a worked illustration. The page says the example is synthetic, so use it to understand structure, data presentation and narrative style rather than copying it as a real disclosure.
How do I turn GDR-M data into a draft narrative and content index line?+−
The draft-output section gives visualisation ideas, narrative starters and a content-index line to help you convert the data into report-ready text. Use those prompts to explain the figure, movement, assumptions and context in a concise way.
Where can I find real company examples for GDR-M reporting?+−
The page includes a 'From company reports' table that links to real published reports at the pages where the topic is disclosed. Use it to see how others present similar information, but keep your own disclosure based on your organisation’s data and context.
More questions this page can help with
GDR-M disclosure checklist for reported figure, unit, calculation approach and assumptionsGDR-M assurance evidence pack what documents do I needHow to use the GDR-M Prep & Assurance workbook and printable Library CardGDR-M common reporting gaps and mistakes to check before submissionGDR-M synthetic example disclosure table how to read itGDR-M period-on-period movement and target progress how to explain in a draftGDR-M reporting context what should be includedWho should review GDR-M data before assuranceGDR-M step-by-step how to prepare the disclosureGDR-M evidence pack and assurance claims explained for practitionersGDR-M draft output narrative starters and content index line examplesGDR-M company report examples where the topic is disclosed
How this library is built
312 published reports indexed
63171 pages with page-level citations
247 practitioner guides
Free · LRA Community
Get your GDR-M tools — free
Your preparation tools are free for LRA Community members and students. Register once (it's free) and your download starts right away — plus the Disclosure Library, templates and the LRA AI-assistant.
✓
You're in — your download is starting
Your file is downloading now. Your Community Cabinet — with the Disclosure Library, templates and the LRA AI-assistant — is ready too.
Open your Cabinet →