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ESRS 2: General Disclosures · 2026-5010-final
Disclosure Requirement GDR-T

Targets in Relation to Material Sustainability Matters

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official EFRAG source.

Dr Ross Kurinko, Sustainability Reporting Trainer
Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by EFRAG
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to explain the targets it has set for the sustainability matters it has identified as material, and how those targets relate to the issues that matter most to the business and its stakeholders. In practice, the focus is on showing what the organisation is aiming to achieve, why those aims are relevant, and how they connect to the material topics already identified in the reporting process.

The practical emphasis is on whether the targets are organisation-wide or limited to particular parts of the business, such as specific operations, regions, products or sites. It also helps readers understand the scope and ambition of the targets, so they can see whether the organisation is covering its full material footprint or only selected activities.

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

Datapoint What to capture Evidence hint Owner
Target level State the intended end point or level the organisation is aiming to reach. Target-setting paper, board-approved plan, or KPI register. Sustainability / strategy
Target assumptions Set out the key assumptions used when the target was designed, including any conditions the target depends on. Target model, planning memo, or assumptions log. Sustainability / strategy
Target legal basis Note any law, regulation, permit, or other formal rule that underpins the target, if one exists. Legal register, compliance memo, or cited statute/permit reference. Legal / compliance
Scenario basis Identify the scenario or planning case used to frame the target, including the named scenario if one was used. Scenario analysis, transition plan, or modelling pack. Strategy / climate planning
Policy fit Explain how the target sits alongside the organisation’s own policies and commitments. Policy map, internal policy register, or alignment note. Sustainability / policy
Scientific support Describe the scientific or technical basis used to justify environmental targets. Technical paper, external science reference, or methodology note. Sustainability / technical team
Target type Specify whether the target is set as a fixed amount or as a proportion, rate, or other relative measure. Target register, KPI definition, or reporting template. Sustainability / reporting
Measurement unit Record the unit used to express the target value, such as tonnes, percentage, or currency. KPI dictionary, target register, or calculation sheet. Sustainability / reporting
Target boundary Define which parts of the business, activities, or locations are included in the target. Boundary statement, consolidation memo, or scope definition. Finance / sustainability reporting
Starting point Capture the starting value used for the target comparison, with the same metric and boundary as the target itself. Baseline calculation, prior KPI report, or source data extract. Sustainability / data team
Base year State the reference year used as the anchor for the target. Target register, board paper, or reporting calendar. Sustainability / reporting
End year State the year by which the target is meant to be achieved. Target register, roadmap, or board-approved plan. Sustainability / strategy
Interim checkpoints List any intermediate milestones or step-down targets on the way to the final target. Roadmap, target trajectory, or milestone tracker. Sustainability / strategy
Target method Describe the method used to set the target, including how the target was calculated or derived. Methodology note, calculation workbook, or target-setting memo. Sustainability / analytics
Progress tracking Explain how progress is monitored when no formal target has been set, including the approach used to follow change over time. Management dashboard, KPI tracker, or monitoring framework. Sustainability / performance management
Effectiveness measures List the indicators used to judge whether the action is working, and show how they are used to assess effectiveness. KPI dashboard, monitoring report, or programme evaluation note. Sustainability / performance management
+ Show GDR-T sub-elements (LRA working checklist)

How to prepare it

1Set the reporting perimeter first: decide which activities, entities, and time periods sit inside the target or tracking statement, and make sure the same boundary is used consistently across the related figures or narrative.
2Define the target or tracking content in business terms: state the level you are aiming for, whether it is an absolute or relative measure, the unit used, the baseline, the base year, the target year, and any interim milestones.
3Gather the support behind the numbers or narrative: pull together the method used, the assumptions made, any legal foundation where relevant, the scenario basis, the policy link, and the scientific basis where the target concerns environmental matters.
4Prepare the actual disclosure text or table: present the target or, where no target exists, explain the tracking approach and the indicators used to judge progress or effectiveness.
5Record anything that affects interpretation: note exclusions, boundary changes, and any changes in approach so readers can understand what is and is not included and why the current presentation differs from earlier periods, if it does.
6Check the draft against the official source before sign-off: confirm every required item is covered, the wording is faithful in meaning, and the final output matches the source requirements without adding or omitting anything.
Request the data

Request the target register and tracking evidence

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

What targets, milestones, and tracking methods are we using for each material sustainability topic, and what evidence supports them?

Use your organisation’s own terms first, then map them to the reporting fields. For example, ask for the target register, KPI pack, or performance dashboard rather than using framework labels in the first message. This is a possible LRA training template only; adapt it to your organisation and check the source material before sign-off.

Weak request

Please provide the ESRS 2:GDR-T information for all material sustainability matters, including target value, baseline, methodology, assumptions, scenario basis, policy alignment, and tracking approach.

Why it fails: It uses framework language that many internal owners will not recognise, and it bundles too many concepts without telling the recipient what practical records to send. It also does not point them to the internal artefacts they actually hold, such as the target register, KPI pack, or dashboard.

Better request

Please send the current target register and progress pack for [topic], including the target level, whether it is absolute or relative, the unit, boundary, baseline, base year, target year, milestones, measurement method, and any assumptions, policy links, scenario inputs, or scientific references used. If there is no formal target, send the measures used to track performance instead. Please include the source file, owner, and approval date.

Formal email template
Subject: Request for target and progress evidence for [material topic / workstream]

Dear [name],

I am preparing the sustainability reporting pack and need the current evidence for [material topic / workstream]. Please share the latest target register, milestone plan, and any tracking material that shows how progress is being measured.

To help us map this correctly, please include:
- the target value or level currently in use
- whether it is an absolute or relative measure
- the unit used internally
- the boundary covered
- the baseline and base year
- the target year
- any interim milestones
- the method used to calculate or monitor progress
- any assumptions, scenario inputs, policy links, or scientific references used when the target was set
- if there is no formal target for this topic, the measures used to track performance instead

Please also include the source file or system, the owner, the approval date, and any notes on changes since the last review.

This is a possible LRA training template only; please adapt it to your organisation’s own language and check the source material before sign-off.

Many thanks,
[preparer name]
Short Teams / Slack version
Hi [name] — I’m pulling together the sustainability pack for [period]. Could you send the latest target tracker / KPI pack for [topic], plus the baseline, milestones, measurement method, and any notes on assumptions or policy links? If there isn’t a formal target, please send the measures you use to track progress instead. Please include the source file and owner. Thanks.
Industry examples
Manufacturing

Context. The business has an energy reduction programme across owned plants and a separate safety improvement plan.

Adapted request. Please send the latest plant-level target tracker for the energy programme and the safety improvement plan, including the target level, unit, baseline, base year, target year, interim milestones, and the method used to roll up site results. If either programme has no formal target, send the KPI dashboard used to monitor progress instead. Please include the source file, owner, and approval date.

Example response. A site tracker showing: energy use reduction target of 12% by FY2028 versus FY2023 baseline; quarterly milestones for FY2025–FY2027; monthly meter-based reporting; and a note that the safety plan is tracked through incident-rate KPIs rather than a formal target.

Retail

Context. The business tracks supplier standards and packaging reduction through separate operational scorecards.

Adapted request. Please send the current scorecards for supplier standards and packaging reduction, including the target level, whether it is an absolute or relative measure, the unit, baseline, base year, target year, milestones, and the method used to monitor progress. If a scorecard has no formal target, please send the indicators used to track performance instead. Include the source system and the owner.

Example response. A procurement scorecard showing: 90% of strategic suppliers assessed by FY2026, baseline FY2024 at 62%; packaging reduction tracked as grams per unit sold with quarterly milestones; and a note that one supplier programme is monitored through audit completion rates rather than a formal target.

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

Explain how the target was defined, including the measurement basis, the unit used, the scope covered, the starting year, the end year, any interim checkpoints, and the approach used to set it.

Context note

Describe what the target means in practice by linking the stated level to the business area covered, the comparison year, and the basis used to support the target.

Fluctuation statement

If the target or its milestones changed, explain what drove the change, such as a revised assumption set, updated scenario work, a different policy position, new scientific input, or a change in legal grounding.

Content index entry
GDR-T Targets in Relation to Material Sustainability Matters — [location / page] / [notes]
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Preparation tools & forms

Professional preparation tools for GDR-T — 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
Go deeper · GDR-T
Learn to prepare this disclosure end-to-end

This guide covers one Disclosure Requirement. The ESRS / CSRD Reporting course walks the full European workflow — double materiality, datapoints, evidence and assurance — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
I have set out the figure in a way that shows the intended level to be reached, and I have stated the unit used to measure it.The assurer may test whether the stated figure is internally consistent, whether the unit matches the metric, and whether the wording could be read as vague or incomplete.Target schedule or KPI register; draft and final report wording; calculation sheet showing the unit applied; sign-off notes confirming the figure and unit were reviewed together.
I have explained the approach used to define the figure, including the main assumptions that materially affected it.The assurer may probe whether the method was chosen consistently, whether key assumptions were documented at the time, and whether any assumption could materially change the result.Methodology paper; assumption log; model inputs and version history; approval papers showing the basis used to set the figure.
I have stated whether the figure is set because a rule or legal duty requires it.The assurer may check whether the statement is clear, current, and supported by a legal assessment rather than a general policy statement.Legal review memo; compliance register; board or committee paper noting the basis for the figure; draft disclosure showing the required/not required conclusion.
I have described the scenario choices, the main information sources used, and how closely the result aligns with relevant public policy aims.The assurer may test whether the chosen scenarios are identifiable, whether the data sources are traceable, and whether the stated policy alignment is supportable.Scenario selection paper; source list and data lineage records; internal assessment of policy alignment; working papers showing how the scenarios were compared.
I have explained the scenario basis, the key datasets behind it, and the extent to which the result fits with policy goals at national, EU, or wider international level.The assurer may probe whether the policy comparison is overstated, whether the datasets are reliable, and whether the basis used is consistent across the disclosure.Scenario analysis pack; data source register; cross-checks against external policy references; review notes confirming the level of compatibility stated.
I have linked each measurable target to the relevant policy aims and actions, and I have shown that it is outcome-focused and time-bound.The assurer may test whether the target is genuinely measurable, whether the link to actions is clear, and whether the target is specific enough to assess progress.Target-setting paper; policy-to-target mapping; action plan or roadmap; approval minutes showing the target was framed as an outcome measure.

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, wrong language
Teams often ask the policy lead or a framework specialist instead of the business owner who actually tracks the target in the organisation’s own terms.
Scope left vague
People sometimes collect a target figure without pinning down which sites, entities, activities or time periods sit inside the boundary.
Baseline and current year mixed up
The data pack can combine the starting point, the reference year and the latest update, so the target path no longer ties back cleanly.
+ Show 7 more

Where judgement is often needed

Setting the starting point after a business change
If a purchase, sale, or reorganisation changes the group you are measuring, choose a baseline that matches the new operating perimeter and explain what changed, when it changed, and whether earlier figures were restated or left as originally reported.
Using one group definition across different countries
Where local reporting populations or legal entities are not identical in every country, pick a consistent organisational boundary for the target and explain any exclusions, local carve-outs, or country-specific adjustments.
Deciding who sits just inside or just outside the target
For people, sites, products, suppliers, or other units near the edge of the target scope, state the inclusion rule you applied and disclose any material exclusions so readers can see how the coverage was drawn.
+ Show 5 more
Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Electric utility

We set a 2035 emissions goal for our own operations and purchased electricity, using 2024 as the starting point and a 2029 checkpoint on the way. The target is a 42% cut from the 2024 baseline of 1,000,000 tCO2e to 580,000 tCO2e by 2035; this is an absolute target, measured in tCO2e, and it covers our consolidated group boundary, including majority-controlled subsidiaries. - The target design is aligned to our climate policy and uses a 1.5°C pathway as the scenario reference. - We rely on a science-based pathway for the environmental target, and the approach assumes stable grid emission factors, no major portfolio acquisitions, and continued access to current abatement technologies. - There is no specific legal requirement driving this target; our method uses emissions inventory data, operational forecasts, and the same boundary used in our annual reporting, with 2029 set as the interim milestone at 760,000 tCO2e.

Illustrative only: this example shows how to describe the target level, baseline, base year, target year, interim checkpoint, unit, scope, absolute/relative framing, policy link, scenario reference, scientific basis, assumptions, legal basis, and method in plain language.

Illustrative (synthetic) example — Food manufacturing

We have set a water-use goal for our direct manufacturing sites, starting from a 2023 baseline and aiming for 2030, with a 2026 checkpoint in between. The plan is to reduce water withdrawal by 18% from 2,500,000 m3 to 2,050,000 m3, so the target is relative rather than absolute, and it applies only to sites we operate and control. - The target sits alongside our resource-efficiency policy and is framed against a high-water-stress scenario for the regions where we operate. - Because this is an environmental target, we use a science-led approach based on site-level water balances, production forecasts, and local catchment stress data; the main assumptions are steady production mix, no plant closures, and no material change in water recycling rates. - We do not rely on a legal obligation for this target, and our interim step is 2,250,000 m3 by 2026.

Illustrative only: this example shows how to describe a non-emissions environmental target using the same required elements in different wording, including the target level, baseline, dates, interim step, unit, boundary, relative framing, policy link, scenario reference, scientific basis, assumptions, legal basis, and method.

Company reportsReal published reports
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How companies report GDR-T in practice

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

Terna S.p.A.
Electric Utilities / IPP / Energy Traders · Italy · 2025
Open report →
Terna S.p.A.'s 2025 Annual Report includes a reported value related to its baseline year for target formulation, identified as 2025 (p.381), and mentions a cumulative target of 598 km scheduled for achievement by 2028 (p.264). There is partial context on incentive allocation over a multi-year horizon without a clear headline value (p.546). However, several datapoints lack clear disclosures or are not found, including detailed methodologies, specific transition scenarios, and resilience verification approaches, with related context often unclear or missing (e.g., p.233, p.350, p.197).
Fluidra, S.A.
Electrical Equipment and Machinery · Spain · 2025
Open report →
Fluidra, S.A.'s 2025 Integrated Annual Report includes reported values for targets related to climate change mitigation and adaptation, with specific progress and base year data presented on pages 36 and 117. The report references ESRS requirements for targets on managing material impacts and risks, but these disclosures are unclear and lack detailed data, as seen on pages 116 and 200. Several datapoints, including GDR T.51.10 through T.51.13 and others, are not found or clearly disclosed in the report.
LANXESS Aktiengesellschaft
Chemicals · Germany · 2025
Open report →
LANXESS Aktiengesellschaft's Corporate Sustainability Report 2025 provides some reported values related to emissions targets, including milestones and target years for CO2e reductions from 2021 to 2050 (p.42) and an interim target of a 25% reduction by 2030 (p.40). The report also includes supporting context on corporate policy reflecting a responsible approach to water use (p.56). However, several specific data points such as GDR T.51.1, T.51.11, and T.51.12 are not found, and some disclosures like GDR T.51.10 and T.51.4 remain unclear due to lack of quotable methodology or narrative.
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Scenarios to work through

A preparer is drafting a climate target for a group with operations in three countries. The draft says emissions will fall by 30% by 2030, but it does not say whether that is measured against the whole group or only one business line, and the team has not yet written down the base year or the starting figure.

QWhat should be clarified before the target description is ready for sign-off?
Reveal model answer →

A sustainability team has set a water-use reduction goal for a manufacturing site. The draft includes the target number and year, but the team has not explained the assumptions behind the plan, whether any law underpins the target, or whether it was built from a future-pathway scenario or from the company’s own policy commitments.

QWhich supporting context should the preparer add so the target is properly explained?
Reveal model answer →

A company has no formal target for reducing waste yet, but it still wants to show investors how it is managing the issue. The draft lists monthly waste volumes and recycling rates, but it does not explain why those measures were chosen or how they help judge whether the approach is working.

QHow should the preparer handle reporting when there is no target in place?
Reveal model answer →

A group has set a biodiversity target that depends on a future land-use pathway and a public policy commitment. The draft mentions the target year and a few milestones, but it does not explain the assumptions behind the pathway or how the target connects to the company’s wider policy position.

QWhat extra detail should be included so the target can be understood properly?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

ESRS
GDR-T
within ESRS 2: General Disclosures
Open official source →
Primary
Related & explore
Go deeper · GDR-T
Learn to prepare this disclosure end-to-end

This guide covers one Disclosure Requirement. The ESRS / CSRD Reporting course walks the full European workflow — double materiality, datapoints, evidence and assurance — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

FAQ

Questions this page answers

What do I need to gather before drafting GDR-T (ESRS 2: General Disclosures) for a sustainability report?+
How do I set the scope and boundary for the GDR-T target information on this page?+
What evidence should I collect to support the GDR-T disclosure and make it assurance-ready?+
How do I use the GDR-T workbook to prepare the disclosure?+
What are the most common mistakes to avoid when preparing GDR-T?+
How should I document target assumptions, scenario basis and scientific support for GDR-T?+
What should I include in the GDR-T evidence pack for assurance review?+
How do I turn the GDR-T data into a draft disclosure?+
Can I use the synthetic example disclosure on the GDR-T page as a template?+
Where can I find real company examples for GDR-T-style reporting on the page?+
More questions this page can help with
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