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ESRS 2: General Disclosures · 2026-5010-final
Disclosure Requirement SBM-3

Material Impacts, Risks and Opportunities and Their Interaction with Strategy and Business Model

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 which material sustainability impacts, risks and opportunities matter most to its business model and strategy, and how those matters connect to the way the organisation creates, delivers and preserves value. In practice, it is about showing the link between what is material and the organisation’s strategic choices, rather than listing issues in isolation.

The practical focus is on whether the organisation has considered its full business, not just a few headline sites or activities. It should describe how the material matters are reflected across operations, value chain and decision-making, and where there are differences in relevance by geography, business line or site type. The aim is to show the breadth of coverage and the real strategic implications, in a way that is clear and specific to the organisation.

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
Interaction with strategy Describe how the issue links with the organisation’s strategy, including the practical way it affects or is affected by that strategy. Strategy papers, board packs, risk registers, business planning notes. Strategy / sustainability team
Strategic response Set out the organisation’s chosen strategic response to the issue, in plain terms that show the direction of travel and the main actions at a high level. Strategy refresh papers, executive committee papers, transformation roadmap. Strategy / executive management
Planned response Capture the actions the organisation plans to take in response to the issue, including the intended measures and implementation approach. Action plans, programme plans, project trackers, management approvals. Business planning / programme management
Revenue effect Explain the expected effect on income, including the main revenue streams that may change and the direction of that change. Budget models, revenue forecasts, commercial plans, finance review papers. Finance / commercial team
Cost effect Explain the expected effect on costs, including the main cost categories that may rise or fall and the direction of that change. Budget and forecast files, cost centre reports, procurement plans, finance commentary. Finance / procurement / operations
Balance sheet effect Describe the expected effect on assets and liabilities, including which balance sheet items may change and how. Forecast balance sheet, impairment papers, provisioning memos, treasury papers. Finance / treasury / accounting
Cash movement effect Explain the expected effect on cash movements, including the main inflows or outflows and when they are expected to arise. Cash flow forecast, treasury model, capex plan, working capital analysis. Treasury / finance
Expected financial change State the financial changes the organisation expects from the issue, covering the relevant measures of performance, position and cash. Integrated forecast, scenario outputs, finance papers, board reporting. Finance / strategy
Assessment periods Set out the time periods used for the assessment, making clear which horizons were considered and how they were grouped. Scenario pack, planning assumptions, board papers, risk assessment notes. Strategy / risk / finance
Planning basis Explain the basis used for the assessment, including the scenario or planning approach and the assumptions behind it. Scenario analysis pack, planning assumptions log, sensitivity analysis, governance approvals. Strategy / risk / finance
Why not quantified Record why the effect could not be measured in numbers, including the specific barrier to quantification. Methodology note, finance memo, data gap log, management review comments. Finance / sustainability reporting
Qualitative financial effect Describe, in words, how the issue is expected to affect the organisation’s finances when a numeric estimate is not available. Management commentary, risk assessment, scenario notes, business impact analysis. Finance / strategy / risk
Affected statement lines List the financial statement line items that are likely to be affected by the issue, using the organisation’s reporting categories. Chart of accounts mapping, financial statement draft, accounting memo, audit trail. Finance / accounting
Resilience assessment Describe how the organisation’s business model and strategy hold up under the issue, including the main conclusions from the resilience review. Resilience assessment, scenario analysis, board papers, strategy review documents. Strategy / risk / sustainability
Assessment method Explain the method used to test resilience, including the analytical approach, inputs and any key assumptions. Methodology paper, scenario model, assumptions log, validation notes. Strategy / risk / finance
Assessment periods used State the time periods applied in the resilience assessment, showing the horizons actually tested. Scenario analysis outputs, planning timetable, board materials, assumptions schedule. Strategy / risk / finance
＋ Show SBM-3 sub-elements (LRA working checklist)

How to prepare it

1Set the boundaries for the write-up first: decide which business areas, activities, and time periods you are covering, and make sure the scope matches the matters you are reporting on.
2Translate each required item into your own reporting definitions: agree what you will treat as the interaction with the business model, the strategic reply, the planned follow-up, the financial effects, the expected changes, and the resilience assessment so the team uses one consistent meaning throughout.
3Gather the support behind each statement before drafting: pull together the internal papers, forecasts, planning materials, scenario work, and other source records needed to back the narrative and any figures.
4Build the disclosure in the required mix of text and numbers: explain the interaction and strategic response, set out the planned response, show the revenue, cost, balance-sheet and cash-flow effects where relevant, and include the expected financial changes, timing, and planning basis.
5If you cannot quantify something, say so plainly and explain why: describe the effect in words, identify the financial statement line items that are likely to be affected, and state the reason the item is not presented as a number.
6Record any exclusions, changes in approach, and the basis for the resilience assessment, then check the final wording back against the official source to confirm nothing important has been missed or altered.
Request the data

Request the strategy-and-financial impact evidence

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

How do the main sustainability-related issues connect to the business model, what actions are being taken, and what financial effects or planning assumptions support that story?

Use your organisation’s own labels first, then map them to the reporting categories. For example, if you talk about business drivers, investment cases, budget pressures, forecast assumptions, or balance sheet items internally, keep that language in the request and only translate it later for reporting.

Weak request

Please provide the ESRS 2:SBM-3 evidence for material impacts, risks and opportunities, including interaction with strategy and business model, financial effects, resilience, and any non-quantified items.

Why it fails: It uses framework language that many internal owners will not recognise, so they may not know which pack, model, or decision paper to send. It also does not point to the business issue, the source file, the planning basis, or the specific financial outputs needed.

Better request

Please send the latest internal pack for [internal issue name] that shows how it affects the business model or plan, what response is underway or planned, and any revenue, cost, asset, liability, or cash impacts. Include the scenario or planning basis, the time view used, and any items that were not quantified with the reason and the line items likely affected.

Formal email template
Subject: Request for strategy and financial impact evidence for [reporting period]

Dear [name/team],

We are preparing the sustainability reporting pack and need your help with the business impacts linked to [internal issue name].

Please share the material you use internally that explains:
- how this issue affects the business model or operating plan;
- what response is already underway or planned;
- any financial effects you have identified, including revenue, cost, asset, liability, or cash impacts;
- the planning basis, time view, and any scenario or assumption set used;
- any cases where the effect could not be quantified, together with the reason and the related line items that may be affected.

Please send the source file or extract, plus a short note on the boundary, period, and owner for the information. If there are multiple versions, please indicate which one is the latest approved or management-reviewed version.

Please adapt this to your organisation’s own terminology and check the official source before sign-off.

Kind regards,
[preparer name]
[team]
[contact details]
Short Teams / Slack version
Hi [name/team] — could you send the latest internal pack for [internal issue name] covering: business impact, current/planned response, any revenue/cost/asset/liability/cash effects, the planning basis, and any qualitative-only items with the reason they were not quantified? Please include the period, boundary, source file, and owner. Please adapt this to your organisation’s own terminology and check the official source before sign-off. Thanks, [name]
Industry examples
Manufacturing

Context. A plant team tracks energy cost exposure, equipment downtime risk, and capex for process changes in monthly operations and budget packs.

Adapted request. Please share the latest operations and finance pack for [internal issue name] showing how it affects plant output, cost base, and investment plan, plus any revenue, cost, asset, liability, or cash impacts. Include the budget or scenario basis, the time view, and any items left qualitative with the reason.

Example response. A workbook with plant-level assumptions, a capex note, a forecast bridge, and a short narrative on why one risk was not quantified because the estimate range was too wide.

Retail

Context. A trading and planning team monitors supplier disruption, product mix changes, margin pressure, and stock impacts through forecast and trading updates.

Adapted request. Please send the latest trading and planning pack for [internal issue name] showing how it affects sales, margin, stock, and cash, together with the response plan and any scenario assumptions used. If any effect was not quantified, please explain why and note the line items likely affected.

Example response. A monthly trading pack with sales and margin sensitivities, stock write-down assumptions, a scenario summary, and a note that one supplier risk was described qualitatively because the timing of disruption was uncertain.

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

Set out how the figures were prepared, including what each measure covers, the basis used for any estimates or scenarios, the time periods applied, and the reason where an effect is described without a number.

Context note

Explain what the reported amounts and descriptions mean for the business, linking the interaction, the response taken, the expected financial effects, and the parts of the accounts that may be affected.

Fluctuation statement

If the numbers or expectations change, point to shifts in the underlying issue, the response plan, the time horizon, or the planning assumptions used to estimate the effect.

Content index entry
SBM-3 Material Impacts, Risks and Opportunities and Their Interaction with Strategy and Business Model — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for SBM-3 — 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
01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧
Go deeper · SBM-3
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
We based the coverage figure on the same boundary we used for the rest of the report, and we can show why any sites, entities or activities were left out.Assurer checks whether the boundary is consistent, whether exclusions were deliberate rather than accidental, and whether the figure could be overstated or understated by missing parts of the business.Boundary memo; list of included and excluded entities/sites/activities; consolidation or reporting scope workpapers; management sign-off on scope decisions; reconciliation of the coverage figure to underlying population data.
We explained how the disclosed operations link back to our business model and strategy, and we kept working papers showing the basis for that mapping.Assurer probes whether the narrative is supported by evidence, whether the link to strategy is genuine, and whether material items were omitted because they were not traced through the business model.Strategy papers; business model diagrams; materiality assessment outputs; mapping of impacts, risks and opportunities to business activities and value chain stages; board or management papers approving the linkage.
We set out the actions already taken and the actions planned to deal with the identified matters, and we retained the decision papers behind those choices.Assurer checks whether the response described is real, current and approved, and whether the report overstates progress or omits planned actions that are still needed.Action plans; investment or change programme approvals; project status reports; governance minutes; implementation trackers; evidence of completed and planned measures.
We described the current financial effect using the figures we could support, and where we did not quantify it we kept the reasons and the related line-item references.Assurer probes whether the numbers tie to finance records, whether any unquantified items were properly justified, and whether the affected statement lines were identified correctly.Finance extracts; calculation sheets; management estimates; audit trail to ledger or reporting packs; rationale for any non-quantified items; mapping to financial statement line items.
We prepared the forward-looking effect view using our planning assumptions and scenario work, and we can show the time bands and the basis used for each estimate.Assurer checks whether the outlook is grounded in approved assumptions, whether the time horizons are consistent, and whether the estimates are too speculative or selectively presented.Budget and forecast packs; scenario analysis files; planning assumptions; sensitivity analyses; time-horizon definitions; governance approval of the modelling basis.
Where we did not put a number on an effect, we recorded why, what it means in practice, and which financial statement lines could be touched.Assurer probes whether the non-quantification is justified, whether the qualitative description is specific enough, and whether the linked financial lines are complete and accurate.Non-quantification rationale; internal review notes; qualitative impact summaries; mapping to affected line items; evidence that quantification was considered and rejected for stated reasons.

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 a team that does not hold the underlying records, so the answer is built from second-hand knowledge instead of the operational source.
Framework language only
People ask for the data using reporting jargon rather than the business’s own terms, and the right team cannot map the request to its records.
Scope left vague
No one states which part of the business, which activities, or which locations are in scope, so different teams collect different slices of the same topic.
＋ Show 5 more

Where judgement is often needed

Acquisitions, disposals, and perimeter shifts
Use the reporting boundary that matches the period you are explaining, and if a buy-in, sale, or reorganisation changes the group of entities covered, say when the change happened and whether the figures include the old or new perimeter.
Different local definitions for the same topic
Where countries or business units use different operational definitions, pick one basis for the group narrative, explain the main differences, and show any material split or reconciliation needed to avoid mixing unlike data.
People or activities near the edge of scope
Decide consistently whether to include borderline workers, sites, products, or customers, then disclose the inclusion rule and any exclusions so readers can see how close-to-the-line cases were handled.
＋ Show 7 more
Examples

Illustrative examples

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

Illustrative (synthetic) example — industrial equipment manufacturing

We explain that a shift in customer demand toward lower-emission products is already changing how we sell, design and source components, so the board and its committees have approved a product redesign programme and a supplier-screening plan for the next two years. In this scenario, we expect a €120 million revenue effect, €18 million of extra operating spend, a €9 million balance-sheet effect and a €6 million cash effect, with the main lines likely touched being revenue, cost of sales, inventories, trade payables and operating cash flow. - Our forward view is based on a three-scenario planning exercise covering the next 12, 24 and 60 months, using internal demand forecasts and transition assumptions; we expect the largest changes in the medium term, with a smaller effect in the short term and a more material shift by year five. - We have not put numbers on some parts of the effect because the timing and size are still too uncertain; those unquantified items are described qualitatively as possible margin pressure, higher working-capital needs and occasional asset write-down risk, and they may affect revenue, operating profit, inventories, receivables and cash flow. - We judge the business model to be resilient because the planned redesign, supplier changes and pricing actions should allow us to keep serving core customers even if the transition is slower or faster than expected.

Synthetic, illustrative only; figures are internally consistent and intended to show how a reporter might describe the interaction, response, quantified effects, unquantified effects and resilience in plain language.

Illustrative (synthetic) example — food and beverage processing

We describe how hotter summers and water constraints are already influencing sourcing, production scheduling and product mix, and our management team has set a response plan covering water efficiency, recipe reformulation and selective price changes. On the basis of a climate-stress test and internal planning assumptions, we expect a €75 million revenue effect, €11 million of added costs, a €4 million asset and liability effect and a €3 million cash effect, with the most likely affected lines being sales, production costs, property and equipment, provisions and operating cash flow. - Our outlook uses a two-path planning basis over the short, medium and longer term, and we expect the financial effect to build gradually rather than arrive all at once. - We have left some items unquantified because the evidence is not yet strong enough to support a reliable estimate; qualitatively, those items could mean lower volumes in peak periods, higher utility and logistics spend, and possible impairment pressure on certain sites, affecting sales, operating expenses, fixed assets, provisions and cash generation. - Even so, we consider the group reasonably robust because the response plan gives us options to shift sourcing, adjust production and protect supply to key customers if conditions worsen.

Synthetic, illustrative only; figures are internally consistent and intended to show a second plausible reporter with a different sector and a different pattern of effects.

Company reportsReal published reports
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How companies report SBM-3 in practice

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

Continental AG
Tires · Germany · 2025
Open report →
Continental AG’s 2025 Annual Report provides evidence of identifying and assessing material actual and potential negative and positive impacts, risks, and opportunities (IROs), with integration of these IROs into the company’s strategy and business model described on page 97. The report also references material impacts, risks, and opportunities related to biodiversity, ecosystems, and business conduct on pages 156, 158, 204, and 211, though detailed disclosures are not clearly presented. Several specific datapoints remain not found or unclear, including explicit disclosures for SBM 3.24.1, 3.24.3, 3.25 series, and 3.27.3, indicating gaps in comprehensive reporting for these elements.
Mowi ASA
Food Production — Animal Source · Norway · 2024
Open report →
Mowi ASA’s Integrated Annual Report 2024 provides a reported value on material impacts, risks, and opportunities and their interaction with strategy and business model on page 60, indicating some coverage of this disclosure (p.60). The report also includes a description of the process to identify and assess material impacts, risks, and opportunities, though this is presented in a general narrative form without clear, specific disclosure of the datapoint (p.69). Several related datapoints, including detailed methodologies and specific quantified disclosures, are not found or remain unclear in the report.
Endesa, S.A.
Electric Utilities / IPP / Energy Traders · Spain · 2025
Open report →
Endesa's 2025 Consolidated Annual Report provides evidence of a comprehensive process studying all sub-topics defined in applicable regulations and analysing dependencies between Impacts, Risks and Opportunities (IROs), as detailed on pages 320 and 331. The report also references the identification of material IROs for the 2025 financial year with a time horizon alignment (p.286) and discusses the interaction of IROs with strategy and business model (p.153), though these disclosures are less clearly articulated. Notably, several specific datapoints related to detailed disclosures of impacts, risks, opportunities, and policies are not found or are unclear in the report.
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Scenarios to work through

A manufacturer has identified a major transition risk from tighter product standards. The board has approved a shift toward lower-emission product lines, but the finance team has not yet linked that shift to any forecast changes.

QWhat should the preparer do when describing how this issue connects to the business model and strategy?
Reveal model answer →

A services group expects a new customer requirement to reduce revenue in one region over the next two years, while also increasing compliance spend and contract assets. Management has a rough estimate for revenue and costs, but not for the balance sheet effect.

QHow should the preparer decide what to include about the financial consequences?
Reveal model answer →

A retailer has run an internal planning exercise using three climate pathways and a five-year budget cycle. The exercise shows that one pathway would materially affect store refurbishment timing, but the team is unsure whether to present the analysis as a resilience assessment or as a general planning input.

QWhat is the right judgement on how to explain the basis for the analysis?
Reveal model answer →

A mining group has identified a long-term water-stress risk that could affect production, but the impact is too uncertain to quantify reliably today. The team can describe likely operational effects and knows the issue may affect impairment testing and provisions.

QWhat should the preparer do when the effect cannot be measured with confidence?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

ESRS
SBM-3
within ESRS 2: General Disclosures
Open official source →
Primary
Related & explore
Go deeper · SBM-3
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

How do I use the SBM-3 page to draft the disclosure from scratch?+
What data do I need to collect for SBM-3 before I start writing?+
How should I decide the scope and methodology for SBM-3?+
Who should own the SBM-3 disclosure and the underlying data?+
What evidence pack do I need to make SBM-3 assurance-ready?+
What are the common mistakes to avoid when preparing SBM-3?+
How do I use the synthetic example disclosures on the SBM-3 page?+
What should I put in the narrative if I cannot quantify a financial effect for SBM-3?+
How do I use the workbook and printable Library Card for SBM-3?+
What does the 'From company reports' table help me do for SBM-3?+
How do I turn SBM-3 data into a draft output the business can review?+
More questions this page can help with
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