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ESRS 2: General Disclosures · 2026-5010-final

Disclosure Requirement GOV-2

Information Provided to and Sustainability Matters Addressed by the Administrative, Management and Supervisory Bodies

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.

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Reviewed by Dr Ross Kurinko · Sustainability Reporting Trainer LRA educational guidance · Not issued or endorsed by EFRAG

To prepare this disclosure

4datapoints↓ 4claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain what sustainability information is actually reaching its administrative, management and supervisory bodies, and which sustainability matters those bodies are dealing with. In practice, it is about showing whether the top governance bodies are being kept informed in a meaningful way, and whether they are discussing the issues that matter most to the business and its impacts, risks and opportunities.

The practical focus is on breadth and relevance, not just isolated examples. An organisation should think about whether the reporting and discussion cover the whole business where relevant, rather than only a few flagship sites, and whether the matters addressed reflect the organisation’s significant sustainability topics. The aim is to show how governance bodies are connected to sustainability oversight in day-to-day decision-making, not just at a high level.

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.

Have we actually used a pay-linked plan for any leaders, or is the answer no? If there is a pay-linked plan, which parts of it do we need to describe: the main features, the measures it tracks, and the share of variable pay tied to sustainability? Are the measures and targets we plan to mention the ones the board used in the period we are reporting on, rather than older or draft versions? Can every figure or percentage we include be traced back to a source we can show, such as payroll, board papers, or the incentive plan document? Have we agreed what counts as a sustainability-linked pay element in our own organisation, so we use the same definition throughout?

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner

Incentive plan flag State whether any pay or bonus arrangement includes a sustainability-linked element for the reporting period. Remuneration policy, bonus plan documents, board or committee papers approving the scheme, HR or reward records. Reward / HR

Scheme design summary Describe the main features of the sustainability-linked pay arrangement, including how it works and who it applies to. Reward policy, plan rules, committee minutes, HR guidance, and any internal summary of the arrangement. Reward / HR

Performance measures used List the measures or indicators used to judge performance under the sustainability-linked pay arrangement. Plan rules, scorecards, KPI schedules, committee papers, and performance framework documents. Reward / HR

Sustainability pay share Capture the share of variable pay that is tied to sustainability-related performance, using the same basis as the remuneration calculation. Reward calculations, bonus model, committee-approved payout schedules, and payroll or reward system outputs. Reward / HR

＋ Show GOV-2 sub-elements (LRA working checklist)

State whether an incentive scheme is in place. Describe the main features of that scheme. Show what share of variable pay is tied to sustainability. List the targets or measures used for that link.

How to prepare it

1Confirm which pay arrangements sit in scope for this disclosure, then separate any scheme that is tied to sustainability from other reward plans so you only assess the relevant ones.

2For each in-scope arrangement, define the basic design features in plain business terms: who can receive it, what drives the award, and how it operates in practice.

3Identify the measures or performance indicators used to judge outcomes, and gather the source records that show how those measures were set and applied.

4Work out the share of variable pay connected to sustainability for the reporting period, using a clear and traceable calculation that can be checked back to the underlying records.

5Record any exclusions, boundary choices, restatements, or changes in method, and explain why they were made so the reported information is understandable and comparable.

6Before finalising, compare the draft against the official source material and internal approvals to make sure the wording, figures, and scope all match the underlying evidence.

Request the data

Request board and committee briefing evidence

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

What information was shared with the board and its committees about sustainability topics, and what pay-linked measures were in place during the reporting period?

Use your organisation’s own names for the board, committees, pay plans and performance measures first, then map them to the reporting disclosure. Keep the ask in business language rather than framework wording, and check the source material before sign-off.

Weak request

Please provide the ESRS 2 GOV-2 information on the evidence needed for ESRS 2:GOV-2, including incentive scheme details and the percentage of variable remuneration linked to sustainability.

Why it fails: This uses framework wording that many internal owners will not recognise, so it is harder to route, harder to answer, and more likely to produce a compliance-style reply instead of the underlying papers and plan data. It also bundles several asks without naming the actual board materials or internal plan records the owner should pull.

Better request

Please send the board and committee papers for [period] that show which sustainability topics were covered, plus any pay plan or scorecard that used sustainability-linked measures and the share of variable pay tied to those measures. Use your own names for the forums and plans, and include the document reference for each item.

Formal email template

Subject: Request for board and committee evidence for sustainability reporting

Hi [name/team],

We are preparing the sustainability reporting pack and need a short evidence extract covering what was shared with the board and committee(s) during [reporting period].

Please send, for [entity/boundary]:
- the main sustainability topics discussed with the board and committee(s)
- the briefing papers, slides, minutes extracts or other records showing those topics
- any pay plan or incentive plan that included sustainability-linked measures
- the measures, targets or scorecard items used
- the share of variable pay linked to those measures, if applicable
- the period covered and the source document reference for each item

Please use your own internal names for the forums, plans and measures. A simple table is fine.

If helpful, I can share a template. Please also check the source material before sign-off.

Thanks,
[preparer name]

Short Teams / Slack version

Hi [name/team] — could you share the board/committee papers for [period] showing the sustainability topics discussed, plus any pay plan details with sustainability-linked measures and the share of variable pay tied to them? Please use your internal names and include the source reference for each item. A table is fine. Thanks.

Industry examples

Manufacturing

Context. The board receives quarterly operational and risk updates, and the bonus plan includes safety and energy efficiency measures.

Adapted request. Please share the board pack extracts and minutes for [period] showing the sustainability topics discussed, plus the annual bonus plan summary where safety and energy efficiency measures were included. For each measure, include the target, the scorecard weight, and the share of variable pay linked to it.

Example response. Board pack Q2 2025; topics covered: plant safety, energy use, water; annual bonus plan: safety incident rate 10%, energy intensity 5%; variable pay linked to sustainability measures: 15%.

Retail

Context. The executive committee reviews supplier standards and customer issues, and the short-term incentive plan includes waste and responsible sourcing measures.

Adapted request. Please provide the executive committee papers for [period] showing the sustainability topics discussed, plus the short-term incentive plan summary where waste reduction and responsible sourcing were included. Include the internal measure names, the target basis, and the share of variable pay linked to those measures.

Example response. Executive committee memo March 2025; topics covered: packaging waste, supplier audits, customer complaints; short-term incentive plan: waste reduction 8%, responsible sourcing 7%; variable pay linked to sustainability measures: 12%.

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

State how you determined whether a sustainability-linked incentive exists, what you counted as its main features, and which targets or measures were included in the analysis.

Context note

Explain what the figures say about how far sustainability considerations are built into variable pay and how central they are within the wider remuneration approach.

Fluctuation statement

If the share linked to sustainability has changed, describe whether that reflects a redesign of the pay scheme, a change in the measures used, or a shift in the weighting applied to those measures.

Content index entry

GOV-2 Information Provided to and Sustainability Matters Addressed by the Administrative, Management and Supervisory Bodies — [location / page] / [notes]

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Preparation tools & forms

Professional preparation tools for GOV-2 — 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 · GOV-2

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.

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Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

We said whether any pay or bonus arrangements for the board and committee members were tied to sustainability matters.An assurer will check that the statement is complete, that the answer is not implied rather than explicit, and that the reporting period and covered people are clear.Approved remuneration policy, board or committee papers, HR or company secretariat records, and the final disclosure sign-off showing the yes/no position stated in the report.

We explained how those pay arrangements connect to sustainability topics and set out the main features of the scheme.An assurer will probe whether the description matches the actual design of the arrangement, whether the features are described consistently across documents, and whether any material element has been left out.Scheme rules, remuneration committee papers, policy documents, and any internal summary used to draft the disclosure, with cross-checks to the published wording.

We identified which sustainability measures or goals were used to judge performance under the pay arrangement.An assurer will test whether the measures named are the ones actually used, whether they were in force for the period reported, and whether the disclosure avoids mixing up targets with broader ambitions.Target-setting papers, scorecards, performance assessment templates, committee minutes, and the final report version showing the measures disclosed.

We stated what share of variable pay depended on sustainability-linked measures.An assurer will check the calculation basis, whether the percentage is for the correct population and period, and whether the figure is internally consistent with the underlying remuneration data.Remuneration calculations, payroll or finance workings, committee approvals, and a reconciliation from the underlying pay data to the percentage reported.

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes or records evidencing the relevant engagement or consultation

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

Chasing the board secretary for pay-plan details, when the live source sits with reward, HR or the remuneration committee pack, leads to incomplete or delayed data.

Framework language first

Asking teams for the governance-body wording instead of their own business terms means people cannot match the request to the records they actually hold.

Scope not pinned down

Pulling figures without stating which entity, plan, committee cycle or staff group is in scope creates a mix of in-scope and out-of-scope records.

Wrong period basis

Using a calendar-year extract for a reporting period that follows a different cut-off produces numbers that do not line up with the period being reported.

Mixed counting basis

Combining headcount, eligible participants and award recipients in one tally makes the denominator unclear and the resulting percentage unusable.

Source labels stripped out

Copying values into a clean spreadsheet without keeping the original field names, file names or system tags breaks the link back to the source record.

Populations merged

Putting executive pay data and wider employee incentive data into one pool hides which group each figure belongs to and can distort the result.

Evidence trail missing

Saving the final numbers without the underlying extract, date stamp and reviewer sign-off leaves no audit trail for later challenge.

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Where judgement is often needed

What counts as a sustainability-linked pay plan

Decide whether the arrangement is a true incentive plan or just a wider pay policy, and explain the basis used to include or exclude it from the board pack.

Which performance measures to name

If different countries, business lines or committees use different measures, set out the version used for the report and note any local variants that were left out.

How to handle a year of change in the group perimeter

When acquisitions, disposals or restructurings change the reporting group, state the cut-off date and whether the figures reflect the old or new structure, with any restated comparatives.

Whether a small or newly joined population is in scope

For people just inside or just outside the relevant pay population, explain the inclusion rule used and whether part-year service, probation or temporary cover was counted.

Choosing between actual results and estimates

If some figures come from calculations, proxies or management estimates rather than direct records, say which parts are estimated and describe the method used to fill the gaps.

Picking the timing basis for the figures

Where the board saw information at a different point from the year-end reporting cut-off, disclose the date or period used and keep the timing basis consistent across the narrative and numbers.

Rounding and percentage presentation

If percentages or amounts are rounded, make the rounding rule clear and ensure the published share linked to sustainability does not conflict with the underlying totals.

Protecting personal data in small teams

Where the relevant group is small enough that individual pay details could be inferred, aggregate the figures to a level that avoids identification and explain the privacy-driven grouping used.

＋ Show 5 more− Show fewer

Examples

Illustrative examples

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

Illustrative (synthetic) example — Manufacturing

We use a variable pay plan for senior leaders, and part of that award depends on sustainability performance. The plan is built around three measures: workplace safety, energy efficiency, and employee retention; in the current year, 30% of variable pay is tied to those measures, based on a total bonus pool of 100 units and 30 units linked to sustainability outcomes.

This example shows a simple pay structure where a portion of annual variable pay is connected to non-financial performance. The figures are internally consistent and purely illustrative.

Illustrative (synthetic) example — Financial services

Our group operates an incentive arrangement for executive management, and sustainability outcomes form one part of the award calculation. We use two measures — financed emissions reduction and staff inclusion outcomes — and 25% of variable remuneration is linked to them, based on 20 units out of a 80-unit variable pay opportunity.

This example illustrates a different sector with a different mix of measures, while still showing whether an incentive arrangement exists, how it is designed, which measures are used, and the share of variable pay connected to sustainability.

Company reportsReal published reports

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How companies report GOV-2 in practice

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

Aena S.M.E., S.A.

Air Transportation — Airport Services · Spain · 2025

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Aena S.M.E., S.A.’s 2025 sustainability report provides some related context on governance and sustainability matters addressed by the company’s administrative and supervisory bodies, with references to collaboration with stakeholders (p.31) and integration of sustainability-related targets (p.68), but these disclosures are not clearly detailed. The report mentions the Board of Directors’ commitment to sustainability (p.25) and links sustainability performance to incentive schemes (p.9), yet it lacks explicit, quotable evidence for GOV 2.1 and clear disclosures on governance information provision (p.299). Overall, while governance and sustainability topics are referenced, the report does not clearly disclose the specific GOV 2 datapoints.

Enagás, S.A.

Gas Utilities · Spain · 2025

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Enagás, S.A.’s 2025 Annual Report includes references to the disclosure topic GOV-2 concerning information provided to and sustainability matters addressed by the company’s administrative, management, and supervisory bodies, with mentions on pages 37, 44, and 81. However, the report does not provide clear or detailed disclosures for GOV 2.1, 2.2, or 2.3, as no quotable evidence was found for these datapoints. There is some related context linked to variable remuneration on page 108, but it is not a clear disclosure of the specific GOV 2.4 datapoint.

Hera S.p.A.

Water Utilities · Italy · 2024

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Hera S.p.A.'s 2024 Consolidated Financial Statements include a specific disclosure of total variable remuneration related to ESG objectives, quantified as Euro 85,280 on page 98. There is related context on page 261 referencing incentive schemes linked to sustainability issues for administrative, management, and control roles, but this does not clearly disclose all aspects of the datapoint GOV 2.gov 2.1. No evidence was found in the report for GOV 2.gov 2.2 and GOV 2.gov 2.3, indicating these datapoints remain unaddressed or unclear.

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Check your understanding

Scenarios to work through

A group has a bonus plan for executive directors, but the sustainability part is only discussed informally in meetings and is not written into the plan documents. The reporting team is deciding whether to treat this as a linked incentive arrangement for the year-end report.

QShould this be counted as a sustainability-linked pay arrangement, or left out because it is only discussed rather than formally built into the plan?

Reveal model answer →Hide answer ↑

Count it only if the arrangement actually ties pay outcomes to sustainability-related measures in a way that can be evidenced. If the link is merely talked about but not part of the remuneration design, it should not be presented as a linked scheme. The team should base the answer on the substance of the pay design, not on informal discussion notes.

Why this matters · Use the real design of the pay arrangement, not loose conversation, when deciding whether sustainability is built into incentives.

The board receives a quarterly pack that mentions emissions, workforce safety and ethics incidents, but the pack also includes many other topics. The preparer is unsure whether to describe all of these as matters the board dealt with, or only the ones that led to actual discussion and follow-up.

QWhich topics should be reported as matters the board addressed: everything in the pack, or only the sustainability topics that were actually taken up in governance discussions?

Reveal model answer →Hide answer ↑

Report the sustainability topics that were genuinely brought to the board or its committees for consideration, not every item that happened to appear in the pack. The focus is on what the top governance group actually dealt with, so the narrative should reflect the matters that were discussed, reviewed or acted on in practice.

Why this matters · Only include sustainability topics that were truly handled in governance, not every subject mentioned in briefing papers.

A company uses a scorecard for annual bonuses. Half of the variable pay depends on financial performance, and the other half depends on a mix of safety, emissions and employee engagement measures. The reporting team has to explain the share linked to sustainability without overstating it.

QHow should the team present the proportion of variable pay tied to sustainability measures when only part of the bonus uses those measures?

Reveal model answer →Hide answer ↑

State the share of variable pay that is connected to sustainability measures as a proportion of the total variable element, and make clear that only the sustainability-linked part is being counted. In this case, the correct figure is 50% of variable pay, because the other half is tied to non-sustainability measures. The explanation should be clear enough for a reader to see how the percentage was derived.

Why this matters · Show the sustainability-linked share of variable pay as a clear proportion of the total variable element.

The sustainability team has a draft note saying the board discussed climate, labour and anti-corruption matters, but it does not say what performance measures were used, whether any incentives were in place, or how much pay was affected. The preparer must decide whether the note is complete enough for disclosure.

QIs it enough to say the board discussed these topics, or does the disclosure also need the incentive link and the measures used to judge performance?

Reveal model answer →Hide answer ↑

The note is not complete on its own. The disclosure should cover whether there is a sustainability-linked incentive arrangement, what its main features are, which targets or measures are used, and the share of variable pay connected to those measures. If the board discussed sustainability matters separately, that should also be described, but it does not replace the remuneration information.

Why this matters · Cover both the incentive design and the sustainability matters handled by governance, because they are separate parts of the disclosure.

Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

ESRS

GOV-2

within ESRS 2: General Disclosures

Open official source →

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 →Metrics in Relation to Material Sustainability Matters → Guide ✓Policies Adopted to Manage Material Sustainability Matters → Guide ✓Targets in Relation to Material Sustainability Matters → Guide ✓Show all 14 related disclosures →

More in ESRS 2 →Browse full catalogue →Disclosure Library home →Search all disclosures →

Go deeper · GOV-2

Learn to prepare this disclosure end-to-end

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

Explore the ESRS / CSRD course →

FAQ

Questions this page answers

How do I use the GOV-2 page to draft a sustainability-linked pay disclosure from scratch?+−

Start with the plain-language explainer, then work through the step-by-step preparation section and the four datapoints to prepare. The page also gives narrative starters, a content-index line and a synthetic example you can adapt into a first draft.

What data do I need to collect for GOV-2: Incentive plan flag, scheme design summary, performance measures used and sustainability pay share?+−

The page lists those four datapoints as the core inputs to prepare. Use them to build the disclosure and check that your figures and descriptions line up before drafting.

How should I set the scope and methodology for the sustainability pay share in GOV-2?+−

Use the page’s preparation steps to define what you are including, then keep the scope and method consistent with the data you report. The page is designed to help you turn that into a clear draft, but it does not give a separate formal methodology.

Who should own the GOV-2 data collection and sign-off in practice?+−

The page is aimed at sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can source the pay and scheme data and check it for accuracy. The workbook is there to help you organise that process.

What should I put in the evidence pack for GOV-2 assurance readiness?+−

The page says there is an evidence pack with five items for assurance readiness. Use it to support the four assurance claims to verify and keep the underlying records together before review.

What are the four assurance claims I need to verify for GOV-2?+−

The page says there are four claims to verify, each with a claim, risk and evidence angle. Use those prompts to test whether the disclosure is supported and whether the evidence pack is complete.

What are the most common GOV-2 reporting mistakes to avoid?+−

The page includes a list of common reporting gaps and mistakes. Use it as a pre-submission check so the datapoints, narrative and evidence all match and nothing important is left out.

How do I use the Prep & Assurance workbook for GOV-2?+−

The Download Centre includes a Prep & Assurance workbook in .xlsx format. It is meant to help you organise the preparation steps, evidence and assurance checks before turning the data into a draft.

What can I do with the synthetic GOV-2 example disclosure on the page?+−

Use the synthetic example as a model for structure, wording and how the quantitative table is presented. It is illustrative only, so you should adapt it to your own data and keep the numbers internally consistent.

How do I turn GOV-2 data into a draft narrative and content-index line?+−

The draft-output section gives visualisation ideas, narrative starters and a content-index line. Use those to convert the prepared datapoints into a concise disclosure that is easy to review and trace back to evidence.

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	Report A	Report B	Report C
Datapoint 1	✓ p.213	unclear	✓ p.87
Datapoint 2	✓ p.214	—	✓ p.90

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Information Provided to and Sustainability Matters Addressed by the Administrative, Management and Supervisory Bodies

Key datapoints to prepare

How to prepare it

Request board and committee briefing evidence

Notes that turn data into a disclosure

Preparation tools & forms

For each claim, check the evidence

Evidence pack to prepare

Common reporting gaps

Mistakes to avoid when collecting the data

Where judgement is often needed

Illustrative examples

How companies report GOV-2 in practice

Scenarios to work through

Related framework references

Questions this page answers

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