Disclosure focus
This disclosure asks an organisation to explain the basis on which it has prepared its sustainability statements. In practice, that means setting out the main reporting choices, assumptions and boundaries used so readers can understand what is included, what is left out, and how the information has been put together. It is about making the reporting approach transparent rather than repeating the underlying data points.
The practical focus is on consistency and coverage: whether the statement reflects the whole organisation and its relevant activities, or only selected parts, and how any exclusions, estimates or judgement calls affect the picture. The aim is to help users judge comparability and completeness, especially where reporting does not cover every operation, site or entity in the same way.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official EFRAG source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show BP-1 sub-elements (LRA working checklist)
State whether the ESG and financial boundaries differ, and explain any difference.
Set out the ESG boundary.
Explain the boundary choice.
Set out the financial boundary.
Say whether the report is prepared on a consolidated or individual basis.
Describe what the coverage includes.
State whether upstream and downstream activities are included.
Say whether the value chain is included.
Provide the compliance statement.
List the datapoints affected.
Give the reason for the treatment used.
Identify the related ESRS reference.
State the type of relief used.
How to prepare it
1Decide the reporting basis first: state whether the disclosure is prepared on a group-wide basis or for a single entity, then set the organisational perimeter you will use for the sustainability side and the financial side.
2Check whether those two perimeters are the same. If they are not, record that they differ and prepare a short explanation of what is different and why.
3Work out whether the report includes parts of the value chain. If it does, specify the upstream and downstream areas you are bringing in, and describe the coverage in practical terms.
4Gather the support for each statement before drafting: the boundary decisions, the scope notes, and any internal records that show how the reporting perimeter was set and applied.
5Draft the required text in one place, making sure you can answer the required yes/no items and provide the accompanying narrative for the scope, any boundary differences, and any value-chain coverage.
6If you have used any permitted relief, document the type of relief, the related ESRS reference, the reason it was used, and which datapoints it affects; then compare the final wording with the official source to confirm nothing has been missed or added.
Request the data
Request the reporting basis and boundary details
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How should we describe the basis, scope and any departures used when preparing the sustainability statements?
Use your own reporting language first, then map it to the sustainability statement wording. Ask for the terms your team already uses for group scope, boundary, value chain coverage and any exceptions, rather than framework labels.
Weak request
Please provide the ESRS 2:BP-1 basis of preparation, including consolidated/individual reporting basis, ESG boundary, financial boundary, value chain inclusion, compliance statement, relief used, related ESRS reference, justification and affected datapoints.
Why it fails: This uses framework labels only, which may not match how the owner works day to day. It also bundles too many technical terms without telling the owner what internal records to pull, which system to use, or how to explain differences in plain business language.
Better request
Please send the reporting pack details for [period]: the basis used for the group or entity view, the sustainability scope, the finance scope, any differences between those scopes, whether upstream or downstream value chain areas were included, and any exception or workaround used. Use your normal internal terms, attach the source file or system, and add a short explanation for any differences so we can map it into the statement.
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
State whether the report is prepared on a group or single-entity basis, explain how the ESG and financial boundaries were set, note whether they differ, describe any value-chain coverage, and identify any reporting relief used together with the related ESRS topic and affected datapoints.
Context note
Explain what the boundary choices mean for the scope of the draft disclosure, including which parts of the business and value chain are covered and whether any differences between the ESG and financial scopes change how the figures should be read.
Fluctuation statement
If the scope changes from one period to the next, point to changes in the reporting basis, boundary alignment, value-chain coverage, or use of relief, and explain how those shifts affect comparability and the figures reported.
Content index entry
BP-1 General Basis for Preparation of Sustainability Statements — [location / page] / [notes]
Download Centre
Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
The request goes to the wrong team or person, so the data is pulled from someone who does not hold the organisation’s actual records.
Framework language used too early
People ask for the information in ESRS-style terms instead of the business terms the source team uses, and the answer comes back mismatched or incomplete.
Scope not pinned down
The collector never fixes which entities, activities or parts of the business are in scope, so different teams report on different populations.
Boundary split not agreed
The team does not separate the reporting perimeter from the finance perimeter, so the figures are gathered on one basis and explained on another.
Wrong period basis
Data is taken from the wrong reporting window or cut-off point, so the numbers do not line up with the period used for the statement.
Counting bases mixed
Headcounts, totals or other measures are combined even though they were built on different counting rules, which makes the dataset internally inconsistent.
Source labels lost
The original file names, system tags or record labels are stripped away during collection, so the team cannot trace each figure back to its source.
Populations merged
Upstream, downstream or other separate groups are rolled into one pool before review, which hides differences that should stay distinct.
Evidence trail incomplete
The collector saves the numbers but not the supporting metadata, so there is no clear record of where the data came from or when it was captured.
No approval trail
The dataset is circulated without a visible check or sign-off step, so nobody can show who reviewed the inputs before drafting began.
Where judgement is often needed
Group perimeter after a deal closes or exits
State which entities and activities are included for the period, and explain any cut-off choice where a purchase, sale or closure changes the reporting perimeter.
Different country labels for the same topic
If local legal or operational labels differ across markets, explain the common rule you used to map them into one reporting view and note any exceptions.
Borderline sites, teams or activities
Say how you treated units that sit near the inclusion line, such as newly opened, dormant, temporary or partly owned operations, and why they were kept in or left out.
One reporting basis versus separate entity reporting
Make clear whether the statement is built on a combined group view or on separate legal entities, and explain the reason if the basis differs from the financial reporting set-up.
Value-chain coverage at the edges
Describe which upstream and downstream parts were brought into scope, including any practical limits where data was unavailable, low quality or not relevant to the topic.
Measured figures versus estimates
Identify where direct records were not available and estimates, proxies or models were used, then explain the method and any main assumptions.
Timing choice for opening and closing balances
Explain the date or period-end used for boundary decisions and data capture, especially where transactions, restructurings or operational changes happened near period end.
Rounding and presentation rules
Set out the rounding approach used for totals, subtotals and percentages so readers can understand small differences between line items and the headline figure.
Privacy-driven grouping of people data
Where individual-level detail could not be shown, explain the aggregation or suppression approach used to protect privacy while still giving a useful picture.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Manufacturing
We report on a consolidated basis, using the same perimeter for our sustainability reporting and our financial statements; there are no differences to explain. Our reporting also brings in selected upstream and downstream activities, covering purchased materials, transport, product use and end-of-life handling, because those parts of the chain are relevant to the impacts we describe. - We state that our sustainability and financial perimeters are aligned, so no separate reconciliation is needed. - We include value-chain activity, with coverage across upstream and downstream links, and the description above sets out what is included. - We have applied the temporary relief for **anticipated financial effects** under **ESRS E1**, because the underlying estimates are not yet reliable enough for a full quantified disclosure; the affected items are the climate-related financial-effect datapoints in that standard.
Synthetic illustration for practitioner review only. It shows how a reporter might describe its reporting basis, value-chain scope, and a temporary relief in plain language without using the standard’s wording.
Illustrative (synthetic) example — Retail
We report on an individual-company basis, while our sustainability reporting covers a wider operational perimeter than our statutory accounts, so the two boundaries are not the same. We also include parts of the value chain, but only upstream activity in this case, focused on suppliers and inbound logistics. - Our sustainability perimeter is broader than the financial one, and we explain the difference by pointing to entities and activities included for impact reporting but excluded from the accounts. - We include upstream value-chain activity only, with coverage limited to supplier sourcing and inbound freight. - We use the temporary relief for **anticipated financial effects** under **ESRS E1** and **ESRS E2**; the reason is that the relevant forward-looking estimates are still too uncertain for dependable quantified reporting, and the affected datapoints are the climate- and pollution-related financial-effect items in those standards.
Synthetic illustration for practitioner review only. It shows a different reporting pattern from the first example: individual reporting, a boundary mismatch, upstream-only value-chain coverage, and use of a temporary relief across two ESRS topics.
How companies report BP-1 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Nokian Tyres
Tires · Finland · 2025
Nokian Tyres' 2025 Sustainability Statement includes some contextual references to sustainability frameworks such as ESRS and mentions integration of sustainability-related governance on page 95, with additional related datapoints noted on pages 97, 100, 102, and 104. However, these references do not provide clear or explicit disclosures for the specific datapoint in question, as the report lacks quotable evidence or detailed narrative on this topic. Overall, the report contains unclear or missing information regarding this disclosure, with no direct or comprehensive coverage found.
Pirelli & C. S.p.A.
Automobiles and Components · Italy · 2025
Pirelli & C. S.p.A.'s 2025 Annual Report includes a consolidated Sustainability Statement outlining the scope of activities subject to reporting (p.85) and confirms no incorporation by reference to other documents within this statement (p.86). The report also addresses disclosure requirements in line with ESRS standards and discusses integration of due diligence into governance and strategy (pp.116, 140). However, no specific narrative details or methodology related to the disclosure were found or clearly presented elsewhere in the report.
Intesa Sanpaolo S.p.A.
Banks / Diverse Financials / Insurance · Italy · 2024
Intesa Sanpaolo S.p.A.'s Annual Report 2024 includes partial coverage of sustainability topics, with materiality assessments related to affected communities (p.253), own workforce (p.220), workers in the value chain (p.248), and consumers and end-users (p.269). However, the report states that the sustainability statement for the year ended 31 December 2024 has not been prepared in full accordance with relevant standards (p.845). There is no clear or quotable disclosure of specific datapoints for this disclosure, and no detailed methodology or narrative explanation is provided.
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Scenarios to work through
A group prepares one sustainability statement for the parent and its subsidiaries. The reporting team also has a separate management view for one overseas unit that is not part of the consolidated financial statements.
QWhich reporting basis should be described, and how should any mismatch between the sustainability perimeter and the financial perimeter be handled?
Reveal model answer →Hide answer ↑State whether the statement is built on a group-wide or single-entity basis, then set out the sustainability perimeter and the financial perimeter in plain terms. If the two do not line up, say so and explain the difference clearly enough for a reader to understand what sits inside each boundary.
Why this matters · Be explicit about the basis used and disclose any gap between the sustainability and financial boundaries.
A preparer wants to include supplier labour issues and downstream product-use impacts in the statement, but the draft only covers the company’s own sites and employees. The team is unsure whether the wider chain should be brought in.
QHow should the preparer decide whether the wider value chain is part of the statement, and what should be described if it is included?
Reveal model answer →Hide answer ↑Decide first whether the statement brings in impacts beyond the company’s own operations. If it does, identify whether the focus is on activities before the company, after it, or both, and describe the parts of the chain that are covered in a way that makes the scope understandable.
Why this matters · If the wider chain is included, say which parts are covered and describe the coverage plainly.
The draft sustainability statement uses a relief for one topic because the underlying information is not yet available in time. The team has named the topic but has not explained why the relief was used or which disclosures are affected.
QWhat needs to be added so the use of relief is properly explained?
Reveal model answer →Hide answer ↑Add a clear statement that a relief was used, identify the related ESRS topic or topics, explain why that route was taken, and list the datapoints or disclosures that were affected. The explanation should let a reader see both the reason and the practical impact on the statement.
Why this matters · When relief is used, identify it, link it to the relevant topic, explain the reason, and show what it changes.
A company has drafted a short statement saying it has prepared its sustainability information in line with the applicable European reporting rules. The wording does not say whether the statement covers all the needed disclosures or whether any parts were left out.
QWhat judgement should the preparer make before sign-off about the overall statement of coverage?
Reveal model answer →Hide answer ↑Confirm that the statement is presented as covering the disclosures expected under the reporting framework, or else make any limitation clear. The reader should not be left guessing whether the package is complete or whether some parts are missing, because the overall basis of preparation needs to be transparent.
Why this matters · The overall coverage of the statement should be clear, including any limits or omissions.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
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 ✓Role of the Administrative, Management and Supervisory Bodies → Guide ✓Show all 14 related disclosures →
FAQ
Questions this page answers
What do I need to gather before drafting BP-1 (ESRS 2: General Disclosures) on this page?+−
Start with the datapoints listed on the page: reporting scope basis, sustainability boundary, financial reporting boundary, any boundary difference flag and note, value chain inclusion flag, value chain scope and coverage note, compliance declaration, any relief applied, linked standard reference, relief rationale, and impacted datapoints. The page also gives a step-by-step preparation section to help you turn those inputs into a draft.
How do I decide the reporting scope basis for BP-1 using this guidance page?+−
Use the page’s preparation steps to set out the basis you are reporting on, then record it consistently with the other scope and boundary datapoints. The page is designed to help you document the basis clearly rather than leaving it implicit.
What should I do if my sustainability boundary is different from my financial reporting boundary for BP-1?+−
The page expects you to flag whether the boundaries differ and add a short note explaining the difference. That helps the disclosure stay transparent and gives reviewers a clear trail from the reported scope to the underlying records.
How should I capture value chain inclusion for BP-1 in a way that is assurance-ready?+−
The page asks for a value chain inclusion flag, the scope of what is included, and a coverage note. Together those fields show whether the value chain is in scope and how far the coverage goes, which is useful for assurance review.
What evidence pack does the BP-1 page suggest I keep for audit or assurance?+−
The page includes an evidence pack with five items to support assurance readiness. Use it alongside the assurance claims section so you can show what was checked, what evidence supports it, and where the underlying records sit.
How do I use the six assurance claims on the BP-1 page?+−
The page gives six claims to verify, each with a claim, risk and evidence prompt. Use them as a checklist to test the draft disclosure, identify weak spots, and assemble the supporting documents before sign-off.
What are the common reporting gaps or mistakes to avoid when completing BP-1?+−
The page lists common reporting gaps and mistakes so you can spot missing scope detail, unclear boundary explanations, or weak evidence before the draft is finalised. It is meant to help you correct issues early rather than after review.
How do I use the BP-1 workbook download to prepare the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the datapoints, track the assurance checks, and build a cleaner draft before you move to the final disclosure.
What is the printable Library Card for BP-1 and when should I use it?+−
The Download Centre also includes a printable Library Card in .pdf format. It is a practical companion for keeping the key points, checks and references together while you prepare the disclosure.
How can I turn the BP-1 data points into a draft narrative?+−
The page includes draft-output support such as visualisation ideas, narrative starters and a content-index line. Use those prompts to convert the collected datapoints into a readable draft without having to start from a blank page.
More questions this page can help with
BP-1 ESRS 2 General Disclosures: what datapoints should I collect first?BP-1 ESRS 2 General Disclosures: how do I document boundary differences and notes?BP-1 ESRS 2 General Disclosures: what should go into the value chain scope note?BP-1 ESRS 2 General Disclosures: how do I make the disclosure ready for assurance?BP-1 ESRS 2 General Disclosures: what evidence should support the compliance declaration?BP-1 ESRS 2 General Disclosures: how do I use the Prep & Assurance workbook?BP-1 ESRS 2 General Disclosures: what are the common mistakes in the draft?BP-1 ESRS 2 General Disclosures: how do I write the relief rationale clearly?BP-1 ESRS 2 General Disclosures: what does impacted datapoints mean in the draft?BP-1 ESRS 2 General Disclosures: how do I build an evidence pack from the page?BP-1 ESRS 2 General Disclosures: what can I use the illustrative example for?BP-1 ESRS 2 General Disclosures: where can I find real company report examples on the page?
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