Disclosure focus
This disclosure asks an organisation to explain what it is doing, and what it is putting in place, to manage its water and marine-related impacts, risks and opportunities. In practice, that means describing the main actions, programmes, investments, policies or operational changes that are relevant to the topic, rather than only stating high-level commitments. The focus is on showing how the organisation is responding in a concrete way, and how those responses link to the material issues it has identified.
The practical emphasis is on coverage and relevance: the report should make clear whether these actions and resources apply across the whole business, specific sites, or only certain activities, and why that scope is appropriate. It should also be clear where the organisation is concentrating effort, for example on operations with the greatest water dependence or impact, and whether the resources allocated are enough to support the stated response.
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 E3-2 sub-elements (LRA working checklist)
Record the measures already put in place.
State the capital spend linked to those measures.
State the operating spend linked to those measures.
Describe steps taken to avoid pollution.
Describe any clean-up or repair steps taken.
Set out when the measures were carried out or are due.
List the water-saving measures used.
Describe the steps taken in areas where water is under pressure.
State where those actions apply geographically.
State the people, money, equipment, or other resources assigned.
How to prepare it
1Set the reporting boundary first: decide which operations, sites, projects and time period you will cover, and separate the ordinary water-related actions from those carried out in places where water stress is a concern.
2Agree the meaning of each item before you start drafting: identify which measures count as implemented actions, which are aimed at using water more efficiently, which are intended to prevent pollution, and which are remediation or clean-up responses.
3Gather the support for each entry: collect internal records, project papers, approvals, budgets, work orders, monitoring results and any other source that shows the action happened, where it happened, and what resources were committed.
4Prepare the disclosure content in the required formats: write the narrative for the actions taken, the measures in water-stressed locations, the resources assigned and the geographic coverage, and calculate the capital and operating spend where a number is needed.
5Record any exclusions, restatements or scope changes clearly: explain what has been left out, why it is outside the boundary, and whether any figures or descriptions differ from earlier reporting periods.
6Check the draft against the official source before sign-off: confirm that every required item is covered, the wording matches the underlying evidence, the numbers are internally consistent, and nothing has been omitted or misclassified.
Request the data
Request the water actions and spend details from Operations
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What water-related actions have been put in place, where are they being delivered, and what budget has been committed to them?
Use your organisation’s own names for teams, sites, projects, controls and spend codes first, then map them to the reporting categories. Keep the ask in day-to-day operational language rather than framework wording, and check the source material before sign-off.
Weak request
Please provide the ESRS E3:E3-2 actions and resources disclosure, including all actions implemented, water efficiency measures, pollution prevention, remediation actions, timelines, CapEx, OpEx, actions in water stress areas, resources allocated, and geographic scope.
Why it fails: This uses framework language that many operational teams will not recognise, so it is harder to answer quickly and accurately. It also bundles several concepts into one ask without telling the owner which tracker, site list, or spend basis to use, which increases the risk of inconsistent or incomplete evidence.
Better request
Please send your current water programme tracker for [period] covering [sites/business units]. Include each action in plain operational terms, the site or area it affects, whether it is in a water-stressed area, the delivery status and dates, and the budget or spend split between capital and operating cost if you track that. If you use a different internal grouping, send that and add a short mapping note.
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 how the company defined the reported water actions, how it grouped them into efficiency, pollution control, and remediation work, and how it identified the locations covered by the water-stress analysis.
Context note
Explain that the figures show the company’s practical response to water-related impacts, including the measures put in place, the timing of delivery, and the resources committed to those actions.
Fluctuation statement
If the numbers moved materially, note whether that was driven by new measures starting, work being completed, a shift in the locations covered, or changes in the level of capital and operating spend.
Content index entry
E3-2 Actions & Resources — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for E3-2 — 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.
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
Asking a team that only sees budgets or only sees site operations leaves the action list incomplete because the people who know the measures, timing and spend are not in the room.
Framework language instead of local terms
Using the disclosure labels instead of the organisation’s own names for projects, controls and recovery work makes staff give generic answers that cannot be matched back to real activity.
Scope not pinned down
Collecting data without first fixing which sites, business units and water-stress locations are in scope leads to mixed figures that cannot be separated later.
Wrong time basis
Pulling numbers from a different reporting period, or from a plan date rather than the period being reported, produces a set of actions and costs that do not line up with the rest of the report.
Counting bases mixed
Combining planned spend, committed spend and actual spend in one figure makes the resource total unusable because the same money is counted on different bases.
Source labels lost
Copying data into a new tracker without keeping the original project codes, site names or document references breaks the link to the source record.
Populations merged
Putting water-efficiency work, pollution controls and remediation work into one undivided list hides which measures belong to which activity type and makes later review difficult.
Evidence details missing
Saving the number without the date, owner, version and source file means nobody can prove where the figure came from or whether it was current when captured.
No sign-off trail
Recording the data before the responsible manager has reviewed and approved it leaves no clear trail showing who checked the figures and when.
Where judgement is often needed
What counts as an action already in place
Use a consistent cut-off date for the reporting period, and explain whether you include only measures that are live, or also those approved, funded, or partly rolled out.
How to treat a business bought or sold during the year
State whether you include measures and spend from acquired or disposed operations only for the time they were in your group, and note any restatement or exclusion approach you used.
Where local site labels do not match group categories
Map country or site-level descriptions into one group-wide set of action types, and disclose the mapping rule when local terminology does not fit neatly into the main reporting buckets.
Whether a site sits inside the water-stress set
Set out the rule used to decide if a location is treated as water-stressed, especially where borders, catchments, or local classifications differ across countries.
How to handle mixed-purpose spend
If one project covers water efficiency, pollution control, and remediation together, explain the split method or the basis for assigning the full amount to one line, and keep the approach consistent.
Measured spend versus estimates
Say which figures come from invoices or ledger data and which are estimated, and describe the estimation method where actual spend is not yet available.
Timing of spend recognition
Explain whether you report amounts when the commitment is approved, when cash is spent, or when the work is delivered, and apply the same timing rule across the disclosure.
Rounding and small differences
State the rounding convention used for amounts and timelines, and make clear that minor differences may arise because of rounding or aggregation.
Protecting sensitive location detail
If naming exact sites would create confidentiality or privacy issues, aggregate the information to a higher level and explain the level at which you have chosen to present it.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Food processing
We set out the main steps we have taken to cut water use, reduce contamination risk, and repair any harm linked to our operations, with delivery planned over 2025–2027. For these measures, we expect capital spend of 12.0 and operating spend of 3.4; the package covers 8 actions in total, including 5 efficiency upgrades, 2 pollution-control measures, and 1 remediation project. - In the two water-stressed catchments where we operate, we have assigned 4.2 of resources to 3 site-level actions, all within our manufacturing network in Spain and South Africa. - The work includes closed-loop rinsing, leak detection, upgraded effluent treatment, and a riverbank clean-up programme; each item is scheduled to finish by Q4 2027.
Synthetic example for practitioner training only; figures are internally consistent and illustrative, not reported data.
Illustrative (synthetic) example — Textile manufacturing
We have a three-year plan to lower freshwater demand, stop avoidable releases, and restore affected land and waterways, with delivery running from 2024 to 2026. The programme carries 9.6 of capital spend and 2.8 of operating spend, and it brings together 6 actions: 4 aimed at using less water, 1 focused on preventing pollution, and 1 dedicated to remediation. - For our two water-stressed operating regions, we have set aside 3.1 of resources for 2 site actions, both in our dyeing and finishing facilities in India and Mexico. - The work covers low-liquor dyeing, reuse of process water, bunded chemical storage, and a wetland restoration project; all measures are expected to be complete by the end of 2026.
Synthetic example for practitioner training only; figures are internally consistent and illustrative, not reported data.
How companies report E3-2 in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Snam S.p.A.
Gas Utilities · Italy · 2025
Snam S.p.A.'s 2025 Annual Report provides specific information on financial resources allocated to climate change, including capital expenditure (CapEx) and operational expenditure (OpEx) for 2024 and 2025, as noted on page 289. The report also references significant current and future financial resources in terms of CapEx and OpEx related to the Plan Period (p.263). However, no detailed numeric values or further narrative explanations about these allocations are found elsewhere in the report, leaving some aspects of the disclosure unclear.
Mowi ASA
Food Production — Animal Source · Norway · 2024
Mowi ASA’s 2024 Integrated Annual Report provides a clear disclosure of resources allocated to its climate action plan, estimating operational expenditures of 13 million euros for 2025-2030 (p.72). The report also references actions and resources initiated to manage material impacts, including dedicated teams and financial investments, though these are described more generally without specific figures (p.75, p.109). However, disclosures related to pollution prevention, biodiversity protection, and detailed water usage metrics are either unclear or not found, with only partial context provided on water risk monitoring and freshwater withdrawal without explicit data or comprehensive narrative (p.25, p.84, p.95).
Globalvia
Ground Transportation — Highways and Railtracks · Spain · 2025
Globalvia’s 2025 Sustainability Report includes a statement on remediation actions, affirming a commitment to prevent, mitigate, and remediate impacts (p.78). There is some related context on resources dedicated to environmental risk prevention, but it does not clearly disclose specific data or actions (p.97). Other expected details, such as numeric values or comprehensive narrative disclosures on climate change policies and targets, are not clearly found or quotable in the report.
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Scenarios to work through
A manufacturer has two water-saving projects underway: one at a plant in a water-stressed basin and one at a site with normal supply. The draft note lists both projects together, but only one site is in the stressed area.
QHow should you separate the description so readers can see which action applies to the stressed location and what resources are tied to it?
Reveal model answer →Hide answer ↑Split the narrative so the action at the water-stressed site is identified on its own, then state the resources set aside for that location and the area it covers. Keep the other project separate if it is outside the stressed basin, so the reader can tell which measures relate to the stressed geography and which do not.
Why this matters · When a measure is location-specific, link it clearly to the relevant area and the resources assigned to it.
A business has installed leak detection, process recycling and a new treatment step, but the draft only says it is “improving water performance”. The project team also wants to mention a supplier pollution-control upgrade and a customer-facing clean-up programme.
QWhat level of detail should you give so the note covers the kinds of action taken without blurring prevention, efficiency and remediation?
Reveal model answer →Hide answer ↑Describe the actual types of action in plain terms: what was done to use less water, what was done to stop or reduce pollution, and what was done to address harm already caused. Do not collapse them into one broad statement, because the reader needs to see the different purposes of the measures.
Why this matters · Separate efficiency, pollution prevention and remedy work so each type of action is understandable on its own.
A group approved a water programme in March, but procurement delays mean some equipment will not be installed until the following year. Finance has recorded the full budget, while operations has only spent part of it so far.
QHow should you present the timing and the money so the disclosure reflects both what has happened and what is still planned?
Reveal model answer →Hide answer ↑State when the action started, what has already been carried out, and the expected timing for the remaining steps. Then show the capital spend and the operating spend linked to the programme, using the amounts that relate to the actions described rather than a broader budget total.
Why this matters · Give a clear timeline and tie the spending figures to the specific water actions being reported.
A company operates in three countries, but only two have water-stressed regions. The draft says the programme is global and gives one combined resource figure, even though the measures in the stressed regions are different from those elsewhere.
QWhat should you do to make the scope and resource allocation clear for the stressed areas?
Reveal model answer →Hide answer ↑Identify which actions take place in water-stressed areas, say where those areas are, and show the resources assigned to those actions. If the programme also covers other countries or sites, keep that separate so the geographic scope of the stressed-area work is not hidden inside a global total.
Why this matters · For stressed-area actions, show both where they happen and what resources are devoted to that geography.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
How do I use the E3-2 Water and Marine Resources page to draft my disclosure from scratch?+−
Start with the plain-language explainer, then work through the step-by-step preparation section and the datapoints list. The page is designed to help you turn source data into a draft narrative, table content and a content-index line.
What data do I need to collect for E3-2 before I can write the disclosure?+−
The page points you to implemented actions, water-saving measures, pollution controls, remediation steps, delivery timetable, capital spend, operating spend, water-stress actions, allocated resources and location coverage. Use that list as your collection checklist so you can see what is already available and what still needs to be requested.
How should I set the scope for E3-2 Water and Marine Resources in practice?+−
Use the page’s preparation steps to decide which actions, spend items and locations are in scope for the disclosure you are drafting. The location coverage datapoint is especially useful for checking whether the information you have is complete enough to support the narrative and any table or visual.
Who should own the E3-2 data collection and sign-off process?+−
The page is set up for a sustainability or ESG manager to coordinate inputs from data owners such as operations, finance, environment or site teams. Use the datapoint list to assign each item to a clear owner and make sure the evidence pack can be signed off before drafting.
What should I put in the evidence pack for E3-2 to be assurance-ready?+−
The page includes an evidence pack with five items to support assurance readiness, alongside six assurance claims to verify. Use those materials to show where each claim comes from, what risk it addresses and what evidence supports it.
What are the common mistakes to avoid when preparing E3-2 Water and Marine Resources?+−
The page lists common reporting gaps and mistakes so you can check for missing datapoints, weak scope decisions and unsupported claims before you draft. It is useful as a final quality-control step before the disclosure goes to review or assurance.
How do I use the E3-2 workbook download to organise the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to help you organise the preparation and evidence-checking process. Use it to track the datapoints, ownership, claims and supporting documents in one place.
What is the printable Library Card for E3-2 and when should I use it?+−
The Download Centre also includes a printable Library Card in .pdf format. It is useful as a quick reference while you are collecting data, checking the assurance claims and drafting the final content.
How do I turn the E3-2 data into a draft narrative and table?+−
The page includes draft-output support with visualisation ideas, narrative starters and a content-index line. Use those prompts to convert your collected data into a readable draft rather than starting from a blank page.
Can I use the synthetic example disclosure on the E3-2 page as a template for my own numbers?+−
Yes, but only as a worked illustration. The example is synthetic, so you should use it to understand the style and structure of the disclosure, then replace it with your own internally consistent data.
Where can I find real company examples for E3-2 Water and Marine Resources?+−
The page has a 'From company reports' table that links to real published reports where the topic is disclosed. Use it for practical reference on how others present similar information, not as a substitute for your own data and judgement.
More questions this page can help with
E3-2 Water and Marine Resources checklist for implemented actions, water-saving measures and pollution controlsHow to evidence remediation steps and delivery timetable for E3-2 disclosureE3-2 capital spend and operating spend: what should I ask finance for?How to document water-stress actions and location coverage for E3-2E3-2 assurance claims and evidence pack: what should be in the file?Common mistakes in E3-2 Water and Marine Resources reportingHow to use the E3-2 Prep & Assurance workbook downloadE3-2 draft narrative starters and content-index line examplesWhere to find company report examples for E3-2 Water and Marine ResourcesE3-2 disclosure preparation steps for ESG managers and data ownersHow to make an E3-2 disclosure assurance-readyE3-2 synthetic example disclosure explained
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