Training pack

Kateri field guide

What each report step is for, what to tick before moving on, and what every field means. The same wording appears in the app, so this sheet and the screen always agree. References marked "(reference to be confirmed)" have not yet been checked against the published standard.

Step 1 of 9

Scope assessment

Decide whether the company must report under CSRD, and from which year. The answer sets the timetable and the amount of work for every later step.

What this step produces

A working scope conclusion with the reasons behind it
The first reporting year the project plans for
The scoping notes that become the audit trail for the conclusion
A scope worksheet (.docx) for the project file and for legal review

Before you move on

The reporting entity is the right legal entity, not a brand or a group name
Employees, turnover and balance sheet come from the latest approved accounts
Any figure that is not known is left as Not assessed instead of guessed
Listed status and any parent report route have been checked
The first reporting year is the year the company expects to report
Assumptions and open questions are written in the scoping notes
Someone has asked for legal or Regulatory Lead review before the client relies on the result

ESRS references

Directive (EU) 2026/470 (Omnibus I), scope of 1,000 employees and EUR 450 million net turnover, as described in Commission SWD(2026) 500

Fields

Entity type

The kind of reporting entity, which decides which scope test applies

In plainer words: What kind of company is reporting

Why we ask: The entity type decides which route into CSRD applies: the standard EU test, a parent report, the listed SME exemption or the non-EU group route. If it is wrong, the size answers below are tested against the wrong rules.

Example: Nordvik Foods GmbH is an EU large undertaking that reports on its own. Its Dutch parent does not publish a sustainability report that covers it.

Common mistakes

Naming the group or the brand when the legal entity is the one that reports
Choosing EU large undertaking for a non-EU group without checking the separate route

ESRS references

Directive (EU) 2026/470 (Omnibus I), scope of 1,000 employees and EUR 450 million net turnover, as described in Commission SWD(2026) 500

Listed status

Whether shares trade on an EU regulated market

In plainer words: Whether the company's shares are traded on a stock exchange in the EU

Why we ask: Listing used to bring small companies into scope. Under the amended rules listed SMEs are understood to be exempt, so a listing alone should not make a company in scope. Confirm this against the Directive and national law. Listing still matters for timing and for which route applies.

Example: Not listed. Nordvik Foods is privately owned and has no shares on any exchange.

Common mistakes

Treating a listing as proof the company is in scope
Recording the parent's listing as the company's own

ESRS references

Directive (EU) 2026/470 (Omnibus I), scope of 1,000 employees and EUR 450 million net turnover, as described in Commission SWD(2026) 500
Directive (EU) 2026/470, listed SME exemption (reference to be confirmed) (reference to be confirmed)

Employees

Average number of employees over the financial year

In plainer words: The average number of people employed during the year

Why we ask: Employee numbers are one of the two tests for CSRD, and both must be met. The Commission describes the test as above 1,000 employees, so a company with exactly 1,000 is not caught by this criterion. Check the exact wording of the Directive and the national law.

Example: 1,240 on average over the year to 31 December 2026, from the payroll summary in the approved accounts. That is More than 1,000.

Common mistakes

Using the headcount on one day instead of the average for the year
Choosing a band for a company at exactly 1,000, which sits in the 250 to 1,000 band

ESRS references

Directive (EU) 2026/470 (Omnibus I), scope of 1,000 employees and EUR 450 million net turnover, as described in Commission SWD(2026) 500

Net turnover

Net turnover from the latest approved accounts

In plainer words: Sales for the year, after discounts and sales taxes, from your approved accounts

Why we ask: Net turnover is the second test for CSRD. The company is in scope only when both employees and turnover are above the thresholds, and the Commission describes the turnover test as above EUR 450m.

Example: EUR 512m in the approved accounts for the year ended 31 December 2026. That is More than EUR 450m.

Common mistakes

Using group turnover when the reporting entity is a single company
Using figures from draft accounts that have not been approved

ESRS references

Directive (EU) 2026/470 (Omnibus I), scope of 1,000 employees and EUR 450 million net turnover, as described in Commission SWD(2026) 500

Balance sheet total

Recorded for the large undertaking definition, not used in the CSRD test

In plainer words: Total assets from your balance sheet, for our records only

Why we ask: The balance sheet total belongs to the general definition of a large undertaking, which is a different test. It does not change the CSRD outcome on this screen, but it is kept so the record is complete if the company is asked about other obligations.

Example: More than EUR 25m. Nordvik Foods reports total assets of EUR 388m.

Common mistakes

Expecting a high balance sheet to bring the company into scope
Leaving it blank and then wondering why the outcome did not change

ESRS references

Directive (EU) 2026/470 (Omnibus I), scope of 1,000 employees and EUR 450 million net turnover, as described in Commission SWD(2026) 500

Parent exemption

Only mark this once the parent report route has been checked

In plainer words: Whether a parent company already reports on your behalf

Why we ask: A subsidiary can be exempt when its parent publishes a sustainability report that covers it. The conditions are strict, so a wrong Yes can leave a company with a legal duty and no plan.

Example: Needs legal review. The Dutch parent publishes a group report, but nobody has confirmed that it covers Nordvik Foods or meets the publication conditions.

Common mistakes

Marking Yes because the parent reports, without checking the report covers the subsidiary
Forgetting that the parent report must be published and available in the right language

ESRS references

Directive (EU) 2026/470 (Omnibus I), scope of 1,000 employees and EUR 450 million net turnover, as described in Commission SWD(2026) 500
Directive 2013/34/EU, exemption by inclusion in a parent's sustainability report (reference to be confirmed)

First reporting year

The year the company expects to report, not the year now under review

In plainer words: The first financial year you will publish a sustainability report for

Why we ask: The first reporting year drives the project timetable, the data you need to start collecting and the date assurance work begins. Newly in scope undertakings are expected to start with financial years beginning on or after 1 January 2027, and national law must first transpose the Directive by 19 March 2027, so confirm the date for this Member State.

Example: 2027. The first report is published in 2028 with the annual report.

Common mistakes

Entering the current financial year by default
Treating a company that already reports for 2024 to 2026 as a new reporter, when it follows the existing wave one rules

ESRS references

Directive (EU) 2026/470 (Omnibus I), scope of 1,000 employees and EUR 450 million net turnover, as described in Commission SWD(2026) 500

Assurance readiness

Whether limited assurance planning, controls and evidence owners are in place

In plainer words: Whether you have started preparing for an independent check of your report

Why we ask: Reports need independent assurance, so evidence has to be traceable from the start. Recording readiness now shows early what is missing, such as named evidence owners or reviewer access.

Example: Limited assurance planning started. The finance director owns the evidence log and the auditor has read access to the data room.

Common mistakes

Leaving the default text without checking it is true for this company
Naming a team instead of a person as evidence owner

ESRS references

Directive 2013/34/EU, assurance of sustainability reporting (reference to be confirmed)

Scoping notes

Assumptions, open questions, source documents and who must review

In plainer words: Anything you are unsure about, and which documents you used

Why we ask: Scope conclusions rest on legal structure and national rules, and they get challenged later. The notes are the audit trail that lets a reviewer see what was assumed and why.

Example: Figures from the 2026 approved accounts. Parent report route not yet checked. Member State transposition of Omnibus I still pending, so timing to be confirmed by the Regulatory Lead.

Common mistakes

Writing the conclusion without the assumptions behind it
Citing a document without saying where it is stored

Step 2 of 9

Value chain and boundary

Describe what the company does, where it operates and who sits upstream and downstream of it. Add broad actor categories first on the map, then refine each selected actor with activity, geography and relationship detail. Then decide where the reporting boundary falls, because that sets how far the double materiality assessment has to look.

What this step produces

Undertaking profile and value chain map, used to screen topics and to build the IRO register
Boundary judgements, used to write the basis of preparation (ESRS 2 BP-1)
Data source table with limitations, used to disclose estimates (ESRS 2 BP-2)
Reviewer sign-off on boundary, screening and data sources, kept as workpaper evidence

Before you move on

Confirmed the report covers the same entity or group as the financial statements
Business activities, NACE code and key countries agreed with the client finance lead
Upstream and downstream actors added by category, each with tier, activity, geography and relationship
Every boundary question answered, and every Needs review has a named owner
Boundary notes cite the source document, such as the consolidation schedule or legal entity chart
Topics ticked in the IRO screen are the ones where impacts could reasonably arise
Each data source says whether it is direct or an estimate, with its limitation
Any legal limit on getting supplier data is recorded, with the alternative evidence

ESRS references

ESRS 1, paragraph 62
ESRS 1, paragraph 63
ESRS 1, paragraph 64
ESRS 1, paragraph 69
ESRS 2 BP-1
ESRS 2 BP-2
ESRS 2 SBM-1

Fields

Business activities

Say what the company makes or sells and where its main environmental or social exposure sits

In plainer words: Tell us in a few lines what your company does, makes or sells

Why we ask: This is the base for the whole assessment. ESRS 2 SBM-1 asks for the same description, and the consultant uses it to judge where impacts are likely to arise. A vague answer gives a generic topic list that an assurance provider will challenge.

Example: Iberia Industrials S.A. designs, machines and coats aluminium, steel and titanium components for automotive, aerospace and energy customers. The main exposure is energy intensive metal processing and surface treatment chemicals at plants in Spain, Portugal and Morocco.

Common mistakes

Pasting the marketing blurb instead of describing the operating model
Leaving out outsourced or leased activities that create exposure
Describing the whole group when the report is for one entity

ESRS references

ESRS 2 SBM-1
ESRS 1, paragraph 39

NACE code

Use the primary NACE code from the client's statistical or tax registration

In plainer words: The main activity code on your company registration or tax filings

Why we ask: NACE is the EU code for a company's main economic activity. Kateri uses it to suggest sector prompts, and SBM-1 asks for revenue by significant ESRS sector, so the sector call is made early. A wrong code sends the consultant down the wrong checklist.

Example: C25.6 Treatment and coating of metals; machining

Common mistakes

Using an old registration code that no longer matches the main activity
Entering several codes with no primary one

ESRS references

ESRS 2 SBM-1

Key geographies

List the countries where operations, suppliers, customers or high risk activities are concentrated

In plainer words: The countries where you have sites, buy from or sell to

Why we ask: Country drives which impacts are likely, such as labour rights, water stress or corruption. It also decides whether results must be split by country. A missing country is how a Tier 2 labour risk gets missed.

Example: Spain (3 plants), Portugal (1 plant), Morocco (1 plant and 3 machining suppliers), Turkey and Germany (metal mills), France and Germany (customers).

Common mistakes

Listing only the head office country
Naming regions so broad, such as Europe, that high risk locations disappear

ESRS references

ESRS 1, paragraph 39
ESRS 1, paragraph 54

Group structure notes

Note subsidiaries, joint ventures, associates and anything unclear about consolidation

In plainer words: List the companies in your group and any you are unsure are included in the accounts

Why we ask: The sustainability statement must cover the same entity as the financial statements, and BP-1 asks you to confirm that. Unclear structure surfaces late as a changed boundary and repeated data collection.

Example: Parent: Iberia Industrials S.A. (Spain). Wholly owned: Iberia Industrials Portugal Lda. and Iberia Industrials Manufacturing Morocco S.A.U. Associate, 48 percent, not consolidated: Iberia Industrials Maroc SA. No joint operations. Source: FY2025 consolidation schedule.

Common mistakes

Working from the legal entity chart instead of the consolidation schedule
Forgetting entities acquired or sold during the year

ESRS references

ESRS 1, paragraph 62
ESRS 2 BP-1
ESRS 1, paragraph 102

Tier

Tier 1 is a direct supplier or customer, Tier 2 and beyond are indirect, end use is users and disposal

In plainer words: How many steps away from you this party is, one step meaning you deal with them directly

Why we ask: Tier shows how far the company's influence reaches and how hard data will be to get. The standard covers direct and indirect business relationships. If everything is mapped as Tier 1, indirect risks drop out of the assessment.

Example: Tier 1: the twelve mills that sell aluminium to Iberia Industrials directly. Tier 2: the refiners that supply those mills.

Common mistakes

Mapping only Tier 1 because that is where contracts exist
Forgetting the end use tier when the product has a use phase impact

ESRS references

ESRS 1, paragraph 63

Category of actor

Use a category such as metal suppliers, not a company name, unless one counterparty is critical

In plainer words: Group similar suppliers or customers together, and name one only if it is critical to you

Why we ask: The standard does not ask for every actor, only for material value chain information. Categories keep the map readable and keep names out of an exported document that may be shared. Dozens of single company rows make the map unusable.

Example: Direct material suppliers: metals and alloys

Common mistakes

Importing the whole supplier master list as one row per supplier
Using a category so broad, such as Suppliers, that nothing can be assessed

ESRS references

ESRS 1, paragraph 64

Activity / input-output

Describe what flows through this actor, such as materials, services, distribution, product use or waste

In plainer words: What this party supplies to you or takes from you

Why we ask: This links the actor to the impact it could cause or carry. SBM-3 asks where in the value chain the material impacts, risks and opportunities are concentrated, and this field is what you will point to.

Example: Supplies raw aluminium, steel and titanium

Common mistakes

Writing the actor's industry instead of what flows to or from the company
Leaving it blank on the assumption that the category says it all

ESRS references

ESRS 2 SBM-3
ESRS 1, paragraph 63

Activity details

Add context a reviewer needs: what the actor does, dependencies and any known sustainability exposure

In plainer words: Anything useful about this party, such as how much you rely on them or any known concerns

Why we ask: This is the evidence behind the screen. A reviewer or assurance provider reads it to see why an actor was kept in or left out. Without it, the screen is an assertion.

Example: 12 mills supply about 60 percent of raw material spend. Smelting is energy intensive. Two mills are in Turkey where the company has no audit rights.

Common mistakes

Leaving it empty because the category looks obvious
Stating exposure with no figure, such as spend share or headcount, to back it

ESRS references

ESRS 1, paragraph 63
ESRS 1, Appendix B, QC 14

Geography

Give the countries or regions where exposure is concentrated, especially higher risk locations

In plainer words: Where this party operates

Why we ask: Country drives how likely impacts such as forced labour or water stress are, and which data route is realistic. It also supports splitting reported information by country where needed.

Example: Spain, Germany, Turkey

Common mistakes

Giving the supplier's head office country when the production sites are elsewhere
Entering Global when the sites are in known countries

ESRS references

ESRS 1, paragraph 39
ESRS 1, paragraph 54

Relationship type

Show whether the link is direct, indirect, a joint venture or an associate

In plainer words: Whether you deal with them directly, indirectly, or own a share of them

Why we ask: This separates direct influence from indirect exposure and from holdings accounted for by the equity method. Joint ventures and associates that are also suppliers must be treated like other business relationships, and they need a different data route.

Example: Associate: Iberia Industrials Maroc SA (48 percent), which also supplies machined parts

Common mistakes

Marking an associate as Direct and so skipping the equity method treatment
Using Indirect for a supplier the company contracts with directly

ESRS references

ESRS 1, paragraph 67

Part of consolidated group?

Say whether the entity is inside the consolidation used for the financial statements

In plainer words: Is this company included in your group accounts? Ask your finance team if unsure

Why we ask: The report must be for the same undertaking as the financial statements, and BP-1 asks for confirmation. If this is wrong, the whole data collection perimeter shifts and numbers must be rebuilt.

Example: Yes. Fully consolidated in the FY2025 group accounts, confirmed by group finance.

Common mistakes

Answering from memory instead of the consolidation schedule
Answering Yes when the legal position is unclear, instead of Needs review

ESRS references

ESRS 1, paragraph 62
ESRS 2 BP-1

Excluded subsidiaries?

Say whether any consolidated subsidiary is exempt from its own sustainability reporting, and on what basis

In plainer words: Is any company in your group exempt from its own sustainability report? If so, why

Why we ask: BP-1 asks the company to indicate which subsidiaries in the consolidation are exempt from their own individual or consolidated sustainability reporting under the Accounting Directive. It is not a way to leave a subsidiary out of the group report, because ESRS 1 says all subsidiaries must be covered. Whether an exemption applies is a legal question for the client's advisers.

Example: All three subsidiaries are covered by the group report. Iberia Industrials Portugal Lda. does not publish its own sustainability statement because the group report includes it, subject to legal confirmation.

Common mistakes

Excluding a small foreign subsidiary because its data is hard to get
Citing an exemption without checking the member state rules

ESRS references

ESRS 2 BP-1
ESRS 1, paragraph 102

Joint operations?

Say whether the company shares control of operations or assets with another party

In plainer words: Do you share a site, plant or project with another company that you do not fully own?

Why we ask: Associates and joint ventures that are equity accounted or proportionally consolidated are covered by ESRS 1 paragraph 67 when they sit in the value chain. Joint arrangements not structured through an entity, meaning jointly controlled operations and assets, are included in GHG emissions to the extent of the company's operational control (ESRS E1 paragraph 46) and shown separately in Scope 1 and 2 (paragraph 50(b)). Mixing the two up leads to data counted twice or missed.

Example: None. The Morocco affiliate is an associate, not a joint operation.

Common mistakes

Treating every joint venture as a joint operation without checking the accounting treatment
Answering from the legal form of the entity and not from the accounting treatment

ESRS references

ESRS 1, paragraph 67
ESRS E1, paragraph 46
ESRS E1, paragraph 50

Leased assets?

Say whether the company runs leased sites, vehicles or equipment, so their data is not missed or double counted

In plainer words: Do you rent buildings, vehicles or machinery that you operate?

Why we ask: Leased sites and vehicles can carry energy use, emissions and workers that belong in the report. ESRS E1 ties the GHG boundary to operational control (paragraphs 46 and 50), so it is not a free choice. ESRS does not mention leases directly, so record who operates each leased asset. Without a record of each lease, the same emissions can be counted twice or missed.

Example: Yes. The Badajoz warehouse and 14 forklifts are leased and operated by Iberia Industrials, so they are recorded for the emissions inventory.

Common mistakes

Ignoring leased vehicles and warehouses because they are not on the asset register
Not recording which party controls the lease, so the same emissions are counted twice

ESRS references

ESRS E1, paragraph 46
ESRS E1, paragraph 50

Dual-role JVs/associates?

Say whether any joint venture or associate is also a supplier or customer

In plainer words: Do you own part of a company that also sells to you or buys from you?

Why we ask: When an associate or joint venture is also a supplier or customer, the company must report on it like other business relationships. Its data is not limited to the share of equity held. Missing this understates value chain impacts.

Example: Yes. Iberia Industrials Maroc SA (48 percent) also supplies machined parts. Treat it as a Tier 1 supplier and request full site data.

Common mistakes

Reporting only the equity share of an associate's data
Missing a supplier relationship because the entity is filed only as an investment

ESRS references

ESRS 1, paragraph 67

Boundary notes

Record the reason, source documents, open questions and reviewer for each boundary decision

In plainer words: Write why each answer above is correct and which document proves it

Why we ask: This note is the workpaper an assurance provider reads to understand the boundary. A judgement with no source cannot be re-performed, so it is hard to defend.

Example: Associate excluded from consolidation on materiality grounds per consolidation schedule v3, reviewed by group finance. Open: confirm the Morocco data route. Reviewer: engagement lead.

Common mistakes

Writing the conclusion without the source document
No named reviewer against an open question

ESRS references

ESRS 2 BP-1
ESRS 1, Appendix B, QC 14

Topics to screen

Tick topics where impacts, risks or opportunities may reasonably arise from the activities or value chain

In plainer words: Tick the areas where your business could affect people or nature, or be affected by them

Why we ask: This is a screen, not the materiality conclusion. The standard says to focus on areas where impacts, risks and opportunities are likely to arise. Ticking everything defeats the screen, and ticking nothing leaves a topic unexamined that you may later have to explain.

Example: E1, E2, E3, E5, S1, S2 and G1 ticked. E4 left for topic screening because the Morocco site borders farmland.

Common mistakes

Ticking all topics so the screen carries no information
Treating a ticked topic as already material

ESRS references

ESRS 1, paragraph 39
ESRS 1, AR 16

Link to IRO register

Link this data source to an IRO in the register to pull across the title, topic and location

In plainer words: Optionally match this data source to an issue already listed in the register

Why we ask: Linking ties the evidence to the issue it supports, so an auditor can go from an IRO to its data. If the register is still empty, leave this manual and link later. Unlinked sources are easy to lose track of.

Example: Link to: E1, GHG emissions from own manufacturing operations

Common mistakes

Leaving every source unlinked, so no IRO shows its data source
Linking to a register row that is later deleted or retitled

ESRS references

ESRS 2 IRO-1

IRO description

Write the impact, risk or opportunity in plain language

In plainer words: Describe the issue this data helps you measure

Why we ask: A plain description keeps the data source readable on its own. It feeds the description of material impacts, risks and opportunities in SBM-3.

Example: Scope 3 emissions from purchased metals, estimated from spend

Common mistakes

Writing a topic name such as Climate instead of a specific impact or risk
Copying the register title without saying what the data measures

ESRS references

ESRS 2 SBM-3

Topic

Pick the ESRS topical standard this source supports

In plainer words: Pick the subject area this data belongs to

Why we ask: The topic routes the data to the right disclosure requirements later and to the right owner in the client. A wrong topic means the evidence is not found when the disclosure is drafted.

Example: E1

Common mistakes

Choosing E1 for everything that involves energy, including water and pollution data
Picking the topic of the person who supplied the data, not of the issue

ESRS references

ESRS 1, AR 16

Value chain location

Use the same wording as the value chain map, such as Upstream Tier 1 or End use customers

In plainer words: Where in your supply chain this data comes from

Why we ask: Matching words let the register, data sources and map be read together. It also shows where in the value chain the data is concentrated.

Example: Upstream Tier 1, direct metal suppliers

Common mistakes

Inventing new location labels that do not match the map
Leaving it blank so the data cannot be traced to a tier

ESRS references

ESRS 2 SBM-3

Source type

Direct data is strongest, so say plainly when you are using an estimate or proxy

In plainer words: Is this real data from the party, or an estimate

Why we ask: The standard allows estimates from sector averages and other proxies when direct data cannot be got after reasonable effort. It then expects the company to say which metrics are estimated and how accurate they are. Mislabelling an estimate as direct data is the error assurance providers look for first.

Example: Spend based estimate, using sector average emission factors, for purchased metals pending primary data from the twelve mills

Common mistakes

Labelling a spend based estimate as direct counterparty data
Using an estimate without recording that direct data was requested first

ESRS references

ESRS 1, paragraph 69
ESRS 1, AR 17
ESRS 2 BP-2

Limitation

State coverage gaps, estimation method, confidence, age of the data or access limits

In plainer words: Anything that makes this data less than complete or exact

Why we ask: BP-2 asks the company to identify estimated metrics, the basis for preparation, the level of accuracy and planned improvements. This field is where that disclosure comes from. An empty limitation implies full confidence, which is rarely true.

Example: Covers 8 of 12 mills (about 70 percent of metal spend). The rest is estimated. Data is from calendar 2024. Improvement: request 2025 data by Q2.

Common mistakes

Writing None for a sector average source
Describing the limitation but not the planned improvement

ESRS references

ESRS 2 BP-2
ESRS 1, paragraph 88

EU law limits

Note GDPR, confidentiality or competition law limits and the alternative evidence you will use

In plainer words: Tell us if a legal or contract rule stops you getting or sharing some data

Why we ask: Some supplier data cannot be shared lawfully or under contract. Recording the limit and the alternative route shows the data gap was reasoned and that reasonable efforts were made. Whether a restriction really applies is a question for the client's lawyers.

Example: Supplier wage data is personal data under GDPR. Use aggregated wage bands from the supplier audit report instead.

Common mistakes

Citing GDPR as a blanket reason to skip supplier data requests
Recording the limit but no alternative evidence route

ESRS references

ESRS 1, paragraph 69
ESRS 1, paragraph 132

Review status

Move to Approved only when a named reviewer has signed off and the limitations are recorded

In plainer words: Leave as Draft until your consultant has reviewed this step

Why we ask: Boundary, screening and data source adequacy are human judgements. A named reviewer on each shows an assurance provider who owned the decision. This is good practice that supports ESRS 2 GOV-5, not a requirement of it.

Example: Approved by the engagement lead after the client finance lead confirmed the consolidation schedule

Common mistakes

Approving with open Needs review answers still in the boundary section
Approving without a named reviewer

ESRS references

ESRS 2 GOV-5

Step 3 of 9

Topic screening

Go through every ESRS sub-topic and decide whether it needs a closer look. This narrows the long list so the impact and financial assessment is spent on topics that could matter.

What this step produces

A status and a written reason for every sub-topic, used to seed the IRO register
The list of topics screened out, used later to explain omissions (ESRS 2 IRO-2)
A Word export of the screening, kept as a workpaper for the assurance provider

Before you move on

Every sub-topic has a status, and none is left as Not assessed
Each Out of scope has a reason that points to sector, operations or value chain facts
Each Deferred has an owner and a date, and none remain at sign-off
Screening matches the topics ticked in the value chain step, or the difference is explained
If climate is screened out, the reason is detailed and says what would change it
Matters the ESRS list does not cover have been considered as entity specific
In scope sub-topics are carried into the IRO register as candidate impacts, risks and opportunities
A reviewer has approved the step

ESRS references

ESRS 1, paragraph 39
ESRS 1, AR 16
ESRS 1, paragraph 32
ESRS 2 IRO-2

Fields

Sub-topic status

Mark each sub-topic In scope, Out of scope or Deferred after a first look, not a final conclusion

In plainer words: Say whether this subject is relevant to your business, not relevant, or still to be decided

Why we ask: The standard asks the company to consider its full list of sustainability matters when it assesses materiality, and this is where that consideration is recorded. In scope sub-topics go forward to scoring. A gap here means a topic reaches the final report, or is dropped, with no trace of how that was decided.

Example: E3 Water: In scope, because two plants sit in high water stress basins. S3 Affected communities: Deferred until the Morocco community survey is back.

Common mistakes

Using Out of scope as a final materiality conclusion before any impact or financial scoring
Leaving large parts of the list as Not assessed and calling the screen complete
Marking everything In scope so the screen narrows nothing

ESRS references

ESRS 1, AR 16
ESRS 1, paragraph 39

Rationale

Give the reason for the status, pointing to sector, operations, value chain actors or earlier discussion

In plainer words: Explain in a sentence or two why you chose this answer

Why we ask: The reason is what an assurance provider tests. If a topic is later left out of the report, this note is the evidence that the omission was considered. If the company concludes climate is not material, the standard expects a detailed explanation, including what could make it material in future. The simplified ESRS adopted in July 2026, once in force, allow a top down conclusion on a topic, but still expect the reasoning to be documented.

Example: Out of scope: E4 Biodiversity. No sites in or near protected areas (site register, March), and no commodities from high deforestation regions. Revisit if the Morocco plant expands.

Common mistakes

Writing Not relevant with no fact behind it
Giving a reason that contradicts the value chain screen
Explaining a Deferred item without saying who decides and by when

ESRS references

ESRS 1, paragraph 32
ESRS 2 IRO-2
ESRS 1 as amended by C(2026) 5010, paragraph 27

IRO register signal

Shows impacts, risks or opportunities already in the register for this topic, so check your status agrees

In plainer words: A reminder that issues have already been recorded for this subject

Why we ask: If the register already holds an issue for a topic you are marking Out of scope, one of the two is wrong. Reconcile them before scoring starts. Otherwise the double materiality assessment scores an issue under a topic the screen has dropped.

Example: E1 shows 2 IROs linked, so E1 sub-topics should be In scope or the register rows should be reviewed.

Common mistakes

Ignoring the signal and screening a topic out while the register still lists issues under it
Adding register rows later without re-opening the screening status

ESRS references

ESRS 2 IRO-1

Step 4 of 9

IRO register

List the impacts, risks and opportunities (IROs) the company has or could have, one row each. This register is the single list that the materiality assessment scores and the disclosures are built from.

What this step produces

IRO rows, scored in the double materiality assessment
Material IROs, used to seed disclosures and write SBM-3 (material IROs and strategy)
Gaps and recommended actions, shown in the gap analysis
An exported register, kept as a workpaper for the assurance provider

Before you move on

Each row is one impact, one risk or one opportunity, not a mix
Each row has a specific title and a description that gives cause, who or what is affected, and where
Both negative and positive impacts are captured, and risks and opportunities as well
Each row has a topic, a value chain location and, where a mapped actor exists, a link to it
Time horizons follow the ESRS definitions, or the departure is recorded
Each row has evidence, or a recorded gap with an owner and an action; pick a row to edit it and keep owner and evidence practical for the next reviewer
The register has been checked against topic screening and stakeholder input
No one has typed a materiality result here, because it comes from the assessment

ESRS references

ESRS 2 IRO-1
ESRS 2 SBM-3
ESRS 1, paragraph 43
ESRS 1, paragraph 49

Fields

Type

Impact is an effect on people or the environment, risk or opportunity is a financial effect on the company

In plainer words: Is this an effect your company has on people or nature, or an effect on your company's finances

Why we ask: The standard has two lenses. Impacts are the company's effect on people and the environment, and risks and opportunities are effects on the company's finances. The type tells the assessor which lens a row starts from. One real issue is often both, so log it twice and link the rows.

Example: Impact: water abstraction at water stressed sites. Risk: production loss if the Badajoz water licence is cut.

Common mistakes

Logging a risk as an impact because it also sounds bad for society
Combining an impact and its financial risk in one row
Recording only negatives, with no positive impacts or opportunities

ESRS references

ESRS 1, paragraph 43
ESRS 1, paragraph 49
ESRS 1, paragraph 38

ESRS topic

Pick the topical standard most closely linked, and put sub-topic detail in the description

In plainer words: Pick the subject area this issue belongs to

Why we ask: The topic routes the row to the right disclosure requirements and decides which topics the gap analysis treats as required. A row on the wrong topic produces the wrong disclosures.

Example: E3 for water abstraction. S2 for labour conditions at a Tier 2 supplier.

Common mistakes

Leaving the default E1 on a row that is about another topic
Choosing a topic by who owns the data rather than what the issue is about

ESRS references

ESRS 1, AR 16

Title

Use a short, specific label that still makes sense in an exported register

In plainer words: Give the issue a short name that anyone could understand

Why we ask: The title is what the assessment table, the disclosures and the export all show. A vague title forces everyone to open the row to know what it is.

Example: Water abstraction at water stressed sites

Common mistakes

Using a topic name such as Climate as the title
Writing the same title on several rows

ESRS references

ESRS 2 SBM-3

Description

Explain the cause, who or what is affected or the financial route, and where the issue shows up

In plainer words: Describe what happens, who or what it affects, and where

Why we ask: SBM-3 asks for a brief description of each material IRO and where it is concentrated, and for how impacts affect people or the environment. This text is the starting point for that disclosure. Without a cause and a pathway, the scorer has nothing to judge.

Example: Cooling and rinse water is drawn from the Guadiana basin at two plants. In dry years this competes with local farms. Costs and licence risk rise at the same plants.

Common mistakes

Describing a policy or a control instead of the issue
Naming the topic with no cause, affected party or financial route

ESRS references

ESRS 2 SBM-3

Link to value chain actor

Link the IRO to the value chain actor where it arises to pull in tier, direction and activity

In plainer words: Optionally pick the supplier or customer group this issue comes from

Why we ask: Linking ties the issue to the map, so you can show where in the value chain it is concentrated. The standard expects value chain information only for the parts where the matter is material.

Example: Upstream, Tier 1, direct material suppliers, for a Scope 3 emissions row

Common mistakes

Skipping the link and typing a location that no longer matches the map
Linking to an actor from the wrong tier

ESRS references

ESRS 1, paragraph 64
ESRS 2 SBM-3

Value chain location preset

Pick a common value chain location, or type your own in the field below

In plainer words: Pick where in your business or supply chain this issue arises

Why we ask: A shared set of locations keeps the register consistent and lets you count how many IROs sit upstream, in own operations or downstream. Free text alone makes that count unreliable.

Example: Upstream Tier 2+

Common mistakes

Selecting Own operations for everything because it is first on the list
Picking a preset that conflicts with the linked actor

ESRS references

ESRS 2 SBM-3

Value chain location

Say where it arises: own operations, upstream tier, logistics, end use or a linked actor

In plainer words: Where in your business or supply chain this issue arises

Why we ask: SBM-3 asks where in the business model, own operations and upstream and downstream value chain the material IROs are concentrated. This field is that answer, row by row.

Example: Upstream Tier 1, aluminium mills in Turkey

Common mistakes

Entering a country instead of a position in the value chain
Leaving the location blank so SBM-3 cannot say where the issue sits

ESRS references

ESRS 2 SBM-3
ESRS 1, paragraph 66

Time horizon

Short, medium and long should follow the project's methodology so assessments stay comparable

In plainer words: How soon this could happen: this year, within five years, or later

Why we ask: The standard defines short term as the reporting period, medium term as up to five years after it and long term as more than five. A company may use other definitions if it says so and gives its reasons. Mixing definitions across rows makes the register incomparable.

Example: Medium: expected to bite within five years as the Guadiana licence is reviewed in 2028.

Common mistakes

Using personal definitions of short and long with no disclosure of them
Using one horizon for everything

ESRS references

ESRS 1, paragraph 77
ESRS 2 BP-2

Materiality

Set by the double materiality assessment, not typed here

In plainer words: This result comes from the scoring step and cannot be typed here

Why we ask: Materiality is the conclusion of the double materiality assessment. Typing it with no scoring behind it is not a legitimate conclusion, and IRO-1 requires the process behind it to be described. The result you see flows on to the gap analysis and to disclosure planning.

Example: Material, written here after the E3 row is scored on both lenses

Common mistakes

Looking for a way to type the result instead of scoring the IRO
Asking the client to confirm a result before the scoring is finished

ESRS references

ESRS 1, paragraph 21
ESRS 2 IRO-1

Evidence

Link or name the source: interviews, policies, site data, incident logs, supplier evidence or datasets

In plainer words: List the documents or data that show this issue is real

Why we ask: An assurance provider will trace a conclusion to its source. The standard expects information to be verifiable, meaning that others can corroborate it or the inputs behind it. A row with no evidence is an opinion.

Example: Site water meter data FY2025; Guadiana basin authority notice of 14 March; interview with the Badajoz plant manager.

Common mistakes

Writing See file with no document name or date
Citing evidence the client cannot produce on request

ESRS references

ESRS 1, Appendix B, QC 13
ESRS 1, Appendix B, QC 14

Gap

Say what is missing or weak between current practice and what good practice or the standard expects

In plainer words: What is missing today, such as a policy, data or a process

Why we ask: Gaps recorded here show up in the gap analysis next to the matching ESRS topic. They also tell the reviewer what needs doing before disclosure. A missing policy or target must be disclosed as missing, so it needs to be known early.

Example: No site level water targets. Abstraction is metered monthly at two of three plants.

Common mistakes

Describing the issue again instead of what is missing to manage it
Leaving it empty on a material IRO, so the gap analysis shows nothing to close

ESRS references

ESRS 1, paragraph 33

Recommended action

Give a concrete next step, specific enough for the action owner to start

In plainer words: What should be done next to close the gap

Why we ask: Actions turn a gap into work with an owner. They appear in the gap analysis and feed the actions and resources the company will disclose for material topics.

Example: Install a meter at the third plant and set a 2026 water use baseline by site.

Common mistakes

Writing Improve monitoring with no owner, scope or date
Proposing an action that depends on data no one has yet

ESRS references

ESRS 2 MDR-A

Owner

Name the person or function who validates the judgement or supplies the missing evidence

In plainer words: Who in your company can confirm this or provide the data

Why we ask: Every judgement in the register needs a named person who can be asked about it, including by the assurance provider. Without an owner, the evidence request has nobody to go to and data arrives late. This is good practice that supports ESRS 2 GOV-5, not a requirement of it.

Example: Plant Manager, Badajoz

Common mistakes

Naming the consultant rather than someone at the client
Using a department with no named contact

ESRS references

ESRS 2 GOV-5

Step 5 of 9

Double materiality assessment

Score each impact, risk and opportunity through two lenses: the company's effect on people and the environment, and the effect of sustainability matters on the company's finances. A matter is material if either lens says so, and the result decides what the company must report.

What this step produces

A materiality conclusion per IRO, written back to the IRO register
A recorded rationale, reviewer and methodology version per IRO, used to describe the process (ESRS 2 IRO-1)
The list of material topics, used to seed disclosures and to size the gap analysis
The reasons for topics left out, used to write ESRS 2 IRO-2

Before you move on

Every IRO has been scored, or deliberately left Not assessed with a reason
Nature, direction and the human rights flag are set before any score is entered
Scores use 1 for low and 5 for high, and the same thresholds apply to every row
The thresholds and the reasoning behind them are written down, because IRO-1 asks for them
Stakeholder input is summarised for each material or borderline IRO
Any override has a reason that says why the scoring did not capture the point
Every rationale is specific enough for another reviewer to repeat the judgement
A named reviewer has approved the result before it flows to disclosure planning

ESRS references

ESRS 1, paragraph 37
ESRS 1, paragraph 42
ESRS 1, paragraph 45
ESRS 1, paragraph 49
ESRS 2 IRO-1
ESRS 2 IRO-2

Fields

Nature

An actual impact is already happening, a potential one may happen, and the test differs for each

In plainer words: Is this already happening, or could it happen in future

Why we ask: The standard tests an actual negative impact on severity alone and a potential one on severity and likelihood. Choosing the wrong nature changes the outcome. If an impact already occurring is scored as potential, its likelihood score wrongly pulls it down.

Example: Actual: Moroccan plant already draws water in a basin under restriction. Potential: a chemical spill at the coating line.

Common mistakes

Leaving every impact on the Potential default
Scoring likelihood low on an impact that has already occurred

ESRS references

ESRS 1, paragraph 45
ESRS 1, paragraph 46

Direction

Negative harms people or the environment, positive benefits them, and each is tested differently

In plainer words: Does this harm people or nature, or help them

Why we ask: Irremediable character, meaning whether harm can be undone, applies only to negative impacts. A positive impact is judged on scale and scope, plus likelihood if it is only potential. Asking for the wrong factors distorts the result.

Example: Positive: apprenticeships for 40 local young people at the Portugal plant each year.

Common mistakes

Treating positive impacts as not worth scoring
Scoring irremediable character on a positive impact

ESRS references

ESRS 1, paragraph 45
ESRS 1, paragraph 46

Human rights impact

Tick if this is a potential negative human rights impact, where severity outranks likelihood

In plainer words: Tick if this could harm someone's basic rights, such as safety, fair pay or freedom from forced labour

Why we ask: For a potential negative human rights impact, the standard says severity takes precedence over likelihood, so a severe but unlikely impact stays material. This cannot be guessed from the topic code. Social topics often involve human rights, but not always.

Example: Ticked: risk of forced labour at a Tier 2 contract supplier. Not ticked: a minor noise complaint from a neighbour.

Common mistakes

Ticking it for every S topic row by default
Missing it on a severe supplier labour issue because the likelihood looks low

ESRS references

ESRS 1, paragraph 45
ESRS 1, AR 11

Scale

Rate how grave the harm is, or how beneficial the effect is, from 1 low to 5 high

In plainer words: How serious is the effect on people or nature, from 1 minor to 5 critical

Why we ask: Scale is one of the three parts of severity. It stands for how serious the effect is. A score with no reasoning behind it cannot be defended, so link it to a fact such as number of incidents, the size of the harm or an external benchmark.

Example: 4: permanent injuries recorded at two plants in the last three years.

Common mistakes

Scoring from gut feel with no fact in the rationale
Scoring the likelihood of the event instead of how serious it is

ESRS references

ESRS 1, paragraph 45
ESRS 1, AR 10

Scope

Rate how widespread the effect is across people, places and value chain tiers, from 1 narrow to 5 systemic

In plainer words: How many people or how much area is affected, from 1 few to 5 very many

Why we ask: Scope is the second part of severity. For people it means how many are affected, and for the environment how large the area or damage is. Count heads or hectares where you can.

Example: 3: affects the 220 workers at one plant, and not the other sites.

Common mistakes

Using company size as a proxy for the number of people affected
Scoring only the own operations when the impact sits upstream

ESRS references

ESRS 1, paragraph 45
ESRS 1, AR 10

Irremediability

Rate how hard it would be to put the affected people or environment back to their earlier state

In plainer words: How hard would it be to fix or undo the harm, from 1 easy to 5 impossible

Why we ask: Irremediable character is the third part of severity, and any one of the three can make a negative impact severe. Harm that cannot be undone, such as a death or lost habitat, should be able to push a row to Material even when scale and scope are modest.

Example: 5: the loss of a protected wetland habitat cannot be restored in a human lifetime.

Common mistakes

Scoring how costly the fix is to the company rather than whether the harm can be undone
Averaging it away when it is the one decisive factor

ESRS references

ESRS 1, paragraph 45
ESRS 1, AR 10
ESRS 1, AR 11

Likelihood (impact)

Rate how likely the impact is over the time horizon, from 1 unlikely to 5 almost certain

In plainer words: How likely is this to happen, from 1 unlikely to 5 almost certain

Why we ask: Likelihood applies to potential impacts only. It is not collected for an actual impact, because the standard tests those on severity alone. For a potential human rights impact, severity still takes precedence.

Example: 2: no incident in ten years, strong controls, but the process uses a toxic chemical.

Common mistakes

Using likelihood to discount a severe human rights impact
Using a different time horizon for likelihood than for the financial lens

ESRS references

ESRS 1, paragraph 45
ESRS 1, paragraph 46

Magnitude

Rate how large the financial effect could be, from 1 negligible to 5 transformational

In plainer words: How big could the money effect on your company be, from 1 tiny to 5 very large

Why we ask: A sustainability matter is financially material if it triggers, or could reasonably be expected to trigger, material effects on the company's finances, access to finance or cost of capital. Magnitude is the size of that effect. Link it to a number or range where you can, so it is not just an opinion.

Example: 4: a water licence cut would idle one plant, about 12 percent of group output.

Common mistakes

Scoring the size of the topic instead of the size of the effect on the company
Leaving out dependencies on natural resources as a source of financial risk

ESRS references

ESRS 1, paragraph 49
ESRS 1, paragraph 51
ESRS 1, AR 15

Likelihood (financial)

Rate how likely the financial effect is over the chosen time horizon, from 1 unlikely to 5 almost certain

In plainer words: How likely is the money effect, from 1 unlikely to 5 almost certain

Why we ask: Risks and opportunities are assessed on a combination of the likelihood of the effect and its potential magnitude. This is the second half of that test. The standard also asks you to consider effects below a more likely than not level.

Example: 3: licence reviews happen every five years and the 2028 review is expected to tighten limits.

Common mistakes

Dismissing low probability, high effect events, which can matter once combined
Rating likelihood without saying over which horizon

ESRS references

ESRS 1, paragraph 51
ESRS 1, AR 15

Financial anchor

Optional: tie the magnitude to an amount, a currency and what it is measured against

In plainer words: If you know roughly how much money is involved, you can enter it here

Why we ask: The standard does not require a financial effect to be quantified. But a magnitude score tied to an amount and a denominator, such as a share of EBIT or revenue, can be defended under challenge, and one with no anchor is a judgement. The export states which it is.

Example: Amount 4.2 million, EUR, of EBIT: estimated cost of a water licence cut for one quarter.

Common mistakes

Entering a figure with nothing to measure it against
Using a number from a different year or currency basis than the financial statements

ESRS references

ESRS 1, paragraph 49
ESRS 2 IRO-1

Time horizons this IRO bites in

Tick the horizons where it applies: short is the reporting year, medium up to five years, long is more

In plainer words: Tick when this could matter: this year, within five years, or later

Why we ask: Time horizons are recorded for disclosure and do not change the score. SBM-3 asks for the reasonably expected time horizons of impacts and financial effects. A company may depart from the standard definitions only if it says so in BP-2.

Example: Medium and long: licence tightening in 2028 and a drier climate beyond 2030.

Common mistakes

Ticking all three horizons on every row
Using the company's budget cycle as the short term when it differs from the reporting period

ESRS references

ESRS 1, paragraph 77
ESRS 2 BP-2
ESRS 2 SBM-3

Stakeholder input

Summarise the interviews, workshops, surveys or client evidence that shaped the score

In plainer words: Who you asked about this issue and what they said

Why we ask: The standard says the materiality assessment is informed by dialogue with affected stakeholders. IRO-1 asks whether and how the process involved consultation with affected stakeholders and experts. This free text is not yet linked to a stakeholder group, so name the group and the date in it.

Example: Works council interview, 12 March: injury risk at the coating line raised by 3 of 4 delegates. Union survey, 214 replies.

Common mistakes

Writing Stakeholders were consulted with no group, date or method
Recording only the views of senior management

ESRS references

ESRS 1, paragraph 24
ESRS 1, AR 8
ESRS 2 IRO-1

Conclusion

The result worked out from your scores, shown with the reasoning and written to the IRO register

In plainer words: The result of the scoring, shown for the consultant to review

Why we ask: Either lens can make a matter material. Watchlist is an internal triage state, not an ESRS category, and it must not be shown to a client as a regulatory conclusion or used to quietly drop a matter. Not assessed means no one has scored it, which is different from not material.

Example: Material (impact lens). Severity 4.3 with a likely potential impact. Financial lens Watchlist. Written to the register as Material.

Common mistakes

Presenting Watchlist to the client as a materiality decision
Reading Not assessed as not material

ESRS references

ESRS 1, paragraph 28
ESRS 1, paragraph 37
ESRS 2 IRO-1

Override the conclusion

Change the result only when the scoring does not capture a real point, and say why

In plainer words: Your consultant may change the result here, with a reason

Why we ask: A scoring model cannot capture everything, so a named assessor may override it. IRO-1 asks for the decision making process and its internal controls. This is good practice that supports ESRS 2 GOV-5, not a requirement of it.

Example: Override Not material to Material: pending EU rule on aluminium imports is not in the scores.

Common mistakes

Overriding to get a preferred topic list instead of following the thresholds
Overriding without a recorded reason

ESRS references

ESRS 2 IRO-1
ESRS 2 GOV-5

Reason for the override

Say what the scoring misses and what evidence supports the different result

In plainer words: Why the result was changed

Why we ask: The reason is the evidence for the override. Without it the override looks arbitrary, and the assurance provider may treat the whole assessment as less reliable.

Example: Regulation on carbon border adjustment extends to our coated products from 2028. Not reflected in the financial lens.

Common mistakes

Writing Management view
A reason that repeats the new result

ESRS references

ESRS 2 IRO-1

Rationale

Explain the judgement, the thresholds applied, the evidence gaps and why the outcome is right

In plainer words: In plain words, why this issue matters or does not

Why we ask: The standard requires thresholds to be set and the company to describe how it set them, in IRO-1 and IRO-2. This note is the proof that they were applied, row by row. A reviewer or assurance provider reads it to repeat the judgement.

Example: Potential impact: solvent spill at the coating line. Scale 4 and scope 2 from the site hazard study, irremediable character 2 because contamination is contained on site. Severity 2.7. Likelihood 2 given bunding and no spill in ten years. Below the Material threshold in the methodology, so Not material. Revisit if line volume doubles. Evidence gap: no spill history for the Morocco site.

Common mistakes

Restating the score without the facts behind it
Never stating the thresholds, so the outcome cannot be repeated
Leaving out the evidence gaps

ESRS references

ESRS 1, paragraph 42
ESRS 1, AR 9
ESRS 2 IRO-1
ESRS 2 IRO-2

Reviewer

Name the person responsible for reviewing this materiality judgement

In plainer words: Who reviewed and agrees with this judgement

Why we ask: Materiality calls need a named human. The assurance provider will ask who decided and on what basis, and good practice is to show who checked the decision. This is good practice that supports ESRS 2 GOV-5, not a requirement of it.

Example: Engagement lead, with sign off by the client Head of Sustainability

Common mistakes

Entering the person who typed the scores rather than an independent reviewer
Leaving the reviewer blank on rows marked Approved

ESRS references

ESRS 2 IRO-1
ESRS 2 GOV-5

Review status

Approved means scoring and rationale are reviewed and ready to flow into disclosure planning

In plainer words: Leave as Draft until your consultant has reviewed this row

Why we ask: Approved rows flow on to the disclosure plan and the gap analysis. Approving before the rationale and stakeholder input are written leaves a thin audit trail on the part of the report an assurance provider tests hardest. This is good practice that supports ESRS 2 GOV-5, not a requirement of it.

Example: Approved: scores, rationale and stakeholder input complete, reviewed by the engagement lead.

Common mistakes

Bulk approving the table before individual rationales are written
Approving rows that still have no stakeholder input

ESRS references

ESRS 2 GOV-5

Step 6 of 9

Stakeholder engagement

Record who the company's key stakeholders are, how it engages with them and what they raised. This is the evidence for the stakeholder description in ESRS 2 SBM-2 and for the consultation that the materiality process (IRO-1) is expected to include.

What this step produces

A stakeholder group register, exported as a Word workpaper
Material for the SBM-2 description of key stakeholders and their views
Stakeholder input for the double materiality assessment and the IRO register
Topic coverage, used to spot ESRS topics that no stakeholder has been asked about

Before you move on

Affected stakeholders are covered: own workers, value chain workers, communities and consumers
Users of the sustainability statement are covered: investors, lenders, banks and similar
Each group is named specifically, not just by category
Engagement method, frequency and the latest occurrence are recorded, with a source such as minutes or survey results
Key topics raised are mapped to ESRS topics, and the coverage panel has been checked for gaps
Groups that cannot speak for themselves, such as nature, are represented through experts or representatives
The overall approach explains how groups were identified and prioritised
The linkage note explains how what stakeholders said changed the IRO list or the scoring

ESRS references

ESRS 1, paragraph 22
ESRS 1, paragraph 24
ESRS 1, AR 8
ESRS 2 SBM-2
ESRS 2 IRO-1

Fields

Overall approach to stakeholder identification

Describe how the company identifies and prioritises affected stakeholders and who oversaw the process

In plainer words: In a few lines, explain how you decided who your key stakeholders are

Why we ask: SBM-2 asks for a summary of the company's stakeholder engagement, including its key stakeholders, how engagement is organised and its purpose. This text is the core of that disclosure. The standard also separates affected stakeholders from users of the report, so the approach should cover both.

Example: Iberia Industrials identified stakeholders from its value chain map, the works council list and its top 20 customers and lenders. The Sustainability Committee reviewed the list. Groups most affected by site operations were prioritised.

Common mistakes

Describing a communications plan instead of how stakeholders were identified
Leaving out who approved the list of groups
Listing only investors and customers, with no affected groups

ESRS references

ESRS 2 SBM-2
ESRS 1, paragraph 22
ESRS 2 IRO-1

Stakeholder group name

Name a specific group, such as Manufacturing site workers, not a general category

In plainer words: A specific group of people, for example Badajoz plant employees

Why we ask: SBM-2 asks for the key stakeholders. A named group can be engaged, evidenced and traced into the materiality scores, and a vague one cannot. Specific names also let an assurance provider ask for the underlying minutes or survey.

Example: Moroccan plant contract workers

Common mistakes

Using only the category name as the group name
Naming individuals instead of groups, which also raises personal data issues

ESRS references

ESRS 2 SBM-2

Frequency

Say how often structured engagement with this group takes place

In plainer words: How often you speak with this group in a planned way

Why we ask: SBM-2 asks whether engagement occurs and for which stakeholder categories. Frequency shows whether the input is current or a one off. Not yet engaged is an honest answer, and it should come with a plan.

Example: Quarterly: works council meetings

Common mistakes

Marking Ongoing when there is no scheduled process behind it
Leaving Not yet engaged with no plan to engage

ESRS references

ESRS 2 SBM-2

Influence

Rate how much this group can affect the company's strategy, operations or reputation

In plainer words: How much this group can affect your company

Why we ask: Influence and interest help the consultant plan engagement and fill the stakeholder map. They are a management tool, not an ESRS test. The standard asks you to prioritise negative impacts by how severe they are, so a low influence group, such as supply chain workers, can still matter most.

Example: High: the works council can stop production through formal consultation rights.

Common mistakes

Rating affected groups with little power as Low and so deprioritising them
Treating the map position as a materiality result

ESRS references

ESRS 1, paragraph 24
ESRS 2 IRO-1

Interest

Rate how much this group cares about, or depends on, the company's sustainability performance

In plainer words: How much this group cares about your sustainability performance

Why we ask: Interest shows who is likely to use the report and who is most exposed to the company's impacts. Together with influence it places the group on the stakeholder map. Do not let the map stand in for evidence of what the group actually said.

Example: High: neighbouring communities are directly affected by emissions and water use.

Common mistakes

Guessing interest instead of using what the group has actually raised
Giving every group the same rating, which makes the map useless

ESRS references

ESRS 1, paragraph 22

Engagement methods

State how engagement is done, such as surveys, town halls, committees or regulatory submissions

In plainer words: How you speak with this group, for example surveys or meetings

Why we ask: SBM-2 asks how engagement is organised and what its purpose is. The method also tells the assurance provider what evidence to expect, such as survey results, minutes or attendance lists.

Example: Annual employee survey, quarterly works council meetings, monthly safety committee at each plant

Common mistakes

Listing methods that were planned but did not happen in the year
Describing channels like email with no sign of dialogue

ESRS references

ESRS 2 SBM-2

Key topics raised

Record the concerns and priorities this group actually raised, in their own terms

In plainer words: The main concerns this group has told you about

Why we ask: SBM-2 asks for the company's understanding of its stakeholders' interests and views, to the extent analysed in the materiality assessment. This is where that understanding is recorded. Without it, the materiality scores have no stakeholder support.

Example: Heat stress on the coating line in summer; late payment of contractor wages; community concern about night noise

Common mistakes

Entering topics the company assumes the group cares about
Using ESRS topic codes instead of the group's own concerns

ESRS references

ESRS 2 SBM-2
ESRS 2 IRO-1

Relevant ESRS topics

Tick the ESRS topics that this group's concerns most closely relate to

In plainer words: Leave blank if unsure and your consultant will tick these

Why we ask: The topic tags drive the coverage panel, which shows topics that no stakeholder has been linked to. A topic with no stakeholder link is a question an assurance provider is likely to ask. Tagging more topics than the concerns support weakens the panel.

Example: S1 and E1: working conditions and heat stress

Common mistakes

Ticking every topic for every group
Leaving the tags blank and so showing false gaps in coverage

ESRS references

ESRS 1, AR 16
ESRS 2 IRO-1

Notes

Add context, constraints or planned changes to engagement with this group

In plainer words: Anything else we should know about this group

Why we ask: Notes hold what the other fields cannot, such as a gap in access to a group, the source of the evidence, or a planned survey. They help the next reviewer understand limits in the engagement.

Example: Contract workers reached through the staffing agency only. A direct survey is planned for Q2 2026.

Common mistakes

Leaving out that a group could only be reached through an intermediary
Writing opinions of the group rather than facts about the engagement

ESRS references

ESRS 2 SBM-2

How stakeholder input feeds into due diligence and IRO identification

Explain how what stakeholders said changed the IRO list, the scores or the strategy

In plainer words: Describe what you did with what stakeholders told you

Why we ask: IRO-1 asks whether and how the process includes consultation with affected stakeholders. SBM-2 asks how their views are taken into account and whether the company changed its strategy or business model. If nothing changed, say so. Engagement that visibly changed nothing is what readers doubt.

Example: Works council feedback on heat stress added a new IRO on summer working conditions and raised its scale score from 2 to 4. The Sustainability Committee reviewed the change on 12 March.

Common mistakes

Describing what was heard but not what was done with it
Claiming input shaped the result with no change visible in the register or scores

ESRS references

ESRS 2 IRO-1
ESRS 2 SBM-2
ESRS 1, paragraph 24

Step 7 of 9

Disclosure requirements

Turn the material topics into a list of ESRS disclosure requirements, give each an owner and evidence, and draft the text. Each row is a workpaper, so every statement in it must trace back to a source.

What this step produces

A disclosure plan with one row per requirement, used by the gap analysis
Draft narrative per requirement, used to build the live report
An evidence list per row, used to answer the assurance provider's requests
Word draft and Excel tracker exports for client review

Before you move on

All ESRS 2 general disclosures are on the list, because they are required whatever the materiality result
Every material topic has its disclosure requirements listed, from the standard and not from memory
Topics assessed as not material have a recorded reason, ready for ESRS 2 IRO-2
Each row has a named owner at the client and the evidence that supports it
No row is Ready for review or Approved without evidence listed
Every AI or rules based draft has been read and edited by a person, and stale drafts regenerated
Each figure in a draft agrees to the evidence, and nothing in the draft is invented
Material matters the ESRS do not cover have been considered as entity specific disclosures

ESRS references

ESRS 1, paragraph 29
ESRS 1, paragraph 30
ESRS 1, paragraph 34
ESRS 1, paragraph 35
ESRS 2 IRO-2

Fields

Standard

Choose the ESRS standard this disclosure belongs to

In plainer words: The reporting standard this item sits under, which your consultant sets

Why we ask: ESRS 2 general disclosures are always reported, whatever the materiality result. Topical standards such as E1 or S1 are reported when the topic is material. The standard sets the group the row appears in, and the way the gap analysis counts coverage.

Example: ESRS 2 for governance, strategy and materiality process. E1 for climate.

Common mistakes

Leaving out ESRS 2 rows because the topics are assessed first
Adding E4 rows for a topic assessed as not material

ESRS references

ESRS 1, paragraph 29
ESRS 1, paragraph 30

Requirement

Use the disclosure requirement code, such as SBM-1, IRO-1, GOV-1 or E1-6

In plainer words: A code that identifies the item in the standard, which your consultant sets

Why we ask: The code is how the gap analysis, the index and an assurance provider find the row. IRO-2 requires a list of the requirements complied with, with page references, and a wrong code breaks that list. Codes will change under the simplified ESRS from 2027.

Example: E1-6 Gross Scopes 1, 2, 3 and total GHG emissions

Common mistakes

Typing a code from memory without checking the standard
Using an internal reference in place of the ESRS code

ESRS references

ESRS 2 IRO-2
ESRS E1-6

Title

Use a plain title so the table is easy to scan

In plainer words: A short name for what this item covers

Why we ask: A clear title helps client reviewers who do not know the codes. It appears in the tracker export. A missing title makes the client chase the consultant to find out what a row is.

Example: Gross Scopes 1, 2 and 3 greenhouse gas emissions

Common mistakes

Repeating the code as the title
Using a title that differs from the heading used in the report

ESRS references

ESRS 2 IRO-2

Status

Use Needs evidence when a draft exists but support is missing, and Ready for review before approval

In plainer words: Where this item stands, from Not started to Approved

Why we ask: The status drives the gap analysis: a row that holds no content, or only a placeholder, counts as outstanding. Honest statuses are what let the project manager see the true state of the report. This is good practice that supports ESRS 2 GOV-5, not a requirement of it.

Example: Needs evidence: draft written, but the Morocco Scope 2 figure is not yet provided.

Common mistakes

Marking Ready for review with no evidence listed
Leaving rows at Drafting for weeks with no owner follow up

ESRS references

ESRS 2 GOV-5

Owner

Assign the person or client function responsible for evidence and review

In plainer words: The person at your company who can supply the data or sign off the text

Why we ask: The consultant cannot supply the data, only the client can. Rows with no owner are the ones that stall. This is good practice that supports ESRS 2 GOV-5, not a requirement of it.

Example: Head of Environment, Iberia Industrials

Common mistakes

Naming the consultant as owner of a client data point
Naming a function with no contact

ESRS references

ESRS 2 GOV-5

Evidence

List the source documents, interviews, datasets or screenshots that support the draft

In plainer words: Name the documents or data that show the text is true

Why we ask: Limited assurance means the provider traces what is written to a source. The standard expects information to be verifiable, meaning inputs and methods can be corroborated. A draft with no evidence list cannot be tested, and the draft is flagged as stale if the evidence changes after it was written.

Example: FY2025 GHG inventory v3 (sheet Scope1), utility invoices Jan to Dec, fuel card export, emission factor table dated 2025

Common mistakes

Listing the folder, not the file, version and date
Citing a source that is not in the evidence requests
Changing evidence after drafting and not regenerating the draft

ESRS references

ESRS 1, Appendix B, QC 13
ESRS 1, Appendix B, QC 14

Narrative draft

Write or generate the text for this requirement, then read it against the evidence

In plainer words: The text that will appear in the report, which your consultant writes and checks

Why we ask: This text goes into the live report and then to the assurance provider. A draft made by the AI assistant or from rules is a starting point only. This is good practice that supports ESRS 2 GOV-5, not a requirement of it.

Example: Scope 1 gross emissions were 47,200 tCO2e in FY2025, from natural gas and diesel use at owned sites. Source: FY2025 GHG inventory v3.

Common mistakes

Accepting a generated draft without checking each figure against the evidence
Leaving evidence placeholders in the text that reach the client
Describing a policy that the company does not actually have

ESRS references

ESRS 1, Appendix B, QC 14
ESRS 2 GOV-5

AI review acknowledgement

Tick only after you have read every AI drafted disclosure and take responsibility for it

In plainer words: Your consultant confirms they have checked the AI drafted text

Why we ask: Exports stay locked until a person confirms they have reviewed all AI drafted text. The acknowledgement records that a named human took responsibility before the text reached the client or an assurance provider. This is good practice that supports ESRS 2 GOV-5, not a requirement of it.

Example: Ticked by the engagement lead after reading all 14 drafted rows against the evidence list.

Common mistakes

Ticking the box to unlock an export without reading the drafts
Ticking it before the last draft was regenerated

ESRS references

ESRS 2 GOV-5

Step 8 of 9

Gap analysis

Compare what the standards require for this company with what has actually been written. It shows which material topics still have outstanding disclosures, so the team can spend its time on the biggest risks first.

What this step produces

Coverage by topic and severity, used to plan the remaining drafting work
A list of outstanding requirements per topic, sent back to the disclosures step
Gaps and actions from the IRO register, collected in one view
A Word export for the client, showing readiness

Before you move on

Every topic has a materiality conclusion, so none are left as not yet assessed
Critical and High gaps on material topics have an owner and a date
Rows that were seeded but hold no text are being treated as outstanding, not as done
ESRS 2 general disclosures show no unexplained gaps, because they are always required
Topics shown as not required have an IRO-2 explanation, and their IRO-1 related requirements are still on the list
Gaps that come from a missing policy, action or target will be disclosed as missing, not hidden
The coverage figure has been read as a count of requirements, not as a measure of quality
A reviewer has approved the gap analysis before it goes to the client

ESRS references

ESRS 1, paragraph 29
ESRS 1, paragraph 30
ESRS 1, paragraph 33
ESRS 2 IRO-2

Fields

Coverage summary

Shows required, disclosed and outstanding requirements, and the coverage percentage across required topics

In plainer words: A headline of how much of the report is written so far

Why we ask: The count covers ESRS 2 plus every topic with a material or potentially material IRO. A topic assessed as not material is left out of the count, but the topical requirements tied to IRO-1 are always disclosed under ESRS 1 paragraph 29, so the figure can understate what is required. Coverage counts requirements that have content, not how good the content is, so it cannot be quoted as evidence of compliance.

Example: 62 of 81 requirements disclosed, 19 outstanding, 77 percent coverage across 6 required topics.

Common mistakes

Quoting the percentage to the client as compliance
Reading 100 percent as complete when topics are still unassessed

ESRS references

ESRS 1, paragraph 29
ESRS 1, paragraph 30

Severity filter

Filter the topics by severity to work through the biggest gaps first

In plainer words: Narrow the list to the most urgent topics

Why we ask: Material topics with many missing requirements carry the highest reporting risk, so they should be closed first. Filtering lets the team plan the next sprint of drafting and evidence requests.

Example: Select Critical to see E1 and S1, each with more than half their requirements missing.

Common mistakes

Clearing only Low and Medium gaps because they are quick wins
Reading the filter counts as the whole picture and not checking unassessed topics

ESRS references

ESRS 1, paragraph 30

Severity logic

Critical and High mean material topics with gaps, Medium potentially material, None no full disclosure needed

In plainer words: How urgent each gap is, from Critical to Low

Why we ask: Severity combines the materiality conclusion with the share of requirements still missing. A topic with no materiality conclusion yet is not a gap, but it is open work, because whether it is required is still unknown. Potentially material topics need a decision before they can be dropped.

Example: Critical: E3 Water is material and 6 of 9 requirements are missing.

Common mistakes

Treating None as done when it means the topic is not required or not assessed
Leaving potentially material topics undecided

ESRS references

ESRS 1, paragraph 29
ESRS 1, paragraph 30

Started, nothing written yet

Rows seeded from the register that hold no draft or review state still count as outstanding

In plainer words: Items that have a place in the report but no text yet

Why we ask: A seeded row is a placeholder, not a disclosure. Counting it as done would move coverage to 100 percent with nothing written, which would not survive a first conversation with an assurance provider.

Example: E5-3 has a row, an owner and no draft, so it shows as outstanding.

Common mistakes

Adding rows and a status without writing text to move the figure
Treating a drafting status with no text as progress

ESRS references

ESRS 1, paragraph 30

Topics not required

Not material topics need no full disclosure, but their IRO-1 related requirements still apply

In plainer words: Subjects that do not need to be reported on, or have not been decided yet

Why we ask: A topic assessed as not material needs no full set of topical disclosures, but it is not free of reporting. The topical requirements tied to IRO-1 are always disclosed, and the assessed and not material conclusion is explained. If climate is not material, the standard expects a detailed explanation. A topic nobody has assessed is different and must not be hidden here.

Example: E4 Biodiversity: not material, with a brief explanation recorded for IRO-2. S3: no conclusion yet.

Common mistakes

Treating a topic nobody has assessed as not required
Dropping climate without the detailed explanation the standard expects

ESRS references

ESRS 1, paragraph 29
ESRS 1, paragraph 32
ESRS 2 IRO-2

Gaps and actions from the register

Shows the gaps and recommended actions written on the IRO register for each topic

In plainer words: The missing items and next steps already recorded for each subject

Why we ask: These are the consultant's own judgements about what is missing, shown beside the formal requirement count. Where the company has no policy, action or target, the standard says to disclose that fact and it may add when it aims to have them. Knowing this early lets the client plan.

Example: No site level water targets. Action: set 2026 baseline and targets by plant.

Common mistakes

Leaving gaps in the register that never become actions with an owner
Hiding a missing policy rather than disclosing it as missing

ESRS references

ESRS 1, paragraph 33

Step 9 of 9

Live report

Assemble the report sections from the work done in earlier steps, then edit and review them. If the source data changes after a section was written, the section is flagged as out of date so the report does not drift from its evidence.

What this step produces

A Word draft of the sustainability statement, for client review and the assurance provider
A review status per section, showing what has been read and approved
A list of open flags and limitations, carried into the limitations section
A record of which sections were AI drafted, with the prompt version, kept as an audit trail

Before you move on

The earlier steps are approved before sections are generated
Check sources has been run and no section is out of date
Every section has been read by a person, and each figure agrees to the evidence
Manual edits are marked for review, and still agree with the source modules
Open gap and warning flags are resolved or carried into the limitations section
AI drafted sections are confirmed by a named reviewer before download
The final statement is arranged in the four parts the standard requires: general, environmental, social and governance
Information taken by reference from another report meets the standard's conditions, including the same level of assurance

ESRS references

ESRS 1, paragraph 111
ESRS 1, paragraph 112
ESRS 1, paragraph 115
ESRS 1, paragraph 120
ESRS 1, Appendix B, QC 14

Fields

View mode

Switch between the standard editor, a wide draft and the full document view

In plainer words: Choose how much of the report you see at once

Why we ask: The full document view shows how sections read together, and it is where the AI confirmation and the download sit. The standard requires the information to be shown in a way that is easy to find and read, so check the full view before sending it.

Example: Edit in Standard view, then use Full doc to read the whole statement once before download.

Common mistakes

Approving sections one by one and never reading the whole statement as one document
Reading only the Wide draft and missing how the sections connect

ESRS references

ESRS 1, paragraph 111

Generate all

Draft every section from the saved module data in one go, then review each one

In plainer words: Your consultant uses this to create a first draft of every section

Why we ask: This builds first drafts from the earlier steps. It saves time, but it only repeats what earlier steps hold. If those steps are thin, the draft is thin, and a confident sounding draft can hide it. Run it after the earlier steps are approved.

Example: Run after double materiality and disclosures are approved, then read the Open limitations section first.

Common mistakes

Generating before the double materiality step is approved
Regenerating over sections that have manual edits, without checking what was replaced

ESRS references

ESRS 1, Appendix B, QC 14

Generate or refresh section

Draft one section from its source modules, or refresh it after the sources change

In plainer words: Your consultant uses this to rewrite one section from the latest data

Why we ask: A section shows which source modules it draws from. When those change, the section is marked Out of date, and refreshing brings it back in line. Using an out of date section is how the report ends up disagreeing with its evidence.

Example: Refresh Value chain, boundary judgements and data limitations after a boundary answer changes.

Common mistakes

Ignoring an Out of date badge before export
Refreshing without checking what changed in the source module

ESRS references

ESRS 1, Appendix B, QC 14

Section text

Edit the draft so every statement is true, specific to this company and supported by evidence

In plainer words: The wording of this section, which your consultant edits and checks

Why we ask: This is the text the assurance provider reads. Manual edits stay in place but mark the section for review, so the draft and its sources do not drift. Statements about policies, targets or figures must exist in the evidence and not just sound plausible.

Example: Replace a generic line about supplier engagement with the actual number of suppliers assessed and the date.

Common mistakes

Leaving generic text that could describe any company
Describing a policy, action or target the company has not adopted
Editing a figure in the text without updating the source module

ESRS references

ESRS 1, Appendix B, QC 14
ESRS 1, paragraph 33

Section review status

Mark a section Needs review or Reviewed after a person has read it against the sources

In plainer words: Shows whether a section has been checked by a person

Why we ask: A named review is good practice. Marking Reviewed on a section nobody has read leaves a false trail. This is good practice that supports ESRS 2 GOV-5, not a requirement of it.

Example: Mark reviewed by the engagement lead after the figures were agreed to the GHG inventory.

Common mistakes

Marking all sections reviewed in one go
Reviewing before the source modules were final

ESRS references

ESRS 2 GOV-5

Check sources

Re-read the saved modules to see which sections are now out of date or have open gaps

In plainer words: Your consultant uses this to check the report still matches the latest data

Why we ask: The check compares each section with the current state of its source modules, such as the IRO register, disclosures and evidence. It shows how many sections are current, how many are stale and how many flags are open. Run it before every export.

Example: Run before download. Result: 7 sections current, 1 stale, 3 open flags.

Common mistakes

Downloading the report without running it after the last data change
Treating a clean check as proof that the content is correct, when it only shows the sections are current

ESRS references

ESRS 1, Appendix B, QC 13

Review flags

Work through each flag, then resolve it or carry it into the limitations section

In plainer words: Points your consultant must settle before the report is final

Why we ask: Flags mark evidence gaps, warnings and limitations found in a section. Hiding an unresolved flag turns a known gap into an unexplained one. The standard expects significant uncertainty in estimates to be disclosed, and flags are how you find them.

Example: Flag: Scope 3 category 1 is a spend based estimate. Carried into limitations with the planned improvement.

Common mistakes

Resolving a flag by deleting the sentence that raised it
Leaving open flags that do not appear in the limitations section

ESRS references

ESRS 1, paragraph 88
ESRS 2 BP-2

AI drafting confirmation

Tick only after you have read every AI drafted section and confirm it is accurate for this client

In plainer words: Your consultant confirms they have checked the AI drafted sections

Why we ask: Download stays locked until a person confirms they have read the AI drafted sections. This puts a named human between the draft and the client and the assurance provider. This is good practice that supports ESRS 2 GOV-5, not a requirement of it.

Example: Ticked by the engagement lead after reading 5 AI drafted sections against the evidence list.

Common mistakes

Ticking to unlock the download without reading the sections
Ticking before the last manual edit or refresh was made

ESRS references

ESRS 2 GOV-5

Ask the field guide

Scope assessment

What this step produces

Before you move on

Fields

Entity type

Listed status

Employees

Net turnover

Balance sheet total

Parent exemption

First reporting year

Assurance readiness

Scoping notes

Value chain and boundary

What this step produces

Before you move on

Fields

Business activities

NACE code

Key geographies

Group structure notes

Tier

Category of actor

Activity / input-output

Activity details

Geography

Relationship type

Part of consolidated group?

Excluded subsidiaries?

Joint operations?

Leased assets?

Dual-role JVs/associates?

Boundary notes

Topics to screen

Link to IRO register

IRO description

Topic

Value chain location

Source type

Limitation

EU law limits

Review status

Topic screening

What this step produces

Before you move on

Fields

Sub-topic status

Rationale

IRO register signal

IRO register

What this step produces

Before you move on

Fields

Type

ESRS topic

Title

Description

Link to value chain actor

Value chain location preset

Value chain location

Time horizon

Materiality

Evidence

Gap

Recommended action

Owner

Double materiality assessment

What this step produces

Before you move on

Fields

Nature

Direction

Human rights impact

Scale

Scope

Irremediability

Likelihood (impact)

Magnitude

Likelihood (financial)