Run ESG and sustainability reporting end to end: fix the reporting boundary, pick and map disclosure frameworks (GRI, ISSB IFRS S1 and S2, ESRS under CSRD), run a documented materiality assessment, collect data across teams with an evidence register, build the GHG inventory, draft the disclosure, and get it assurance ready. Use when someone is preparing an ESG, sustainability, CSRD, or climate disclosure report, starting a reporting cycle, or fixing a report that is a loose set of questions with no collection workflow behind it.
name: esg_reporting_prep description: >- Run ESG and sustainability reporting end to end: fix the reporting boundary, pick and map disclosure frameworks (GRI, ISSB IFRS S1 and S2, ESRS under CSRD), run a documented materiality assessment, collect data across teams with an evidence register, build the GHG inventory, draft the disclosure, and get it assurance ready. Use when someone is preparing an ESG, sustainability, CSRD, or climate disclosure report, starting a reporting cycle, or fixing a report that is a loose set of questions with no collection workflow behind it.
ESG Reporting Prep
Purpose
Turn a reporting obligation or a voluntary commitment into one controlled cycle: scope, materiality, a disclosure register, data collection with evidence, drafting from that register, and assurance prep. The core rule is collect once, map many. One verified datapoint feeds every framework that asks for it, instead of three teams answering three overlapping questionnaires three different ways.
This skill prepares a report and its evidence. It does not give legal advice on whether a company is in scope, and it does not issue assurance. Scope, filing duties, and deadlines get confirmed against current law in the reporting jurisdiction and, where the stakes call for it, with counsel.
Workflow
1. Fix the scope before asking for any data
Record these in a one page scoping note and get the report owner to sign it off:
- Reporting entity and consolidation boundary: single entity or group, which subsidiaries, joint ventures, and leased assets are in or out, and why.
- Reporting period and the financial reporting period it aligns to.
- Organisational boundary for emissions: equity share, financial control, or operational control, following the GHG Protocol Corporate Standard. State the choice; do not mix approaches inside one inventory.
- Value chain boundary: which upstream and downstream stages are covered, and where coverage stops this cycle.
- Jurisdictions involved and who confirmed in-scope status and deadlines, and on what date. Framework scope and timing change; verify them at kickoff, never from last year's file.
Output: scoping-note.md. No data requests go out before this exists.
2. Choose frameworks and build the map
Pick frameworks by audience and obligation, then map them to each other before collecting anything. Full detail in references/framework-map.md.
| Need | Lead framework | Materiality lens | |---|---|---| | Broad stakeholder and impact reporting, voluntary or exchange required | GRI Standards | Impact: most significant impacts on economy, environment, and people | | Investor facing sustainability and climate disclosure where adopted | ISSB: IFRS S1 and IFRS S2 | Financial: information that could affect cash flows, access to finance, or cost of capital | | EU regulated sustainability statement | ESRS under CSRD | Double: impact and financial, either one makes a topic material |
Rules for the map:
- One row per disclosure requirement in the register, with every framework reference that row satisfies. A GHG total is collected once and tagged GRI 305, IFRS S2, and ESRS E1 as applicable.
- ESRS 2 general disclosures apply regardless of the materiality outcome. Topical ESRS (E1 to E5, S1 to S4, G1) apply when the topic is material.
- GRI reporting uses GRI 1, GRI 2, and GRI 3 for every report, an applicable Sector Standard when one exists for the sector, and Topic Standards matched to the material topics.
- If a jurisdiction has adopted IFRS S1 and S2 with local modifications, the local text governs. Note the modification in the register.
3. Run the materiality assessment and document it like an auditor will read it
- Understand the context: activities, business model, strategy, and the full value chain map from step 1.
- Build the long list of sustainability matters from the framework topic lists, sector guidance, prior year topics, incidents, and grievances. Break each matter into impacts, risks, and opportunities (IROs).
- Engage affected stakeholders and subject experts. Record who was consulted, when, and what changed as a result. An assessment with no stakeholder input is a weak file under GRI and ESRS alike.
- Set thresholds in writing before scoring. Scoring first and picking a threshold to fit the answer is the failure this step exists to prevent.
- Score impact materiality: for actual impacts use severity, meaning scale, scope, and irremediable character. For potential impacts add likelihood. For potential human rights impacts, severity takes precedence over likelihood.
- Score financial materiality: magnitude of the possible financial effect and its likelihood, over short, medium, and long term horizons the company defines in the note.
- Apply the framework rule: double materiality (ESRS) means material under either lens counts. GRI alone uses the impact lens. ISSB alone uses the financial lens.
- Validate the short list with the report owner and governance body, record dissent, and write the outcome into the register. Every framework topic that was assessed and excluded gets a reason, not silence. Excluding climate needs a specific, evidence based explanation; a generic not applicable will not survive review.
Worked scoring sheet: assets/materiality-scores.csv. Keep the scored sheet, the threshold note, and the stakeholder log as one materiality file. That file is the first thing an assurance provider asks for.
4. Build the disclosure register, the single source of truth
One row per datapoint, columns in assets/disclosure-register.csv:
id, topic, disclosure_refs, definition, unit, owner, source_system, method, evidence, period, status, reviewer, value
owner is a named person, not a department.
method states how the number is produced: metered, invoiced, calculated with a named factor source and year, estimated with a named proxy, or supplier reported.
status moves only in this order: requested, received, queried, verified, locked. Nothing drafts from a row that is not at least verified.
- Run the checker before drafting:
python3 bin/esg_check.py assets/disclosure-register.csv validates required fields, status values, duplicate ids, and rows claiming verified or locked without evidence.
5. Collect data across teams with request packs, not open ended asks
For each owner, send one request pack per topic containing: the exact register rows they own, the definition and unit for each row, the prior year value, the evidence required, the deadline, and one worked example of a good submission (a completed row with its invoice or system export attached).
Collection rules:
- Evidence hierarchy, best first: third party invoice or meter record, system export from the system of record, signed internal record, documented estimate. Label every row with the tier it rests on.
- Estimates are allowed, hidden estimates are not. The method and proxy go in the register, and the report's methodology note repeats them.
- Restatement policy decided up front: define the significance threshold that triggers restating a prior year figure, what counts as a structural change versus an error, and who approves a restatement. Apply it consistently.
- Chase by exception: the checker output lists missing owners, missing evidence, and stale statuses. Send that list, not a general reminder to everyone.
- Freeze date: after the freeze, changes go through a change log with a reason and a reviewer, not a quiet edit.
6. Build the GHG inventory inside the same register
- Scope 1: direct emissions from owned or controlled sources, for example fuel burned on site and in company vehicles, process emissions, and fugitive releases.
- Scope 2: indirect emissions from the generation of purchased energy consumed: electricity, steam, heat, and cooling. Record the calculation approach used and check the current GHG Protocol Scope 2 Guidance before choosing factors.
- Scope 3: all other indirect emissions in the value chain, assessed against the 15 categories of the Corporate Value Chain (Scope 3) Standard. Screen all 15, include the relevant ones, and record why each excluded category is not relevant or not material. Purchased goods and services, business travel, employee commuting, use of sold products, and end of life treatment of sold products are common starting points, not a default answer.
- Every emissions row carries: activity data and its source, emission factor source and year, global warming potential source if converting gases, and the person who checked the calculation.
- Report gross emissions. State carbon credits and removals separately; never net them into the gross figure in the register.
7. Control and verify before drafting
- Second person check on every calculated row: recalculate a sample, trace a sample back to source evidence.
- Variance review: flag any datapoint that moved sharply against prior year and require a written reason (real change, boundary change, method change, or error) in the register notes.
- Tie outs: headcount, energy, and revenue figures in the report must match the figures used elsewhere in the annual report or financial statements, or carry an explained difference.
- Check narrative claims against the register. Every number in prose must exist as a locked row. Every target claim must point to a baseline row and a target row.
8. Draft from the register
Report skeleton, adapted to the lead framework:
- Basis of preparation: boundary, period, frameworks applied, materiality summary, restatements, estimation approach.
- Governance: who oversees sustainability matters, their role, and how they are informed.
- Strategy and business model, including how material IROs interact with it.
- Risk management: how IROs are identified, assessed, and monitored.
- Topic sections for each material topic: policies, actions, targets, and metrics, in that order.
- Metrics tables drawn only from locked register rows.
- Content index: each framework disclosure reference mapped to a page or section. Build it from the register's
disclosure_refs column, not by hand after drafting.
Plain drafting rules: report negative results and missed targets alongside progress, name the reporting period's setbacks, and never let a case study stand in for a metric.
9. Prepare for assurance
- Know the engagement type: ISAE 3000 (Revised) is the common standard for non financial assurance, with ISAE 3410 for GHG statements. Limited assurance is substantially narrower than reasonable assurance; plan evidence for the level actually contracted.
- Assemble the assurance file as you go: scoping note, materiality file, register with evidence links, calculation files, change log, restatement decisions, and sign offs. Rebuilding this after drafting costs more time than the drafting did.
- Pre-empt the standard samples: expect the provider to pick high value, high estimate, and high movement rows. Make sure those rows have the cleanest evidence in the file.
- Log and fix findings in the register, then re-run the checker. A finding fixed only in prose will recur next year.
10. Sign off, publish, archive
Named sign off from the report owner and the governance contact, publication in the format the lead framework or local law requires, and an archive containing the final report, the final locked register, and the materiality file. Next year's cycle starts from that archive, not from memory.
Output Contract
A completed cycle produces:
scoping-note.md: entity, boundary, period, value chain coverage, jurisdiction check with date and checker.
materiality file: long list of IROs, thresholds set before scoring, scored sheet, stakeholder log, final material topics with reasons for exclusions.
disclosure-register.csv: every datapoint with owner, method, evidence, status, and reviewer; checker output clean or with named exceptions.
- Draft report built from locked rows only, with a content index generated from the register.
assurance file: the evidence pack in step 9, plus a findings log.
Operating Rules
- Every factual claim in the report traces to a register row or a primary source document in the file. Untraceable means cut it or label it clearly as an estimate or a management judgement.
- Never invent framework requirements, thresholds, deadlines, or company figures. Framework scope rules change; verify the current text of the standard or law before citing it.
- Thresholds before scores, always. Moving a materiality threshold after seeing the results needs a written reason and a second approver.
- One datapoint, one collection. If two frameworks ask for near identical data with different definitions, collect both definitions explicitly as separate rows and explain the difference in the methodology note.
- Gross before net for emissions, actuals before estimates in evidence quality, bad news included. Balance is a reporting principle, not a style choice.
- Status discipline: no drafting from unverified rows, no locked row changes without the change log.
- This skill prepares and organises. Legal scope calls and the assurance opinion belong to the professionals engaged for them; flag both early, because both set the timetable.
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