ESRS 2 General Disclosures

CSRD ESRS ESRS 2 General Disclosures Sustainability Reporting Governance Double Materiality EFRAG ISAE 3000 GRC ESG

Overview

Draft and validate the mandatory ESRS 2 general-disclosures pack for CSRD sustainability statements: BP-1/BP-2, GOV-1..5, SBM-1..3, IRO-1/IRO-2, due-diligence mapping, sustainability reporting controls, and an IRO-2 Disclosure Requirements index kept in sync with DMA outputs and datapoints.

What It Covers

Basis-of-preparation disclosures for the sustainability statement, including consolidation perimeter, value-chain inclusion, estimates, changes in preparation, phase-ins, and uncertainty.
Governance disclosures for oversight bodies, information flows, incentive schemes, due-diligence mapping, and internal controls over sustainability reporting.
Strategy and business-model disclosures that connect value-chain context, stakeholder interests, and material impacts, risks, and opportunities.
IRO-1 narrative that summarises the approved Double Materiality Assessment without reopening the scoring performed by the DMA skill.
IRO-2 Disclosure Requirements index that assigns each ESRS disclosure to a materiality basis, output section, data owner, evidence reference, sibling skill owner, and ESRS 2 Appendix B / other-EU-legislation datapoint status where applicable.
Scope discipline for the wider CSRD bundle: ESRS 2 consumes DMA outputs, feeds topical ESRS skills, and avoids taking over Taxonomy, assurance-testing, or ESEF tagging work.

Example Conversation

You: We finished our Double Materiality Assessment for FY2025. Can you draft the ESRS 2 pack from our program/ files? We have material topics, an IRO register, stakeholders, a governance log, and a partial datapoint index.
Agent: I will first reconcile the source-of-truth files: entity-profile.md, material-topics.md, governance-log.md, stakeholders.md, iro-register.csv, datapoint-index.csv, and evidence-index.md. Then I will draft BP-1, BP-2, GOV-1 through GOV-5, SBM-1 through SBM-3, IRO-1, and IRO-2. I will use [PENDING: owner/source] placeholders for gaps instead of inventing missing evidence, and I will keep topical detail as cross-references for the E1, S1, and G1 teams.
You: The audit committee minutes are strong, but we have not decided whether sustainability performance will affect executive incentives.
Agent: For GOV-3, I will state that no current sustainability-linked incentive decision has been approved, identify the decision owner and target date if available, and avoid implying a metric linkage that is not supported by the governance log. GOV-2 and GOV-5 will cite the dated audit committee evidence and sustainability reporting controls. I will also build the IRO-2 index so sibling topical skills can see the Disclosure Requirements they own and where datapoint-index rows are still pending.

Sample Output Excerpt

The excerpt below illustrates the tone and traceability expected in an ESRS 2 narrative pack.

GOV-2 — Information provided to and sustainability matters addressed by governance bodies

During FY2025, the Audit Committee and Sustainability Steering Committee received quarterly updates on the Double Materiality Assessment, value-chain data availability, and readiness of ESRS datapoints for limited assurance. The matters addressed were recorded in program/governance-log.md and linked to the material IRO register.

Date	Governance body	Matter addressed	Linked IROs / topics	Evidence reference
2025-04-18	Sustainability Steering Committee	DMA methodology, stakeholder coverage, and value-chain boundary	IRO-001 to IRO-018; E1, S1, G1	GOV-2025-04-18-minutes
2025-06-27	Audit Committee	ESRS datapoint gap status and evidence-file readiness	BP-1, BP-2, GOV-5, IRO-2	AC-2025-06-27-pack

[PENDING: confirm whether the Board has formally approved the DMA topic scoping decision-log and record the approval reference in program/evidence-index.md.]

IRO-2 — Disclosure Requirements covered by the sustainability statement

Standard	DR code	DR title	Required status	Materiality basis	Output section / owner	Evidence reference
ESRS 2	BP-1	General basis for preparation	Required	Cross-cutting	`output/esrs-2-general-disclosures.md#bp-1` / Group Controller	ENT-BOUNDARY-001
ESRS 2	GOV-5	Risk management and internal controls over sustainability reporting	Required	Cross-cutting	`output/esrs-2-general-disclosures.md#gov-5` / Sustainability Controller	CTRL-SR-2025-001
ESRS E1	E1-1	Transition plan for climate change mitigation	Required	E1 material per DMA	Sibling skill: `esrs-e1-climate-change`	[PENDING: E1 evidence pack]

Extension Tools

validate_esrs_2_general_disclosures validates an ESRS 2 Markdown, CSV, or text artefact. It supports three validation modes:

full_pack — checks BP-1/BP-2, GOV-1..5, SBM-1..3, IRO-1/IRO-2, due diligence, controls, source-file references, and evidence traceability.
governance_pack — checks GOV-1..5 coverage, governance-log evidence, controls, and evidence retention.
iro_2_index — checks the Disclosure Requirements index for standard, DR code, required/conditional/omitted status, materiality basis, output section/file, data owner, evidence reference, sibling skill owner, and Appendix B / other-EU-legislation datapoint consideration.

The tool returns a PASS / NEEDS WORK result with missing items and warnings. Warnings also flag apparent scope leakage, such as drafting detailed E1 transition-plan or S1 workforce disclosures that should stay with sibling topical ESRS skills.

Getting Started

Start from a csrd-esrs-program workspace after the DMA has populated the shared program/ assets. Upload or complete the entity profile, material topics, governance log, stakeholder file, IRO register, datapoint index, and evidence index. Ask for the full ESRS 2 pack, a governance-only draft, or the IRO-2 index. The skill will reconcile source files, draft the requested sections, mark missing facts with [PENDING: owner/source], update shared assets where durable facts belong, and run validation before finalising.