esg-disclosure-draft

ESG Disclosure Draft Skill

Disclosure text fails in two ways: it overclaims (greenwash, assurance findings) or it hides gaps (omission, restatement risk). This skill drafts a section that survives both an assurer and a skeptical reader — every metric travels with its methodology and limitation, and missing data is disclosed, not disappeared. It drafts; it does not give legal or compliance advice.

What This Skill Produces

• A disclosure section draft with double-materiality framing (impact + financial)
• A metric table where every figure carries methodology and known limitations
• Forward-looking statements each anchored to a stated basis
• An explicit "data not yet available" treatment with a collection plan
• A pre-submission review checklist for the compliance team

Required Inputs

Ask for these if not provided; from a thin brief, draft with labelled assumptions and mark every invented placeholder value as [to confirm] rather than refusing:

• Topic and framework — which sustainability matter (e.g. climate, workforce, circularity) and target framework (ESRS by default; adapt on request)
• Materiality result — why this topic is material: impact materiality, financial materiality, or both, and for whom
• Metrics and data — the figures, their units, reporting period, and how each was produced
• Targets and transition plans — existing commitments, baselines, and progress
• Known gaps — what the organization cannot yet measure or report
• Audience and length — annual report section, standalone report, or regulator response

Drafting Framework

1. Double-materiality framing. Open the section by stating why this matters on both axes: the organization's impact on people/environment (impact materiality) and the topic's effect on the organization's finances (financial materiality). If only one axis is material, say which and why the other was assessed as not material.

2. Metric–methodology–limitation triplets. Never publish a bare number. Each metric gets three parts:

Part	Rule
Metric	Figure, unit, period, boundary
Methodology	How it was produced: measured, calculated (which factors/model), estimated, or proxy — and any change vs prior year
Limitation	What the number does not cover, its uncertainty, and known weaknesses

3. Forward statements with basis. Every target or projection names its basis: baseline year, scenario or assumption set, dependencies (e.g. grid decarbonization, supplier action), and whether it is a commitment or an ambition. No basis available → downgrade the language to intent and say the basis is being developed.

4. Honest gap handling. For each required datapoint that is missing: state that it is not yet reported, why, what interim proxy (if any) is used and its weakness, and when it will be reported. A disclosed gap is defensible; an omitted one is a finding.

5. Plain-language discipline. Prefer "reduced scope 1 emissions 8% against a 2023 baseline" over "continued our climate leadership journey". Strip adjectives that a metric doesn't support.

Output Format

Disclosure draft: [topic] — [framework]

1. Materiality statement — impact and financial materiality conclusions, assessment method in one sentence, stakeholders affected.

2. Policies, actions, and resources — what the organization does about this topic, stated as verifiable facts (dates, coverage, owners), not aspirations.

3. Metrics — the triplet table (metric / methodology / limitation), plus prior-year comparatives and restatement notes where methodology changed.

4. Targets and forward statements — each with baseline, timeframe, basis, and dependencies. Distinguish commitments from ambitions.

5. Data gaps and roadmap — what is not reported yet, why, interim proxies, and the collection timeline.

6. Compliance review checklist — the specific datapoints and claims the compliance team must verify before publication.

Include this line in the artifact: "This is a working draft. Verify required datapoints, phase-in reliefs, and wording against the applicable standard and regulation (e.g. ESRS, local transposition) with your compliance team and legal counsel before publication."

Quality Checks

• Both materiality axes are addressed — asserted, or explicitly assessed as not material
• Every metric has all three triplet parts; none appears as a bare number
• Every forward statement names its basis and dependencies
• Every known gap is disclosed with a reason and a timeline, not omitted
• Methodology changes vs prior year are flagged with restatement notes
• No claim in the prose exceeds what the metric table supports
• Placeholder values from a thin brief are marked [to confirm]

Anti-Patterns

• Do not omit a required datapoint silently — disclose the gap and the plan to close it
• Do not write aspiration as fact — "we aim to" and "we have" are different disclosures
• Do not publish a target without baseline year, scope, and basis
• Do not bury a methodology change that flatters the trend — flag it and restate or explain
• Do not use unanchored superlatives ("industry-leading", "best-in-class") in disclosure text
• Do not present this draft as compliance-cleared — the applicable standard and legal review govern

Based On

CSRD/ESRS disclosure architecture (double materiality, policies–actions–metrics–targets structure, phase-in and gap disclosure practice), adaptable to ISSB/GRI-style reports.