When a company compiles a sustainability report for the first time, it often starts with the discussion of “what chapters should be written?” and then assigns the topics to various departments, and only collects the information intensively before the deadline. This method may be able to complete a report, but it is prone to problems such as inconsistent caliber, untraceable numbers, and disconnection between narrative and actual management. A truly stable approach is to treat sustainability reporting as a cross-departmental management project: first confirm the purpose and applicable criteria of the report, then identify major impacts, establish data responsibilities, and finally move into writing and design.
Sustainability reports are more than just annual copywriting projects
The function of the report is to let investors, customers, employees, communities and other stakeholders understand how the company manages sustainability issues, what positive and negative impacts it has had, and what management actions it has taken. Taking the GRI Code as an example, material themes refer to the significant impact that an organization has or may have on the economy, environment and people (including human rights). This is not the same as “the results that the company most wants to publicize”, nor can it be determined by just the average score of a questionnaire.
For a credible report, there should be a system behind the text that can be operated repeatedly: the data is clearly defined, the responsible person is clear, the evidence is traceable, the supervisor has completed the approval, and the gaps and improvement directions can be explained. The release of the report is only the result of this process presented to the outside world.
Step 1: Confirm the purpose, scope and adoption criteria of the report
When starting a project, management should first identify why the report is being issued. Are you responding to regulatory, customer supply chain or capital market requirements, or are you hoping to use reports to drive internal management? Then decide which companies, locations and operations are covered in the report, whether the reporting period will be consistent with the financial year, and whether external assurance is required.
At the same time, take stock of applicable frameworks. GRI focuses on the impact of organizations on the economy, environment and people; IFRS S1 and S2 focus on sustainability-related financial information that may affect corporate prospects. Enterprises may refer to multiple sets of requirements at the same time, but it is not appropriate to mix all the questions in the same information sheet. A better approach would be to establish a common data base and then indicate the corresponding disclosure requirements for each indicator.
Step 2: Identify major themes from operational activities
To determine materiality, we can first understand the company’s activities, business relationships, and operational context, and then identify actual and potential, positive and negative impacts. Data sources may include regulatory records, complaint cases, environmental monitoring, occupational accident data, supplier audits, customer requirements, media information and industry standards. Stakeholder interviews and questionnaires are important inputs, but they are not the only basis.
Then, the severity of the impact is evaluated based on conditions such as the scale, scope, irremediableness, and likelihood of occurrence, and priorities are established. The entire process should leave the source of the topic, scoring basis, participants, meeting minutes and approval results. Only in this way can we explain why a certain issue is classified as important and a certain issue has not been included when we are convinced or asked by external parties.
Step 3: Convert the disclosure request into a data dictionary
After identifying major topics, do not immediately ask departments to “provide information” but first establish a data dictionary. Each indicator must at least describe the definition, unit, coverage, calculation formula, period, data source, submitter, reviewer and supporting documents. For example, “number of employees” should indicate the end-of-period or annual average, and whether contracts and dispatches are included; “energy usage” should indicate the location, energy type, conversion unit, and coefficient version.
A data dictionary can prevent the same nouns from being understood in different ways by different departments, and it can also help them be used in the next year. For estimated data, assumptions, estimation methods and limitations should be recorded. It is not appropriate to just leave the last number.
Step 4: Establish cross-department division of labor and schedule
The sustainability unit is suitable to serve as project coordinator and code interpreter, but data responsibility should still return to the business process. The human resources department manages employees and training data, the environmental, safety and health or factory management manages energy, water, emissions and occupational safety, procurement controls suppliers, finance is responsible for data linked to financial reports, and legal affairs and auditing help confirm compliance and control.
The schedule should not only set the final delivery date, but should be broken down into nodes such as indicator confirmation, first-time submission, correction of gaps, review by supervisor, text writing, design proofreading, and approval by the highest governance unit. If external confirmation is expected, time should be reserved for sampling, replacement and adjustment.
Step 5: Align numbers, policies and management actions
A common problem when writing articles is that the policy declaration is complete, but it is not clear who actually implements it; or the performance figures have declined, and the text only describes the results without explaining the reasons. Each major topic should at least answer: What is the company committed to, how to manage it, what actions to take, what metrics to track, what the results were, and what to improve next.
If the performance falls short of the target, there is no need to cover it up with vague words. Clearly communicating the influencing factors, corrective actions taken, and follow-up plans often builds credibility better than presenting only positive information. Before publishing, it is also necessary to cross-check the annual financial report, official website, questionnaire and other public information to avoid different versions of the same indicator.
What problems can be improved after introducing the co-editing process?
When communicating back and forth via email and spreadsheets, coordinators were often unable to immediately determine the latest version, and it was difficult to see who had not yet filled in the form. After the co-editing and review process is established, each indicator can be bound to the responsible person, deadline and evidence, and modifications and approvals can also be recorded. For those who fill out the form, the biggest help is that they can directly check the definitions and last year’s data, without having to guess again every year; for managers, it can detect gaps and anomalies early, without having to wait until the deadline to remedy them.
However, tools cannot replace materiality judgment and division of responsibilities. If indicators are poorly defined, the system will only accumulate inconsistent data faster. Therefore, the rules should be set first before deciding which processes are suitable for digitalization.
Common reasons for failure
- Treating the materiality questionnaire score as the only determination without assessing the actual impact.
- The sustainability department fills in the numbers on behalf of all units, and the data responsibility is not returned to the source department.
- Only the final version of the spreadsheet is saved, and the original evidence, estimation logic and approval records are not retained.
- The report content uses different statistical boundaries from the official website, annual report or customer questionnaire.
- Only data is collected during the reporting season, and there are no tracking indicators and improvement actions in normal times.
Which companies are suitable to start preparing now?
- It is the first time to compile a sustainability report, and I am not sure how to divide the work on the project.
- Spend a lot of time collecting and reconciling cross-department data every year.
- Facing GRI, IFRS sustainable disclosure or customer questionnaire requirements at the same time.
- Plan to accept third-party certification and need to improve evidence and version management.
- Already have reports published, but want to really get metrics into day-to-day decisions.
Frequently asked questions before compilation
Is it necessary to reveal all indicators at once when compiling for the first time?
Enterprises should first confirm the standards and applicable requirements they claim to adopt, and should not arbitrarily omit necessary information; however, this does not mean that all sustainability issues must be covered equally. Priority should be given to fully describing major topics, and for projects where information is temporarily lacking, limitations, estimates or improvement arrangements should be clearly disclosed. Rather than filling chapters with a lot of empty text, it is better to establish a few reliable indicators and then expand the depth of the data year by year.
After the report is released, when will preparation begin in the next year?
After release, this year’s deficiencies, adjustments and cross-department feedback should be sorted out, and the data dictionary and responsibility list should be updated. Major topics can be reviewed regularly based on operational changes, without having to wait for the next report to be restarted. Indicators that can be obtained monthly or quarterly can be included in routine management meetings, so that the annual report can directly use the data that has been confirmed on a daily basis.
This can also reduce the time required to re-confirm the caliber every other year.
How can a report project be scheduled?
If a company expects to release a report within six months of the end of the year, it can plan backwards. In the first stage, the reporting scope, standards, governance structure and external assurance requirements are confirmed; in the second stage, the determination of major themes and the list of indicators are completed; in the third stage, data filling, discrepancy explanation and supporting review are carried out; in the fourth stage, the text writing, supervisor confirmation, design and confirmation are entered. Finally, time should be reserved for overall proofreading, management unit approval, and online preparation.
Each stage can partially overlap, but the definition of major themes and materials should not be delayed until after the manuscript is written, otherwise the division of chapters will change repeatedly. If the company has multiple subsidiaries or overseas bases, it can arrange a trial filling before formally filling in the form to check whether the unit, period, conversion and authority are reasonable from a few indicators. Problems discovered during the trial filling should be written directly back into the data dictionary and should not be corrected privately by the coordinator.
What fields can be included in the data dictionary?
Taking energy usage as an example, in addition to “annual electricity consumption”, the data dictionary should also explain which sites are covered, whether leased offices are included, the data comes from bills or meters, statistics are based on calendar years or financial years, who fills out and reviews the report, and how the bills, meter photos or system export files are named. If you need to convert joules or greenhouse gas emissions, also save the coefficient name, version, source and formula.
For human resources data, it is necessary to first define regular employees, atypical workers, full-time and part-time workers, and confirm the difference in the number of employees at the end of the period, the average number of employees, or the number of employees. Occupational disasters, education and training, supplier and community investment also have their own calculation standards. Enterprises can create unique codes for each indicator so that the report text, GRI content index, assurance manuscripts and internal dashboards use the same source to avoid repeated maintenance of the same numbers.
How to prepare for third-party assurance?
If the report is expected to receive external assurance, the assurance criteria, scope, assurance level and key indicators should be confirmed at the early stage of the project so that the data owner knows what evidence needs to be provided in the future. Assurance officers often don’t just look at the final numbers. They also understand the process, spot-check raw records, recalculate formulas, and confirm that boundaries are consistent with the narrative in the report.
Enterprises can conduct an internal pre-check before the formal audit: select several important indicators from the report, and follow the numbers back to the system, bills, rosters or other original records; then have the non-original submitter recalculate and confirm the formula, unit and excluded items. If the data comes from multiple locations, check whether there are any missing parts, duplications or out-of-date data. This kind of pre-inspection can identify problems better than simply asking departments to sign.
Text content also needs to be managed with evidence
The policies, systems and achievement descriptions in the report also need to be based on. For example, if you claim that “all suppliers have completed the assessment”, you should be able to explain the supplier base, assessment period, completion definition and exceptions; if you claim “significant reduction”, you should provide comparison benchmarks and data. When there is no clear evidence, you can truthfully describe the current progress, and it is not appropriate to use absolute or overly general terms.
Photos, awards and activity records can increase readability but cannot replace management performance. Writers can mark the source and content person for each paragraph of text, and then remove internal annotations after proofreading. If the supervisor modifies the figures or external commitments, he should also go back to the original data or the approval process for confirmation to prevent the design draft from becoming another untraceable version.
After publishing, how to make the report actually used?
After release, stakeholder inquiries, convinced suggestions, internal gaps and unfinished projects can be sorted out to form an improvement list for the next year. Important goals do not need to wait for the next report to be reviewed, but can be included in quarterly meetings; for external commitments, responsible persons and due reminders should be set. If major events, organizational boundaries or calculation errors affect published information, it is also necessary to evaluate whether corrections and external clarification are needed.
Companies can also observe readers’ searches, downloads, and inquiry topics to understand which content attracts the most attention, but the value of a report cannot be judged solely by the number of views. More important indicators include data punctuality, the number of confidence adjustments, progress in improving major themes, and whether the report information is used in procurement, investment, risk or product decisions. When these efforts form a cycle, the report is no longer a one-time publication.
Self-checking that can be completed before compilation
- Have the reporting purpose, covered organizations, period, adoption criteria and approval level been confirmed?
- Do major themes come from impact identification and stakeholder opinions, rather than just looking at questionnaire rankings?
- Does each indicator have a definition, unit, boundary, submitter, reviewer and evidence?
- Are the same data in the annual financial report, official website, customer questionnaire and report consistent?
- For indicators that require external assurance, can the reported figures be traced back to the original records?
- Have transparent reasons and improvement arrangements been prepared for projects that have not achieved their goals or have insufficient data?
If you still cannot answer many of them, you can do a small-scale trial filling and pre-checking before entering into full writing. This often leads to early detection of boundary and responsibility issues and avoids significant revisions of numbers and text only after the design is complete.
Conclusion
The quality of a sustainability report does not only depend on whether the text is smooth, but also on whether the company can clearly explain major impacts, management methods and performance evidence. Establish the scope, significance, data dictionary and review process first, so that subsequent writing will be smooth, and the annual compilation work can gradually transform from a temporary project to a stable system.
##Official reference material
Data access date: July 20, 2026.