DATA FLOWS → DISCLOSURE DATA
Disclosure Data
The structured evidence that flows into corporate sustainability reports,
regulatory filings, and stakeholder communications.
In 30 Seconds
Disclosure data is the structured information that companies report to regulators, investors, and stakeholders about their sustainability performance. It's the output layer where ground-level measurement becomes formal corporate communication.
Quantitative
Emissions (Scope 1, 2, 3), water use, waste, energy consumption, biodiversity metrics.
Qualitative
Policies, governance structures, risk management processes, transition plans.
Normalised
Intensity metrics – per revenue, per employee, per product – enabling comparison.
Why it matters now: Disclosure is shifting from voluntary to mandatory. CSRD affects 50,000+ EU companies. ISSB standards are being adopted globally. CDP requests now include TNFD-aligned biodiversity questions. The era of pick-your-own-framework is ending.
Where This Fits
Disclosure data operates at Layer 4 (Governance) in our Data Flows vertical – where evidence meets regulatory requirements:
Data Flows context: Disclosure data aggregates information from MRV (ground-level measurement) and Traceability (supply chain evidence) into regulatory-compliant formats. It's the translation layer between operational data and external reporting.
The Disclosure Framework Landscape
Multiple frameworks have emerged to standardise sustainability disclosure. They're converging, but understanding their origins and focus areas remains essential.
CSRD / ESRS
EU MANDATORYCorporate Sustainability Reporting Directive / European Sustainability Reporting Standards
The EU's comprehensive sustainability disclosure regime. Requires double materiality assessment, covering both financial materiality (risks to the company) and impact materiality (company impacts on environment/society).
- • 12 ESRS standards covering E, S, and G topics
- • ~50,000 companies in scope (post-Omnibus: ~10,000 largest)
- • Third-party assurance mandatory from first year
- • XBRL digital tagging required
2025-2026 Updates (Omnibus I)
- • Scope narrowed: >1,000 employees + €450M turnover
- • Data points reduced by ~61%
- • Wave 2/3 companies delayed by 2 years
- • Simplified ESRS Set 2 expected mid-2026
- • Value chain reporting capped at Tier 1
ISSB / IFRS S1-S2
GLOBAL BASELINEInternational Sustainability Standards Board
The global baseline for investor-focused sustainability disclosure. IFRS S1 (general requirements) and S2 (climate) provide a foundation that jurisdictions can build upon. Uses single materiality (financial materiality only).
- • 30+ jurisdictions adopting or implementing
- • Built on TCFD framework (now consolidated)
- • Industry-specific guidance via SASB standards
- • Interoperable with GRI for double materiality
Adoption Status (Jan 2026)
- • UK: UK SRS S1/S2 finalised, voluntary 2026
- • Singapore: Mandatory for large listed 2025
- • Australia: First reports 2026
- • Japan: SSBJ standards FY2027 for Prime Market
- • Malaysia, Qatar, Rwanda: Adopted
CDP
INVESTOR-DRIVENCarbon Disclosure Project (Climate, Water, Forests)
The dominant voluntary disclosure platform, backed by 740+ investors with $142T+ AUM. Annual questionnaires on climate, water security, and forests/deforestation. Scores from D- to A provide benchmarking.
- • 24,000+ companies disclosing
- • TNFD-aligned biodiversity section since 2024
- • Integrated ISSB and TCFD requirements
- • Supply chain module for value chain disclosure
2026 Timeline
- • April: Question bank released
- • June: Response window opens
- • September: Scoring deadline
- • November: A-List published
TNFD
NATURE-FOCUSEDTaskforce on Nature-related Financial Disclosures
The nature equivalent of TCFD. Provides a framework for organisations to report on nature-related dependencies, impacts, risks, and opportunities. LEAP approach for assessment.
- • 14 recommended disclosures across 4 pillars
- • LEAP: Locate, Evaluate, Assess, Prepare
- • Sector-specific guidance available
- • Aligned with GRI 101: Biodiversity 2024
Integration Points
- • CDP biodiversity questions now TNFD-aligned
- • ESRS E4 (Biodiversity) references TNFD
- • ISSB developing nature standard
- • 500+ early adopters committed
GRI
IMPACT-FOCUSEDGlobal Reporting Initiative
The original sustainability reporting framework (since 1997). Focuses on impact materiality – an organisation's impacts on the economy, environment, and people. Used by 10,000+ organisations globally.
- • Universal, Topic, and Sector Standards
- • GRI 101: Biodiversity 2024 effective Jan 2026
- • 40 sector standards in development
- • Interoperable with ISSB for full double materiality
GRI + ISSB = Double Materiality
GRI (impact) + ISSB (financial) together satisfy double materiality requirements. EFRAG guidance supports using both frameworks for ESRS compliance.
Double Materiality
The central concept driving European sustainability disclosure. A topic is material if it meets either threshold – financial or impact.
Financial Materiality
"Outside-in" – How sustainability affects the company
Sustainability matters that create risks or opportunities affecting the company's development, financial position, or performance. This is what investors traditionally care about.
Examples
- • Physical climate risk to assets
- • Transition costs from regulations
- • Stranded asset exposure
- • Supply chain disruption risk
- • Reputational risk from controversies
Impact Materiality
"Inside-out" – How the company affects sustainability
The company's actual or potential impacts on people and the environment, regardless of whether they create financial risk. This is what civil society and stakeholders care about.
Examples
- • GHG emissions (Scope 1, 2, 3)
- • Biodiversity loss from operations
- • Water pollution or depletion
- • Labour rights in supply chain
- • Community displacement
The Assessment Process
1. Identify
Map sustainability matters against business model, value chain, and stakeholder concerns.
2. Assess
Evaluate severity (scale, scope, irremediability) for impacts; likelihood and magnitude for risks.
3. Determine
Apply thresholds. Material = report. Document reasoning for both included and excluded topics.
Assurance Requirements
Third-party assurance is becoming mandatory. Understanding the levels and timelines is critical for planning.
Limited Assurance
"Nothing has come to our attention..."
Negative form of conclusion. Procedures primarily involve inquiry and analytical procedures. Less rigorous than reasonable assurance but provides some confidence.
- • Review of processes and controls
- • Analytical procedures on data
- • Inquiry of management
- • Limited testing of underlying evidence
Reasonable Assurance
"In our opinion, the information is fairly stated..."
Positive form of conclusion. Same level as financial statement audits. Requires extensive testing of underlying data and controls.
- • Detailed testing of data and calculations
- • Site visits and physical verification
- • Third-party confirmations
- • Internal control assessment
CSRD Assurance Timeline
| Wave | Companies | First Report | Assurance Level |
|---|---|---|---|
| Wave 1 | Large PIEs (>500 employees) | 2025 (FY2024) | Limited → Reasonable by 2028 |
| Wave 2 | Large companies | 2027 (FY2026)* | Limited initially |
| Wave 3 | Listed SMEs | 2028 (FY2027)* | Limited initially |
* Omnibus I (Dec 2025) delayed Wave 2 and 3 by 2 years. Dates shown are post-delay.
Technology & Platforms
The disclosure data challenge has spawned a growing ecosystem of ESG data management platforms, disclosure automation tools, and reporting software. The market is projected to reach $7.4B by 2035.
Data Collection
Gathering data from across the organisation and value chain. Often the hardest part.
- • Automated utility data capture
- • ERP integration
- • Supplier data collection portals
- • IoT and sensor integration
Data Management
Storing, validating, calculating, and preparing data for disclosure.
- • Emission factor libraries
- • Calculation engines (GHG Protocol)
- • Audit trails and versioning
- • Data quality checks
Reporting
Generating disclosures in required formats for each framework.
- • Multi-framework mapping
- • XBRL tagging for ESRS
- • CDP response automation
- • Board report generation
Platform Categories
Enterprise Platforms
Full-suite solutions for large organisations. Often integrated with financial reporting systems.
Examples: Workiva, Wolters Kluwer CCH Tagetik, SAP Sustainability Control Tower
Carbon Specialists
Focused on GHG accounting, particularly Scope 3 emissions calculations.
Examples: Persefoni, Watershed, Sweep, Plan A
Disclosure Automation
Framework-specific tools for preparing and submitting disclosures.
Examples: Position Green, Coolset, Novisto
Data Aggregators
Collect and normalise ESG data for investors and analysts.
Examples: MSCI, Sustainalytics, CDP, Bloomberg
Convergence Dynamics (2025-2026)
The disclosure landscape is consolidating. After years of framework proliferation, we're seeing meaningful alignment – though regional differences remain.
ISSB as Global Baseline
ISSB standards (S1, S2) serve as the investor-focused foundation. Jurisdictions build on top with additional requirements. 30+ jurisdictions adopting, representing ~60% of global GDP.
ESRS Simplification
Omnibus I reduces ESRS complexity (~61% fewer data points), improves ISSB alignment, and narrows scope. The EU is stepping back from being the most demanding regime to something more proportionate.
CDP Integration
CDP questionnaires now incorporate ISSB, TCFD, and TNFD requirements. Responding to CDP can satisfy multiple framework requirements simultaneously.
GRI + ISSB Interoperability
GRI (impact materiality) combined with ISSB (financial materiality) provides complete double materiality coverage. Official guidance supports using both together.
The Strategic Implication
Build your data infrastructure around ISSB/IFRS S1-S2 as the foundation. Layer on GRI for impact materiality where required (EU, stakeholder pressure). Use CDP as the primary voluntary channel. This architecture satisfies most global requirements with minimal duplication.
Who Operates in Disclosure Data
Reporters
Preparing disclosures
Corporates, sustainability teams, finance functions
How do we build data systems that serve multiple frameworks efficiently?
Standard Setters
Defining requirements
ISSB, EFRAG, GRI, TNFD
How do we drive convergence while respecting jurisdictional needs?
Assurance Providers
Validating claims
Big 4, specialist verifiers, accounting bodies
How do we scale assurance capacity for mandatory requirements?
Data Platforms
Enabling infrastructure
ESG software vendors, registries, aggregators
How do we make disclosure easier without compromising quality?
The Pandion View
Disclosure is the bridge between doing sustainability work and communicating it credibly. But too often, organisations treat disclosure as a compliance exercise disconnected from strategy.
The organisations that excel are those that build their disclosure infrastructure as a strategic asset – using the data collection process to understand their business better, identify improvement opportunities, and engage stakeholders meaningfully.
As a hybrid professional, we help clients navigate the disclosure landscape strategically. We understand both the technical requirements (ESRS data points, ISSB metrics, CDP scoring criteria) and the strategic context (what matters to your specific stakeholders, where your risks actually lie).
The goal isn't perfect disclosure – it's disclosure that serves your business while meeting legitimate stakeholder expectations. That requires understanding both sides of the equation.