Preparing an ESRS Sustainability Statement requires organisations to coordinate a substantial number of disclosure requirements, datapoints, calculations, methodologies, supporting documents and narrative explanations. Information is often collected from different systems, departments, locations and data owners, making the reporting process time-consuming and difficult to manage consistently.

Embla Compliance brings the reporting framework, applicable disclosure requirements, underlying data, narrative disclosures, supporting evidence and completion monitoring into one structured environment.

It supports organisations in preparing their Sustainability Statement under the CSRD framework and in accordance with the applicable ESRS. By providing a controlled and repeatable workflow, the application reduces manual work, improves consistency and strengthens traceability from source information to the final reported disclosure.

The application helps organisations to:

• Reduce manual work and avoid duplication
• Organise the reporting process in accordance with ESRS
• Identify applicable and outstanding disclosure requirements
• Coordinate information from different systems and data owners
• Maintain consistency between narrative disclosures, metrics and supporting tables
• Monitor completion by standard, disclosure requirement and datapoint
• Retain source information, supporting evidence and reporting snapshots
• Strengthen internal control, traceability and assurance readiness
• Generate a structured Sustainability Statement and supporting Appendix

The application does not replace management judgement, determine materiality on behalf of the organisation or provide external assurance. The organisation remains responsible for defining its reporting boundary, completing and approving its double materiality assessment, selecting appropriate methodologies, validating reported information and approving the final Sustainability Statement.

Klappir provides the structure, workflow and controls required to complete these activities more efficiently and consistently.

The application supports the preparation of an organisation's annual Sustainability Statement. The Sustainability Statement explains:

• How the organisation's activities affect people and the environment
• How sustainability matters may affect the organisation's financial position, financial performance, cash flows, access to finance or cost of capital
• How the organisation identifies and manages its material sustainability-related impacts, risks and opportunities
• What policies, actions, targets and metrics are used to manage and monitor sustainability performance

The application is structured around the simplified European Sustainability Reporting Standards—ESRS (2026). It provides a controlled reporting framework for preparing the general disclosures and the environmental, social and governance information determined to be material through the organisation's double materiality assessment.

The applicable reporting requirements depend on the organisation's reporting year, reporting boundary, material sustainability matters and applicable transitional provisions. These matters should therefore be defined, documented and approved before the final Sustainability Statement is generated.

Klappir supports a structured process from the registration of source information to the approval of the final Sustainability Statement.

The source, reporting entity, reporting period, data type and responsible data owner are identified. This establishes responsibility for the information and records where it originated.

Source records, datasets and supporting documents are received, registered and connected to the relevant reporting process.

Information may originate from internal systems, external data providers, suppliers, operational records, invoices, calculations, surveys, policies or other supporting documentation.

Required fields, formats, dates, units, currencies, duplicates and logical inconsistencies are checked. Identified errors or missing information can be returned to the responsible data owner for correction or explanation.

Validation helps improve the accuracy, completeness and reliability of the information before it is used in calculations or disclosures.

Activities, transactions and expenditure are mapped to the applicable resource, procurement, emissions and ESRS classifications.

Consistent classification makes it possible to organise information across entities, locations, reporting periods and disclosure requirements.

Units, currencies, organisational identifiers and category names are converted into a consistent Klappir data structure.

Normalisation allows information received in different formats to be compared, calculated and consolidated consistently.

Approved emission factors, conversion factors, allocation methods and calculation methodologies are applied. The factors, assumptions and methodologies used are retained with the resulting information.

Primary, activity-based and supplier-specific information should be used where available and appropriate. Estimates, secondary data or spend-based methods may be used where more specific information is unavailable, subject to the organisation's approved methodology.

Results are assigned to the relevant reporting entity, location, activity, GHG Protocol Scope, Scope 3 category and ESRS disclosure.

Allocation rules should be applied consistently and documented where management judgement, assumptions or estimation methods are used.

Information is aggregated in accordance with the organisation's reporting boundary, organisational structure and consolidation rules.

The consolidation process ensures that information from subsidiaries, operations, locations and value-chain activities is treated consistently within the Sustainability Statement.

The organisation's approved double materiality assessment is used to identify material sustainability matters and determine the applicable topical standards, disclosure requirements and datapoints.

The organisation remains responsible for completing and approving the double materiality assessment and for determining whether sustainability information is material from an impact perspective, a financial perspective or both.

Reported information is mapped to the applicable ESRS disclosure requirements and reviewed for completeness, consistency and traceability.

The review identifies missing disclosures, incomplete datapoints, inconsistencies between narrative and quantitative information, and items requiring further evidence or management explanation.

Consolidated information, narrative disclosures, calculations and supporting evidence are compiled for the Sustainability Statement, internal review and external assurance.

The application supports assurance readiness by maintaining the connection between reported information and the underlying sources, methodologies, calculations, assumptions and evidence.

Responsible data owners, management and the relevant administrative, management and supervisory bodies review and approve the reported information and the final Sustainability Statement.

Final approval remains the responsibility of the organisation.

Throughout the workflow, source documents, calculations, methodologies, assumptions, estimates, changes, approvals and other supporting evidence are retained and linked to the relevant reported information. This creates a traceable record from the original source to the final Sustainability Statement.

The application supports the reporting process from initial configuration to final document production:

1. Configure the reporting year and reporting environment.
2. Review the standards and applicable datapoints in Master Data.
3. Confirm the reporting boundary and applicable ESRS version.
4. Apply the approved double materiality assessment.
5. Determine which topical standards, disclosures and datapoints are applicable.
6. Prepare the narrative disclosures and supporting tables in Workbook.
7. Monitor completion and resolve outstanding items in Gap analysis.
8. Save reporting snapshots in Archive.
9. Complete the internal review and approval process.
10. Generate the final Sustainability Statement and Appendix.

This provides a clear and repeatable process that can be used from one reporting year to the next.

Master Data contains the reference framework used throughout the reporting process.

It includes:

• The applicable ESRS standards
• Disclosure requirements
• Individual reporting datapoints
• Datapoint descriptions and references
• Reporting classifications
• Other supporting reference information

Master Data provides the foundation for the Compliance Report and helps ensure that reporting content is mapped consistently to the correct ESRS requirements.

Users should generally treat Master Data as controlled reference information. Changes should only be made by authorised users responsible for maintaining the reporting framework.

Before beginning the annual reporting process, the organisation should confirm that Master Data contains the correct version of ESRS for the relevant reporting year.

Workbook is the main reporting workspace. This is where the Sustainability Statement is prepared, reviewed and completed.

It contains two principal components:

• Compliance Report
• Appendix

The Compliance Report contains the main narrative disclosures and tracks the reporting status of each applicable requirement.

It allows the organisation to:

• Review the applicable disclosure requirements
• Prepare and revise disclosure text
• Record whether a disclosure is complete, incomplete or not applicable
• Identify information that still needs to be collected
• Document explanations for omitted or non-applicable information
• Maintain consistency across the different ESRS standards
• Confirm that all material disclosures have been addressed

Where a disclosure is considered not applicable, the underlying reason should be recorded where appropriate. A disclosure should only be marked as complete when the required information has been entered, reviewed and supported by appropriate underlying data or documentation.

The Compliance Report provides the principal content used to generate the portrait-format Sustainability Statement.

The Appendix contains the detailed supporting information associated with the main Sustainability Statement.

This may include:

• Metrics and quantitative datapoints
• Detailed tables
• Methodologies and calculation explanations
• Reporting boundaries
• Definitions and assumptions
• Estimates and estimation methods
• Reconciliations
• Supplementary information
• References to supporting evidence

Separating the principal disclosures from the detailed supporting tables makes the main Sustainability Statement easier to read while preserving the information required for transparency, traceability and assurance.

Information presented in the Appendix should be consistent with the corresponding narrative disclosures in the Compliance Report. Any changes to figures, methodologies or reporting boundaries should therefore be reflected in both components where applicable.

Gap analysis provides an overview of the current reporting status.

It shows completion by ESRS standard and provides an itemised list of disclosures that remain outstanding. This helps reporting managers identify gaps, prioritise work and follow up with the relevant data owners.

The Gap analysis section can be used to:

• Monitor overall completion
• Compare progress between ESRS standards
• Identify missing or incomplete disclosures
• Identify disclosures awaiting review or approval
• Prioritise outstanding work
• Support internal reporting meetings
• Confirm readiness for management review and external assurance

Gap analysis should be reviewed regularly throughout the reporting process. Before generating the final Sustainability Statement, users should review the outstanding-items list and resolve or formally explain all remaining gaps.

A completion indicator does not, by itself, confirm that a disclosure complies with ESRS. The organisation must still review the quality, accuracy, materiality and consistency of the reported information.

Files lists the documents loaded for this statement, by type and reporting year. Empty folders are not shown.

A snapshot records the reporting content at a specific point in time and can be reloaded when required. This supports version control and provides a record of how the Sustainability Statement developed during preparation, review and approval.

Snapshots should be saved at important stages, including:

• Completion of the initial draft
• Completion of data-owner review
• Completion of management review
• Submission for internal or external assurance
• Incorporation of review or assurance comments
• Final approval of the Sustainability Statement

Snapshots should be clearly named so that the reporting stage and date can be identified.

Archive reduces the risk of losing earlier versions and makes it possible to return to a previously saved reporting position. It also supports traceability by maintaining a record of the information available at important points in the reporting process.

Setup is where the work starts: choose the language and reporting year, then upload the documents and data for the statement. It sits at the bottom of the sidebar, just above Master Data. The reporting set-up is under Record / Upload Data; language and logo are under Localisation.

It includes:

• Reporting year — determines the financial year covered by the Sustainability Statement
• Standards — the reporting framework used: ESRS 2026, VS 2026 or ESG
• Display language — controls the language used within the application and generated documents
• Upload an existing statement — fills the app from a Sustainability Statement you already have, as a starting point

These settings should be reviewed before reporting work begins. Changes to the reporting year, standard or display language may affect the information presented within the application and in the generated documents.

The reporting year should be confirmed before disclosures are prepared, as the applicable standards, transitional provisions and comparative information may depend on the selected reporting period.

Once all applicable disclosures have been prepared, reviewed and approved, open Sustainability Statement in the sidebar.

The application compiles the completed reporting content into two documents:

• A portrait-format Sustainability Statement containing the main disclosures
• A landscape-format Appendix containing the detailed tables and supporting information

The documents are then ready to be downloaded, reviewed, printed, shared or incorporated into the organisation's management report.

Generation of the documents does not constitute final approval. The organisation should complete a final review before publication.

Before publication, the organisation should confirm that:

• The correct reporting year has been selected
• The correct version of ESRS has been applied
• The reporting boundary and consolidation approach have been defined and applied consistently
• The double materiality assessment has been completed and approved
• All applicable disclosure requirements and datapoints have been addressed
• Non-applicable or omitted disclosures have been appropriately explained
• Figures are consistent between the Sustainability Statement and the Appendix
• Comparative information is presented where required
• Methodologies, assumptions, uncertainties and estimates are appropriately explained
• Supporting evidence is available and linked to the reported information
• Material changes from previous reporting periods are explained
• The information has been reviewed by the responsible data owners
• Required management and governance approvals have been obtained
• The Sustainability Statement clearly identifies the reporting framework and version of ESRS applied

Following final review and approval, the Sustainability Statement and Appendix can be used as part of the organisation's external sustainability reporting and assurance process.

The result is a more efficient, consistent and controlled reporting process, providing traceability from the original source information and management judgements to the completed Sustainability Statement and supporting Appendix.