How to prepare a sustainability report in Colombia, step by step

Colombia has no single law setting out how a sustainability report is produced, so the first step is not writing: it is deciding what you are answering to. Usually there are four destinations at once, on different calendars: the regulatory environmental filing to the Single Environmental Registry, the financial disclosure if you are a securities issuer, the voluntary report you publish for the market, and the questionnaires from customers, banks and investors.

The good news is that all four draw on the same dataset. Build that dataset once and properly, and each destination is just a different format of the same thing. This guide runs in the order that works.

Step 1. Work out which frameworks apply to you

Before touching a single data point, write a table of what binds you, to whom and when. This is the general picture for Colombia as of August 2026.

Two clarifications that save wasted effort. IFRS S1 and S2 are not mandatory in Colombia: they sit in an initially voluntary convergence process. And the mandatory emissions report created by Law 2169 of 2021 is not yet enforceable, although its implementing rules are in progress. If somebody sells you an urgent project on either of those, ask for the rule.

Step 2. Fix the boundary and the period first

The boundary is the decision that is hardest to undo. Settle three things and write them down:

• Which entities are in. Group companies, associates, leased operations. Pick a consolidation approach, operational control or equity share, and apply it the same way every year.
• Which sites are in. Colombia imposes a useful constraint here: the RUA is filed per establishment, so if your environmental accounting is not broken down by site, you will have to break it down anyway.
• Which period is covered. The RUA covers the full calendar year. If your financial year does not match the calendar year, you need the data on both grids or you will end up recalculating.

Step 3. Gather the data, in blocks

This is the part that eats 80% of the time. Organise it by where the data comes from, not by report chapter, because a different person holds each one.

Energy and fuels

• Electricity invoices by site, in kWh and by period.
• Fuel purchases by type (diesel, gasoline, LPG, natural gas, coal, fuel oil), in physical units and with the invoice.
• Own fleet consumption and mileage.
• Self-generation and renewable supply contracts, if any.

Water and discharges

• Abstraction by source and the associated concession.
• Discharge volumes and the characterisations required by the permit.

Waste

• Hazardous waste generated, by stream and licensed handler, with certificates.
• Non-hazardous waste and recovery rates.
• Packaging placed on the market, if you are a producer.

Emissions and processes

• Air emissions from stationary sources and the measurements the permit requires.
• Refrigerant top-ups, which are almost always forgotten and are scope 1.
• Raw materials and output, so you can calculate intensities.

Value chain

• Purchases by supplier and spend category.
• Contracted freight transport.
• Business travel and employee commuting.

A practical rule: every data point has to be traceable to a source document, and that document has to be stored. It is the first thing a verifier asks for and the first thing that is missing.

Step 4. Calculate the greenhouse gas inventory

With activity data collected, calculate scopes 1 and 2 as a minimum, and scope 3 in the categories where you have reasonable data. The reference standards are the GHG Protocol and ISO 14064; if you are unsure which to use, see our comparison of GHG Protocol and ISO 14064-1.

Three decisions must be documented: the base year and its recalculation policy, the emission factors used with their source and version, and the scope 2 method (location-based or market-based). If those three are not written down, the number is not auditable however good it looks.

This same inventory is what lets you assess the non-accrual mechanism of the national carbon tax, which can waive up to 50% of the tax if you certify carbon neutrality. The calculation has to run on actual fuel consumption, not estimates.

Step 5. Materiality and narrative content

Disclosure under External Circular 031 of 2021 is built on financial materiality: which environmental, social and climate matters can affect the value of the company. If you also report for European customers, they will ask for the double materiality view, which adds the company's impact on the environment. Our guide to double materiality analysis covers the method.

Whichever approach you take, the structure that travels best between frameworks is the ISSB's four pillars: governance, strategy, risk management, and metrics and targets. Writing that way covers Circular 031, fits IFRS S if convergence lands, and answers most questionnaires without a rewrite.

Step 6. Verify

If you are putting emissions figures through verification, keep article 34 of Law 2169 of 2021 in mind: emissions and GHG reductions or removals are validated and verified through first-party declarations or accredited third-party conformity declarations, and ONAC is the body that accredits validation and verification bodies in Colombia. Check the scope of your verifier's accreditation before you engage them, not after.

Verification is not prepared at the end. What decides whether it goes well is whether, during the year, you kept the invoices, the handler certificates and the audit trail behind every conversion.

Step 7. Publish and file, in calendar order

A typical year in Colombia runs like this:

1. January: close the previous year's data and reconcile it with the accounts.
2. February to April: file the RUA in whichever window your tax ID falls into.
3. First half: Circular 031 disclosure in the year-end report, if you are an issuer.
4. All year: two-monthly carbon tax filings and, where relevant, managing the non-accrual mechanism before the tax accrues.
5. As they come: voluntary report, customer and bank questionnaires, and the packaging management plan with ANLA.

Where people get stuck

1. The boundary does not match across frameworks

The RUA works per establishment, financial disclosure works at consolidated group level, and the European customer asks per plant and per product. If you do not define the boundary at the finest level of detail from the start, you end up recalculating three times.

2. Energy data arrives late and undifferentiated

Invoices covering several sites, periods that do not match the month, consumption estimated by the retailer. This is the most common bottleneck and it is solved by collecting monthly, not annually.

3. Scope 3 is attempted all at once

Start with the material categories using a spend-based method, and replace with primary supplier data where the weight justifies it. Our guide to the 15 scope 3 categories helps with prioritisation.

4. The non-accrual file does not add up

The typical mistake is not buying the wrong credits, it is being unable to demonstrate the match between certified tonnes, invoiced fuel and the period. On top of that, a certificate already used cannot be reused for another tax benefit, so you need a record of what was applied to what.

5. The report is written before the numbers exist

It is tempting, because narrative drafts quickly. But when the data lands it forces the strategy and targets to be rewritten. Numbers first.

6. Nobody owns the data

Energy sits with maintenance, waste with HSE, purchasing with finance and fleet with logistics. Without a named owner per block and a deadline, the close depends on one person's persistence.

Frequently asked questions

Is publishing a sustainability report mandatory in Colombia?

Not as a general rule. What is mandatory is disclosure of social, environmental and climate matters by securities issuers under External Circular 031 of 2021 of the Financial Superintendence, alongside regulatory environmental filings such as the RUA.

Which standard should you use?

For the emissions inventory, the GHG Protocol or ISO 14064-1. For the structure of the report, the ISSB's four pillars, which fit Circular 031 and what customers and investors ask for.

How long does a first report take?

Almost entirely depends on the quality of the starting data. With centralised invoices and consumption broken down by site it is a matter of weeks. Without that, data collection takes up most of the project.

Does the report have to be verified?

Not always, but yes when the figure is used for the carbon tax non-accrual mechanism or when a customer or lender requires it. In Colombia, GHG verification bodies are accredited by ONAC.

If you want the full map of obligations before deciding the scope of your report, start with our guide to environmental and sustainability regulation in Colombia. And to keep the numbers ordered and traceable all year, see Manglai's carbon footprint solution.