To prepare a sustainability report in Argentina, the order that works is this: decide why you are reporting, choose the framework, set the boundary and the period, run materiality, gather the data, calculate emissions, write it up and decide whether to have it assured. Choosing the framework before collecting data is what stops you doing the work twice, and it is exactly the step most people skip.
The legal starting point matters: Argentina has no general law requiring a company to publish a sustainability report. The only comparable requirement reaches issuers under the public offering regime, who must disclose in the annual report their environmental or sustainability policy and their main performance indicators, or explain why they are not relevant, under General Resolution 1115/2026 of the Comisión Nacional de Valores. Everything else is driven by customers, parent companies, banks and export markets.
Step 0: define who the report is for
It sounds obvious, and it is where most time gets lost. The document answering a European customer subject to the CSRD is not the same as the one accompanying a debt issuance or the one your parent company needs to consolidate. Write the primary audience in a single line before going further. That line decides the framework, the level of detail and the calendar.
Step 1: choose the framework
FACPCE Technical Resolution 60, on standards applicable to the preparation of sustainability information, replaces Technical Resolution 36 on the Social Balance Sheet and recognises two acceptable frameworks: the GRI Standards and the IFRS Sustainability Disclosure Standards, that is IFRS S1 and IFRS S2 from the ISSB. It leaves out the European ESRS on the grounds that they are tailored to the EU regulatory context. And it obliges nobody to report: it says how, not who.
| GRI | IFRS S1 and S2 | VSME | |
|---|---|---|---|
| Looks at | The company's impacts on its surroundings | Risks and opportunities affecting company value | A reduced set of basic metrics |
| Typical audience | Broad stakeholder base | Investors and lenders | A large customer asking you for data |
| When it fits | First full public report | Listed issuer, subsidiary of a listed group, access to capital | Supplier to a company subject to the CSRD |
If you supply a European group, the voluntary standard based on the VSME, adopted on 3 July 2026, acts as a cap on what your customer can demand of you as part of its value chain. That is a useful argument when a disproportionate questionnaire lands in your inbox.
A practical note: FACPCE technical resolutions are adopted by each provincial professional council, so confirm the effective date that applies to you with the council in your jurisdiction.
Step 2: set the boundary and the period
Before requesting a single data point, decide and write down:
- Which entities are in. Companies, plants, sales offices, joint ventures. In Argentina it is common to run several operating companies behind one brand.
- Which consolidation approach. Operational control or financial control. Pick one and stick to it.
- Which period it covers. Aligning it with the financial year is the natural choice so the report matches the annual report and the financial statements.
- Base year. The first full year with reliable data. Document the recalculation rule for when you buy or sell a site.
Step 3: run materiality
GRI works with impacts and the IFRS Sustainability Disclosure Standards with financial risks and opportunities. They are not contradictory: they can be run as a single exercise that identifies topics from both angles and then prioritises them.
For an Argentine company, the topics that almost always come out material are energy and emissions, water in water-stressed regions such as Cuyo, waste and effluents, the agricultural supply chain where there are EU exports, and labour relations, given the weight of collective bargaining. Talk to procurement, operations, legal and employee relations, not just communications.
Step 4: gather the data
This is the long phase. The rule that separates a report that survives review from one that does not: every figure has to be traceable back to its source document.
| Data | Source document | Who holds it |
|---|---|---|
| Electricity by site | Utility invoices | Finance |
| Natural gas and fuels | Invoices and delivery notes | Procurement and maintenance |
| Fleet | Litres fuelled and kilometres driven | Logistics |
| Water | Invoices and borehole readings | Site |
| Hazardous waste | Manifests and operator certificate | Environment and safety |
| Non-hazardous waste | Hauler or recycler delivery notes | Site |
| Refrigerants | Recharge orders and equipment records | Maintenance |
| Headcount, turnover, training | HR system | Human resources |
| Accident rates | Health and safety records | Safety |
Use what you already have. If you employ more than 300 workers, article 25 of Law 25,877 already requires you to prepare an annual social balance sheet covering headcount, turnover, pay evolution, training, outsourcing and accidents, handed to the union with legal representation status within 30 days. That covers a good part of the social block of GRI. Watch the name: that social balance sheet is a labour document and does not replace the sustainability report.
Step 5: calculate emissions
Emissions are calculated under the GHG Protocol or ISO 14064-1, organising the result by scopes 1, 2 and 3. If you are undecided between frameworks, see the comparison of GHG Protocol and ISO 14064-1.
- Scope 1: combustion in boilers, furnaces and the owned fleet, plus refrigerant leaks.
- Scope 2: purchased electricity. Here the Argentine grid emission factor carries the weight. Document which factor you used, from which source and for which year, and keep the criterion consistent between reporting years.
- Scope 3: the 15 GHG Protocol categories. Start with purchased goods and services, transport and distribution, and waste. Do not attempt all fifteen in year one.
Do not mix the result with the National Greenhouse Gas Inventory: that one is territorial and organised by IPCC sectors, yours is corporate and organised by scopes. All they share are emission factors.
Step 6: cross-check against your local obligations
Before closing, reconcile the report with what you already declare elsewhere, because an inconsistency between documents is the first thing a reviewer spots:
- The annual report and financial statements, and the sustainability block required by the CNV if you are a listed issuer.
- The social balance sheet under Law 25,877.
- Environmental certificates and declarations: hazardous waste Environmental Certificate, provincial Environmental Fitness Certificate, effluent declarations.
- The environmental insurance policy and the environmental complexity category behind it.
If you need the full regulatory map, it is in our guide to environmental and sustainability regulation for companies in Argentina.
Step 7: decide on assurance
It is not mandatory in Argentina for a voluntary report, but it changes how much weight the document carries with a bank or a customer. If you are going to do it, engage early and be clear that the reviewer will ask for full traceability on a sample of figures. Assurance is planned before you collect data, not after you have written the text.
Where people get stuck in Argentina
- The grid emission factor. Different teams use different factors from different years, and the series stops being comparable. Fix one, document it and apply the same criterion to every year you publish.
- Intensity metrics in pesos. In the Argentine economy, dividing emissions by revenue in current currency produces meaningless series. Use physical units (per tonne produced, per unit, per square metre) or constant currency, and explain the criterion.
- Dispersion across provinces. Each site has its own file, nomenclature and format. Without one common data template, consolidation becomes an archaeology exercise every year.
- Confusing the social balance sheet with the sustainability report. They are different documents, with different audiences and different content.
- Scope 3 with suppliers who do not measure. Start with spend data and average factors, then replace with primary data in the big categories. This is where knowing how to get past the supplier data barrier helps.
- Starting with the design. The polished PDF comes last. Start there and you end up writing around the data you happen to have instead of gathering the data you need.
A typical calendar
| When | What you do |
|---|---|
| 4 months before year end | Framework, boundary, materiality and data template |
| Year end | Data collection and validation by site |
| 1 to 2 months later | Emissions calculation and indicator consolidation |
| 2 to 3 months later | Drafting, reconciliation with the annual report and social balance sheet |
| Before publishing | Internal review and, where applicable, external assurance |
Frequently asked questions
Is sustainability reporting mandatory in Argentina?
Not as a general rule. Issuers under the public offering regime must disclose their environmental or sustainability policy and their main performance indicators in the annual report, or explain why they are not relevant, under CNV General Resolution 1115/2026. For everyone else, the requirement is contractual or market-driven.
GRI or IFRS S1 and S2: which framework fits?
It depends on the audience. GRI if the report is public and aimed at a broad stakeholder base, the IFRS Sustainability Disclosure Standards if investors and lenders are what matter. FACPCE Technical Resolution 60 recognises both.
Can I use the social balance sheet under Law 25,877 as a sustainability report?
No. It is a labour document with prescribed content, delivered to the union with legal representation status. It is, however, an excellent source for the social block of your report.
How long does a first report take?
Between six and nine months of real work in a multi-site company starting from scratch, and most of that goes into gathering and validating data, not writing.
Do emissions need to be verified?
It is not mandatory in Argentina, but third party verification is what turns your figure into something a bank, a large customer or an investor can actually use.
If what slows you down is gathering consumption, waste and emissions across several sites with the source document attached to every figure, that is exactly the problem Manglai's carbon footprint solution solves.
