How should we handle data gaps in SASB reporting?

• A. Acknowledge gaps, explain remediation plans, and consider substituting with proxy metrics or qualitative disclosures where appropriate.
• B. Ignore gaps.
• C. Wait until next period to disclose.
• D. Fill gaps with estimates without disclosure.

Answer: (A)

When data gaps appear in SASB reporting, the focus should be on transparency and how you plan to improve. The best approach is to acknowledge the gaps, explain what you will do to fix them, and, where appropriate, supplement the disclosure with proxy metrics or qualitative information. This shows readers the scope of missing data, the potential impact on decision-making, and the steps the organization is taking to close the gaps over time.

Acknowledging gaps communicates honesty about what isn’t yet measured or reported, which helps users assess risk and materiality without guessing. Explaining remediation plans provides a clear timeline, accountability, and governance around data collection and quality improvements. Using proxy metrics or qualitative disclosures, when appropriate, keeps the narrative informative and decision-useful while precise data are being developed, as long as these proxies are clearly labeled, justified, and limitations are disclosed. The aim is to maintain useful, comparable information rather than leaving readers in the dark or presenting uncertain numbers as exact.

Ignore gaps, wait until the next period, or fill gaps with undisclosed estimates would reduce transparency and reliability. Those approaches can mislead readers about the actual state of performance and governance around data quality.