The Impact Reporting Norms: Follow the new standard with leonardo

Your latest impact report took weeks to assemble. Your team harmonised data from a dozen portfolio companies, debated which metrics to include, and made countless judgement calls about structure and scope. You shared it with your LPs. And then the questions started:

“How do we know these numbers reflect what stakeholders actually experience?”
"Are unintended and negative impacts reflected in your reporting?"

Sound familiar? You are not alone. Impact reporting in private markets has operated without a shared playbook for years. Every GP builds their own format, selects their own metrics, and makes their own decisions about what to include and what to leave out. For GPs, this means significant time spent on reporting structure and format rather than on the substance of impact performance. For LPs, it makes it harder to navigate and engage meaningfully with the reports they receive.

That is starting to change.

The Impact Performance Reporting Norms, published by Impact Frontiers in April 2024, establish shared expectations for the content and structure of impact reports in private markets. They do not prescribe specific metrics or create a universal template. Different strategies will still require different indicators. But they do create a common reference point for what a well-constructed impact report should address, and how. They are the result of an 18-month public consultation involving more than 350 asset managers, asset owners, consultants, and assurance providers.

Recognizing the operational shift this requires from fund managers, leonardo has become a Founding Adopter of the Impact Reporting Norms. We are committing to integrate the norms into our Impact Management Platform (IMP) and the consulting services our clients rely on to measure, verify, and report their impact.

Have a look at how we implemented the Norms within our partnership with Development Partners International (DPI) to enhance their IMM.

And now: Let’s dive into what this means for you.

What exactly are the reporting norms?

The reporting norms do not prescribe specific metrics, templates, or scoring models. Instead, they define the content that belongs in an impact performance report and the guiding principles for how to present it:

The framework is structured around two complementary parts:

Part 1: Content
Six sections that an impact report should cover: 

1. Entity Overview and Impact Thesis
2. Impact Management Approach
3. Impact Performance
4. Governance
5. Case Studies
6. Independent Review (optional)
   

Each section details the specific content that report preparers should include, or explain why they have not.

Part 2: Guiding Principles
Adapted from the IFRS Conceptual Framework for Financial Reporting, these principles define what makes impact information useful.

Two fundamental characteristics: 

1. Relevance 
2. Faithful representation
   

Four enhancing characteristics: 

1. Comparability
2. Verifiability
3. Timeliness
4. Understandability

The whole system operates on a “comply or explain” basis, which means: Include the suggested content, or explain why you don’t. Rather than functioning as a simple compliance checklist, this mechanism provides fund managers with the operational flexibility required across diverse investment strategies. For a GP, the "explain" function acts as a strategic opportunity to articulate methodological choices, outline practical data limitations, and demonstrate a sophisticated understanding of their specific portfolio context, all while delivering the structural consistency the broader market requires.

Why should impact fund managers care?

If you manage an impact fund, you know the pain: Every LP wants data in a slightly different format, informed by different frameworks, at different levels of granularity. The result? An enormous reporting burden that drains time from actual impact management.

The Reporting Norms address this head-on. When GPs and LPs share a common reference point for what a complete impact report looks like, conversations shift from debating format to discussing substance: the actual performance and what it means for investment decisions.

Four aspects of the Norms are particularly worth noting:

1. Measurement along the impact pathway. The Norms push for reporting as far down the impact pathway as possible, at the level of outcomes or impacts, not just activities or outputs. If you cannot report outcomes, explain how strong the link is between your proxy metrics and the changes experienced by stakeholders. This is a significant shift from the “number of people reached” metrics that still dominate many reports.

2. Honest reporting of negative impacts. Section 3.3 explicitly calls for disclosure of unintended and negative impacts. The Norms make a pointed observation: leaving this section blank suggests the preparer is unaware of the negative impacts they may be generating, which itself represents an impact risk. This is uncomfortable territory for many managers, but it is exactly where credibility is built.

3. Stakeholder voice as evidence. The Norms require evidence that reported content faithfully represents the experiences of affected stakeholders. Impact claims need to be grounded in data from those closest to the impact, not just in assumptions made at the fund level.

4. Investor contribution. GPs are encouraged to describe both financial and non-financial investor contribution, and to highlight where contextual evidence suggests the investee would not have received similar support without the investor. This moves reporting beyond “what happened” toward “what happened because of us.”
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A neutral depiction means there is no bias in which information is selected or in the way that information is presented. Colloquially, a ‘neutral’ depiction would be one free of ‘green-washing’ or ‘impact-washing. 

What it means that leonardo is a Founding Adopter

leonardo. impact has joined the Reporting Norms initiative as a Founding Adopter in the role of a service provider. This is distinct from the roles of report preparers (GPs writing the reports) and report users (LPs engaging with them).

As a service provider Founding Adopter, our commitment is concrete: To integrate the Reporting Norms into the products and services we offer. That means the methodologies we use for framework development, data collection, validation, and reporting are designed to reflect the content requirements and guiding principles set out in the Norms.

For our clients, impact fund managers and their portfolio companies, this creates a practical advantage:

When utilizing leonardo's platform, the underlying data structures and output reports are designed from the ground up to support alignment with the Reporting Norms. GPs do not need to spend valuable time reverse-engineering their existing reporting processes to force compliance. Instead, the platform's architecture ensures that compliance is naturally the path of least resistance.

How our platform maps to the Reporting Norms

Leonardo’s IMP was built to solve the core data challenges that fund managers face in impact measurement and reporting. Here is how our capabilities align with the expectations codified in the Norms:

Framework customisation → Sections 1.2 and 2.1 of the Norms. The Norms require a clear impact thesis, including the impact pathway, intended outcomes, and affected stakeholders. Our custom methodology consulting and  AI-powered indicator recommendation engine helps GPs build custom frameworks aligned to standards such as IRIS+, GRI, SFDR, IFC, and the SDGs, harmonising diverse LP requirements into a single, comparable reporting structure. No more maintaining separate templates for each investor.

Primary data collection from stakeholders → Section 3.2 (Faithful Representation). The Norms state that impact claims are most credible when evidenced by data from those closest to the stakeholders experiencing impact. Our tools (leonardo. Forms, leonardo. Connectors, and leonardo. Survey) enable scalable primary data collection through auto-generated surveys, IoT integrations, and stakeholder interviews (in-person, phone or digital), even in remote areas. This shifts reporting from assumptions to verified evidence.

AI-powered data validation → Section 3.2 (Accuracy and Verifiability). The Norms call for accuracy, audit trails, and the identification of areas where data is stronger or weaker. Our AI-powered validation engine detects inconsistencies, during reporting and runs data quality checks on survey responses regarding consistency, representativity and integrity. The IMP generates audit logs ensuring every data point is traceable, and the smart review flow saves weeks of back-and-forth.

‍Portfolio-level aggregation → Section 3.2 and Appendix E/F. The Norms outline approaches to portfolio-level synthesis, including common metrics and construct equivalence. Our platform provides instant consolidation with smart aggregation and disaggregation across portfolio companies, supporting both investment-by-investment and fund-level views.

Voices of Impact → Section 3.2 (Stakeholder Evidence). The Norms emphasise that content should faithfully represent stakeholder experiences. Our Impact Studies evaluate social impact by listening to the people affected by your investments. We integrate and optimise your impact framework, generate custom survey designs following acknowledged standards, and empower your portfolio companies by training local staff to collect data through in-person interviews, phone surveys, or digital channels. All data is cleaned, processed, and validated through the leonardo Intelligence and visualised in its depth and breadth on our individual impact dashboard in leonardo’s IMP. 

Reporting Norms Index support → Annex I. Founding Adopters who prepare reports are encouraged to include a Reporting Norms Index, a table mapping where each content element can be found. Our platform helps generate this mapping, linking report sections directly to the Norms’ requirements.

From reporting to management: the real opportunity

The Reporting Norms are an important step forward. But at leonardo. impact, we believe the real opportunity lies beyond reporting itself.

When impact data is collected rigorously, verified systematically, and reported transparently, it stops being a compliance exercise and becomes a management tool. It informs portfolio decisions, strengthens LP conversations, and, most importantly, creates feedback loops that actually improve outcomes for people and the natural environment.

For impact fund managers navigating the growing expectations of LPs, regulators, and stakeholders, the Reporting Norms provide a credible, market-tested framework to structure your reporting practice. And as a Founding Adopter and service provider, leonardo. impact is here to help you move from aspiration to implementation, efficiently and with confidence.

We do not need more reporting requirements for the sake of accountability, but actionable data for the sake of improving sustainability performance.

Dr. Jan Moellmann, Co-Founder & CEO at leonardo. impact