Disclose progress toward each disclosed target or goal and how it was achieved, updated every fiscal year with the actions taken during the year, including a discussion of material impacts on the business, results or financial condition as a direct result of the target or the actions, and quantitative and qualitative disclosure of material expenditures and material impacts on financial estimates and assumptions as a direct result (1504(c)(2), which has the later compliance date). Expenditures actually incurred are historical facts outside the safe harbor.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.