Disclosure focus
This disclosure asks an organisation to explain how it is responding to climate-related risks and opportunities through its strategy, including whether it has a transition plan. In practice, the report should show what the organisation intends to do, how those actions fit into its wider business plans, and whether the response is already being put into effect or is still being developed.
The practical focus is on the organisation’s overall approach, not just a few headline projects or flagship sites. Readers should be able to understand whether the response covers the business as a whole, how far it reaches across operations and value chain where relevant, and what parts of the organisation are included in the plan.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official IFRS source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
＋ Show s2-14-a sub-elements (LRA working checklist)
Describe any changes to the way the business makes money or allocates resources.
Set out the actions the organisation takes directly to reduce harm or adapt.
Explain the steps taken through suppliers, customers or other parts of the value chain.
State the main assumptions and dependencies that the plan relies on.
Summarise the organisation’s chosen responses to the issue.
Show the route the organisation expects to follow to meet its target.
Outline the transition plan in practical terms.
How to prepare it
1Set the boundary for the disclosure first. Decide which parts of the business, value chain and planning horizon you are covering, so the same scope is used for every item in this disclosure.
2Agree what each item will mean in your report. For every required point, define the business changes, direct actions, upstream or customer-linked actions, assumptions, dependencies, strategic responses, the route to target delivery, and the transition plan in terms your team can apply consistently.
3Gather support for each point before drafting. Pull together board papers, project papers, budgets, implementation plans, scenario work, target trackers, and any other records that show the position you are reporting.
4Draft the figures or narrative for each required point. Where the item is qualitative, write a clear explanation; where it is quantitative, compile the numbers and make sure they tie back to the underlying records.
5Record anything left out or revised. If you have excluded a matter, changed a method, or updated an estimate, note what changed, why it changed, and whether the same approach was used across the disclosure.
6Check the draft against the official source before sign-off. Confirm that every required point is covered, the wording matches the underlying evidence, and the final version is consistent with the source material and internal approvals.
Request the data
Request the strategy and transition evidence pack
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What changes, actions, assumptions and pathway are we using to explain how the business is responding and moving towards the target state?
Use your organisation’s own planning and programme language first, then map it to this disclosure. For example, ask for the strategy update, transformation roadmap, decarbonisation plan, or change programme if those are the terms your teams actually use. Keep the request in business terms and check the source material before sign-off.
Weak request
Please provide the IFRS S2 strategy response and transition plan evidence for the disclosure.
Why it fails: It uses framework language only, so the owner has to translate the ask from scratch. It does not say which internal pack, system, version, or business terms to use, and it does not separate the different pieces of evidence needed.
Better request
Please send the latest strategy, transformation, or transition pack for [period] that shows: plan changes, direct actions, supplier/customer-linked actions, assumptions and dependencies, the response we are taking, the pathway to the target state, and any transition roadmap. Include version, approval date, owner, and links. If your team uses different labels, send the equivalent internal pack and I will map it.
Industry examples
Draft your disclosure
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
Describe the basis used to compile the disclosure, including how the business defined each action category, what period the data covers and how management judged whether an item belongs in the plan.
Context note
Explain that the figures show how the organisation is reshaping operations, spending and wider value-chain activity to support its transition route and target pathway, rather than a standalone list of initiatives.
Fluctuation statement
If the numbers moved materially, explain whether that was driven by timing, revised assumptions, changed priorities, new actions or progress in delivery, and note any one-off effects.
Content index entry
s2-14-a Strategy response and transition plan — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for s2-14-a — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
The request goes to the wrong team, so the people who hold the plan, actions, or assumptions never confirm the source material.
Framework language first
The data call is written in reporting jargon instead of the organisation’s own terms, and staff cannot match it to the records they actually keep.
No boundary set
The team collects mixed material without stating which business units, activities, or time horizon belong in scope.
Wrong timing basis
Information is pulled for the wrong reporting period or cut-off date, so the evidence does not line up with the year being reported.
Mixed counting basis
Different measures are combined without separating how each was built, which makes totals and comparisons unreliable.
Source labels lost
Original file names, version tags, or system labels are stripped away, so the team cannot trace each item back to where it came from.
Separate groups merged
Direct actions, supplier or customer actions, and other response types are lumped together even though they should stay distinct for review.
Evidence trail missing
The pack is assembled without the supporting metadata and approval trail, so no one can show who provided it, when, or on what basis.
Where judgement is often needed
Set the reporting perimeter after a deal closes
If a purchase, sale, or carve-out changes the group’s footprint, explain which entities and activities are included in the plan and from what date the change is reflected.
Choose one working definition where country rules differ
Where local laws or market practice use different labels or thresholds for the same activity, state the definition you used, why it was chosen, and whether it was applied consistently across locations.
Decide how to handle near-boundary operations
For sites, products, or teams that sit close to the inclusion line, disclose the rule used to include or exclude them and note any material judgement made in the process.
Fix the timing basis for actions and milestones
If some actions are planned, underway, or already completed at different dates, explain the cut-off date used and distinguish what is committed, in progress, and delivered.
Separate measured figures from management estimates
When hard data is not available for parts of the response or pathway, identify which figures are directly observed and which are estimated, and describe the method used to fill the gaps.
State the assumptions behind the pathway
For the main drivers that underpin the response, set out the assumptions and dependencies that could change delivery, including any external conditions the plan relies on.
Explain how indirect actions are counted
If the response depends on suppliers, customers, or other third parties, clarify which actions are treated as part of the organisation’s own plan and which are only expected from others.
Use a consistent basis for progress against targets
When showing movement toward a target, disclose the metric basis, the period covered, and any restatements so readers can see how the pathway was built.
Round and aggregate without losing meaning
If figures are rounded or combined to protect confidentiality or keep the report readable, say so and make sure the totals still reconcile to the underlying evidence.
Protect sensitive detail with careful grouping
Where operational detail cannot be shown at site, customer, or supplier level, explain the aggregation approach used and confirm that the grouped view still supports the strategy narrative.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — manufacturing
We are reshaping capital spend so that 62% of this year’s investment budget is directed to lower-emission equipment, site electrification and process efficiency, up from 41% last year. To support our transition plan, we have already completed 18 of 30 planned actions, including retrofitting two plants, switching 55% of purchased electricity to renewable contracts and setting supplier requirements for logistics and packaging; the remaining 12 actions are scheduled through 2030. - Our main assumptions are stable access to renewable power, timely grid upgrades and continued customer demand for lower-carbon products, because those conditions affect the pace of delivery. - We expect our pathway to the 2030 target to come from a mix of direct operational changes, supplier engagement and customer-facing product redesign, with 74% of the planned emissions reduction already covered by actions in train.
Synthetic example showing how a company can describe changes in spending, direct and indirect actions, assumptions, strategic response and progress against a transition plan in plain language.
Illustrative (synthetic) example — food retail
We have redirected 38% of our annual capital programme toward store energy upgrades, low-carbon refrigeration and fleet charging, compared with 24% in the prior year, while also changing procurement rules so that 70% of own-brand packaging spend now sits with suppliers that meet our new design criteria. On the operational side, we have cut methane-intensive waste by 22% through food-donation routes and better stock planning, and we are asking logistics partners and key growers to adopt route optimisation, fertiliser reduction and traceability tools. - Our plan depends on customer uptake of refill and reusable options, supplier data quality and the availability of charging infrastructure, so we have built those into our scenario assumptions. - The strategy is to combine near-term efficiency gains with longer-term product and network changes; by 2028, 16 of 21 milestones should be complete, putting us on track for the 2030 emissions and waste targets in our transition plan.
Synthetic example showing a retailer-style narrative that links investment shifts, direct action, supply-chain/customer measures, assumptions and milestone-based progress.
How companies report s2-14-a
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
SITC International Holdings Company Limited
Water Transportation · Hong Kong · 2025
SITC International Holdings Company Limited’s 2025 Environmental, Social and Governance Report provides coverage of its business model changes and resource allocation in response to sustainability-related risks and opportunities, as detailed on pages 188 and 193. The report also addresses strategic responses and transition planning, including the use of diverse climate-related scenarios, on pages 195 and 193. However, the report does not clearly disclose direct mitigation or adaptation actions (p.197), nor does it provide information on indirect supply chain or customer actions, key assumptions and dependencies, or target achievement pathways.
Enel Chile S.A.
Electric Utilities / IPP / Energy Traders · Chile · 2025
Enel Chile’s 2025 Integrated Annual Report provides coverage of direct mitigation and adaptation actions as well as a transition plan related to climate risks, both detailed on page 373. The report includes references to resource allocation connected to the business model and value chain on the same page, though the disclosure is unclear. Notably, the report lacks clear information on key assumptions and dependencies, strategic responses, and target achievement pathways, while indirect supply chain or customer actions are mentioned but not clearly disclosed (p.195).
MTR Corporation
Ground Transportation — Railroads · Hong Kong · 2025
MTR Corporation’s Sustainability Report 2025 provides some contextual information related to strategic responses and mitigation strategies, mentioning plans to enhance railway asset management and embedding nature-related considerations (pp. 87, 92). The report also references current practices and readiness to adopt more sustainable operating approaches (p. 58). However, clear disclosures on direct mitigation adaptation actions, business model resource allocation changes, key assumptions and dependencies, indirect supply chain customer actions, target achievement pathways, and a transition plan are either unclear or not found in the report.
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Scenarios to work through
A manufacturer has approved a three-year shift from gas-fired equipment to electric lines, but the finance team has only budgeted the capex and not the related retraining and site upgrades. The draft narrative also mentions a supplier programme, yet no one has checked whether it is actually funded.
QHow should you decide what to include when describing the organisation’s response and transition plan?
Reveal model answer →Hide answer ↑Set out the concrete changes to the business model and where money and other resources are being redirected, then describe the direct actions the organisation will take itself and the steps it expects from suppliers or customers. If a programme is mentioned, make sure the supporting assumptions and dependencies are identified, and do not present an unfunded idea as part of the plan.
Why this matters · The narrative should connect strategy, resource shifts, direct action, indirect action and the assumptions that make the plan plausible.
A utility has a pathway to cut emissions by 2035, but the board paper only states the end goal and gives no explanation of the milestones, interim actions or the conditions that must hold for delivery. The sustainability team is unsure whether the target story is enough on its own.
QWhat should you check before treating the target story as a complete transition narrative?
Reveal model answer →Hide answer ↑Confirm that the disclosure explains the route to the target, not just the destination: what the organisation will do over time, how those actions support the target, and what assumptions or external conditions the route depends on. If the pathway is missing, the disclosure is incomplete even if the end target is clear.
Why this matters · A target needs a credible route to it, with the key dependencies made visible.
A retailer plans to reduce emissions by changing its own logistics fleet, but it also expects major emissions cuts from suppliers switching to lower-carbon materials. The draft only describes the fleet change because that is the part management controls directly.
QHow should you handle the supplier-related element when drafting the response?
Reveal model answer →Hide answer ↑Include the supplier-side action if it is part of the organisation’s planned response, and distinguish it from the measures the organisation will carry out itself. The reader should be able to see which actions are internal, which rely on others in the value chain, and what assumptions sit behind the expected contribution from those others.
Why this matters · Separate internal action from value-chain action so the plan is clear about who must do what.
A property group has a transition plan that depends on planning approvals, tenant cooperation and access to green finance. The draft mentions these in passing, but the team has not linked them to the timing of the plan or to the resource shifts already approved.
QWhat judgement should you make about those dependencies before finalising the disclosure?
Reveal model answer →Hide answer ↑Bring the dependencies into the main explanation and show how they affect the timing, feasibility and resource allocation in the plan. If delivery depends on approvals, counterparties or finance, the disclosure should make that clear rather than leaving them as background comments.
Why this matters · Dependencies matter when they shape whether, when and how the plan can be delivered.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
Primary
Related & explore
FAQ
Questions this page answers
How do I use the s2-14-a page to draft the disclosure from scratch?+−
Start with the plain-language explainer, then work through the step-by-step preparation section and the datapoints to prepare. The page also gives draft-output support, including narrative starters and a content-index line, so you can turn the collected information into a first draft.
What information do I need to gather for s2-14-a before I start writing?+−
The page says to prepare information on business model changes, direct response actions, value chain actions, planning assumptions, strategic climate responses, target delivery route and the transition plan. Use that list as your collection checklist so you are not drafting before the underlying data is ready.
How should I scope the data for s2-14-a so the disclosure is complete?+−
Use the page’s datapoints to define scope around the company’s climate-related response, not just one isolated action. The list covers internal changes, value chain actions, assumptions, targets and the transition plan, so the scope should capture the full story behind the disclosure.
Who should own the inputs for s2-14-a in my organisation?+−
The page does not assign roles, so ownership needs to be set internally. A practical approach is to split responsibility across the people who hold the relevant information for business model changes, actions, assumptions, targets and the transition plan, then have one person coordinate the draft.
What should go into the evidence pack for s2-14-a assurance?+−
The page includes an evidence pack with five items and also lists five assurance claims to verify. Use those together to build a file that links each claim to the supporting evidence before the draft is reviewed for assurance readiness.
What are the common mistakes to avoid when preparing s2-14-a?+−
The page has a section on common reporting gaps and mistakes, so it is designed to help you spot weak or missing content before sign-off. In practice, use it as a final check against the datapoints, the evidence pack and the draft-output section.
How do I use the Prep & Assurance workbook for s2-14-a?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is there to help organise preparation and assurance work. Use it alongside the page’s step-by-step guidance, evidence pack and assurance claims so the workbook reflects the same information you plan to disclose.
Can I use the synthetic example on the s2-14-a page as a template for my own disclosure?+−
Yes, but only as a synthetic illustration. The page’s example disclosure and quantitative table are there to show how the content can be presented, so you should adapt the structure to your own data rather than copying the example itself.
How do I turn the s2-14-a data into a draft narrative and table?+−
Use the draft-output section, which includes visualisation ideas, narrative starters and a content-index line. That gives you a practical way to move from collected datapoints to a readable draft with a clear structure.
Is the s2-14-a page useful if I am checking the disclosure for assurance?+−
Yes. It gives five assurance claims to verify and an evidence pack with five items, so you can check whether the draft is supported before it goes to review. The common gaps section is also useful for spotting issues that could slow assurance down.
How does s2-14-a relate to ESRS E1, and can I reuse the same data?+−
The page says the closest ESRS correspondence is ESRS E1 (Climate Change). That means the data may be reusable across reporting work, but you still need to check the page’s own datapoints, evidence and draft requirements for this disclosure.
More questions this page can help with
s2-14-a disclosure checklist for sustainability managers2-14-a evidence pack items for assurance reviews2-14-a workbook download xlsx how to uses2-14-a common reporting gaps and mistakess2-14-a business model changes data collections2-14-a transition plan and target delivery route what data is neededs2-14-a narrative starters and content index lines2-14-a synthetic example disclosure tables2-14-a who owns the disclosure inputss2-14-a assurance claims to verify claim risk evidences2-14-a from company reports exampless2-14-a ESRS E1 data reuse
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