Disclosure focus
This disclosure asks an organisation to explain how far it has moved on from the climate-related plans it set out previously. In practice, it is about reporting progress against earlier commitments, targets or transition actions, rather than restating the plan itself. The focus is on what has actually changed, what has been delivered, and where progress is still incomplete.
The practical emphasis is on giving a fair picture of coverage and momentum across the business, not just highlighting a few successful projects or flagship sites. An organisation should make clear whether progress applies across its full operations, selected business units, or only certain locations, and should note any material gaps, delays or changes in direction compared with the prior 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-c sub-elements (LRA working checklist)
State which milestones were achieved and which were not.
Link the update back to the earlier plan.
Describe progress in words, not just numbers.
Show progress using figures where available.
Explain why delivery moved slower or faster than expected.
How to prepare it
1Set the reporting boundary first: decide which climate-related targets, projects, or commitments are in scope for this update, and make sure the same scope is used consistently across the whole response.
2Map each item to the earlier plan it came from, so you can show which target or milestone is being tracked against which original commitment or timetable.
3Gather the underlying support for each update, including records that show whether milestones were reached or not, and any source material that backs the progress statement.
4Prepare both forms of progress reporting: a short narrative explaining what changed, plus the numerical progress information where you have it, using the same basis throughout.
5Explain any shortfall or faster-than-expected movement, and note the main causes behind it in plain language so the reader can understand the movement in context.
6Before finalising, check the draft against the original source material, and record any exclusions, scope changes, or reclassifications so the reported progress can be traced back cleanly.
Request the data
Request the plan-tracking evidence from programme owners
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What was planned, what actually happened, and why did any key dates or deliverables move?
Use your organisation’s own terms for plans, workstreams, milestones, targets, initiatives, or programmes first, then map them to the disclosure wording. Keep the request anchored in how the team already tracks delivery, and check the source material before sign-off.
Weak request
Please provide the progress against prior plans disclosure evidence for IFRS S2.
Why it fails: It uses framework language only, so the owner may not know which tracker, plan, or delivery record is needed. It also does not specify the period, scope, source of record, or the exact delivery items to extract.
Better request
Please send the latest tracker or board pack for [plan / programme name] covering [period] and [boundary / scope], showing the milestones due, which were met or missed, the progress figures, and the reasons for any delay or acceleration. Include the source file and approver so we can trace the numbers back to the working record.
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
Explain what you counted as a milestone, how you matched each item to the original plan, and the basis used to measure progress so readers understand how the figures were built.
Context note
Set out what the progress figures mean in practice by linking them to the delivery plan, the milestone status, and the overall direction of travel.
Fluctuation statement
Describe any notable change by pointing to the operational or external reasons that helped or hindered delivery, and show how those factors affected the pace of progress.
Content index entry
s2-14-c Progress against prior plans — [location / page] / [notes]
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Preparation tools & forms
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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 for the source pack
The team asks the reporting lead instead of the project owner, so the evidence comes back as a polished summary rather than the working records that show what actually happened.
Using framework labels too early
People ask for information in reporting jargon instead of the business’s own terms, and the source team cannot map it back to the plan, milestone log, or action tracker.
No clear boundary for the plan set
The collector does not define which plan, programme, or workstream is in scope, so updates from unrelated initiatives get mixed into the evidence set.
Wrong period or cut-off basis
Data is pulled for the wrong month, quarter, or year-end point, which means the progress view does not line up with the period being reported.
Mixing different counting methods
Milestones, dates, and percentages are combined without checking the same basis was used throughout, so the final figures cannot be compared like for like.
Losing the original source labels
The team copies figures into a new sheet without keeping the source names, version marks, or file references, so nobody can trace each item back to the original record.
Combining groups that should stay separate
Progress for different sites, projects, or teams is rolled together even though they were tracked separately, which hides where delivery moved forward or slipped.
Missing evidence trail details
The pack is saved without the date, owner, and file history for each input, so reviewers cannot tell which version was used or when it was last checked.
No sign-off record before handover
The data is passed on without a named reviewer confirming it, leaving no clear trail that the numbers and notes were checked before drafting starts.
Where judgement is often needed
What counts as the same plan after a business change
If a purchase, sale or reorganisation changes the operating perimeter, explain whether you kept the earlier plan as-is or rebuilt the comparison set, and make clear which milestones and progress figures sit inside the revised boundary.
When local targets use different meanings in different markets
Where country teams track the same aim with different local definitions, choose one basis for the comparison, state how you aligned the figures, and note any places where the local measure does not map neatly to the group view.
How to handle activities that sit partly inside the scope
For sites, programmes or teams that are only partly covered by the plan, set out the rule you used to include, exclude or split them, and explain the effect on the progress story.
Which date anchors the progress check
Be explicit about whether you measured progress at period end, at a cut-off earlier in the cycle, or on another internal date, and keep the timing basis consistent with the prior plan you are comparing against.
Using estimates where direct counts are not available
If some progress numbers come from estimates rather than direct measurement, say which parts are estimated, why that approach was used, and how you treated the uncertainty when describing milestones met or missed.
Rounding and small differences in the numbers
State the rounding rule used for the progress figures and make sure the narrative, percentages and milestone counts still tie back to the same underlying data after rounding.
How much detail to show when people or sites could be identified
If disclosing progress at a level that could expose personal or commercially sensitive information, aggregate the data to a safer level, explain the grouping approach, and keep the explanation consistent with the figures shown.
Choosing the comparison basis for mixed reporting periods
Where parts of the organisation report on different cycles, explain which reporting period you used for the comparison, why that basis was chosen, and how you avoided mixing unlike periods in the same progress update.
Deciding whether a missed step is a delay or a reset
If a milestone moved because the plan changed rather than because delivery slipped, describe the reason in plain terms, separate the revised target from the original one, and show both the movement and the revised expectation clearly.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Manufacturing
Over the year, we moved several climate-transition actions forward against the plan we set last period: 8 of 10 scheduled actions were completed, while 2 were carried into next year. We also saw one target reached early and one timing slip, mainly because supplier data arrived later than expected and a plant upgrade took longer to commission than planned. - Compared with the prior plan, most work stayed on track, and the main delay was in the equipment rollout rather than in the design work. - In overall terms, progress was solid but uneven: delivery was faster than expected in procurement, while implementation at one site lagged behind the timetable.
This synthetic disclosure shows how to describe progress against a previously stated plan using plain language, with both completed and delayed items, plus a brief explanation of why timing changed.
Illustrative (synthetic) example — Retail
Against the roadmap we published last year, we finished 5 of 6 customer-facing energy measures and brought forward the remaining one into the first quarter of next year. The work moved faster than expected because store refits were bundled with routine maintenance, although one supplier switch took longer than planned and pushed back a small part of the programme. - The main milestones were largely met, with only one item deferred from the original schedule. - Progress was stronger than the baseline in store operations, but the slower supplier change meant the full package was not finished within the original window.
This synthetic disclosure demonstrates how to link current-year delivery back to an earlier plan, show what was achieved or deferred, and explain both acceleration and slippage in simple narrative form.
How companies report S2-14-c in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Abu Dhabi Commercial Bank (ADCB)
None · United Arab Emirates · 2024
Abu Dhabi Commercial Bank’s 2024 ESG Report provides qualitative information about the progress of plans disclosed in previous reporting periods, as noted on page 131. However, the report does not clearly disclose quantitative progress or specific milestones met or missed, with related context found but not definitive on pages 125 and 137. Additionally, there is no clear reference to prior plans or explanations for any slippage or acceleration in progress.
Coca-Cola HBC AG
Food and Beverage Processing · Switzerland · 2024
Coca-Cola HBC AG’s Sustainability Statement 2024 provides qualitative information on the progress of key actions or action plans disclosed in prior periods, particularly related to the health and safety programme, as noted on page 111. The report includes references to the scope of action and progress of actions or plans on pages 68, 69, 77, 81, 84, and 98, but these do not clearly disclose milestones met or missed. There is no quantitative progress data or explanations for any slippage or acceleration found in the report.
COSCO SHIPPING Ports
Water Transportation — Ports and Services · China / Hong Kong · 2025
COSCO SHIPPING Ports’ Sustainability Report 2025 includes a disclosure on the progress of plans disclosed in previous reporting periods, specifically related to climate resilience, as noted on page 70. The report also references qualitative and quantitative climate-related targets set to monitor progress, though the clarity on milestones met or missed is unclear (p.72). However, the report does not provide a clear narrative on qualitative progress or reasons for any slippage or acceleration, and quantitative progress details remain ambiguous (no clear disclosures found).
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Scenarios to work through
A company set a 2025 plan to cut operational emissions by 20% from a 2022 baseline, with a mid-year checkpoint at 10%. By year-end it has cut them by 8%, and the team has board papers showing the original plan, the latest tracker, and notes on a delayed equipment upgrade.
QHow should the preparer decide what to include about the earlier plan and the current position?
Reveal model answer →Hide answer ↑They should link the update back to the earlier plan, state the milestone that was expected and what was actually achieved, and explain the gap in plain language. The write-up should show both the amount of progress and the reason the target was not reached on time, using the underlying records as support.
Why this matters · The update should connect the current result to the earlier plan and explain any shortfall or faster-than-expected movement.
A business had planned to complete a supplier training rollout by September, but it finished in July after simplifying the materials and using an online format. Internal reporting shows 180 suppliers trained against a target of 150, and the project team has a summary of the revised delivery approach.
QWhat should the preparer do when the work moved ahead of schedule and exceeded the original target?
Reveal model answer →Hide answer ↑They should describe the earlier target, the actual outcome, and the fact that delivery moved faster than planned. The narrative should explain what changed in the delivery approach and show the amount by which the result beat the original expectation, without leaving out the plan reference or the comparison point.
Why this matters · Where delivery is ahead of plan, the explanation should still anchor the reader to the original target and show the scale of the improvement.
A group had a three-year plan to install energy-saving controls across 40 sites. By the reporting date, 28 sites were complete, 8 were in installation, and 4 had not started because of permit delays; the project file includes the original schedule and monthly progress reports.
QHow should the preparer present the progress when some work is done, some is underway, and some is delayed?
Reveal model answer →Hide answer ↑They should give a balanced account of the work completed so far, the work still in progress, and the part that has slipped. The answer should refer back to the earlier schedule, quantify the current position against that plan, and explain why the delayed sites have not yet been delivered.
Why this matters · A useful progress update shows the split between done, underway, and delayed work, tied back to the earlier timetable.
A company’s earlier transition plan said it would pilot a low-carbon product line in two markets by the end of the year. One market launched on time, the second slipped by two months because certification took longer than expected, and the team has a memo showing the revised launch date and the cause of delay.
QWhat judgement should the preparer make about the explanation for the missed timing?
Reveal model answer →Hide answer ↑They should keep the focus on the original plan, the actual timing, and the reason the second launch moved back. The explanation should make clear which milestone was met, which one slipped, and why, so readers can see the progress picture without guessing.
Why this matters · When timing changes, the explanation should identify what was achieved, what slipped, and the cause of the change.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
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FAQ
Questions this page answers
For s2-14-c, what data do I need to gather before I start drafting the disclosure?+−
The page says to prepare five datapoints: milestones achieved or missed, the link to the earlier plan, an explanation of progress, measured progress, and the drivers behind any delay or speed-up. Use those as the starting checklist before you draft anything.
How do I use the step-by-step prepare section for s2-14-c in practice?+−
Use it as a working sequence: identify the datapoints, collect supporting evidence, check the common gaps, then turn the material into a draft. The page is designed to help you move from raw information to a disclosure-ready narrative.
What should I include in the evidence pack for s2-14-c if I want to be assurance-ready?+−
The page includes a five-item evidence pack to support assurance readiness, alongside five claims to verify. Build the pack around the claim, the risk it addresses, and the evidence that shows the datapoint is supported.
What are the five assurance claims I need to check for s2-14-c?+−
The page says there are five claims to verify, each framed around the claim, the related risk, and the evidence. Use those checks to test whether the disclosure is supportable before it goes to review.
What are the common reporting mistakes on the s2-14-c page, and how do I avoid them?+−
The page lists common reporting gaps and mistakes so you can spot weak points early. A practical way to use that section is to compare your draft against the listed gaps before finalising the narrative and evidence pack.
How do I turn the s2-14-c datapoints into a draft disclosure?+−
The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. Use those to turn the prepared datapoints into a structured draft rather than starting from a blank page.
What does the synthetic example on s2-14-c show, and can I use it as a template?+−
The page includes synthetic illustrative examples, including a quantitative table, to show how the disclosure can be presented. Treat them as examples only and adapt the structure to your own data and evidence.
How should I assign ownership for the s2-14-c disclosure across ESG, HR or data owners?+−
The page is set up for practitioners to use when preparing the disclosure, but it does not assign roles for you. In practice, use the page’s datapoints and evidence pack to decide who owns each input and who signs off the final draft.
Can I use the Prep & Assurance workbook for s2-14-c to manage the disclosure process?+−
Yes. The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to help you organise preparation and assurance work for the disclosure.
What is the printable Library Card for s2-14-c, and when would I use it?+−
The Download Centre includes a printable Library Card in .pdf format. It is there as a practical companion to the page content, so you can keep the key points to hand while drafting or reviewing the disclosure.
Is there a real-report example I can look at for s2-14-c before I draft mine?+−
Yes. The page has a 'From company reports' table that links to real published reports where the topic is disclosed, which you can use to see how others have presented similar information.
More questions this page can help with
s2-14-c disclosure checklist for sustainability managers2-14-c evidence pack for assurance reviews2-14-c common mistakes and reporting gapss2-14-c workbook download how to uses2-14-c draft narrative starters and content indexs2-14-c milestones achieved or missed data pointss2-14-c progress explanation and measured progresss2-14-c delay or speed drivers disclosures2-14-c link to earlier plan what evidence to keeps2-14-c assurance claims claim risk evidences2-14-c synthetic example disclosure tables2-14-c ESRS E1 climate change reusable data
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