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IFRS S1: General Requirements for Disclosure of Sustainability-related Financial Information · 2024

Paragraphs 27–b

Management role in governance

Practical guidance for preparing this disclosure. Use this card to identify the information to prepare, verify claims and organise supporting evidence. For exact requirements, always refer to the official IFRS source.

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Under review Editorial review in progress Prepared from official source material and published report evidence Use alongside the official IFRS source while human review is in progress.

Real report See how 3 companies report this ↓

Hang Lung Properties Limited

Also seen in

Westports Holdings Berhad

Hyundai Engineering & Construction Co.,Ltd.

To prepare this disclosure

4preparation fields↓ 5claims to verify↓ 5evidence areas↓ 3report examples↓

Disclosure focus

This disclosure asks an organisation to explain how management is involved in overseeing and carrying out sustainability-related governance responsibilities. In practice, it is about showing where management has real responsibility, what it does, and how that role connects to the wider governance structure rather than leaving the topic only at board level.

The practical focus is on the organisation’s actual arrangements across the business: who is responsible, what decisions or monitoring they handle, and whether this applies broadly or only in certain parts of the organisation. A useful response should make clear the scope of management involvement, including whether it covers the whole organisation, specific business units, or only selected sites or functions.

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.

Have we actually put in place the controls and working routines we plan to describe, and can we point to where they sit in our internal records? Is there a named manager, committee, or other delegated group doing this work, and have we agreed exactly which part of the organisation that covers? Do we need to explain how this sits alongside risk, finance, legal, internal audit, or any other team, and have we settled which links are in scope? If a delegated group is involved, have we decided who keeps watch over it and what that oversight looks like in practice? Are the facts we will use traceable to a source we can check, and have we fixed the reporting cut-off or period they come from?

Preparation

Key information to prepare

Preparation field What to capture Evidence hint Owner

Controls and checks Whether the organisation has documented controls and procedures in place for this area, and a brief description of what those controls and procedures are. Policy or process note, control framework, procedure document, or governance paper showing the controls in use. Governance / reporting lead

Delegated role or committee Which management role or committee has been given responsibility for this area, including the named body or position and the scope of the delegation. Terms of reference, delegation matrix, committee charter, or management responsibility schedule. Company secretary / governance

Cross-functional integration How this area is connected with risk, finance, legal, internal audit, and any other relevant functions, including the main coordination points or shared processes. Cross-functional governance map, committee papers, RACI, meeting minutes, or process documentation showing the links. Risk / finance / legal coordination lead

Delegated role oversight What oversight is exercised over the delegated role, and by whom, including the main review, challenge, or monitoring arrangements. Board or committee minutes, oversight schedule, reporting pack, or governance terms showing how the delegated role is monitored. Board secretary / governance

＋ Show s1-27-b sub-elements (LRA working checklist)

Set out the controls and procedures that are used. Identify any management role or committee that has been given this task. Show how this work is linked with risk, finance, legal, internal audit, or similar functions. Explain how the board or other oversight group keeps watch over the delegated role.

How to prepare it

1Map the controls and procedures you actually use for this disclosure, so you can show the process rather than a generic description.

2Identify who carries the delegated management responsibility, or which committee does so, and note the role in plain business terms.

3Set out how that work connects with risk, finance, legal, internal audit, or any other relevant team, using the wording your organisation uses internally.

4Gather the supporting evidence for each point, such as meeting papers, approvals, process notes, or other records that show the arrangement in practice.

5Prepare the final figures or narrative, then record any exclusions, changes in approach, or updates so the reader can see what was included and why.

6Check the draft against the official source to confirm you have covered the required items and have not added, missed, or misstated anything.

Request the data

Request board delegation and oversight evidence

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

How is day-to-day sustainability oversight delegated, connected to other control functions, and kept under board supervision?

Use your organisation’s own governance terms first (for example, board, committee, executive forum, delegated lead, control functions), then map them to the disclosure. Keep the request in your internal language and check the source text before sign-off.

Weak request

Please provide the governance disclosure wording for management role in governance.

Why it fails: This asks for framework language rather than the underlying internal evidence. It does not tell the owner what records to pull, which governance bodies or control teams matter, or what period and entity boundary to cover.

Better request

Please send the board or committee papers, delegation note, and any reporting pack for [reporting period] that show which internal forum handles day-to-day sustainability oversight, how it connects with risk, finance, legal, internal audit, or other control teams, and how the board keeps watch over that arrangement. Please include the source documents, dates, and any changes during the period.

Formal email template

Subject: Request for governance evidence for [reporting period]

Hi [name],

We are preparing the sustainability reporting pack and need your help with the governance evidence for [entity / boundary] for [reporting period].

Please share the materials that show:
- which board or committee has been given day-to-day responsibility for sustainability matters;
- how that role connects with risk, finance, legal, internal audit, or any other relevant control teams; and
- how the board or equivalent top governance group keeps oversight of that delegated role.

Please include the source documents, the period they cover, and any recent changes to the arrangement.

A possible LRA training template is below — please adapt this to your organisation’s own terms and check the source text before sign-off.

Thanks,
[preparer name]

Short Teams / Slack version

Hi [name] — could you send the board/committee papers or delegation note for [reporting period] showing who handles day-to-day sustainability oversight, how it links to risk/finance/legal/internal audit, and how the board keeps oversight? Please include the source docs and any recent changes. Thanks, [preparer name]

Industry examples

Manufacturing

Context. A group with a sustainability steering committee reporting to the board audit committee.

Adapted request. Please share the steering committee terms of reference, meeting minutes, and board pack for [reporting period] showing which committee handles day-to-day sustainability oversight, how it links with risk, finance, legal, and internal audit, and how the audit committee keeps oversight.

Example response. Attached: steering committee terms of reference (v4, effective 1 Apr 2025), three meeting minutes, and two board packs. The committee meets monthly, receives risk and finance updates, and escalates material issues to the audit committee each quarter.

Financial services

Context. A bank where sustainability matters are handled by an executive risk forum with board oversight.

Adapted request. Please provide the executive forum papers and delegation memo for [reporting period] showing which executive group manages sustainability matters, how it is linked into risk, finance, legal, and internal audit, and how the board receives oversight updates.

Example response. Attached: delegation memo dated 15 Feb 2025, executive risk forum packs for Q1–Q4, and board dashboard extracts. The forum reviews sustainability risks monthly and the board receives a quarterly summary with escalation points.

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 practical basis used to identify the controls, procedures, delegated responsibilities and oversight links included in the disclosure, and explain how you decided which governance arrangements to count or describe.

Context note

Explain what the governance setup shows about how sustainability matters are managed in practice, including where responsibility sits and how the different business functions support it.

Fluctuation statement

If the governance picture changed from the prior period, note whether that was due to a new control, a revised delegated role, stronger links with other functions, or a change in oversight arrangements.

Content index entry

s1-27-b Management role in governance — [location / page] / [notes]

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Preparation tools & forms

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01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧

Go deeper · s1-27-b

Learn to prepare this disclosure end-to-end

This guide covers one requirement. The IFRS S1 & S2 Reporting course walks the full ISSB workflow — governance, strategy, risk management and metrics — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

Explore the IFRS S1 & S2 course →

Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check

We say the coverage figure was built using documented checks and sign-off steps, not ad hoc judgement.The assurer may find the figure was assembled informally, with no clear control trail or approval before publication.Process notes, control logs, review sign-offs, version history, and any pre-publication approval record for the coverage figure.

We explain which manager or committee took the lead on the disclosed matter and whether that role was assigned to someone else.The assurer may question whether responsibility is overstated, unclear, or not actually delegated in practice.Governance chart, role descriptions, delegation papers, committee terms of reference, and meeting minutes showing the assigned lead.

We describe how that lead role sits alongside the wider internal process, including links to other teams that help prepare the disclosure.The assurer may see a gap between the named lead and the rest of the reporting process, or unclear hand-offs between functions.Workflow maps, cross-functional reporting procedures, RACI or similar responsibility matrix, and evidence of coordination with relevant teams.

We state how the board or equivalent group keeps watch over any delegated lead or committee handling the matter.The assurer may doubt whether oversight is real, regular, or sufficiently documented.Board or committee papers, escalation routes, periodic reporting packs, challenge notes, and records of follow-up actions.

We note that the reporting process draws on risk, finance, legal, internal audit, or other relevant teams where needed.The assurer may find the disclosure omits important review inputs or overstates the breadth of internal involvement.Review comments from relevant functions, sign-off chains, internal control documentation, and evidence of issue resolution before publication.

Evidence pack to prepare

The governing policy or written commitment behind this disclosureA methodology / definition note setting out how the disclosure was scoped and preparedSource-system exports the figures or facts were drawn fromThe internal approval / sign-off record for the disclosure before publicationMinutes or records evidencing the relevant engagement or consultation

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

Asking the board team instead of the process owner

The request goes to directors’ support staff when the real evidence sits with the manager who runs the control, so the file comes back incomplete or second-hand.

Using framework labels instead of the business term

People are asked for a governance phrase they do not use internally, and they cannot map it to the committee, role or process they actually track.

Leaving the scope too loose

The team never pins down which business units, committees or delegated roles are in scope, so different contributors send data from different populations.

Mixing periods or cut-off dates

One source is pulled for the current quarter while another is taken from a later sign-off pack, which makes the evidence set inconsistent.

Combining unlike counting bases

Headcount-style totals, named-role lists and process descriptions are merged into one extract, even though they need to stay separate for clean review.

Dropping the original source labels

The extract loses the document titles, version marks or system tags that show where each item came from, so reviewers cannot trace it back.

Skipping evidence metadata

The pack contains the answer but not the date, owner, version or location of the underlying record, which leaves no audit trail for checking.

No sign-off trail on the draft

The collected material is circulated without a clear reviewer and approver record, so nobody can show who checked the inputs before drafting.

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Where judgement is often needed

Newly acquired or sold parts of the business

Set a clear cut-off for when a business unit starts or stops being included, and explain any change in the management role narrative where the reporting perimeter has moved during the period.

Different local job titles for the same management role

Use one organisation-wide label for the delegated role or committee, then note any country-specific titles only where they help readers understand the same function across locations.

Mixed reporting lines across functions

If the role draws on risk, finance, legal, internal audit or other teams in different ways, describe the actual working arrangement rather than forcing a single structure that does not fit every unit.

Partial coverage of the organisation

Where the management role is only in place for some operations, explain which parts are covered, which are not, and why the boundary is set that way.

Timing of changes during the year

Choose a consistent point for reflecting a new delegation, committee change or oversight arrangement, and disclose that timing so readers can see whether the description is based on year-end or an earlier state.

Judgement between direct evidence and management estimate

If the description relies on interviews, policy review or other indirect evidence rather than a single formal record, say so and explain the basis used to support the wording.

Aggregation to protect sensitive people data

When naming individuals or small teams would create privacy issues, summarise the role at a higher level and state that the detail has been grouped to avoid identifying people.

Rounding and level of detail in role descriptions

If you simplify counts, dates or reporting lines for readability, keep the method consistent and make clear that the figures or descriptions are rounded or summarised.

Different governance practices by country

Where local entities use different control or oversight arrangements, explain whether the disclosure reflects the group-wide model, local practice, or a blend of both, and keep that choice consistent.

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Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Manufacturing

Our board receives a quarterly control pack that combines policy updates, incident trends, and assurance findings, and it uses that pack to steer how sustainability matters are handled across the group.
- Day-to-day coordination sits with a cross-functional sustainability steering group chaired by a senior executive, with members from risk, finance, legal, and internal audit.
- That group prepares recommendations, tracks actions, and escalates material issues to the board, while the board keeps formal oversight through scheduled reviews, challenge sessions, and approval of key decisions.

This example shows a board using regular reporting and a formal committee-style forum to manage sustainability work, with clear links into risk, finance, legal, and internal audit, and with directors retaining oversight of the delegated group.

Illustrative (synthetic) example — Retail

We run a monthly management dashboard that brings together control testing results, compliance updates, and finance impacts so that sustainability topics are reviewed alongside other business priorities.
- Operational ownership is delegated to a sustainability and compliance committee led by a senior manager, with input from risk, legal, finance, and internal audit teams.
- The board’s audit and risk committee receives a standing update from that committee, checks progress against agreed actions, and intervenes where issues need escalation or extra scrutiny.

This example shows a management committee carrying the operational workload, supported by several control functions, while the board’s committee keeps watch over the delegated arrangement and steps in when needed.

Company reportsReal published reports

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How companies report S1-27-b in practice

Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.

Hang Lung Properties Limited

Real Estate · Hong Kong · 2025

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Hang Lung Properties Limited’s Sustainability Report 2025 provides evidence that management uses controls and procedures to support the oversight of climate-related risks and opportunities, as detailed on page 188. The report also describes how oversight is exercised through a delegated management-level role or committee on page 222. However, the specific role of the Board Executive Committee in delegated management and the integration of these controls with other internal functions such as risk, finance, legal, or internal audit remain unclear, with related context found on pages 25 and 188 but without explicit disclosure.

Westports Holdings Berhad

Water Transportation — Ports and Services · Malaysia · 2025

Open report →

Westports Holdings Berhad’s 2025 Sustainability Report provides evidence of structured controls and procedures supporting oversight responsibilities, including audits and risk assessments, with management committees such as the Sustainability Committee playing a dedicated role (p.13). The report also indicates that sustainability-related risks and opportunities are embedded within Board oversight and the Enterprise Risk Management framework, influencing strategic planning and business decisions (pp.6, 16, 17). However, there is no clear evidence regarding integration with risk, finance, legal, internal audit, or other functions, nor is there specific information on oversight over delegated roles.

Hyundai Engineering & Construction Co.,Ltd.

Construction and Engineering · South Korea · 2025

Open report →

Hyundai Engineering & Construction Co., Ltd.’s 2025 Sustainability Report provides coverage on the delegated management role committee and the oversight exercised over that role, both detailed on page 140. The report also references management’s role in governance processes, controls, and procedures used to monitor and manage climate-related risks and opportunities (p.140). However, disclosures on the specific controls and procedures used and the integration of sustainability-related risks with risk, finance, legal, or internal audit functions remain unclear, with only related context found on pages 138 and 140.

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Check your understanding

Scenarios to work through

A finance director has asked the sustainability lead to run the day-to-day climate reporting process, with input from risk and internal audit. The board wants to know how that arrangement is controlled and who checks the work.

QWhat should the preparer explain about the way this delegated role is set up and monitored?

Reveal model answer →Hide answer ↑

Describe the practical controls and checks around the delegated role, including how it links with other functions such as risk, finance, legal or internal audit, and how the board or its committees keep oversight of the work. The explanation should show both the assignment of the task and the supervision around it, using wording adapted to the organisation and checked against the source before sign-off.

Why this matters · Show both the delegation itself and the control framework around it, not just who does the work.

A sustainability committee has been given responsibility for preparing the climate section, while the main board receives a summary only at year end. The reporting team is unsure whether that committee arrangement is enough to describe in governance disclosures.

QHow should the team decide what to say about the committee’s role?

Reveal model answer →Hide answer ↑

State clearly that a committee or similar management group has been given the task, and explain what part of the reporting process it handles. Keep the description factual and specific to the organisation, and make sure it is clear how that group sits within the wider governance setup before finalising the wording.

Why this matters · Name the delegated group and its job in plain language, with enough detail for readers to understand its place in the process.

The legal team reviews external climate claims, the finance team checks assumptions in the numbers, and internal audit tests the reporting controls. The sustainability manager is unsure whether these links need to be described together or separately.

QWhat is the right way to present the involvement of these other functions?

Reveal model answer →Hide answer ↑

Bring out how the delegated reporting role is connected to the relevant support functions, whether that is risk, finance, legal, internal audit or another part of the business. The point is to show the joined-up process around the management role, not to list departments without explaining their contribution.

Why this matters · Explain the cross-functional links that support the delegated role and make the process credible.

A board committee has delegated climate reporting to management, but the board only receives a short dashboard and does not review the underlying controls. The reporting team is drafting governance text and is unsure whether that limited review is enough to mention.

QWhat should the disclosure make clear about oversight of the delegated role?

Reveal model answer →Hide answer ↑

Explain how the board or its committees keep watch over the delegated work, including what they review and how they stay informed. If oversight is limited, describe it honestly and in a way that matches the organisation’s actual practice, then check the source wording before sign-off.

Why this matters · The disclosure should show real oversight of the delegated role, not just the existence of delegation.

Framework references

Relevant IFRS / ISSB requirements and related disclosures

Available framework references and nearby disclosures relevant to preparing this requirement.

IFRS / ISSB

s1-27-b

within IFRS S1: General Requirements for Disclosure of Sustainability-related Financial Information

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Primary

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Fair presentation →Materiality →Reporting entity →Connected information →Core content architecture →Browse all disclosures →

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Go deeper · s1-27-b

Learn to prepare this disclosure end-to-end

This guide covers one requirement. The IFRS S1 & S2 Reporting course walks the full ISSB workflow — governance, strategy, risk management and metrics — with exercises on your own data.

Available as Guided Flex, Live Cohort, 1:1 Expert Mentorship or Corporate Programme.

Explore the IFRS S1 & S2 course →

FAQ

Questions this page answers

For s1-27-b, what data do I need to gather before I start drafting the disclosure?+−

The page says to prepare four datapoints: controls and checks, delegated role or committee, cross-functional integration, and delegated role oversight. Use those as the starting checklist before you draft anything.

How do I use the step-by-step 'how to prepare' section for s1-27-b in practice?+−

Use it as a working sequence for collecting the right inputs, checking what evidence exists, and turning that into a draft. The page is designed to help you move from preparation to a report-ready output.

What should I include in the evidence pack for s1-27-b if I want to be assurance-ready?+−

The page includes an evidence pack with five items to support assurance readiness. Build it around the claims, risks and evidence approach shown on the page so you can show how the disclosure was prepared and checked.

What are the five assurance claims I need to verify for s1-27-b?+−

The page says there are five assurance claims to verify, each framed around a claim, risk and evidence. Use that structure to test whether your draft is supported and whether the evidence pack is complete.

What are the common reporting gaps or mistakes to avoid when drafting s1-27-b?+−

The page lists common reporting gaps and mistakes so you can spot weak spots before sign-off. Use that section as a pre-submission check against missing evidence, unclear ownership or incomplete drafting.

How should I assign ownership for the s1-27-b disclosure across HR, ESG and other teams?+−

The page points you to delegated role or committee, cross-functional integration, and delegated role oversight. In practice, that means you should show who owns the work, who contributes, and how oversight is tracked.

What does 'cross-functional integration' mean for the s1-27-b data collection process?+−

The page treats cross-functional integration as one of the datapoints to prepare, so it is something you should evidence rather than assume. Use it to show how different teams feed into the disclosure and how the information is coordinated.

How do I turn the s1-27-b page into a draft disclosure with narrative and visuals?+−

The draft-output section gives visualisation ideas, narrative starters and a content-index line. Use those to move from raw inputs to a structured draft that is easier to review and finalise.

Which download should I use for s1-27-b: the Prep & Assurance workbook or the printable Library Card?+−

The Download Centre offers both a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook for working through the disclosure and the PDF if you want a quick reference copy.

Can I use the 'From company reports' table to find real examples for s1-27-b?+−

Yes. The page includes a table linking to real published reports at the pages where the topic is disclosed, which can help you see how others have presented similar information.

Is there an ESRS cross-reference for s1-27-b, and can I reuse the same data?+−

The page says the closest ESRS correspondence is ESRS 2 (General Disclosures). You can treat that as a useful cross-framework reference point and reuse the same underlying data where it fits your reporting process, but the page does not say the requirements are identical.

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	Report A	Report B	Report C
Datapoint 1	✓ p.213	unclear	✓ p.87
Datapoint 2	✓ p.214	—	✓ p.90

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Management role in governance

Key information to prepare

How to prepare it

Request board delegation and oversight evidence

Notes that turn data into a disclosure

Preparation tools & forms

For each claim, check the evidence

Evidence pack to prepare

Common reporting gaps

Mistakes to avoid when collecting the data

Where judgement is often needed

Illustrative examples

How companies report S1-27-b in practice

Scenarios to work through

Relevant IFRS / ISSB requirements and related disclosures

Questions this page answers

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