Disclosure focus
This disclosure asks an organisation to explain how sustainability-related matters are built into strategy and day-to-day decision-making. In practice, it is about showing whether leaders consider these matters when setting direction, making choices, and allocating resources, rather than treating them as a separate or occasional topic.
The practical focus is on the organisation’s real decision-making process across the business, not just on a few flagship sites or isolated examples. The report should make clear where sustainability-related considerations are applied, how consistently they are used across operations, and how they influence strategic choices and management actions.
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 information to prepare
＋ Show s1-33 sub-elements (LRA working checklist)
Describe the actions being taken now in response.
Set out the actions intended for later response.
Explain what has been achieved against earlier plans.
Provide evidence of progress using numbers, narrative, or both.
Show which trade-offs were weighed when decisions were made.
How to prepare it
1Set the reporting boundary first: decide which response actions sit inside this disclosure, and separate what is already being done from what is only planned.
2Define the content for each item in plain business terms, so you can distinguish current actions, future actions, progress since the last plan, the evidence of that progress, and the compromises weighed in decision-making.
3Gather support for each point from the underlying records, such as internal papers, trackers, approvals, metrics, or narrative notes that show what was done and what was intended.
4Prepare the disclosure content by pairing each required item with the right form of information: a factual description where the item is narrative, and figures or other measurable detail where the item calls for progress evidence.
5Record any gaps, exclusions, or changes in approach, including where a prior plan has shifted, so the reader can see how the current position differs from earlier expectations.
6Check the draft against the official source before sign-off, confirming that every required item is covered, the wording matches the underlying evidence, and nothing material has been left out or misstated.
Request the data
Request the strategy and decision evidence pack
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What actions are being taken now, what is planned next, what progress has been made against earlier plans, what evidence shows that progress, and what trade-offs were weighed when decisions were made?
Use your organisation’s own wording first, then map it to the disclosure labels. For example, if you talk about programmes, initiatives, priorities, or management actions internally, keep those terms in the request and only translate them afterwards for reporting. This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off.
Weak request
Please provide the IFRS S1 strategy and decision-making evidence required for disclosure ifrs-s1::s1-33.
Why it fails: This uses framework language rather than the organisation’s own terms, so the owner may not know which documents, meetings, or trackers to search. It also does not separate current actions, planned actions, progress, evidence, and trade-offs into a practical ask.
Better request
Please send the current programme actions, next planned steps, progress against earlier plans, supporting evidence, and the main trade-offs considered for [business area] in [reporting period]. Use your team’s normal terms and include links to the source papers, tracker, or dashboard.
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
Define the scope of the response information you have gathered, explain how you distinguished actions already underway from those still being prepared, and state the basis used to judge progress and the evidence relied on.
Context note
Explain what the response data indicates about how the organisation is managing the issue, including what has been done, what remains planned, how far earlier intentions have been delivered, and what the evidence suggests about effectiveness.
Fluctuation statement
If the pattern has changed over time, describe the main reasons for that movement, such as shifts in priorities, updated evidence, or revised balancing of competing considerations.
Content index entry
s1-33 Strategy and decision-making — [location / page] / [notes]
Download Centre
Preparation tools & forms
Professional preparation tools for s1-33 — 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 team asks the board secretary or sustainability lead for operational evidence when the real source sits with the business manager, project owner, or finance contact who actually tracked the action.
Using framework language too early
People request information in disclosure terms instead of the organisation’s own labels, so teams cannot map the request cleanly to their working files or systems.
No clear boundary
The collector does not define which business units, projects, or response activities are in scope, so different teams send mixed sets of records that cannot be compared.
Wrong time basis
Evidence is pulled from the wrong reporting window or from a later update, so the file no longer matches the period being described.
Mixed counting basis
One source counts individual actions while another counts cases, sites, or approvals, and the final pack blends them as if they were the same measure.
Source labels stripped out
Original file names, system tags, or reference codes are removed during consolidation, making it hard to trace each item back to the first record.
Separate groups merged
Current actions, future actions, and progress evidence are combined into one list even though they need to stay separate for review and sign-off.
Missing evidence trail
The pack contains the numbers or narrative but not the supporting notes, dates, or document references needed to show where each item came from.
No sign-off record
Draft data moves through email or chat without a named reviewer and approval trail, so nobody can show who checked the figures and when.
Where judgement is often needed
Acquisitions and disposals during the reporting period
Set a clear cut-off for when a bought-in business or sold unit enters or leaves the reporting population, and explain any restatement or non-restatement of prior figures so the trend line is understandable.
Different local meanings for the same operational measure
Where country teams use different definitions for the same activity or risk, choose one group-wide basis or explain the mapping between local and central versions so readers can compare like with like.
Borderline sites, teams, or activities
Decide whether items just inside or just outside the reporting boundary are included, then disclose the rule used and any exclusions or inclusions that materially affect the picture.
Timing of action plans and progress updates
Be explicit about whether progress is shown at the date of the period end, at a later management review point, or on another basis, and state the timing used consistently.
Measured data versus management estimates
If some figures come from direct records and others from estimates, say which is which, describe the estimation approach in plain terms, and flag where judgement affects the result.
Rounding and small numerical differences
Apply one rounding approach across the disclosure, and if totals do not exactly match the parts because of rounding, note that the difference is purely presentational.
Privacy limits on people-related detail
When individual-level information cannot be shown, aggregate it enough to protect privacy while still giving a meaningful view of the actions taken, progress made, and trade-offs considered.
Comparability after a change in scope or method
If the population, calculation basis, or evidence source changes from one period to the next, explain the change and, where helpful, provide a bridge so users can see what moved and why.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — manufacturing
We are **synthetically illustrating** how our company might describe its response to a climate-related risk and the way we track delivery. In the current year, we installed heat-recovery equipment at 3 of 5 sites, updated maintenance routines, and shifted 40% of planned capital spend toward lower-energy machinery; for next year, we have approved a further 2 site upgrades and a supplier review to reduce downtime risk.
- Compared with the prior plan, 3 site upgrades were completed on time, while 1 was delayed by permitting and moved into the next cycle.
- The completed actions cut electricity use at the upgraded sites by 12% versus the same period last year, and unplanned stoppages fell from 10 to 7 events.
- In deciding what to do first, we weighed faster emissions and cost savings against short-term disruption to production and chose the sequence that protected output while still improving resilience.
Synthetic illustration only: this shows how a reporter could describe what it is doing now, what it intends to do next, how delivery compares with the earlier plan, what evidence shows movement, and the trade-offs that shaped the choices.
Illustrative (synthetic) example — food retail
We are **synthetically illustrating** how our group might explain its response to a water-stress issue and the way we judge progress. This year we fitted low-flow fixtures in 18 of 30 stores, trained site managers on leak checks, and moved 25% of refurbishment spend toward water-saving works; next year we plan to cover the remaining 12 stores and add remote monitoring at 10 high-use locations.
- Against the earlier plan, 18 stores were completed, 2 were deferred because contractors were unavailable, and the remaining work stayed within the revised timetable.
- Water use in the upgraded stores fell by 9%, and leak-related callouts dropped from 22 to 14, giving us practical evidence that the measures are working.
- When choosing between options, we balanced lower water demand and lower running costs against higher upfront spend and some store disruption, and selected the mix that gave the best overall result.
Synthetic illustration only: this example shows a plain-language way to cover present measures, next steps, delivery versus the earlier plan, measurable and descriptive signs of movement, and the trade-offs behind the decision.
How companies report S1-33 in practice
Examples of full and partial reporting practice. These are evidence-led reviews, 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 shows that the company has both responded to and plans to respond to sustainability-related risks and opportunities within its strategy and decision-making processes (p.188). The report includes some context related to progress against prior plans and assessments of the resilience of its strategy, but these disclosures are not clearly detailed or quantified (pp.189, 193). There is no evidence in the report regarding consideration of trade-offs in decision-making.
DBS Group Holdings
None · Singapore · 2025
DBS Group Holdings’ Sustainability Report 2025 includes evidence of current response actions to climate-related risks identified through scenario analysis, as noted on page 114. The report also references governance structures overseeing sustainability disclosures and climate-related targets, with some related context on progress against prior plans mentioned on page 8, though this is not clearly detailed. However, the report does not provide information on planned response actions, quantitative or qualitative progress evidence, or trade-offs considered in decision-making.
Hang Lung Properties Limited
Real Estate · Hong Kong · 2025
Hang Lung Properties Limited’s Sustainability Report 2025 provides evidence of progress against prior plans, specifically detailing progress against KPIs and targets related to climate mitigation and adaptation on page 30. The report also references its approach to sustainability goals, targets, and KPIs, including monitoring progress towards strategic goals and regulatory targets on pages 220 and 232. However, there is no clear disclosure of current or planned response actions, and while sustainability-related risks and opportunities are mentioned on page 218, the consideration of trade-offs in decisions remains unclear.
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Scenarios to work through
A group has already started a programme to cut water use at two factories. In the current reporting cycle, the team has updated the board pack with what is being done now, what will happen next, and a short note on how last year’s plan is progressing.
QWhat should the preparer include so the disclosure shows both the live response and the next steps, rather than only one of them?
Reveal model answer →Hide answer ↑The write-up should cover the actions already under way and the actions planned for later, so readers can see the organisation’s present response and its intended follow-up. It should not collapse everything into a single generic description.
Why this matters · Separate what is happening now from what is planned next, and present both clearly.
A finance team says the prior year’s climate adaptation plan is “on track” because the project is still open. However, no one has gathered any figures, milestones, or other evidence to show what has actually changed since the last report.
QCan the preparer rely on a broad status label alone, or is more support needed to explain progress against the earlier plan?
Reveal model answer →Hide answer ↑A broad label is not enough on its own. The disclosure should explain how far the earlier plan has moved forward and back that up with evidence that can be described in numbers, facts, or other concrete observations, depending on what is available.
Why this matters · Progress claims need supporting evidence, not just a headline status.
A company is deciding whether to invest in a cleaner production line or keep funding a faster expansion project. The board wants the report to explain why the cleaner option was chosen, but the draft only states the final decision and omits the competing considerations.
QWhat should the preparer add so the report shows the reasoning behind the choice?
Reveal model answer →Hide answer ↑The disclosure should explain the competing factors that were weighed when the decision was made, including the practical give-and-take between options. That lets readers understand why one course was preferred over another.
Why this matters · Show the main trade-offs that shaped the decision, not just the outcome.
A sustainability lead has a draft section that lists last year’s emissions target, the current reduction actions, and a short note saying the target was missed. The draft does not say whether the team has any new actions planned or what evidence supports the progress statement.
QWhat is missing if the aim is to give a complete picture of the organisation’s response and progress?
Reveal model answer →Hide answer ↑The draft still needs the next set of response actions and a clearer explanation of progress, supported by evidence that shows what has changed since the earlier plan. Without that, the reader cannot see the full response cycle or judge the update properly.
Why this matters · A complete update links past plans, current action, future action, and evidence of movement.
Framework references
Relevant IFRS / ISSB requirements and related disclosures
Available framework references and nearby disclosures relevant to preparing this requirement.
IFRS / ISSB
s1-33
within IFRS S1: General Requirements for Disclosure of Sustainability-related Financial Information
Open official source →Related & explore
FAQ
Questions this page answers
How do I use the s1-33 page to draft a first-pass disclosure for IFRS S1 general requirements?+−
Start with the plain-language explainer, then work through the datapoints to prepare and the step-by-step preparation section. The page also gives narrative starters and a content-index line you can use to turn your notes into a draft.
What data do I need to gather for s1-33 before I can write the disclosure?+−
The page points you to five datapoints: current response steps, next response steps, follow-up progress, progress evidence metrics, and decision trade-offs. Use those as your minimum data checklist before drafting.
How should I scope the s1-33 disclosure so I can collect the right information from HR, ESG and other owners?+−
Use the page’s step-by-step preparation section to break the disclosure into the five datapoints and assign each one to the person who holds the underlying information. That helps you collect a complete set of inputs without mixing narrative, metrics and evidence.
What should go into the evidence pack for s1-33 if I want to be assurance-ready?+−
The page includes a five-item evidence pack for assurance readiness, alongside five assurance claims to verify. Build the pack around the claim, the risk it addresses and the supporting evidence so a reviewer can trace the draft back to source material.
What are the common mistakes people make when preparing s1-33 disclosures?+−
The page lists common reporting gaps and mistakes, so it is meant to help you spot missing data, weak evidence and incomplete drafting before sign-off. Use that section as a pre-submission check against your draft and evidence pack.
How do I use the Prep & Assurance workbook for s1-33?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is intended to help you organise preparation and assurance inputs. Use it alongside the page’s datapoints, evidence pack and assurance claims to build a working draft.
What is the printable Library Card PDF for s1-33 used for?+−
The Download Centre also provides a printable Library Card in .pdf format. It is there as a quick-reference companion to the page content, so you can keep the disclosure steps, evidence needs and common gaps in one place.
Can I use the synthetic example disclosure on the s1-33 page as a model for my own draft?+−
Yes, the page includes synthetic illustrative example disclosures, including a quantitative table where relevant. Treat them as examples of structure and presentation only, then replace the figures and wording with your own company data.
How do I turn the s1-33 page content into a draft narrative and content-index line?+−
Use the draft-output section, which gives visualisation ideas, narrative starters and a content-index line. That section is designed to help you move from collected data to a readable draft without starting from a blank page.
Is there a cross-framework way to reuse data from s1-33 for ESRS 2 General Disclosures?+−
The page notes ESRS 2 (General Disclosures) as the closest correspondence, so the same underlying data may be reusable across frameworks. Do not assume the reporting asks are identical; use the page as a practical bridge, not a substitute for framework-specific review.
More questions this page can help with
What are the five datapoints listed on the s1-33 page and how do I use them in a working paper?How do I assign ownership for s1-33 preparation across ESG, HR and finance teams?What evidence should I keep for each s1-33 assurance claim?How do I check my s1-33 draft against the common reporting gaps on the page?What should I pull from the from company reports table when preparing s1-33?How do I use the step-by-step how to prepare section for s1-33?What belongs in the progress evidence metrics for s1-33?How do I document decision trade-offs for s1-33 in a way an assurance reviewer can follow?How do I use the narrative starters on the s1-33 page to write a disclosure?What is the best way to combine the workbook, library card and example disclosures for s1-33?How do I avoid overclaiming in an s1-33 draft when the evidence is still partial?What does the page mean by follow-up progress for s1-33 and how should I evidence it?
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