Disclosure focus
This disclosure asks an organisation to report the metrics it uses to track each sustainability-related risk and opportunity that it has identified. In practice, that means explaining the measures, indicators or calculations that are most relevant to how the organisation monitors performance, exposure or progress for each issue, rather than giving only a general narrative.
The practical focus is on using metrics that are meaningful for the business and applied consistently enough to show what is happening across the organisation. Coverage should be considered across the relevant parts of the business, not just a few flagship sites or isolated examples, so readers can understand the scale and spread of the risk or opportunity being measured.
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 s1-46-48 sub-elements (LRA working checklist)
Use the IFRS metrics that apply to the entity.
Explain how you chose metrics where no specific standard applies.
Set out the entity’s own monitoring measures.
State which industry-based measures were used.
List the performance measures used.
How to prepare it
1Set the reporting boundary first. Decide which parts of the business, operations and value chain are in scope for the measures you will report, so the same boundary is used consistently across the pack.
2Work out what each measure means in your organisation. For any metric tied to a named reporting source, use that source as the basis; where no named source fits, record the logic you used to choose the measure and why it is the right one for your circumstances.
3Gather the support for every figure or narrative. Pull together source files, calculations, assumptions, system extracts and sign-offs so each reported item can be traced back to evidence.
4Prepare the reported outputs in the right form. Some items will be numerical measures, while others will be explanatory text; make sure the final presentation matches the type of information being reported and is internally consistent.
5Record anything you left out or changed. If a measure is not included, or if the way it is calculated, selected or presented has changed, note the reason and the nature of the change clearly enough for a reviewer to follow.
6Check the draft against the official source before sign-off. Confirm that the measures you have used are the ones required or selected, that the evidence is complete, and that your wording and calculations still match the underlying source material.
Request the data
Request the metrics pack from Finance
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What measures are we using to track each sustainability-related risk or opportunity, and what is the basis for each measure?
Use your organisation’s own reporting and performance terms first, then map them to the disclosure. Ask for the measures the business already tracks, the source they come from, and the reason each one was chosen. Do not use framework wording with the owner unless that is how they already speak internally.
Weak request
Please provide the sustainability metrics required for the disclosure, including the applicable metrics, the basis for selection where no specific standard applies, entity-specific monitoring metrics, industry-based metrics used, and performance metrics.
Why it fails: This uses framework language that many operational owners will not recognise, so it is harder to action. It also does not say which business issue the measures relate to, what source to pull from, or what practical evidence is needed to support the figures and the reason they were chosen.
Better request
Please send the measures your team already uses to track [risk/opportunity name] for [period], with the source file/system, calculation method, and a short note on why each measure is used. If you have both standard business KPIs and team-specific measures, include both and identify the main management view.
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
Start by explaining how each measure was chosen, including the basis used when no named reporting rule applies, and make clear whether it comes from the framework, the entity’s own monitoring, or sector practice.
Context note
Set out what the chosen measures are intended to show about performance, so readers can understand how the numbers relate to the business’s reporting approach and decision-making.
Fluctuation statement
If any measure changes materially, explain whether that is due to a different selection basis, a revised internal monitoring approach, or a shift in the measures used for reporting.
Content index entry
s1-46-48 Metrics for each sustainability-related risk and opportunity — [location / page] / [notes]
Download Centre
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 asked
The team chases the sustainability lead for figures that sit with finance, operations, HR, or risk, so the first data request goes to someone who does not hold the source records.
Framework terms used too early
People ask for the data using disclosure language instead of the organisation’s own operational labels, and the right dataset is missed because staff do not recognise what is being requested.
Scope not pinned down
The request does not say which business units, sites, or activities are in scope, so different teams send numbers from different parts of the organisation that cannot be compared.
Boundary left unclear
The collector does not state whether the count should follow the group, a division, or a project boundary, which leads to figures being pulled from the wrong population.
Wrong period basis
Data is gathered for the wrong time window or cut-off point, so the numbers reflect a different reporting period from the one being prepared.
Counting methods mixed
One team sends headcount, another sends full-time equivalent, and a third sends transaction totals, but the measures are merged as if they were the same basis.
Source labels stripped out
Original field names, system codes, and file tags are removed during collection, so later reviewers cannot trace each figure back to the record it came from.
Populations merged by mistake
Separate groups that should stay distinct, such as sites, product lines, or risk areas, are combined into one file and the underlying differences are lost.
Evidence trail missing
The collector saves the number but not the supporting file version, extraction date, or reviewer note, leaving no clear trail for later checking.
No sign-off record
The final dataset is circulated without a named reviewer or approval note, so nobody can show who checked the figures before they were used.
Where judgement is often needed
Set the reporting perimeter after buy-sell changes
If a business has been bought or sold during the period, state whether the figures cover the old group, the new group, or a like-for-like view, and explain the cut-off used so readers can see what changed.
Choose one country rule when local definitions differ
Where the same measure is defined differently across countries, pick one basis for the group, apply it consistently, and explain the local differences that were bridged or excluded.
Decide how to treat sites or teams on the boundary
For operations, assets, workers, customers, or suppliers that sit partly inside and partly outside the scope, explain the inclusion rule used and whether any borderline cases were counted, split, or left out.
State the timing basis for the numbers
If the measure is taken at period-end, averaged over the year, or linked to a different cut-off, say which timing basis was used and why it best matches the risk or opportunity being tracked.
Show when estimates stand in for direct measurement
Where the figure is built from models, proxies, sampling, or management judgement rather than direct counts, identify the method, the main assumptions, and any known limits on accuracy.
Round in a way that does not distort the picture
If rounding changes the displayed total or component figures, explain the rounding rule used and make sure the published numbers still reconcile in a sensible way to the underlying data.
Aggregate sensitive data to protect privacy
When detailed people or location data cannot be shown because of privacy or confidentiality limits, combine the information to a level that protects individuals and explain the aggregation approach and any resulting loss of detail.
Separate group-wide measures from issue-specific measures
If you use both broad monitoring measures and issue-specific performance measures, explain which numbers are used for each risk or opportunity and how each one helps track progress.
Explain the basis for any non-standard metric
When no specific standard fits and you choose your own measure, set out the selection basis, the data source, and why that measure is the best fit for the matter being tracked.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — manufacturing
We report the measures that the relevant IFRS sustainability rules call for, and where no sector rule exists we explain why we chose the measures we use. In our case, we track three company-specific indicators alongside two industry-style measures, and we also show the performance measures used by management: 92% of production sites met the energy-intensity target (46 of 50), and 8 sites did not.
- The measures we disclose include the IFRS-linked items that apply to our business, plus our own operational indicators where the framework leaves room for judgement.
- For each company-specific measure, we state the reason it was selected, including how it reflects our exposure, controls, or decision-making needs.
- We also identify the sector-style measures we use and the performance measures monitored by management, so readers can see how the numbers are used in practice.
This example shows how a reporter can describe the metrics it uses, explain why any self-chosen measures were selected, and distinguish between externally aligned measures and internal management indicators.
Illustrative (synthetic) example — financial services
We set out the sustainability measures that apply to our group under the IFRS framework, then add the indicators we monitor internally where no specific rule points to a single measure. Our reporting pack includes four externally driven measures, two business-specific metrics chosen because they best capture our risk profile, and three industry-based indicators used by management; for example, 18 of 20 portfolio reviews were completed on time, or 90%, and 2 were late.
- We name the IFRS-linked measures that are relevant to our activities and explain any judgement used where the framework does not prescribe one exact figure.
- We describe the basis for each internal metric we selected, linking it to the way we manage the business and assess sustainability-related effects.
- We also show the sector-based indicators and the performance measures used by management, so the reader can follow both external reporting and internal oversight.
This example illustrates a second plausible reporter using the same disclosure logic, but with different figures and a different mix of externally driven, sector-based, and internal measures.
How companies report S1-46-48 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 includes reported values for applicable IFRS required metrics and performance metrics related to sustainability risks and opportunities, as noted on page 191. The report provides some context on processes and policies for monitoring climate-related issues (p.196) and references industry-based metrics in the SASB Index (p.180), but these disclosures are not clearly detailed. Additionally, the basis for selecting metrics where no specific standard applies is mentioned on page 51 but lacks a clear explanation.
Land Securities Group Plc
Real Estate · United Kingdom · 2025
Land Securities Group Plc’s 2025 Sustainability Performance and Data Report includes entity-specific monitoring metrics such as the number of assets on page 41 and industry-based metrics related to carbon emissions from business travel, employee commuting, and downstream leased assets on page 9. However, the report does not provide clear evidence of applicable IFRS-required metrics or performance metrics. Additionally, the basis for selection where no specific standard applies is mentioned in a general context on page 42 but lacks a clear, detailed disclosure.
Nedbank Group
None · South Africa · 2025
Nedbank Group’s 2025 Climate Report includes coverage of performance metrics used to evaluate and address climate-related risks and opportunities, with relevant information found on page 70 and further details on pages 71 and 88 (p.70, p.71, p.88). The report states that it has applied the principles, core content, and disclosure objectives of IFRS S1 and IFRS S2 to the extent practicable, using a climate-first approach (p.4). However, there is no clear disclosure of applicable IFRS-required metrics (p.4), and no evidence was found regarding the basis for selection where no specific standard applies, entity-specific monitoring metrics, or industry-based metrics.
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Scenarios to work through
A manufacturer has one climate-related supply risk and one water-efficiency opportunity. The team has a sector benchmark for the climate risk, but the water opportunity is being tracked with an internal yield measure because no sector measure fits well.
QHow should the preparer decide what to include for each item, and what evidence should sit behind the choice?
Reveal model answer →Hide answer ↑For each risk or opportunity, the preparer should show the metric or metrics used to track it, and keep support for why those measures were chosen. Where a sector measure is available and used, that should be identified; where no sector measure fits, the file should explain the logic for the alternative measure and how it links to the matter being monitored.
Why this matters · Each risk or opportunity needs a clear metric trail, with the reason for the chosen measure documented when a sector measure is not the right fit.
A retailer reports a labour-supply risk using a staff turnover rate and a training completion rate. The sustainability team also tracks a bespoke absenteeism indicator, but it is not yet used in management reporting.
QShould the preparer include the bespoke indicator as part of the reported measures for that risk?
Reveal model answer →Hide answer ↑Only if the indicator is actually used to monitor the risk or opportunity in practice. A measure that sits outside the organisation’s monitoring process should not be presented as part of the reported set; the disclosure should reflect the measures that are genuinely used to track the matter.
Why this matters · Reported measures should match the organisation’s real monitoring approach, not just any data it happens to collect.
A mining group has a biodiversity-related opportunity and uses a mix of sector measures and an internal restoration scorecard. The scorecard was built by the sustainability team, but the finance team is unsure whether it is too bespoke to mention.
QHow should the preparer treat the internal scorecard in the disclosure?
Reveal model answer →Hide answer ↑If the scorecard is used to monitor the opportunity, it can be included as an entity-specific monitoring measure, alongside any sector measures used. The disclosure should make clear that it is an internal measure and explain its basis in plain terms so users can understand what it captures and why it is relevant.
Why this matters · Internal measures are acceptable when they are genuinely used and their basis is explained clearly.
A services company has two material sustainability matters: one is tracked with a sector measure, the other with a custom client-retention metric. The draft note lists the measures, but it does not say which ones are sector-based and which are internal, and it gives no explanation for the custom metric.
QWhat should the preparer do before sign-off?
Reveal model answer →Hide answer ↑The note should separate the measures by type, identify which ones come from sector practice, and explain the basis for any custom measure used where no sector measure applies. That way, users can see both the tracking method and the reasoning behind it for each matter.
Why this matters · Users need to see both the measure used and whether it comes from sector practice or from the organisation’s own design.
Framework references
Relevant IFRS / ISSB requirements and related disclosures
Available framework references and nearby disclosures relevant to preparing this requirement.
IFRS / ISSB
s1-46-48
within IFRS S1: General Requirements for Disclosure of Sustainability-related Financial Information
Open official source →Related & explore
FAQ
Questions this page answers
For IFRS S1 s1-46-48, what data do I need to gather before I start drafting the disclosure?+−
The page says to prepare the IFRS metrics used, the basis for selecting them, any company-specific metrics, any industry metrics used, and the reported performance measures. Use that list as your starting data set before you draft anything.
How do I use the step-by-step preparation section for IFRS S1 s1-46-48 in practice?+−
Use it as a working sequence rather than a checklist to read once: it is there to help you move from scoping and data collection through to a draft disclosure. The page is designed to support a practical build, not just a read-through.
What should I include in the scope and methodology notes for this disclosure?+−
The page points you to the selection basis for the metrics and the reported performance measures, so your notes should explain what was chosen and how the figures were put together. Keep the method clear enough that someone else can follow the same approach.
Who should own the inputs for IFRS S1 s1-46-48 in a company workflow?+−
The page is aimed at sustainability or ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the people who can explain the metric choice, source data, and performance figures. The practical aim is to make one person or team accountable for each input in the pack.
What evidence do I need to build for assurance on IFRS S1 s1-46-48?+−
The page includes five assurance claims to verify and a five-item evidence pack for assurance readiness. Use those to assemble support for the claim, the risk, and the evidence behind each reported point.
What are the common mistakes or reporting gaps to avoid on this disclosure?+−
The page has a section on common reporting gaps and mistakes, so use it to check for missing metric choices, weak explanations, or unsupported performance figures. It is meant to help you spot issues before the draft goes out for review.
How do I use the Prep & Assurance workbook for IFRS S1 s1-46-48?+−
The workbook is one of the downloads on the page and is intended to support preparation and assurance readiness. Use it to organise the datapoints, evidence, and draft outputs in one place.
What is the printable Library Card PDF for this disclosure page used for?+−
The page says the Download Centre includes a printable Library Card PDF alongside the workbook. It is there as a practical companion for the disclosure page, so you can keep the key points to hand while you work.
Can I use the synthetic example disclosure on the page as a template for my own draft?+−
Yes, as a drafting aid only. The example is synthetic and includes a quantitative table, so it can help you see how the disclosure might look, but you still need to replace it with your own internally consistent data.
How can I turn the page content into a first draft for IFRS S1 s1-46-48?+−
Use the draft-output section: it gives visualisation ideas, narrative starters, and a content-index line. That makes it easier to move from raw data and evidence into a structured draft.
Is the ESRS 2 correspondence on this page enough to reuse my data for another framework?+−
The page says the closest ESRS correspondence is ESRS 2, so the data may be reusable across reporting work. Treat that as a practical cross-reference, not as a statement that the requirements are identical.
More questions this page can help with
What should I pull together first for IFRS S1 s1-46-48 if I am starting from scratch?How do I decide which IFRS metrics and industry metrics to include for this disclosure?What does the selection basis need to show for IFRS S1 s1-46-48?How do I make sure the reported performance measures are ready for review?What should go into an evidence pack for this disclosure page?How do I assign ownership for the data behind IFRS S1 s1-46-48?What are the most common mistakes people make when drafting this disclosure?How do I use the synthetic example table without copying it into my report?Where do I find the real company report links on the page and how should I use them?How do the narrative starters help me write the disclosure faster?What is the best way to use the content-index line in the draft-output section?Can the ESRS 2 correspondence help me reuse the same data pack for another report?
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