Disclosure focus
This disclosure asks an organisation to explain how it is responding to climate-related risks and opportunities through its strategy, including whether it has a transition plan. In practice, the report should show what the organisation intends to do, how those actions fit into its wider business plans, and whether the response is already being put into effect or is still being developed.
The practical focus is on the organisation’s overall approach, not just a few headline projects or flagship sites. Readers should be able to understand whether the response covers the business as a whole, how far it reaches across operations and value chain where relevant, and what parts of the organisation are included in the plan.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official IFRS source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key information to prepare
＋ Show s2-14-a sub-elements (LRA working checklist)
Describe any changes to the way the business makes money or allocates resources.
Set out the actions the organisation takes directly to reduce harm or adapt.
Explain the steps taken through suppliers, customers or other parts of the value chain.
State the main assumptions and dependencies that the plan relies on.
Summarise the organisation’s chosen responses to the issue.
Show the route the organisation expects to follow to meet its target.
Outline the transition plan in practical terms.
How to prepare it
1Set the boundary for the disclosure first. Decide which parts of the business, value chain and planning horizon you are covering, so the same scope is used for every item in this disclosure.
2Agree what each item will mean in your report. For every required point, define the business changes, direct actions, upstream or customer-linked actions, assumptions, dependencies, strategic responses, the route to target delivery, and the transition plan in terms your team can apply consistently.
3Gather support for each point before drafting. Pull together board papers, project papers, budgets, implementation plans, scenario work, target trackers, and any other records that show the position you are reporting.
4Draft the figures or narrative for each required point. Where the item is qualitative, write a clear explanation; where it is quantitative, compile the numbers and make sure they tie back to the underlying records.
5Record anything left out or revised. If you have excluded a matter, changed a method, or updated an estimate, note what changed, why it changed, and whether the same approach was used across the disclosure.
6Check the draft against the official source before sign-off. Confirm that every required point is covered, the wording matches the underlying evidence, and the final version is consistent with the source material and internal approvals.
Request the data
Request the strategy and transition evidence pack
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What changes, actions, assumptions and pathway are we using to explain how the business is responding and moving towards the target state?
Use your organisation’s own planning and programme language first, then map it to this disclosure. For example, ask for the strategy update, transformation roadmap, decarbonisation plan, or change programme if those are the terms your teams actually use. Keep the request in business terms and check the source material before sign-off.
Weak request
Please provide the IFRS S2 strategy response and transition plan evidence for the disclosure.
Why it fails: It uses framework language only, so the owner has to translate the ask from scratch. It does not say which internal pack, system, version, or business terms to use, and it does not separate the different pieces of evidence needed.
Better request
Please send the latest strategy, transformation, or transition pack for [period] that shows: plan changes, direct actions, supplier/customer-linked actions, assumptions and dependencies, the response we are taking, the pathway to the target state, and any transition roadmap. Include version, approval date, owner, and links. If your team uses different labels, send the equivalent internal pack and I will map it.
Industry examples
Draft your disclosure
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
Describe the basis used to compile the disclosure, including how the business defined each action category, what period the data covers and how management judged whether an item belongs in the plan.
Context note
Explain that the figures show how the organisation is reshaping operations, spending and wider value-chain activity to support its transition route and target pathway, rather than a standalone list of initiatives.
Fluctuation statement
If the numbers moved materially, explain whether that was driven by timing, revised assumptions, changed priorities, new actions or progress in delivery, and note any one-off effects.
Content index entry
s2-14-a Strategy response and transition plan — [location / page] / [notes]
Download Centre
Preparation tools & forms
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Assurance readiness
For each claim, check the evidence
Evidence pack to prepare
Common reporting gaps
The information is presented without a date or as-at point.The scope or boundary of the statement is left undefined.Key terms are used inconsistently across the report.Material changes since the previous period are not disclosed.Assertions are made without supporting detail or a source record.Boilerplate is used that does not actually answer what is asked.
Common gaps
Mistakes to avoid when collecting the data
Wrong owner
The request goes to the wrong team, so the people who hold the plan, actions, or assumptions never confirm the source material.
Framework language first
The data call is written in reporting jargon instead of the organisation’s own terms, and staff cannot match it to the records they actually keep.
No boundary set
The team collects mixed material without stating which business units, activities, or time horizon belong in scope.
Wrong timing basis
Information is pulled for the wrong reporting period or cut-off date, so the evidence does not line up with the year being reported.
Mixed counting basis
Different measures are combined without separating how each was built, which makes totals and comparisons unreliable.
Source labels lost
Original file names, version tags, or system labels are stripped away, so the team cannot trace each item back to where it came from.
Separate groups merged
Direct actions, supplier or customer actions, and other response types are lumped together even though they should stay distinct for review.
Evidence trail missing
The pack is assembled without the supporting metadata and approval trail, so no one can show who provided it, when, or on what basis.
Where judgement is often needed
Set the reporting perimeter after a deal closes
If a purchase, sale, or carve-out changes the group’s footprint, explain which entities and activities are included in the plan and from what date the change is reflected.
Choose one working definition where country rules differ
Where local laws or market practice use different labels or thresholds for the same activity, state the definition you used, why it was chosen, and whether it was applied consistently across locations.
Decide how to handle near-boundary operations
For sites, products, or teams that sit close to the inclusion line, disclose the rule used to include or exclude them and note any material judgement made in the process.
Fix the timing basis for actions and milestones
If some actions are planned, underway, or already completed at different dates, explain the cut-off date used and distinguish what is committed, in progress, and delivered.
Separate measured figures from management estimates
When hard data is not available for parts of the response or pathway, identify which figures are directly observed and which are estimated, and describe the method used to fill the gaps.
State the assumptions behind the pathway
For the main drivers that underpin the response, set out the assumptions and dependencies that could change delivery, including any external conditions the plan relies on.
Explain how indirect actions are counted
If the response depends on suppliers, customers, or other third parties, clarify which actions are treated as part of the organisation’s own plan and which are only expected from others.
Use a consistent basis for progress against targets
When showing movement toward a target, disclose the metric basis, the period covered, and any restatements so readers can see how the pathway was built.
Round and aggregate without losing meaning
If figures are rounded or combined to protect confidentiality or keep the report readable, say so and make sure the totals still reconcile to the underlying evidence.
Protect sensitive detail with careful grouping
Where operational detail cannot be shown at site, customer, or supplier level, explain the aggregation approach used and confirm that the grouped view still supports the strategy narrative.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Manufacturing
We have redirected £18m of capital spending this year, with £11m aimed at lower-emission equipment, £4m at site energy upgrades and £3m at process redesign, while also changing procurement rules so 62% of key inputs now come from suppliers with their own decarbonisation plans.
- Our response combines on-site efficiency work, fleet changes and product redesign with customer-facing support for lower-carbon use of our products.
- The plan assumes stable access to renewable power, timely equipment delivery and continued customer demand for the revised product mix; if any of these weaken, delivery dates and spend phasing would move.
- We expect 70% of our 2030 emissions-reduction goal to come from actions already under way, 20% from projects due to start next year and 10% from supplier and customer measures, with the full pathway reviewed each year against milestones.
This synthetic example shows how a reporter can describe where money is being directed, what it is doing itself, what it expects from suppliers and customers, and the assumptions that could affect delivery, all in one narrative.
Illustrative (synthetic) example — Retail and logistics
We have shifted £9m of planned spend into electric delivery vans, warehouse controls and packaging changes, and we have set aside a further £2m for staff training and route-planning software to support the move.
- Our own actions include depot electrification, better load management and heat-reduction measures at sites; outside our operations, we are asking suppliers to cut packaging waste and helping major customers switch to lower-impact delivery options.
- The pathway to our 2035 target relies on grid upgrades, vehicle availability and supplier participation, so we have staged the programme in three phases and linked each phase to annual checks on emissions, cost and service levels.
- Our wider transition plan sets out how these steps, together with contract changes and customer engagement, are expected to close most of the gap to target, with the remaining balance covered by later technology upgrades and further supplier action.
This synthetic example shows a different type of reporter describing internal investment shifts, direct operational measures, actions pushed through the value chain, and the dependencies that shape the timing and credibility of the plan.
How companies report S2-14-a in practice
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
Abu Dhabi Commercial Bank (ADCB)
None · United Arab Emirates · 2024
Abu Dhabi Commercial Bank’s 2024 ESG Report includes coverage of its target achievement pathway on page 131, detailing key assumptions and dependencies related to its transition plan. The report also discusses the transition plan itself on page 138, outlining actions for portfolio alignment and future client transition plan development. However, the report provides only unclear information regarding changes in the business model and resource allocation in response to sustainability risks (p.125, p.130-131), and there is no clear disclosure of direct mitigation or adaptation actions, indirect supply chain or customer actions, or strategic responses.
Hang Lung Properties Limited
Real Estate · Hong Kong · 2025
Hang Lung Properties Limited’s Sustainability Report 2025 provides clear evidence of current and anticipated changes to the entity’s business model, including its resource allocation, as detailed on page 224. The report also discusses the current and anticipated effects of sustainability-related and climate-related risks and opportunities on the business model and value across pages 215, 216, 222, and 223. However, disclosures on direct mitigation and adaptation actions are unclear (p.47), and there is no found evidence regarding indirect supply chain or customer actions, key assumptions and dependencies, strategic responses, target achievement pathways, or a transition plan.
SITC International Holdings Company Limited
Water Transportation · Hong Kong · 2025
SITC International Holdings Company Limited’s 2025 Environmental, Social and Governance Report provides evidence of current and anticipated changes to the entity’s business model, including its resource allocation (p.193). The report also discusses the current and anticipated effects of climate-related risks and opportunities on the business model and value chain (p.188, p.192). However, disclosures on direct mitigation or adaptation actions (p.197), key assumptions and dependencies, strategic responses, target achievement pathways, and a clear transition plan (p.195) are either unclear or not found in the report.
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Check your understanding
Scenarios to work through
A manufacturer has approved a three-year shift from gas-fired equipment to electric lines, but the finance team has only budgeted the capex and not the related retraining and site upgrades. The draft narrative also mentions a supplier programme, yet no one has checked whether it is actually funded.
QHow should you decide what to include when describing the organisation’s response and transition plan?
Reveal model answer →Hide answer ↑Set out the concrete changes to the business model and where money and other resources are being redirected, then describe the direct actions the organisation will take itself and the steps it expects from suppliers or customers. If a programme is mentioned, make sure the supporting assumptions and dependencies are identified, and do not present an unfunded idea as part of the plan.
Why this matters · The narrative should connect strategy, resource shifts, direct action, indirect action and the assumptions that make the plan plausible.
A utility has a pathway to cut emissions by 2035, but the board paper only states the end goal and gives no explanation of the milestones, interim actions or the conditions that must hold for delivery. The sustainability team is unsure whether the target story is enough on its own.
QWhat should you check before treating the target story as a complete transition narrative?
Reveal model answer →Hide answer ↑Confirm that the disclosure explains the route to the target, not just the destination: what the organisation will do over time, how those actions support the target, and what assumptions or external conditions the route depends on. If the pathway is missing, the disclosure is incomplete even if the end target is clear.
Why this matters · A target needs a credible route to it, with the key dependencies made visible.
A retailer plans to reduce emissions by changing its own logistics fleet, but it also expects major emissions cuts from suppliers switching to lower-carbon materials. The draft only describes the fleet change because that is the part management controls directly.
QHow should you handle the supplier-related element when drafting the response?
Reveal model answer →Hide answer ↑Include the supplier-side action if it is part of the organisation’s planned response, and distinguish it from the measures the organisation will carry out itself. The reader should be able to see which actions are internal, which rely on others in the value chain, and what assumptions sit behind the expected contribution from those others.
Why this matters · Separate internal action from value-chain action so the plan is clear about who must do what.
A property group has a transition plan that depends on planning approvals, tenant cooperation and access to green finance. The draft mentions these in passing, but the team has not linked them to the timing of the plan or to the resource shifts already approved.
QWhat judgement should you make about those dependencies before finalising the disclosure?
Reveal model answer →Hide answer ↑Bring the dependencies into the main explanation and show how they affect the timing, feasibility and resource allocation in the plan. If delivery depends on approvals, counterparties or finance, the disclosure should make that clear rather than leaving them as background comments.
Why this matters · Dependencies matter when they shape whether, when and how the plan can be delivered.
Framework references
Relevant IFRS / ISSB requirements and related disclosures
Available framework references and nearby disclosures relevant to preparing this requirement.
Primary
Related & explore
FAQ
Questions this page answers
For s2-14-a, what data do I need to gather before I start drafting the disclosure?+−
The page says to prepare seven datapoints: business model changes, direct response actions, value chain actions, planning assumptions, strategic climate responses, target delivery route and the transition plan. Use those as the starting checklist before you draft anything.
How do I use the step-by-step 'how to prepare' section for s2-14-a in practice?+−
Use it as a working sequence rather than a reference note: identify the datapoints, collect the supporting evidence, check the assurance claims, then turn that into a draft. The page is designed to help you move from raw inputs to a report-ready disclosure.
What should I ask the business model, strategy and climate owners for when preparing s2-14-a?+−
Ask for the information behind the seven datapoints, especially any changes to the business model, direct actions taken, value chain actions and the route to delivering targets. The page is set up to help different owners contribute the pieces needed for one disclosure.
What evidence should I keep for s2-14-a so the disclosure is assurance-ready?+−
The page includes an evidence pack with five items for assurance readiness, so keep the underlying documents that support the claims and datapoints you report. It also gives five assurance claims to verify, each with a claim, risk and evidence prompt.
How do I use the five assurance claims on the s2-14-a page?+−
Treat them as a check on whether your draft is backed by evidence and whether the main risks have been addressed. The page frames them as claim/risk/evidence prompts, which is useful for both internal review and external assurance preparation.
What are the common mistakes to avoid when drafting s2-14-a?+−
The page lists common reporting gaps and mistakes, so use that section as a final quality check before sign-off. It is there to help you spot missing datapoints, weak evidence or unclear wording early.
How can I turn the s2-14-a page into a first draft quickly?+−
Use the draft-output section: it gives visualisation ideas, narrative starters and a content-index line. That makes it easier to turn the prepared datapoints into a structured draft without starting from a blank page.
What should go into the s2-14-a evidence pack for audit or assurance review?+−
The page says the evidence pack has five items, so build it around the documents that support the disclosure claims and the datapoints you used. Keep it organised so a reviewer can trace the draft back to source material.
Can I use the workbook and printable library card to prepare s2-14-a?+−
Yes. The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf, which are there to support preparation and review. Use them to organise inputs, track evidence and shape the draft.
What does the synthetic example on the s2-14-a page help me do?+−
It shows how the disclosure can be written in practice, including a quantitative table where relevant. Because it is synthetic, use it as a drafting pattern rather than as a source of real-world figures.
How does the ESRS E1 climate change reference help me with s2-14-a?+−
The page says ESRS E1 is the closest correspondence, which can help you think about whether the same underlying data can be reused across reporting needs. It does not say the requirements are identical, so treat it as a cross-reference rather than a rulebook.
More questions this page can help with
s2-14-a disclosure checklist for business model changes and transition plan evidences2-14-a how to collect planning assumptions and target delivery route datas2-14-a assurance evidence pack what documents should I keeps2-14-a common reporting gaps and mistakes to avoids2-14-a workbook download how to use the Prep & Assurance workbooks2-14-a printable library card pdf what is it fors2-14-a draft output narrative starters and content index lines2-14-a synthetic example disclosure table how to use its2-14-a who should own direct response actions and value chain actionss2-14-a how to make the disclosure assurance readys2-14-a evidence pack and claim risk evidence promptss2-14-a ESRS E1 cross reference can data be reused
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