Disclosure focus
The practical point is comparability and completeness. An organisation should be clear about the scope of the financed emissions information it presents, for example whether it covers all relevant operations and portfolios or only certain business lines, entities, or flagship activities. The aim is to avoid giving a headline number without showing how representative it is of the organisation’s overall financed emissions exposure.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official IFRS source.
Prepare
What to collect before drafting
Tick each field as the evidence lands. Owners are the teams that usually hold the source files.
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Asset mix by sector
Investment reporting / portfolio analyticsRecord the portfolio split by asset class and by investee industry, using the same categories used in the reporting pack and source holdings data.
Evidence Portfolio analytics export, holdings schedule, and the classification mapping used to group assets and sectors.
Watch for Asset-class and sector labels do not reconcile to the holdings system, so the split is built from mixed classification rules.
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Portfolio size measure
Finance / investment reportingCapture the reported portfolio size using the chosen basis, either assets under management or gross exposure, and keep the currency basis consistent with the source report.
Evidence Management accounts, portfolio valuation report, or risk report showing the selected measure and reporting date.
Watch for AUM and gross exposure are mixed, or the figure is taken from a different period than the rest of the disclosure.
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Screening exclusions
ESG / investment complianceList the exclusion rules applied to the portfolio, including what was screened out and the reason or policy basis for each exclusion.
Evidence Exclusion policy, screening logs, and any exception or override records.
Watch for The exclusion list does not match the screening engine output, or a portfolio segment covered by the policy is left out.
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Emissions by scope
ESG data / climate reportingSet out financed emissions separately for each emissions scope used in the calculation, with the scope labels and totals kept distinct.
Evidence Carbon accounting workbook, issuer emissions source files, and calculation outputs by scope.
Watch for Scope categories are not aligned to the calculation file, so emissions are rolled up under the wrong scope or a scope is omitted.
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Coverage percentage
ESG data / portfolio analyticsState the share of the portfolio or holdings set that is included in the calculation, using the same denominator as the methodology and the same reporting period.
Evidence Coverage calculation, denominator schedule, and reconciliation to the full portfolio universe.
Watch for The included percentage is calculated against the wrong denominator, or period-end coverage is mixed with an average basis.
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Allocation method
ESG methodology / financeDescribe the rule used to assign financed emissions or exposure across holdings, including the allocation logic, data hierarchy, and any fallback approach.
Evidence Methodology note, calculation workbook, and model assumptions showing how values were allocated.
Watch for The allocation rule in the disclosure does not match the calculation model, or a fallback method is used without being reflected in the reported basis.
Before you start
- Have you settled which holdings or lending books are included, and which asset classes or sectors you will group them into?
- Do you know the balance figure you will use for the portfolio size, and whether it comes from assets under management or gross exposure?
- Have you decided which positions, entities or activities sit outside the calculation, and can you explain why they are left out?
- Is the emissions figure split by source type in a way that matches your internal data, and have you fixed which emissions categories you will cover?
- Have you confirmed the share of the portfolio that is actually counted in the result, and can you trace that percentage back to a source record?
- Is the allocation approach settled, including how you apportion emissions across holdings, and is the method documented well enough to repeat?
How to prepare it
Request the data
Request the portfolio data from Investments
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
What portfolio holdings and calculation basis should we use to prepare the financed emissions disclosure for the reporting period?
Use your organisation’s own portfolio and exposure terms first, then map them to the disclosure wording. For example, ask for the holdings book, mandate book, or exposure file if that is how the team works. Keep the request in the language the owner already uses, and check the source before sign-off.
Weak request
Please provide the financed emissions data required for the disclosure, including all relevant methodology and exclusions.
Why it fails: It uses framework language instead of the team’s own portfolio terms, so the owner may not know which file or calculation run is being asked for. It also does not specify the period, source system, exposure basis, or the exact fields needed to evidence the working paper.
Better request
Please send the month-end portfolio exposure file for [reporting period] used in the climate pack, including the holdings in scope, the exposure measure for each line, the asset and industry labels, any exclusions and reasons, the emissions scope split, the share covered, and the allocation method. Include the source file name, extract date, version, and reviewer details. Use your own internal terms and we will map them for the disclosure pack.
Formal email template
Subject: Request for portfolio data for [reporting period] climate disclosure Hi [name/team], We are preparing the climate disclosure pack for [reporting period] and need the portfolio data used for the financed emissions working paper. Please send the latest file or extract covering: - the portfolio / book names in scope - the exposure measure used for each holding - the asset and industry grouping used in your file - any holdings excluded, with the reason for each exclusion - the emissions scope split used in the analysis - the share of the portfolio covered by the calculation - the method used to attribute emissions to holdings - the source system or file name, extract date, and version If you use different internal terms, please keep those in your own wording and we will map them for the disclosure pack. Please also include the preparer, reviewer, and approval date so we can retain the evidence trail. This is a possible LRA training template only. Please adapt it to your organisation and check the source material before sign-off. Thanks, [preparer name]
Short Teams / Slack version
Hi [name/team] — could you share the latest portfolio/exposure file for [reporting period]? We need the holdings, exposure basis, asset/industry groupings, exclusions, emissions scope split, coverage %, and method notes for the financed emissions working paper. Please include the source file name/version and who prepared/reviewed it. Use your team’s own terms and we’ll map them. This is a possible LRA training template only — please adapt to your organisation and check the source before sign-off.
Industry examples
Asset management
Context. The team maintains a monthly holdings file for pooled funds and segregated mandates.
Adapted request. Please share the month-end holdings and exposure extract for [reporting period] across the funds and mandates in scope, including the exposure basis used, the fund and mandate labels, any excluded positions, the emissions scope split, the coverage %, and the attribution method. Please include the source system, file version, and reviewer details.
Example response. Attached: month-end holdings extract; fund and mandate list; exposure basis = market value; exclusions tab with reasons; scope split tab; coverage summary showing 92% included; method note describing the allocation approach; source system and approval trail.
Commercial banking
Context. The team tracks lending books and off-balance-sheet exposures in a credit risk system.
Adapted request. Please provide the period-end exposure file for [reporting period] for the lending books in scope, including the book names, exposure measure used, industry labels, excluded facilities and reasons, emissions scope split, coverage %, and the allocation method used in the credit model. Please include the system extract details and sign-off trail.
Example response. Attached: credit risk extract; lending book list; exposure basis = gross exposure; exclusions tab for out-of-scope facilities; scope split summary; coverage at 88%; allocation notes for the attribution model; extract date, version, preparer, and reviewer.
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
Set out the basis used to assign emissions to each holding, including how the portfolio was grouped, how exposure or assets under management were measured, which parts were left out, and what share of the portfolio was actually covered.
Context note
Explain what the figures represent in practice: the size of the portfolio segments, the emissions linked to them, the proportion included in the analysis, and how the results should be read alongside the chosen allocation approach.
Fluctuation statement
If the numbers move materially, point to the main drivers such as changes in portfolio mix, coverage, exclusions, or the allocation approach used, and note whether the shift reflects a real change in the portfolio or a change in the data set.
Content index entry
s2-29-a-vi-2 Financed emissions — [location / page] / [notes]Download Centre
Preparation tools & forms
Download preparation tools for s2-29-a-vi-2 with free verified email access for 24 hours. Source-report links remain public.
Check
For each claim, check the evidence
We prepared the coverage figure from the disclosed operations and the relevant portfolio data we hold, using the same cut-off date and reporting currency throughout.
Risk The assurer will check whether the population used is complete, whether the date basis is consistent, and whether the currency translation has been applied on a like-for-like basis.
Evidence to check Population listing or data extract used for the calculation; reporting cut-off memo; currency conversion working papers; reconciliation to the source ledger or portfolio system.
We separated the disclosed amounts by the business lines and asset types we actually use in our internal records, rather than combining unlike items into one total.
Risk The assurer will probe whether the split is genuinely based on underlying records and whether any grouping or reclassification has distorted the result.
Evidence to check Chart of accounts or portfolio taxonomy; mapping file from source records to disclosure categories; review notes showing how items were grouped; sign-off from the preparer and reviewer.
Where we left items out of the calculation, we documented the reason for each exclusion and the amount affected before finalising the table.
Risk The assurer will test whether exclusions were justified, consistently applied, and fully quantified, and whether omitted items should have been included.
Evidence to check Exclusion log; supporting policy or methodology note; item-level exception list; evidence of approval for each exclusion; reconciliation showing excluded amounts against the starting population.
We used the same calculation approach across the table and kept a clear working paper showing how each figure was built up from source data.
Risk The assurer will look for consistency in the method, traceability from source to output, and whether any manual adjustments were made without support.
Evidence to check Methodology paper; calculation workbook with formulas; version history; audit trail of manual overrides; source-to-report reconciliation.
Before publication, we checked the totals, the subtotals, and the percentages against the underlying records and had an independent reviewer challenge the final draft.
Risk The assurer will test whether the pre-publication checks were sufficient to catch arithmetic errors, broken links, and presentation mistakes.
Evidence to check Review checklist; evidence of independent review; recalculation notes; variance analysis; approval email or sign-off record.
Evidence pack to prepare
Common reporting gaps
- A percentage is stated without the underlying counts (numerator and denominator).
- The denominator — what the figure is a share of — is not explained.
- Partial scope is reported as if it were complete coverage.
- One-off activities are counted as if they were ongoing programmes.
- Boundary or period changes that move the figure are not flagged.
- Exclusions from the reported scope are not listed or explained.
Where drafts go wrong
Mistakes to avoid and where judgement is needed
The left column is what preparers get wrong while collecting; the right column is where you will have to make and explain a judgement.
Mistakes to avoid
- Wrong ownerChasing the sustainability team alone leaves the figures with the wrong business owner, when the data actually sits with finance, risk, portfolio, or product teams.
- Framework words instead of business termsAsking for the data in disclosure language confuses colleagues, so they cannot match it to the labels they use in their own systems and reports.
- No clear boundaryPulling numbers without first fixing which holdings, products, or books are in scope leads to a mixed dataset that cannot be defended later.
- Wrong reporting periodUsing a different cut-off date or time basis from the rest of the pack makes the figures inconsistent with the period being reported.
- Mixed counting basisCombining values built on different bases, such as one set on exposure and another on assets under management, produces totals that do not compare like for like.
- Source labels lostCopying data into a new file without keeping the original source names and tags breaks the audit trail back to the underlying record.
- Separate populations mergedPutting together groups that should stay apart, such as different asset classes or industry buckets, hides the breakdown needed for review.
- Missing evidence trailSaving the numbers without the supporting file details, version history, and sign-off record leaves no proof of where the data came from or who checked it.
Judgement needed
- What sits inside the reporting perimeter after a deal closesSet a clear cut-off for bought or sold businesses, explain whether the figures reflect the opening or closing group, and note any restatements or one-off exclusions caused by the change.
- Different country labels for the same activityWhere local classifications do not line up, map them to one internal grouping, explain the mapping rule used, and disclose any material cases that were grouped differently.
- Borderline counterparties and partial coverageState how you treated exposures that are only partly in scope, including mixed-purpose arrangements or small holdings near the threshold, and explain the rule used to include or leave them out.
- Choosing the measurement date or period basisIf the portfolio moved during the year, explain whether the numbers are based on a point-in-time view, an average, or another internal basis, and keep that choice consistent across the table.
- Using estimates where direct figures are missingSay which lines rely on modelled or proxy inputs rather than source data, describe the fallback approach, and identify any material assumptions that could change the result.
- Allocating emissions across shared financingWhen one exposure supports more than one activity or borrower, explain the split rule used to apportion the amount and the emissions, and show the same basis across similar cases.
- Rounding and small differences in totalsChoose one rounding approach for the whole disclosure, apply it consistently, and explain any small gaps between subtotals and the total caused by rounding.
- Protecting client confidentiality through groupingIf individual positions cannot be shown, combine them into a broader band or segment, explain the aggregation rule, and make clear how much of the portfolio is still covered.
Examples
How it reads on the page
Synthetic, written by LRA — not from a company report, not text from any standard.
We have shown the part of our portfolio we include in this calculation, split by asset type and industry where relevant. For each slice, we show the amount covered, the emissions we attribute to it by scope, the share included, the exclusions, and the allocation approach used.
Synthetic illustration only. This example shows how a firm might present a covered portfolio view with emissions split by scope, alongside the share of the portfolio used and the basis for allocation.
We have set out the lending and project-finance book we used, grouped by borrower sector. For each group, we show the balance covered, the emissions we assign across scopes, the portion included, the amounts left out, and the method used to spread emissions across our exposure.
Synthetic illustration only. This example shows how a lender might present financed emissions by sector, with the covered balance, excluded balance, included share, and the allocation basis used to attribute emissions.
Quality ladder
- Basic
I report financed emissions of 1,200 tCO2e.
- Better
I report financed emissions of 1,200 tCO2e for our lending book, covering corporate loans and excluding cash balances, based on a balance-sheet share approach.
- Best
I report financed emissions of 1,200 tCO2e for the year ended 31 December 2025 across our lending and bond portfolios, covering 85% of our £10.0 billion exposure, excluding sovereign holdings and cash, using a balance-sheet share approach; the increase from last year mainly reflects higher client borrowing and fuller data coverage.
Check your understanding
Scenarios to work through
A lender has a mixed portfolio: some loans are fully in scope for the financed-emissions calculation, while a small legacy book is left out because the data needed to allocate emissions is not available. The draft note also splits the included book by asset class and industry, and shows the exposure amount used for each slice.
An asset manager reports financed emissions for two portfolios. One is measured using assets under management, the other using gross exposure, because the underlying products are structured differently. The preparer is unsure whether both bases can sit in the same note.
A bank has calculated financed emissions for lending and investment activities, but the emissions profile is not the same across all greenhouse gas categories. For one book, only some scopes are available from counterparties; for another, all scopes are estimated. The draft note currently gives one total with no further detail.
A preparer has a draft table showing the included percentage as 92%, the exposure base as 500 million currency units, and financed emissions by scope. However, the narrative says the calculation covered 95% of the portfolio, and the exclusions note lists a segment that appears to be part of the 8% gap.
Real reports
How 3 companies report it
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
The Shanghai Commercial & Savings Bank, Ltd.
Partial
TS Financial Holding Co., Ltd.
Partial
E.SUN Financial Holding Company, Ltd.
Partial| Field | The Shanghai Commercial & Savings Bank, Ltd. | TS Financial Holding Co., Ltd. | E.SUN Financial Holding Company, Ltd. |
|---|---|---|---|
| Asset mix by sector | Not found | Partial | Not found |
| Portfolio size measure | Partial | Not found | Partial |
| Screening exclusions | Not found | Not found | Not found |
| Emissions by scope | Not found | Not found | Partial |
| Coverage percentage | Not found | Not found | Not found |
| Allocation method | Not found | Partial | Partial |
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Advice, not assurance
Framework references
Relevant IFRS / ISSB requirements and related disclosures
IFRS / ISSB
s2-29-a-vi-2
within IFRS S2: Climate-related Disclosures
Guides that settle this question
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FAQ
Questions this page answers
The page says to prepare asset mix by sector, portfolio size measure, screening exclusions, emissions by scope, coverage percentage and the allocation method. Use the step-by-step preparation section to turn that list into a working data request.
It is there to help you move from the disclosure topic to a draft by setting scope, collecting the listed datapoints and checking what evidence you have. The page also points you to the workbook and library card to support that process.
Ask for the specific datapoints named on the page, plus the evidence needed to support them. In practice that means the underlying figures, the method used to allocate them, and any exclusions or coverage notes.
The page tells you to work from the listed datapoints and the allocation method, so scope and method should be set before drafting. Use the preparation section and workbook to keep the approach consistent and documented.
The page includes an evidence pack with five items for assurance readiness, alongside five assurance claims to verify. Use those items to show how the figures were built and what supports them.
The page says there are five claims to verify, each with a claim, risk and evidence angle. Use them as a checklist to test whether your draft is supported and where the main assurance risks sit.
The page lists common reporting gaps and mistakes to help you spot weak points before sign-off. Use that section as a pre-submission check so you can fix missing data, unclear methods or unsupported statements.
The workbook is a downloadable .xlsx designed to help you prepare the disclosure and get assurance-ready. Use it to organise the required datapoints, evidence and checks before you draft the final text.
The page includes synthetic illustrative examples, including a quantitative table, to show what a finished disclosure can look like. Treat them as a drafting aid only and make sure any real numbers in your own version are internally consistent.
The page gives draft-output support in the form of visualisation ideas, narrative starters and a content-index line. Use those to turn your prepared data into a clear first draft, then check it against the evidence pack and common gaps.
The page notes ESRS E1 (Climate Change) as the closest correspondence, so the same data may be reusable across both contexts. It does not say the requirements are identical, so you still need to check the other framework separately.
More questions this page can help with