IFRS S1 and S2 Compliance Checklist and Free Disclosure Matrix

Technical note. This article distinguishes IFRS requirements from London Reporting Academy implementation practices. Illustrative examples and tools must be adapted to the entity’s facts, reporting period, jurisdiction and applicable adoption requirements.

Independence note. London Reporting Academy is an independent education and consulting provider. IFRS®, ISSB®, IFRS S1 and IFRS S2 are referenced for educational purposes; this material is not issued or endorsed by the IFRS Foundation.

Figure 1. IFRS S1/S2 compliance architecture: reporting basis, four content areas and cross-cutting tests.

The row design should force the team to record the conclusion and the evidence trail. Short labels and controlled lists improve consistency, but free-text rationale is still needed for significant judgements. The following fields are included in the downloadable workbook or can be adapted to an existing reporting-control system.

The stronger row is not stronger because it is longer. It is stronger because it identifies the decision, location, evidence and control in a way another reviewer can reproduce.

Figure 2. How to use the IFRS S1/S2 disclosure matrix: from authoritative requirement to evidence-based sign-off.

1. Confirm the requirement and source edition

Start with the official paragraph and any relevant application guidance. Record the edition, effective date and amendment status. Do not rely on a copied checklist from a prior year without a source review. Where a paragraph contains several distinct tests or owners, create more than one row rather than hiding complexity in a long comment.

2. Decide applicability before considering data availability

Applicability asks whether the requirement is relevant to the entity, reporting basis and period. It is not a measure of convenience. Record the rationale, assumptions and approver for “no” or “conditional” conclusions. For example, a target disclosure may be applicable because the entity has set a target, even if the performance dataset is incomplete.

3. Apply materiality to the information

IFRS S1 requires material information, not every potentially relevant detail. The matrix should record whether information is material in the specific entity context and preserve the evidence for significant judgements. A requirement can be applicable while a particular item of information is not material. Do not use “not material” as a substitute for an unperformed assessment or weak evidence.

4. Link the row to evidence and controls

Reference the records that support the conclusion and the disclosure. Evidence can include approved policies, board papers, risk registers, scenario models, financial reconciliations, contracts, calculation files, emission-factor registers, target approvals and source-system extracts. The control field should explain how completeness, accuracy, consistency and review were achieved and whether exceptions occurred.

5. Locate the disclosure precisely

Record the exact report section, paragraph, table or permitted cross-reference and the draft version. If the information is incorporated by cross-reference, test the IFRS S1 conditions, including availability on the same terms and at the same time. A location such as “annual report” is too broad to support final completeness testing.

6. Review technical, financial and cross-report consistency

The technical reviewer confirms the paragraph and conclusion; finance checks connected data, assumptions and financial effects; relevant specialists review methods; and editorial review checks that the wording remains complete and understandable. Cross-report review should compare the sustainability disclosures with the financial statements, management commentary, risk report, remuneration disclosures, financing instruments and other public claims where relevant.

7. Assign a status that does not hide the basis

A green, amber or red indicator can help programme management, but it should be derived from controlled criteria. The workbook uses maturity and status fields to distinguish design from operation and evidence from drafting. A row should not become green because a draft sentence exists. The evidence reference, control result, reviewer and unresolved limitations should support the status.

8. Complete sign-off after final changes

Final sign-off should occur after all material edits, calculations, cross-references and comparative changes have been retested. Record the reviewer, date, version, board-pack reference and conclusion. If the row relies on a relief, exception or significant judgement, ensure the condition and effect remain valid. The compliance statement is approved only after the package-level completeness test, not row by row in isolation.

The workbook groups detailed rows, but management and the board also need package-level gates. A “no” answer to a critical gate should block an unreserved compliance statement until the issue is resolved or a valid relief, exception or materiality conclusion is documented.

Reporting basis gate: reporting entity, period, location, applicable editions, adoption basis and transition choices are approved.

Fair-presentation gate: material sustainability-related risks and opportunities are completely, neutrally and accurately depicted, with additional information where necessary.

Materiality gate: material information decisions are documented; immaterial information does not obscure material information.

Connected-information gate: relationships within the disclosures and with the related financial statements are coherent, and significant differences are explained.

Governance and process gate: disclosed oversight, management roles and controls match what operated during the period.

Strategy and financial-effects gate: business-model, value-chain, strategy, financial position, performance and cash-flow effects are connected to planning and evidence.

Climate and GHG gate: scenario analysis, resilience, Scope 1/2/3 emissions, industry metrics and targets use the applicable methods and boundaries.

Relief, judgement and uncertainty gate: all material reliefs, exceptions, significant judgements and estimation uncertainty are recorded and transparently reflected.

Publication gate: location, cross-references, timing, comparatives, digital requirements and accessibility are complete for the applicable period.

Compliance-statement gate: every applicable requirement is satisfied in the final version and the explicit and unreserved statement is approved after the last material change.

Reliefs and exceptions should be visible in the same system as the disclosure. Record the exact paragraph, the condition, the evidence of eligibility, the reporting period, the effect on information and comparatives, any required disclosure, the owner and the planned end state. First-year reliefs should have an expiry and second-year action. Commercial-sensitivity or legal-prohibition conclusions require especially careful evidence and jurisdictional review.

Measurement uncertainty should be linked to the estimate and method, not used as a general disclaimer. Record the sources of uncertainty, assumptions, range or sensitivity where relevant, data-quality limitations and the control used to review the estimate. The matrix should distinguish unavoidable uncertainty from a remediable control or data gap.

The stronger row makes the unresolved issue visible and prevents a premature green status. It also allows a reviewer to reproduce the conclusion without relying on the person who prepared the report.

IFRS S1 allows an explicit and unreserved statement of compliance only when all applicable requirements have been complied with. The matrix supports that conclusion by making requirements, evidence, judgements, reliefs and review visible. It does not create the conclusion automatically. Management should perform a final package-level review that considers fair presentation, material information, additional information required for understanding, connected information, final edits, comparatives and the effect of unresolved control exceptions.

Where the entity has not met all applicable requirements, it should not use the unreserved compliance statement. The report may describe the standards used as a reference or explain partial application, provided the claim is accurate and not misleading. The matrix should record the exact approved wording and the evidence for that reporting basis.

Is the downloadable matrix an official IFRS Foundation checklist?

No. It is a London Reporting Academy educational implementation aid. The official IFRS S1 and IFRS S2 text remains authoritative, and the workbook must be technically reviewed for the applicable edition and reporting period.

Can the matrix be used for external assurance?

It can support assurance readiness by organising criteria, evidence, controls and review status, but it is not an assurance work programme or conclusion. The practitioner determines the engagement approach and evidence required.

Should immaterial requirements be deleted from the matrix?

Usually no. Retaining the row with an evidenced materiality conclusion preserves the decision trail and supports future review. The public report need not include immaterial information.

How often should the matrix be updated?

At least for each reporting cycle and whenever an amendment, interpretation, jurisdictional rule, material event, boundary change or control finding affects a row. Source and content versions should be recorded.

Can we state “IFRS S1/S2 aligned” when the compliance statement is not available?

Any alternative claim should accurately describe what was prepared and avoid implying full compliance. The wording depends on the facts, the content and jurisdictional rules and should receive technical and legal review where relevant.