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 datapoints 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
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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 — Retail banking
We have put in place a mix of actions to manage the main sustainability-related risks and opportunities we identified, including tighter credit screening for higher-risk sectors, extra staff training, and a phased upgrade of our data controls. Compared with the prior plan, we have completed 8 of 10 scheduled control changes, cut manual data corrections from 120 to 45 per month, and lifted on-time completion of mandatory training from 78% to 94%; the remaining work is now scheduled for the next two quarters. - Looking ahead, we plan to extend the screening model to the full lending book, finish the last two control changes, and run a second round of scenario testing before year-end. - In deciding what to do first, we weighed faster risk reduction against cost, customer impact, and delivery capacity, and chose to sequence the work so the highest-risk areas were addressed first.
This example shows how to describe what has already been done, what is next, how delivery compares with the earlier plan, what evidence shows movement, and what trade-offs shaped the choices.
Illustrative (synthetic) example — Industrial manufacturing
Our group has already started the response package by replacing the most energy-intensive equipment on one production line, tightening supplier checks, and adding monthly management reviews to track delivery. Against the earlier plan, 6 of 9 planned equipment upgrades are complete, energy use on the upgraded line is down 12% versus the baseline, and supplier review coverage has risen from 60% to 89%; the three unfinished upgrades are now in procurement. - Next, we intend to finish the remaining upgrades, broaden the supplier checks to the rest of the site network, and test a backup sourcing option for critical inputs. - We chose this order after balancing emissions reduction, production continuity, and capital spend, so the quickest gains were taken first while larger changes were staged later.
This example illustrates a narrative update that covers current steps, future steps, comparison with the earlier plan, measurable and descriptive signs of progress, and the practical trade-offs behind the sequence.
How companies report s1-33
Real reports where this topic is disclosed. These are report practice, 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 provides quantitative and qualitative evidence of progress against prior plans related to climate considerations on page 193, including details on resourcing activities and progress of previously disclosed plans. The report also references current response actions linked to climate-related considerations on page 197, though these disclosures are not clearly detailed. Notably, the report lacks clear information on planned response actions and provides only unclear context regarding trade-offs considered in decision-making (pages 192 and 197).
MTR Corporation
Ground Transportation — Railroads · Hong Kong · 2025
MTR Corporation's Sustainability Report 2025 includes some contextual information on progress against prior plans, referring readers to the Environmental and Social Objectives section for details (p.88). The report mentions that current protective measures remain adequate under mid-21st century extreme weather projections and notes the existence of flood handling procedures and regular inspections of flood protection and drainage facilities (p.80, p.84-85). However, there is no clear disclosure of current or planned response actions, quantitative or qualitative progress evidence, or consideration of trade-offs in decision-making within the report.
Enel Chile S.A.
Electric Utilities / IPP / Energy Traders · Chile · 2025
Enel Chile S.A.'s 2025 Integrated Annual Report includes references to sustainability-related governance, with the Directors Committee advising the Board on sustainability evaluation and decision-making, including environmental and social aspects (pp. 57, 59, 168). The report mentions action plans to improve ESG information and enhance ESG performance (p.120) and notes monitoring and reporting of actions defined in the CSV Plan (p.273). However, there is no clear disclosure of current or planned response actions, progress against prior plans, or quantitative and qualitative progress evidence, and the consideration of trade-offs in decisions is only mentioned unclearly (p.168).
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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
Related framework references
How this disclosure maps across the major reporting frameworks.
IFRS / ISSB
s1-33
within IFRS-S1: 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 turn the plain-language explainer into a first draft disclosure?+−
Start with the explainer, then use the datapoints to prepare, the step-by-step preparation section, and the draft-output section to shape your narrative. The page is designed to help you move from understanding the topic to producing a usable draft, not to replace your own judgement or internal process.
What data do I need to collect for IFRS S1 s1-33 on this page?+−
The page points you to five datapoints to prepare: current response steps, next response steps, follow-up progress, progress evidence metrics, and decision trade-offs. Use those as your data-collection checklist and make sure each item is supported by evidence you can file for review.
How should I set the scope and methodology for s1-33 using this guidance page?+−
Use the step-by-step 'how to prepare' section to define what you are reporting, then align the datapoints and evidence pack to that scope. The page does not give a fixed methodology, so you need to apply your organisation’s own approach consistently and document it clearly.
Who should own the s1-33 disclosure work and what should they provide?+−
The page is useful for a sustainability lead, HR or data owner, and assurance reviewer because it shows what information needs to be gathered and evidenced. Ownership should sit with the people who can supply the current steps, next steps, progress updates, metrics, and trade-off decisions, with evidence retained in the pack.
What should go into the evidence pack for s1-33 assurance readiness?+−
The page includes an evidence pack with five items to support assurance readiness, alongside five assurance claims to verify. Use those materials to show how each claim is supported and keep the evidence linked to the relevant datapoint or narrative point.
What are the five assurance claims on the s1-33 page and how do I use them?+−
The page says there are five claims to verify, each framed around a claim, risk, and evidence. Use them as a review checklist so you can test whether the disclosure is supported, identify gaps, and gather the right backup before sign-off.
What are the common reporting gaps or mistakes on the s1-33 page that I should avoid?+−
The page lists common reporting gaps and mistakes, so it is meant to help you spot weak points before you finalise the disclosure. Use that section as a pre-submission check against your draft, evidence pack, and workbook outputs.
How do I use the Prep & Assurance workbook and printable Library Card for s1-33?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. Use the workbook to organise preparation and assurance work, and the Library Card as a quick reference while drafting or reviewing the disclosure.
Can I use the synthetic example disclosure on the s1-33 page as a template for my own report?+−
Yes, but only as a synthetic illustration of how the disclosure might be written and structured. Treat it as a drafting aid, then replace it with your own organisation’s facts, evidence, and numbers.
How does the s1-33 page relate to ESRS 2, and can I reuse the same data?+−
The page says the closest ESRS correspondence is ESRS 2 (General Disclosures). You can reuse data where it is relevant to both frameworks, but the page does not say the requirements are identical, so check your own reporting needs separately.
More questions this page can help with
s1-33 IFRS S1 general requirements disclosure: what should a sustainability manager prepare first?s1-33 disclosure data points checklist for current steps, next steps and progress evidence metricsHow do I document decision trade-offs for s1-33 in a draft disclosure?Who should sign off the s1-33 evidence pack and what evidence should be attached?s1-33 assurance readiness: how to map claims, risks and evidenceWhat are the most common mistakes in s1-33 reporting and how do I avoid them?How do I use the s1-33 workbook download to build a draft disclosure?What does the s1-33 synthetic example show about narrative and quantitative data?s1-33 from company reports: how should I use the linked published examples?Can I reuse s1-33 data for ESRS 2 general disclosures?
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