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 datapoints 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]
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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 ask for, and where no sector rule exists we explain why we chose our own indicators. For our manufacturing group, that includes energy use, water withdrawals, waste sent for disposal, and workplace safety rates, alongside our own plant-level downtime and defect-rate tracking. - We also use sector-style measures on emissions intensity and resource efficiency to compare sites, and we show the year-on-year movement in each key performance measure against our 2025 baseline. - In this illustration, total recordable injuries were 18, of which 6 led to lost time, so the lost-time share was 33% (6/18).
This example shows how a reporter can combine required sustainability measures with its own chosen indicators, while explaining the basis for any company-specific selection and presenting performance movement in plain language.
Illustrative (synthetic) example — financial services
We set out the sustainability measures that apply under the IFRS framework, then explain the extra indicators we chose because no specific rule covered the topic we were tracking. For our financial services group, that means financed-emissions data, portfolio alignment, customer complaint trends, and our own cyber-incident and staff-training measures. - We also include industry-style indicators for credit quality and client retention, and we describe how each measure helps us monitor delivery of our sustainability objectives. - In this illustration, we handled 240 customer complaints in total, and 36 related to digital access, so that category made up 15% (36/240).
This example shows a different type of reporter using the required framework measures, adding its own monitoring metrics where needed, and linking industry-style indicators to internal performance tracking.
How companies report s1-46-48
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 includes reported values for applicable IFRS required metrics on page 191 and uses industry-based metrics such as metric tonnes of greenhouse gas emissions to assess costs, as noted on page 197. The report references sustainability-related risks and opportunities and mentions monitoring progress towards targets on page 187, but does not clearly disclose specific performance metrics. There is no evidence found regarding the basis for selection where no specific standard applies or entity-specific monitoring metrics.
MTR Corporation
Ground Transportation — Railroads · Hong Kong · 2025
MTR Corporation’s Sustainability Report 2025 includes some contextual references to entity-specific monitoring metrics on page 9, mentioning materiality thresholds based on their risk management framework, and to performance metrics on page 23, noting ongoing development of KPI establishment and management processes. The report also directs readers to its sustainability website for detailed climate-related disclosures and policies (p.80), and references nature-related disclosures and metrics on page 94 and biodiversity data integration on page 98. However, the report does not provide clear or specific disclosures on applicable IFRS-required metrics, the basis for metric selection when no standard applies, or the use of 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
Related framework references
How this disclosure maps across the major reporting frameworks.
IFRS / ISSB
s1-46-48
within IFRS-S1: 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 page?+−
The page says to prepare five datapoints: IFRS metrics used, the selection basis, company-specific metrics, industry metrics used, and reported performance measures. Use those as your starting checklist before you draft anything.
How do I use the step-by-step 'how to prepare' section for s1-46-48 in practice?+−
Use it as a working sequence for building the disclosure: identify the datapoints, then move into drafting and evidence collection. The page is designed as a practitioner guide, so it is meant to help you turn source data into a draft rather than just describe the topic.
What should I include in the evidence pack for IFRS S1 s1-46-48 if I want to be assurance-ready?+−
The page includes an evidence pack with five items to support assurance readiness. It also gives five assurance claims to verify, each framed around a claim, the related risk, and the evidence you would need.
What are the common reporting gaps or mistakes to watch for on s1-46-48?+−
The page has a section on common reporting gaps and mistakes, so it is intended to help you spot weak points before sign-off. Use it alongside the datapoint checklist and evidence pack to avoid missing information or leaving the basis of reporting unclear.
How do I assign ownership for the data behind IFRS S1 s1-46-48?+−
The page is set up for practitioner use, so ownership should sit with the people who can explain the metrics, the selection basis, and the reported performance measures. In practice that usually means the ESG/sustainability lead coordinating with HR, finance, or other data owners who hold the source evidence.
Can I use the synthetic example disclosures on the s1-46-48 page as a template for my own draft?+−
Yes, but only as an illustrative guide. The examples are synthetic and internally consistent, and the page also includes a quantitative table, so you can see how the disclosure might look without treating it as a real company example.
What does the draft-output section give me for IFRS S1 s1-46-48?+−
It gives practical drafting support: visualisation ideas, narrative starters, and a content-index line. That makes it easier to turn your collected data into a first draft rather than starting from a blank page.
Where do I find the workbook and printable card for s1-46-48, and what are they for?+−
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 card as a quick reference while drafting or reviewing.
How do I use the 'From company reports' table on the s1-46-48 page?+−
It links to real published reports at the pages where the topic is disclosed, so you can see how others have handled the topic in practice. It is a reference point for drafting and benchmarking, not a substitute for your own data and evidence.
Is there a cross-framework link for IFRS S1 s1-46-48, and can I reuse data for ESRS?+−
Yes, the page notes ESRS 2 (General Disclosures) as the closest correspondence. You can treat that as a useful cross-check and reuse data where it fits your reporting process, but the page does not say the requirements are identical.
More questions this page can help with
IFRS S1 s1-46-48 checklist for sustainability manager: what should I collect first?s1-46-48 evidence pack items for assurance reviewHow to avoid common mistakes when drafting IFRS S1 s1-46-48s1-46-48 workbook download how to use the Prep & Assurance workbookWhat is the best way to turn s1-46-48 data into a draft narrative?s1-46-48 synthetic example disclosure table explainedWho should own the data for IFRS S1 s1-46-48 in a company process?How to build an assurance-ready file for IFRS S1 s1-46-48What are the datapoints to prepare for s1-46-48?Can I reuse s1-46-48 data for ESRS 2 General Disclosures?Where are the real company report examples for s1-46-48?What does the content-index line do in the s1-46-48 draft output?
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