Disclosure focus
This disclosure asks an organisation to explain who in its governance structure is responsible for overseeing sustainability-related matters, and how that oversight is carried out in practice. The focus is on identifying the relevant body or individual, describing their role, and showing that oversight is real rather than nominal.
In practical terms, the reporting should cover the organisation’s actual oversight arrangements across the business, not just a flagship site or a single project. It should make clear where responsibility sits, how often it is exercised, and how it connects to decision-making and monitoring across operations.
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 s1-27-a sub-elements (LRA working checklist)
Set out the group’s remit and what it is expected to do.
Check how performance goals and pay are linked, and keep that under review.
Agree how often updates go to the board or committee.
Name the board, committee or person that carries this responsibility.
Explain how it helps shape strategy, approve major deals, and weigh trade-offs.
Describe the process used to assess and build the needed skills and capability.
How to prepare it
1Identify the governance arrangement you will describe, then pin down who is accountable: the board, a committee, or a named individual. Keep the scope to the body or person that actually carries the responsibility.
2Set out the formal basis for that role and gather the supporting papers. Use the approved mandate, terms of reference, or equivalent records that show the authority and remit in place.
3Confirm what the role covers in practice. Collect evidence showing how it deals with strategy, significant deals, and the judgement calls or trade-offs that arise.
4Compile the reporting trail. Show how often information goes up to the governance body, and keep minutes, packs, or other records that support the stated rhythm.
5Document how the role connects to targets and pay. Prepare a clear explanation, backed by evidence, of any oversight of goals and any link to remuneration decisions.
6Check the competence process and then reconcile the draft against the source material. Record how skills or capability are assessed, note any exclusions or changes in wording or scope, and verify the final disclosure against the official source before release.
Request the data
Request board and committee oversight evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Which board, committee, or named individual is responsible for sustainability oversight, and what documentary evidence shows their remit, reporting rhythm, decision role, target and pay linkage oversight, and skills process?
Use your organisation’s own labels first, then map them to the disclosure. For example, if you say ‘board pack’, ‘committee charter’, ‘remit note’, ‘management update’, or ‘skills review’, keep those terms in the request and only translate them later for reporting.
Weak request
Please send the governance body oversight disclosure evidence for the sustainability reporting standard.
Why it fails: This is too framework-led and vague. It does not tell the owner which internal documents to pull, which governance topics matter, what period or entity boundary to use, or what counts as usable evidence. It also uses disclosure language that many teams will not recognise in day-to-day work.
Better request
Please send the board and committee papers, remit documents, and minutes for [period] that show who owns sustainability oversight, how often they are updated, how they are involved in strategy and major decisions, whether they review links between goals and pay, and how skills are checked. Include dates, version numbers, and the source folder. Use your team’s own document names and I’ll map them later.
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 identify the relevant governance owner, the scope of matters included, and how the organisation defines each topic in practice.
Context note
Explain what the governance information shows about how sustainability matters are handled, including who is responsible, how often updates are received, and where the board or its delegates are involved in strategic choices and trade-offs.
Fluctuation statement
If the governance arrangement, reporting frequency, or assigned responsibilities changed during the period, explain what changed, why it changed, and whether it reflects a shift in oversight approach or organisational structure.
Content index entry
s1-27-a Governance body or individual oversight — [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
Asking the wrong owner
The request goes to a team that only knows the board pack, while the actual source sits with the company secretary, committee chair, or named lead.
Using framework labels instead of internal terms
People ask for the answer in disclosure language, so the business cannot map it cleanly to its own committee names, job titles, or reporting lines.
Leaving the scope undefined
The team does not state whether the data should cover the board, a sub-committee, or one named person, so different contributors send different populations.
Mixing time bases
One source gives the current reporting cycle, another gives an older approval date, and the final pack combines them as if they were the same period.
Blending different counting bases
Updates from separate governance groups are merged even though one source counts meetings, another counts papers, and another counts decisions.
Dropping the original source labels
The extract loses the exact committee name, document title, or file reference, so reviewers cannot trace each field back to the underlying record.
Combining separate populations
Board-level information and committee-level information are rolled into one line, which hides who actually handled strategy, major deals, or trade-off decisions.
Missing evidence metadata
The team captures the answer but not the date, version, or document reference, so no one can tell which source was used or whether it is current.
No sign-off trail
The draft moves forward without a named reviewer or approval record, so there is no clear trail showing who checked the data before it was written up.
Where judgement is often needed
Who counts as the named overseer when duties are split
If the board, a committee and one executive all share the work, name the person or group that actually carries the main oversight and explain the split in plain terms.
When the oversight role changes during the year
If responsibility moves between directors, committees or an individual part-way through the period, describe the position at the period end and note the timing of the handover.
How to handle group structures with local boards or committees
Where country teams or subsidiary boards have their own review process, explain whether they feed into the central oversight route or are separate, and use the same basis across the group.
Different job titles for the same oversight function
If one market calls the role a board, another a supervisory council and another a management committee, map each label to the actual decision-maker and disclose the mapping you used.
Defining the reporting rhythm when meetings are irregular
If updates go to the board on a fixed cycle but ad hoc papers are also sent, state the normal rhythm and separately mention any extra escalation points that matter.
Describing strategy and deal oversight when the process is informal
If climate matters are discussed inside wider business papers rather than in a dedicated forum, explain how those trade-offs are reviewed in practice and avoid overstating formality.
Linking targets to pay when the connection is partial or indirect
If only some incentives depend on climate measures, set out which parts are linked, which are not, and the basis used to decide that connection.
Using estimates where the underlying review is not fully measured
If the oversight evidence comes from sampled papers, management summaries or other estimates, say so and explain the method and any limits on confidence.
Protecting sensitive governance information while still being clear
If naming individuals, committee papers or country-level details would create privacy or confidentiality issues, aggregate the description enough to protect data but still show who oversees what.
Rounding and boundary choices for mixed-period or mixed-entity reporting
If acquisitions, disposals or rounding affect which oversight activities are included, state the cut-off used, explain any material boundary changes and keep the totals internally consistent.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — manufacturing
Our board’s audit and risk committee has written terms that set out how it oversees sustainability matters, while the full board keeps the final say on major deals and strategic shifts. - The committee receives a quarterly update from the sustainability lead, reviews progress against our climate and safety goals, and checks whether pay outcomes are aligned with those goals; the board is also briefed before any acquisition, disposal or other significant transaction where sustainability trade-offs could affect the decision. - We keep the committee’s skills current through an annual review of director experience, targeted training on climate and social topics, and external support where needed, so the board can judge whether its mix of expertise remains fit for purpose.
This example shows how a manufacturing group might describe who does the oversight work, how often they hear from management, how they connect targets to pay, and how they refresh board capability.
Illustrative (synthetic) example — financial services
Our risk committee has a formal remit covering sustainability oversight, and the board uses it to monitor our transition plan, incentive outcomes and the implications of any large portfolio move or restructuring. - The committee gets a written pack every two months from the chief sustainability officer, with a fuller board discussion each quarter, and it reports back on whether performance against our medium-term targets is being reflected in variable pay. - Director capability is checked through an annual board skills matrix, one-to-one development plans and periodic external benchmarking, so we can see whether the people around the table still have the right mix of knowledge for strategy and difficult trade-off decisions.
This example shows how a financial services group might explain the committee’s remit, the reporting rhythm, the link between targets and remuneration, and the process used to assess board skills.
How companies report S1-27-a in practice
Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.
Westports Holdings Berhad
Water Transportation — Ports and Services · Malaysia · 2025
Westports Holdings Berhad’s Sustainability Report 2025 provides clear evidence of defined terms of reference and role descriptions for identifying and managing sustainability-related risks and opportunities, as well as a responsible board committee individual overseeing these matters (p.13). The report includes related context on governance frameworks and oversight, such as ISO 37001:2016 implementation and leadership in sustainability governance, but does not clearly disclose the reporting cadence to the governance body or the board’s role in strategy for major transactions and trade-offs (pp.13, 14, 20). Notably, there is no evidence found regarding a skills competency process within the report.
SITC International Holdings Company Limited
Water Transportation · Hong Kong · 2025
SITC International Holdings Company Limited’s 2025 Environmental, Social and Governance Report provides clear evidence that executive management remuneration is linked to climate-related considerations, as detailed on page 197. The report also includes related context on governance oversight, such as management-level positions or committees and their oversight mechanisms, but these disclosures are unclear or incomplete, particularly regarding the mandate terms of reference, responsible board committee individuals, roles in strategy and trade-offs, and skills competency processes (p.187). Notably, there is no found evidence on the reporting cadence to the governance body.
Hyundai Engineering & Construction Co.,Ltd.
Construction and Engineering · South Korea · 2025
Hyundai Engineering & Construction Co., Ltd.'s 2025 Sustainability Report includes a clear disclosure of a responsible board committee individual overseeing climate-related risks and opportunities on page 148. However, other governance aspects such as the mandate terms of reference (p.138), oversight of targets and remuneration linkage (p.140), reporting cadence to the governance body (p.145), and the role in strategy major transactions and trade-offs (p.143) are only discussed in related context without clear disclosure. Additionally, there is no evidence found regarding a skills competency process in the report.
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Scenarios to work through
A preparer is drafting the sustainability governance section and has minutes showing the board approved a climate oversight charter on 15 March 2025. The same pack also notes that the audit committee receives a quarterly sustainability update and that the remuneration committee links part of executive pay to emissions and safety measures.
QWhat should be pulled together so the disclosure shows who oversees the topic, how often they hear updates, and how targets connect to pay?
Reveal model answer →Hide answer ↑Bring in the named board-level group or person, the update rhythm, and the link between performance measures and pay decisions. Also include the date or timing of the charter or terms that set out that oversight role, because the reader needs to see the basis for the arrangement, not just the existence of meetings.
Why this matters · The disclosure should connect the oversight arrangement, the reporting rhythm, and any pay linkage in one clear account.
A company has one sustainability lead who reports to the board twice a year, but the board paper only says the lead 'keeps directors informed'. The preparer also has a skills matrix showing two directors completed external training on climate risk and one on human rights during the year.
QHow should the preparer decide whether the narrative is strong enough on who is responsible and how capability is maintained?
Reveal model answer →Hide answer ↑Name the individual or group that carries the oversight role, state the reporting frequency in plain terms, and explain the process used to keep the relevant people capable for the job. A vague statement about keeping directors informed is not enough if it does not show the actual reporting pattern or the way skills are assessed and refreshed.
Why this matters · Use specific language for responsibility, update frequency, and competence-building, rather than broad statements.
The board approved a major acquisition in September 2025 after reviewing climate transition risks and a supplier due-diligence issue. The preparer is unsure whether this belongs in the oversight section because the transaction was mainly financial, even though sustainability trade-offs were part of the decision pack.
QShould the disclosure mention the board’s role in major deals and the trade-offs it considered, or leave that out because the deal was not primarily about sustainability?
Reveal model answer →Hide answer ↑Include it if the board or committee considered sustainability-related trade-offs when deciding on the transaction or strategy. The point is to show how the governance group participates in significant decisions where sustainability factors affect the choice, even when the deal also has a financial purpose.
Why this matters · Major decisions belong in the narrative when sustainability considerations shaped the judgement, not only when the topic was labelled as sustainability.
A preparer has a draft that says 'the sustainability committee oversees targets and remuneration' but does not say when the committee was set up, who sits on it, or how often it reports to the board. The only supporting evidence is a policy note and a slide deck from one meeting.
QWhat extra detail is needed before the disclosure is ready for sign-off?
Reveal model answer →Hide answer ↑Add the date or timing that shows the committee’s remit was established, identify the board, committee, or individual actually responsible, and state the reporting cadence to the board or equivalent governance group. The draft also needs enough detail on the skills or competency process so readers can see how the people involved are kept fit for the role.
Why this matters · A usable disclosure needs the responsible party, the reporting pattern, the basis for the remit, and the competence process, not just a label for the committee.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
IFRS / ISSB
s1-27-a
within IFRS S1: General Requirements for Disclosure of Sustainability-related Financial Information
Open official source →Related & explore
FAQ
Questions this page answers
For s1-27-a, what data points should I gather before I start drafting the disclosure?+−
The page says to prepare six datapoints: mandate date, targets pay oversight, board reporting frequency, named oversight lead, strategy decision role, and skills review process. Use those as your starting checklist before you write anything.
How do I use the step-by-step preparation section for s1-27-a in practice?+−
Use it as a working sequence for scoping, collecting the right inputs, and turning them into a draft. The page is set up to help you move from preparation to assurance readiness rather than leaving you with a blank template.
Who should own the s1-27-a data in my organisation: ESG, HR, company secretariat or the board team?+−
The page points you to assign ownership for the named datapoints, so the right owner is whoever can evidence each item and keep it current. In practice, that often means splitting ownership across governance, HR and the board reporting process.
What evidence should I keep for s1-27-a so the disclosure is assurance-ready?+−
The page includes an evidence pack with five items to support assurance readiness, alongside six claims to verify. Build your file so each claim can be traced back to a source document or record.
What are the six assurance claims I need to check for s1-27-a?+−
The page says there are six claims to verify, each with a claim, risk and evidence angle. Use that structure to test whether the draft is supported and whether the underlying records are complete enough for review.
What are the common mistakes people make when reporting s1-27-a?+−
The page lists common reporting gaps and mistakes, so it is useful for a pre-submission check. Use it to spot missing ownership, weak evidence, or a draft that does not line up with the datapoints you prepared.
How do I turn the s1-27-a data into a draft disclosure quickly?+−
The page gives draft-output support, including visualisation ideas, narrative starters and a content-index line. That should help you move from raw inputs to a first draft without starting from scratch.
Can I use the s1-27-a workbook and library card to build my evidence pack?+−
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 assurance readiness.
Is there a worked example for s1-27-a that I can copy into my own draft?+−
The page includes synthetic illustrative example disclosures, including a quantitative table. Treat them as examples of presentation and structure only, and make sure any real draft uses your own data.
How does the s1-27-a 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 treat the data as reusable where it fits your reporting process, but the page does not say the requirements are identical.
More questions this page can help with
What should I collect first for s1-27-a if I am starting from zero?How do I decide the scope for s1-27-a before drafting?Which team should provide the mandate date and board reporting frequency for s1-27-a?What does the page mean by targets pay oversight in s1-27-a?How do I evidence the named oversight lead for s1-27-a?What is the best way to document the strategy decision role for s1-27-a?How should I record the skills review process for s1-27-a?What should go into the s1-27-a evidence pack for assurance review?How do I use the claim-risk-evidence checks on the s1-27-a page?What are the most common gaps in s1-27-a reporting?How do I use the synthetic example table on the s1-27-a page?Where can I find the s1-27-a workbook and printable library card?
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