Disclosure focus
This disclosure asks an organisation to explain how management is involved in overseeing and carrying out sustainability-related governance responsibilities. In practice, it is about showing where management has real responsibility, what it does, and how that role connects to the wider governance structure rather than leaving the topic only at board level.
The practical focus is on the organisation’s actual arrangements across the business: who is responsible, what decisions or monitoring they handle, and whether this applies broadly or only in certain parts of the organisation. A useful response should make clear the scope of management involvement, including whether it covers the whole organisation, specific business units, or only selected sites or functions.
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-b sub-elements (LRA working checklist)
Set out the controls and procedures that are used.
Identify any management role or committee that has been given this task.
Show how this work is linked with risk, finance, legal, internal audit, or similar functions.
Explain how the board or other oversight group keeps watch over the delegated role.
How to prepare it
1Map the controls and procedures you actually use for this disclosure, so you can show the process rather than a generic description.
2Identify who carries the delegated management responsibility, or which committee does so, and note the role in plain business terms.
3Set out how that work connects with risk, finance, legal, internal audit, or any other relevant team, using the wording your organisation uses internally.
4Gather the supporting evidence for each point, such as meeting papers, approvals, process notes, or other records that show the arrangement in practice.
5Prepare the final figures or narrative, then record any exclusions, changes in approach, or updates so the reader can see what was included and why.
6Check the draft against the official source to confirm you have covered the required items and have not added, missed, or misstated anything.
Request the data
Request board delegation and oversight evidence
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
How is day-to-day sustainability oversight delegated, connected to other control functions, and kept under board supervision?
Use your organisation’s own governance terms first (for example, board, committee, executive forum, delegated lead, control functions), then map them to the disclosure. Keep the request in your internal language and check the source text before sign-off.
Weak request
Please provide the governance disclosure wording for management role in governance.
Why it fails: This asks for framework language rather than the underlying internal evidence. It does not tell the owner what records to pull, which governance bodies or control teams matter, or what period and entity boundary to cover.
Better request
Please send the board or committee papers, delegation note, and any reporting pack for [reporting period] that show which internal forum handles day-to-day sustainability oversight, how it connects with risk, finance, legal, internal audit, or other control teams, and how the board keeps watch over that arrangement. Please include the source documents, dates, and any changes during the period.
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 practical basis used to identify the controls, procedures, delegated responsibilities and oversight links included in the disclosure, and explain how you decided which governance arrangements to count or describe.
Context note
Explain what the governance setup shows about how sustainability matters are managed in practice, including where responsibility sits and how the different business functions support it.
Fluctuation statement
If the governance picture changed from the prior period, note whether that was due to a new control, a revised delegated role, stronger links with other functions, or a change in oversight arrangements.
Content index entry
s1-27-b Management role in governance — [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 board team instead of the process owner
The request goes to directors’ support staff when the real evidence sits with the manager who runs the control, so the file comes back incomplete or second-hand.
Using framework labels instead of the business term
People are asked for a governance phrase they do not use internally, and they cannot map it to the committee, role or process they actually track.
Leaving the scope too loose
The team never pins down which business units, committees or delegated roles are in scope, so different contributors send data from different populations.
Mixing periods or cut-off dates
One source is pulled for the current quarter while another is taken from a later sign-off pack, which makes the evidence set inconsistent.
Combining unlike counting bases
Headcount-style totals, named-role lists and process descriptions are merged into one extract, even though they need to stay separate for clean review.
Dropping the original source labels
The extract loses the document titles, version marks or system tags that show where each item came from, so reviewers cannot trace it back.
Skipping evidence metadata
The pack contains the answer but not the date, owner, version or location of the underlying record, which leaves no audit trail for checking.
No sign-off trail on the draft
The collected material is circulated without a clear reviewer and approver record, so nobody can show who checked the inputs before drafting.
Where judgement is often needed
Newly acquired or sold parts of the business
Set a clear cut-off for when a business unit starts or stops being included, and explain any change in the management role narrative where the reporting perimeter has moved during the period.
Different local job titles for the same management role
Use one organisation-wide label for the delegated role or committee, then note any country-specific titles only where they help readers understand the same function across locations.
Mixed reporting lines across functions
If the role draws on risk, finance, legal, internal audit or other teams in different ways, describe the actual working arrangement rather than forcing a single structure that does not fit every unit.
Partial coverage of the organisation
Where the management role is only in place for some operations, explain which parts are covered, which are not, and why the boundary is set that way.
Timing of changes during the year
Choose a consistent point for reflecting a new delegation, committee change or oversight arrangement, and disclose that timing so readers can see whether the description is based on year-end or an earlier state.
Judgement between direct evidence and management estimate
If the description relies on interviews, policy review or other indirect evidence rather than a single formal record, say so and explain the basis used to support the wording.
Aggregation to protect sensitive people data
When naming individuals or small teams would create privacy issues, summarise the role at a higher level and state that the detail has been grouped to avoid identifying people.
Rounding and level of detail in role descriptions
If you simplify counts, dates or reporting lines for readability, keep the method consistent and make clear that the figures or descriptions are rounded or summarised.
Different governance practices by country
Where local entities use different control or oversight arrangements, explain whether the disclosure reflects the group-wide model, local practice, or a blend of both, and keep that choice consistent.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — Manufacturing
We are providing this as a synthetic example only. Our board receives a quarterly control pack that combines sustainability risks, finance updates, legal matters and internal audit findings, and it uses that pack to review the way our reporting process is run. - A sustainability steering committee, chaired by the CFO and including the general counsel, head of internal audit and risk lead, prepares the monthly review pack and escalates unresolved issues to the board. - The board approves the reporting timetable, sign-off steps and evidence checks, while the audit committee tracks whether the delegated group has carried out its actions and reports back on any gaps.
Illustrative only: shows one way a company might describe the governance chain, the linked functions, and how directors keep watch over the delegated group.
Illustrative (synthetic) example — Retail
This is a synthetic illustration, not a real disclosure. Our directors use a monthly assurance dashboard to oversee how sustainability reporting is controlled, with input from finance, legal, risk and internal audit so that issues are considered alongside wider business decisions. - An ESG reporting committee made up of the finance director, company secretary, risk manager and internal audit manager runs the day-to-day process, including evidence collection, review points and issue logging. - The board’s audit and risk committee receives exception reports each quarter, checks whether the committee has followed the agreed process, and asks for remediation plans where controls need strengthening.
Illustrative only: demonstrates a different sector example with a separate delegated group, connected support functions and board-level monitoring of that group’s work.
How companies report s1-27-b
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 shows that sustainability-related risks and opportunities are integrated into and inform the entity’s overall risk management process (p.190). The report also references procedures and relevant documentation related to sustainability governance and risk, though it does not clearly disclose specific controls and procedures used (p.176). Additionally, while there is related context about management’s role and oversight over delegated roles, these aspects are not clearly detailed in the report (pp.181, 184).
MTR Corporation
Ground Transportation — Railroads · Hong Kong · 2025
MTR Corporation’s Sustainability Report 2025 shows that the day-to-day management of the Corporation's business is delegated to the Executive Committee (p.13), with oversight of the risk management framework and its implementation detailed on page 82. The report references the use of an Enterprise Risk Management (ERM) framework to evaluate sustainability-related impacts, risks, and opportunities, including materiality assessments (p.7, p.9). However, there is no clear disclosure on the controls and procedures used, and the integration of sustainability governance with finance, legal, or internal audit functions remains unclear (p.80).
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Scenarios to work through
A finance director has asked the sustainability lead to run the day-to-day climate reporting process, with input from risk and internal audit. The board wants to know how that arrangement is controlled and who checks the work.
QWhat should the preparer explain about the way this delegated role is set up and monitored?
Reveal model answer →Hide answer ↑Describe the practical controls and checks around the delegated role, including how it links with other functions such as risk, finance, legal or internal audit, and how the board or its committees keep oversight of the work. The explanation should show both the assignment of the task and the supervision around it, using wording adapted to the organisation and checked against the source before sign-off.
Why this matters · Show both the delegation itself and the control framework around it, not just who does the work.
A sustainability committee has been given responsibility for preparing the climate section, while the main board receives a summary only at year end. The reporting team is unsure whether that committee arrangement is enough to describe in governance disclosures.
QHow should the team decide what to say about the committee’s role?
Reveal model answer →Hide answer ↑State clearly that a committee or similar management group has been given the task, and explain what part of the reporting process it handles. Keep the description factual and specific to the organisation, and make sure it is clear how that group sits within the wider governance setup before finalising the wording.
Why this matters · Name the delegated group and its job in plain language, with enough detail for readers to understand its place in the process.
The legal team reviews external climate claims, the finance team checks assumptions in the numbers, and internal audit tests the reporting controls. The sustainability manager is unsure whether these links need to be described together or separately.
QWhat is the right way to present the involvement of these other functions?
Reveal model answer →Hide answer ↑Bring out how the delegated reporting role is connected to the relevant support functions, whether that is risk, finance, legal, internal audit or another part of the business. The point is to show the joined-up process around the management role, not to list departments without explaining their contribution.
Why this matters · Explain the cross-functional links that support the delegated role and make the process credible.
A board committee has delegated climate reporting to management, but the board only receives a short dashboard and does not review the underlying controls. The reporting team is drafting governance text and is unsure whether that limited review is enough to mention.
QWhat should the disclosure make clear about oversight of the delegated role?
Reveal model answer →Hide answer ↑Explain how the board or its committees keep watch over the delegated work, including what they review and how they stay informed. If oversight is limited, describe it honestly and in a way that matches the organisation’s actual practice, then check the source wording before sign-off.
Why this matters · The disclosure should show real oversight of the delegated role, not just the existence of delegation.
Framework references
Related framework references
How this disclosure maps across the major reporting frameworks.
IFRS / ISSB
s1-27-b
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 s1-27-b, what should I actually gather before drafting the disclosure?+−
The page says to prepare four datapoints: controls and checks, delegated role or committee, cross-functional integration, and delegated role oversight. Use those as the starting point for your data request and evidence pack.
How do I use the step-by-step 'how to prepare' section for s1-27-b?+−
Use it as a working sequence for drafting the disclosure: identify the datapoints, collect supporting evidence, and then turn that into a narrative and draft output. The page is designed as a practical prep aid rather than a formal standard.
What evidence should I keep for assurance on s1-27-b?+−
The page includes five assurance claims to verify, each framed around a claim, the related risk, and the evidence to support it. It also gives a five-item evidence pack to help you build an assurance-ready file.
What goes into the evidence pack for s1-27-b assurance readiness?+−
The page provides a five-item evidence pack to support assurance readiness. Use it alongside the five assurance claims so you can show what was checked, who was involved, and what documents support the disclosure.
What are the common mistakes people make when reporting s1-27-b?+−
The page lists common reporting gaps and mistakes to help you avoid weak or incomplete disclosures. It is useful as a final check before you turn the data into a draft.
How do I turn the s1-27-b data into a draft disclosure?+−
The page includes draft-output support such as visualisation ideas, narrative starters, and a content-index line. Those are meant to help you convert the prepared data into a usable draft quickly.
Is there a workbook or download I can use for s1-27-b prep and assurance?+−
Yes. The Download Centre includes a Prep & Assurance workbook in .xlsx format and a printable Library Card in .pdf format. They are there to help you organise the disclosure work and evidence.
Can I use the 'From company reports' table to see how others disclosed s1-27-b?+−
Yes. The page links to real published reports at the pages where the topic is disclosed, so you can review how the disclosure appears in practice. Use it as a reference point, not as a template to copy.
What is the closest ESRS correspondence for s1-27-b, and can I reuse the data?+−
The page says the closest ESRS correspondence is ESRS 2 (General Disclosures). You can treat the data as reusable across frameworks where relevant, but the page does not say the requirements are identical.
What kind of illustrative example does the s1-27-b page include?+−
It includes synthetic illustrative example disclosures, including a quantitative table. The examples are there to show how the disclosure might look in practice, not to provide real company data.
More questions this page can help with
s1-27-b disclosure checklist: what datapoints, evidence and draft outputs does the page give me?How do I assign ownership for s1-27-b across HR, ESG and controls teams?What should a data owner collect for s1-27-b controls and checks?How do I make s1-27-b assurance-ready using the workbook and evidence pack?What are the five assurance claims to verify for s1-27-b?What are the common gaps in s1-27-b reporting and how do I avoid them?How do I use the narrative starters on the s1-27-b page to write a first draft?Where can I find real company report examples for s1-27-b on the page?What does delegated role or committee mean in the s1-27-b prep page?How do I evidence cross-functional integration for s1-27-b?Can I use the s1-27-b Library Card PDF for internal review and sign-off?How should I use the content-index line in the s1-27-b draft output section?
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