IFRS S2 overview

Pillar 2 of 4

IFRS S2: Strategy

Climate-related risks and opportunities, their effects on the business model and value chain, strategic response and transition plans, financial effects over the short, medium, and long term, and climate resilience under scenario analysis. Covers paragraphs 9 through 23.

51 disclosuresAuthored by Greentryst Climate Disclosure Desk

Requirement

Specifically, an entity shall disclose information to enable users of general purpose financial reports to understand the climate-related risks and opportunities that could reasonably be expected to affect the entity's prospects (see paragraphs 10 to 12).

Verbatim · IFRS S2

What it means

This opening requirement sets the scope of everything that follows in the Strategy pillar. The entity must identify the climate-related risks and opportunities reasonably expected to affect its prospects, meaning its financial position, performance, and cash flows over the short, medium, and long term. Paragraphs 10 through 12 set out how to do it: describe each risk and opportunity, classify physical versus transition, and place each on a time horizon.

Plain English · Greentryst

Illustrative Disclosure

"We have identified six principal climate-related risks and four principal opportunities, grouped by transition and physical categories and mapped to our three-horizon planning cycle. Each is supported by a short description, the business units most exposed, and the time horizon over which we expect the effect to crystallise. Full detail follows in the tables accompanying this section."

What a good disclosure looks like

Requirement

The current and anticipated effects of those climate-related risks and opportunities on the entity's business model and value chain (see paragraph 13).

Verbatim · IFRS S2

What it means

Having identified the risks and opportunities under 9(a), the entity must trace them into its business model and value chain. "Current" effects are those observed in the reporting period; "anticipated" effects are those the entity expects to occur within its planning horizons. Paragraph 13 expands on the mechanics.

Plain English · Greentryst

Illustrative Disclosure

"The transition risks identified in 9(a) are already reshaping procurement: steel inputs subject to the EU CBAM have added 4.2 per cent to landed cost on affected SKUs in 2024. We anticipate a further 12 to 18 per cent increase by 2028 under our central transition scenario, concentrated in three product families manufactured at our two European plants."

What a good disclosure looks like

Requirement

The effects of those climate-related risks and opportunities on the entity's strategy and decision-making, including information about its climate-related transition plan (see paragraph 14).

Verbatim · IFRS S2

What it means

The test is whether climate information is changing decisions, not merely being tracked. The entity describes how risks and opportunities flow into strategy reviews, capital allocation, acquisitions and divestments, and product design, and it summarises its transition plan if one exists. Paragraph 14 prescribes the detail.

Plain English · Greentryst

Illustrative Disclosure

"Climate inputs are now incorporated into our annual strategy review and into every capital proposal above £25 million. Our transition plan, approved by the Board in June 2024, sets out how we intend to reach 2030 interim emissions targets through a combination of asset retirement, renewable power procurement, and low-carbon product redesign."

What a good disclosure looks like

Requirement

The effects of those climate-related risks and opportunities on the entity's financial position, financial performance and cash flows for the reporting period, and their anticipated effects on the entity's financial position, financial performance and cash flows over the short, medium and long term, taking into consideration how those climate-related risks and opportunities have been factored into the entity's financial planning (see paragraphs 15 to 21).

Verbatim · IFRS S2

What it means

Climate is not disclosed in isolation from the numbers. The entity must explain how the risks and opportunities have already affected this year's financial statements and how they are expected to affect future periods. Paragraphs 15 through 21 prescribe the quantitative and qualitative expectations and provide relief where quantification is not feasible.

Plain English · Greentryst

Illustrative Disclosure

"Physical damage from the Q3 2024 flood at our Rotterdam facility reduced EBIT by £14m, recognised within cost of sales. Over our five-year plan we expect between £40m and £90m of additional operating costs from the two plants in hydrologically exposed catchments, and between £25m and £60m of revenue upside from low-carbon product lines. The ranges reflect the spread of outcomes across our two central transition scenarios."

What a good disclosure looks like

Requirement

The climate resilience of the entity's strategy and its business model to climate-related changes, developments and uncertainties, taking into consideration the entity's identified climate-related risks and opportunities (see paragraph 22).

Verbatim · IFRS S2

What it means

Resilience is tested using climate-related scenario analysis. The entity must describe how its strategy and business model hold up under a set of plausible but divergent climate futures, and must be explicit about what would have to change to remain viable in each. Paragraph 22 sets out the depth of disclosure expected.

Plain English · Greentryst

Illustrative Disclosure

"Under our high-warming physical scenario, two of our six production sites become operationally uneconomic before 2040 without material adaptation investment. Under our fast-transition scenario, our internal combustion product family loses roughly 35 per cent of addressable market by 2035. The transition plan and capital allocation framework described in 9(c) are designed to respond to both sets of conditions."

What a good disclosure looks like

IFRS S2 10(a)Lesson 2.1
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Requirement

An entity shall disclose information that enables users of general purpose financial reports to understand the climate-related risks and opportunities that could reasonably be expected to affect the entity's prospects. Specifically, the entity shall describe climate-related risks and opportunities that could reasonably be expected to affect the entity's prospects.

Verbatim · IFRS S2

What it means

The entity lists and describes each climate-related risk and opportunity by name. Generic categories are not enough; the description should be specific enough that a reader can understand what exposure it refers to, what causes it, and where it sits in the business.

Plain English · Greentryst

Illustrative Disclosure

"Risk P2: Chronic water stress at our Gujarat and Andalucía sites. Driver: declining annual precipitation and rising competing demand from agriculture. Potential impact: production curtailment during summer months, forced withdrawals to tankered supply. Business units affected: Industrial Coatings and Specialty Chemicals."

What a good disclosure looks like

IFRS S2 10(b)Lesson 2.1
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Requirement

An entity shall explain, for each climate-related risk the entity has identified, whether the entity considers the risk to be a climate-related physical risk or climate-related transition risk.

Verbatim · IFRS S2

What it means

Every risk described under 10(a) is tagged as physical or transition. Physical risks are driven by the changing climate itself (acute events, chronic shifts). Transition risks are driven by the response to climate change (policy, technology, market, reputation). Some risks present as both; the disclosure should say so and split the exposure where possible.

Plain English · Greentryst

Illustrative Disclosure

"Of the six identified principal risks, four are physical (two acute, two chronic) and two are transition (policy and market). Risk T1, regulatory cost of carbon, is treated primarily as a transition risk but has a secondary physical element where carbon-price-driven demand shifts expose us to stranded assets."

What a good disclosure looks like

IFRS S2 10(c)Lesson 2.1
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Requirement

An entity shall specify, for each climate-related risk and opportunity the entity has identified, over which time horizons, short, medium or long term, the effects of each climate-related risk and opportunity could reasonably be expected to occur.

Verbatim · IFRS S2

What it means

Each risk and opportunity is placed on a time horizon. The standard does not fix the boundaries; the entity chooses but must explain its choice under 10(d). The same risk can span multiple horizons; disclosures typically show the primary horizon and note any spillover.

Plain English · Greentryst

Illustrative Disclosure

"Risk T1 (regulatory cost of carbon) crystallises in the medium term, driven by the EU CBAM ramp to 2034. Risk P3 (acute heat stress at the Chennai site) is already present (short term) and intensifies in the long term. Opportunity O2 (low-carbon steel premium) emerges medium term and scales long term."

What a good disclosure looks like

IFRS S2 10(d)Lesson 2.1
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Requirement

An entity shall explain how the entity defines 'short term', 'medium term' and 'long term' and how these definitions are linked to the planning horizons used by the entity for strategic decision-making.

Verbatim · IFRS S2

What it means

The entity tells the reader how to interpret its time labels. The key discipline is consistency: the short, medium, and long term windows used for climate should be the same windows used in strategic planning, capital allocation, and enterprise risk management. Any deviation should be explained.

Plain English · Greentryst

Illustrative Disclosure

"We define short term as up to three years, medium term as three to ten years, and long term as ten to thirty years. These windows align with our annual operating plan (short), our five-year strategic review cycle extended for climate (medium), and our long-lived asset replacement horizon (long). The same definitions are applied in our principal-risk reporting."

What a good disclosure looks like

Requirement

In identifying the climate-related risks and opportunities that could reasonably be expected to affect an entity's prospects, the entity shall use all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort, including information about past events, current conditions and forecasts of future conditions.

Verbatim · IFRS S2

What it means

This is the effort test. The entity is expected to use information it has, information it could reasonably obtain, and information it is capable of forecasting. "Without undue cost or effort" is not a license to ignore: the threshold is set against the entity's size, sophistication, and the materiality of the matter.

Plain English · Greentryst

Illustrative Disclosure

"Our identification process drew on ten years of internal loss data, two independent physical-risk datasets (Jupiter Intelligence and an internal catchment model), policy horizon scans prepared by our regulatory affairs team, and three externally sourced transition scenarios. The process is described in more detail under Risk Management in this report."

What a good disclosure looks like

Requirement

In identifying the climate-related risks and opportunities that could reasonably be expected to affect an entity's prospects, the entity shall refer to and consider the applicability of the industry-based disclosure topics defined in the Industry-based Guidance on Implementing IFRS S2.

Verbatim · IFRS S2

What it means

The ISSB inherited SASB's industry-based guidance. The entity is required to consider the disclosure topics listed for its industry and explain what applies. The entity may conclude that a topic is not material and should say so, but it cannot ignore the guidance silently.

Plain English · Greentryst

Illustrative Disclosure

"As an Electric Utilities & Power Generators issuer, we have reviewed the IFRS S2 industry-based topics. We consider all topics applicable except 'Nuclear Safety and Emergency Management', which is not relevant to our generation mix. Our material industry topics are disclosed alongside the cross-industry disclosures in the Metrics and Targets section."

What a good disclosure looks like

IFRS S2 13(a)Lesson 2.2
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Requirement

An entity shall disclose a description of the current and anticipated effects of climate-related risks and opportunities on the entity's business model and value chain.

Verbatim · IFRS S2

What it means

The entity describes, in narrative form, how climate-related risks and opportunities are reshaping inputs, operations, outputs, and customer relationships. The description is forward-looking where the entity has a view and backward-looking where effects have already landed.

Plain English · Greentryst

Illustrative Disclosure

"Climate-related transition pressure has shifted our procurement toward certified low-carbon raw materials, now representing 34 per cent of purchased volume in 2024 against 11 per cent in 2020. We anticipate this share rising to above 60 per cent by 2028 under our central transition scenario."

What a good disclosure looks like

IFRS S2 13(b)Lesson 2.2
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Requirement

An entity shall disclose a description of where in the entity's business model and value chain climate-related risks and opportunities are concentrated (for example, geographical areas, facilities and types of assets).

Verbatim · IFRS S2

What it means

Aggregate numbers hide risk. The entity must pinpoint where exposures are concentrated: specific geographies, named sites, asset classes, supply-chain nodes. The level of specificity should be enough for a reader to understand where failure would hurt most.

Plain English · Greentryst

Illustrative Disclosure

"Physical risk is concentrated at four sites accounting for 38 per cent of Group revenue: two in the Gulf of Mexico (storm surge), one in Gujarat (water stress), and one in Queensland (bushfire). Transition risk is concentrated in our carbon-intensive downstream product line, which represented 22 per cent of revenue in 2024."

What a good disclosure looks like

IFRS S2 14(a)(i)under 14(a)Lesson 2.3
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Requirement

An entity shall disclose information about current and anticipated changes to the entity's business model, including its resource allocation, to address climate-related risks and opportunities (for example, these changes could include plans to manage or decommission carbon-, energy- or water-intensive operations; resource allocations resulting from demand or supply-chain changes; resource allocations arising from business development through capital expenditure or additional expenditure on research and development; and acquisitions or divestments).

Verbatim · IFRS S2

What it means

The entity describes how its business model is being reshaped by its climate response. Decommissioning plans, capital reallocation, acquisitions and divestments, and R&D pivots are all in scope. Vague aspirations are insufficient; the disclosure should name the moves.

Plain English · Greentryst

Illustrative Disclosure

"We have accelerated the decommissioning of our two coal-fired assets to 2028 and 2031 (previously 2035 and 2038), released approximately £340m of capital from the coal-linked trading business, and reallocated £280m of it to the low-carbon hydrogen development pipeline. The remaining £60m funds adaptation investments at our two water-stressed sites."

What a good disclosure looks like

IFRS S2 14(a)(ii)under 14(a)Lesson 2.3
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Requirement

An entity shall disclose information about current and anticipated direct mitigation and adaptation efforts (for example, through changes in production processes or equipment, relocation of facilities, workforce adjustments, and changes in product specifications).

Verbatim · IFRS S2

What it means

"Direct" means effects within the entity's own operations. The disclosure covers process and equipment upgrades, facility moves, workforce transition, and product redesign. The standard wants concrete examples, not a general commitment to reduce emissions.

Plain English · Greentryst

Illustrative Disclosure

"We installed electric boilers at our Rotterdam and Antwerp plants in 2024, retiring 4.2 MW of gas-fired steam capacity. We relocated a processing line out of our flood-exposed Chennai facility to a lower-risk inland site. We re-specified our flagship coating product to meet a 30 per cent embodied-carbon reduction by 2025, with qualification complete in Q2 2024."

What a good disclosure looks like

IFRS S2 14(a)(iii)under 14(a)Lesson 2.3
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Requirement

An entity shall disclose information about current and anticipated indirect mitigation and adaptation efforts (for example, through working with customers and supply chains).

Verbatim · IFRS S2

What it means

"Indirect" means effects beyond the entity's operational boundary: supplier engagement, customer enablement, co-investment. The disclosure should describe the mechanisms (programmes, contracts, incentives) and the expected reach.

Plain English · Greentryst

Illustrative Disclosure

"Our Top 50 Supplier Engagement Programme, launched in 2023, has now seen 42 suppliers set SBTi-validated targets covering 68 per cent of our Purchased Goods and Services spend. On the customer side, we launched an embodied-carbon advisory service in 2024 which has supported 280 customer product specifications toward lower-carbon alternatives."

What a good disclosure looks like

IFRS S2 14(a)(iv)under 14(a)Lesson 2.3
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Requirement

An entity shall disclose information about any climate-related transition plan the entity has, including information about key assumptions used in developing its transition plan, and dependencies on which the entity's transition plan relies.

Verbatim · IFRS S2

What it means

A transition plan is disclosable when it exists. The standard asks for the underlying assumptions (policy path, carbon price, technology availability) and the external dependencies (grid decarbonisation, public infrastructure, supplier capability) that the plan relies on. Fragile dependencies must be named.

Plain English · Greentryst

Illustrative Disclosure

"Our transition plan assumes a 4 per cent per year decarbonisation of the Indian electricity grid between 2024 and 2035, a carbon price reaching €120/t in the EU by 2030, and commercial availability of direct-reduction iron using hydrogen by 2032. A slower grid decarbonisation path would materially reduce our 2030 Scope 2 reduction by up to 8 percentage points."

What a good disclosure looks like

IFRS S2 14(a)(v)under 14(a)Lesson 2.3
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Requirement

An entity shall disclose information about how the entity plans to achieve any climate-related targets, including any greenhouse gas emissions targets, described in accordance with paragraphs 33 to 36.

Verbatim · IFRS S2

What it means

Targets without pathways are not credible. The entity must link each target to the levers that deliver it and provide enough visibility that a reader can see how the arithmetic adds up.

Plain English · Greentryst

Illustrative Disclosure

"Our 2030 Scope 1 and 2 absolute reduction target of 42 per cent vs 2020 is delivered through four named levers: coal-to-renewable-electricity switch (22 percentage points), process electrification (11 points), energy efficiency (6 points), and early retirement of two legacy assets (3 points). Each lever has an owner, a capital budget, and a milestone schedule tracked quarterly."

What a good disclosure looks like

IFRS S2 14(b)Lesson 2.3
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Requirement

An entity shall disclose information about how the entity is resourcing, and plans to resource, the activities disclosed in accordance with paragraph 14(a).

Verbatim · IFRS S2

What it means

Plans need money, people, and time. The entity discloses how it is funding the activities above and what capability it is building. This is where a transition plan stops being aspiration and starts being a capital and operating commitment.

Plain English · Greentryst

Illustrative Disclosure

"The transition plan is resourced through a ring-fenced capital envelope of £1.2bn over 2024 to 2030, approved by the Board. Operating capability sits in the 34-person Decarbonisation Programme Office reporting to the Chief Sustainability Officer. Supplier engagement is funded through a dedicated £18m annual budget within the Procurement function."

What a good disclosure looks like

IFRS S2 14(c)Lesson 2.3
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Requirement

An entity shall disclose quantitative and qualitative information about the progress of plans disclosed in previous reporting periods in accordance with paragraph 14(a).

Verbatim · IFRS S2

What it means

A year-over-year accountability line. The entity reports against what it said last year: what was delivered, what slipped, and why. This is how IFRS S2 prevents transition plans from resetting every year.

Plain English · Greentryst

Illustrative Disclosure

"Of the nine 2024 transition plan milestones set in the 2023 disclosure, six were delivered on time, two delivered late (electric boiler commissioning at Antwerp, delayed 4 months by grid connection; supplier engagement enrolment, now at 42 against target 50), and one was re-baselined (hydrogen pilot deferred 12 months pending technology readiness)."

What a good disclosure looks like

IFRS S2 15(a)Lesson 3.1
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Requirement

An entity shall disclose information that enables users of general purpose financial reports to understand the effects of climate-related risks and opportunities on the entity's financial position, financial performance and cash flows for the reporting period (current financial effects).

Verbatim · IFRS S2

What it means

Current-period financial effects must be surfaced. These are the effects that have already landed in this year's numbers, whether as asset impairments, higher operating costs, revenue changes, or capital spend. The entity points the reader to the line items where the effects sit.

Plain English · Greentryst

Illustrative Disclosure

"Climate-related current financial effects in 2024 were £68m, comprising: £41m of accelerated depreciation on the two coal assets being decommissioned early; £14m of flood-related loss at the Rotterdam facility within cost of sales; £9m of increased CBAM-linked raw material cost; and £4m of one-off EU ETS allowance purchases."

What a good disclosure looks like

IFRS S2 15(b)Lesson 3.1
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Requirement

An entity shall disclose information that enables users of general purpose financial reports to understand the anticipated effects of climate-related risks and opportunities on the entity's financial position, financial performance and cash flows over the short, medium and long term, taking into consideration how climate-related risks and opportunities are included in the entity's financial planning (anticipated financial effects).

Verbatim · IFRS S2

What it means

Forward-looking financial effects are required in quantitative or qualitative form. The entity explains how its financial plan incorporates climate assumptions, what range of outcomes this produces, and where material effects concentrate.

Plain English · Greentryst

Illustrative Disclosure

"Our five-year financial plan includes a central transition scenario that adds approximately £180m to cumulative operating cost through 2029 and approximately £240m of additional capital expenditure. A sensitivity to a faster transition path adds a further £90m to operating cost and accelerates £150m of capital expenditure into 2026 to 2027."

What a good disclosure looks like

IFRS S2 16(a)Lesson 3.1
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Requirement

Specifically, an entity shall disclose quantitative and qualitative information about how climate-related risks and opportunities have affected its financial position, financial performance and cash flows for the reporting period.

Verbatim · IFRS S2

What it means

A closer-grained version of 15(a): the entity explains not only that climate effects have landed in the numbers but how they flowed through specific captions. Asset write-downs, provisions, revenue variance, operating cost, and capital expenditure are the usual vectors.

Plain English · Greentryst

Illustrative Disclosure

"The coal-asset decommissioning acceleration led to £41m of accelerated depreciation recognised in cost of sales, and a £12m impairment charge on related decommissioning infrastructure recognised as a non-operating item. The £14m Rotterdam flood loss is net of £22m of insurance recoveries recognised within other operating income."

What a good disclosure looks like

IFRS S2 16(b)Lesson 3.2
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Requirement

The climate-related risks and opportunities identified in paragraph 16(a) for which there is a significant risk of a material adjustment within the next annual reporting period to the carrying amounts of assets and liabilities reported in the related financial statements.

Verbatim · IFRS S2

What it means

The twelve-month outlook. The entity flags the climate-related matters most likely to move the balance sheet in the next reporting period: impairment triggers, provision updates, asset-retirement obligation re-measurements.

Plain English · Greentryst

Illustrative Disclosure

"We consider there to be a significant risk of a material adjustment in the next reporting period to: (a) the carrying value of the Gujarat facility, subject to ongoing water-availability monitoring that may trigger an impairment review in H1 2026; and (b) the asset retirement obligation for the two coal plants, where decommissioning cost assumptions are being refreshed in Q4 2025."

What a good disclosure looks like

IFRS S2 16(c)(i)under 16(c)Lesson 3.2
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Requirement

An entity shall disclose quantitative and qualitative information about how the entity expects its financial position to change over the short, medium and long term, given its strategy to manage climate-related risks and opportunities, taking into consideration its investment and disposal plans (for example, plans for capital expenditure, major acquisitions and divestments, joint ventures, business transformation, innovation, new business areas, and asset retirements), including plans the entity is not contractually committed to.

Verbatim · IFRS S2

What it means

The entity ties its climate strategy to movements on the balance sheet: what will be bought, built, retired, or divested over the coming planning horizons. Non-committed plans count; investors read them as strategic intent.

Plain English · Greentryst

Illustrative Disclosure

"Over the next five years we plan approximately £1.2bn of climate-related capital expenditure, concentrated in low-carbon process equipment at European sites; we expect to divest our coal-linked trading subsidiary by end 2026, with a carrying value of approximately £220m; and we will complete the retirement of two coal assets by 2031, removing £340m of property, plant, and equipment from the balance sheet."

What a good disclosure looks like

IFRS S2 16(c)(ii)under 16(c)Lesson 3.2
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Requirement

An entity shall disclose quantitative and qualitative information about how the entity expects its financial position to change over the short, medium and long term, given its strategy to manage climate-related risks and opportunities, taking into consideration its planned sources of funding to implement its strategy.

Verbatim · IFRS S2

What it means

The entity explains how the climate strategy will be funded: operating cash flow, debt, equity, sustainability-linked instruments, green bonds, divestment proceeds. If sustainable finance is used, the instrument terms and key performance conditions should be described.

Plain English · Greentryst

Illustrative Disclosure

"The £1.2bn transition capital programme is funded approximately 55 per cent from operating cash flow, 30 per cent from two sustainability-linked loans issued in 2023 and 2024 (total facility £650m, step-up/step-down linked to Scope 1+2 intensity), and 15 per cent from divestment proceeds from the planned coal-linked trading exit."

What a good disclosure looks like

IFRS S2 16(d)Lesson 3.2
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Requirement

An entity shall disclose quantitative and qualitative information about how the entity expects its financial performance and cash flows to change over the short, medium and long term, given its strategy to manage climate-related risks and opportunities (for example, increased revenue from products and services aligned with a lower-carbon economy; costs arising from physical damage to assets from climate events; and expenses associated with climate adaptation or mitigation).

Verbatim · IFRS S2

What it means

Bridges to the income statement and cash flow. The disclosure names the revenue opportunities, cost exposures, and mitigation expense associated with climate strategy, and ties them to the same time horizons used elsewhere.

Plain English · Greentryst

Illustrative Disclosure

"We expect our low-carbon product families to add between £150m and £300m of annual revenue by 2028, and between £350m and £700m by 2033. Physical damage cost is expected to average £10m to £20m per year over the next five years, net of insurance. Adaptation operating expense is expected to be £25m to £40m per year, largely at the two water-stressed sites."

What a good disclosure looks like

IFRS S2 18(a)Lesson 3.3
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Requirement

In preparing disclosures about the anticipated financial effects of a climate-related risk or opportunity, an entity shall use all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort.

Verbatim · IFRS S2

What it means

Mirror of paragraph 11 applied to financial effects. The entity is expected to use the information it has and the information it could reasonably obtain. The standard does not require new analytical methods the entity does not possess; it does require genuine effort against the information that exists.

Plain English · Greentryst

Illustrative Disclosure

"Anticipated financial effects in this disclosure are prepared using our existing five-year financial planning model extended for climate inputs: internal carbon price, expected physical-loss frequency from the two external datasets referenced under paragraph 11, and product-mix assumptions from Strategy. Beyond the five-year window, disclosures are qualitative."

What a good disclosure looks like

IFRS S2 18(b)Lesson 3.3
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Requirement

In preparing disclosures about the anticipated financial effects of a climate-related risk or opportunity, an entity shall use an approach that is commensurate with the skills, capabilities and resources that are available to the entity for preparing those disclosures.

Verbatim · IFRS S2

What it means

The proportionality principle. A small entity is not expected to run the same quantitative modelling a large insurer would. But the entity must be explicit about the approach it used and the capability constraints it faced.

Plain English · Greentryst

Illustrative Disclosure

"We have applied a bottom-up site-level model for physical effects given our in-house modelling team and data access. For transition effects, we have used externally sourced scenarios and supplier-level price and volume effects because we do not maintain an in-house macroeconomic capability. Methods are described further below."

What a good disclosure looks like

IFRS S2 21(a)Lesson 3.3
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Requirement

If an entity determines that it need not provide quantitative information about the current or anticipated financial effects of a climate-related risk or opportunity applying the criteria set out in paragraphs 19 to 20, the entity shall explain why it has not provided quantitative information.

Verbatim · IFRS S2

What it means

The standard allows qualitative-only disclosure in specific circumstances (paragraphs 19 and 20) but requires the entity to say why. The explanation should identify which criterion applied (data availability, skills, measurement uncertainty) and be specific to the exposure in question.

Plain English · Greentryst

Illustrative Disclosure

"For the supply-chain disruption risk identified under 10(a), we have not provided quantitative current or anticipated financial effects. Our Tier-2 supplier emissions and location data are not yet sufficient to support a defensible monetary estimate. We expect to move to a quantitative estimate for 2026 reporting as our supplier engagement programme delivers improved input data."

What a good disclosure looks like

IFRS S2 21(b)Lesson 3.3
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Requirement

If an entity determines that it need not provide quantitative information about the current or anticipated financial effects of a climate-related risk or opportunity applying the criteria set out in paragraphs 19 to 20, the entity shall provide qualitative information about those financial effects, including identifying line items, totals and subtotals within the related financial statements that are likely to be affected, or have been affected, by that climate-related risk or opportunity.

Verbatim · IFRS S2

What it means

Qualitative does not mean vague. The entity still points the reader to the specific financial-statement line items where the effect lands or is expected to land: which revenue stream, which cost caption, which asset class.

Plain English · Greentryst

Illustrative Disclosure

"For the supply-chain disruption risk, we expect financial effects to flow primarily through cost of sales (input-price pass-through) and inventory (working-capital build for critical components), with a secondary effect on revenue in the two product families most dependent on single-source inputs."

What a good disclosure looks like

IFRS S2 21(c)Lesson 3.3
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Requirement

If an entity determines that it need not provide quantitative information about the current or anticipated financial effects of a climate-related risk or opportunity applying the criteria set out in paragraphs 19 to 20, the entity shall provide quantitative information about the combined financial effects of that climate-related risk or opportunity with other climate-related risks or opportunities and other factors unless the entity determines that quantitative information about the combined financial effects would not be useful.

Verbatim · IFRS S2

What it means

Where a single exposure cannot be quantified, the standard still invites the entity to provide a combined quantitative view if doing so is informative. The exception clause ("unless... not useful") should be applied sparingly.

Plain English · Greentryst

Illustrative Disclosure

"Although we have not quantified the supply-chain disruption risk individually, it is incorporated into the combined stress scenario described under paragraph 22, which estimates aggregate operating-cost pressure of £120m to £230m under our fast-transition case through 2030."

What a good disclosure looks like

IFRS S2 22(a)(i)under 22(a)Lesson 3.4
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Requirement

An entity shall disclose the entity's assessment of its climate resilience as at the reporting date, which shall enable users of general purpose financial reports to understand the implications, if any, of the entity's assessment for its strategy and business model, including how the entity would need to respond to the effects identified in the climate-related scenario analysis.

Verbatim · IFRS S2

What it means

The resilience headline. The entity states what the scenario analysis tells it about the viability of its current strategy and business model, and names the responses that would be needed if a given scenario materialised.

Plain English · Greentryst

Illustrative Disclosure

"Under our fast-transition scenario, two downstream product lines representing 22 per cent of Group revenue would require redesign or retirement by 2030; the transition plan addresses this through the low-carbon product programme. Under our high-warming physical scenario, adaptation investment of approximately £180m would be required at three sites by 2035 to maintain operations at historic throughput."

What a good disclosure looks like

IFRS S2 22(a)(ii)under 22(a)Lesson 3.4
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Requirement

An entity shall disclose the significant areas of uncertainty considered in the entity's assessment of its climate resilience.

Verbatim · IFRS S2

What it means

The entity is explicit about what it does not know. Policy timing, technology readiness, physical-climate sensitivity, and macro-economic response are the usual suspects. Naming the uncertainties is evidence of rigour, not weakness.

Plain English · Greentryst

Illustrative Disclosure

"The three most significant areas of uncertainty in our assessment are: the pace of grid decarbonisation in our two largest Asian markets; the commercial readiness of green hydrogen for our primary process heat needs; and the regional distribution of extreme precipitation events around our South American operations."

What a good disclosure looks like

IFRS S2 22(a)(iii)(1)under 22(a)(iii)Lesson 3.4
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Requirement

The entity's capacity to adjust or adapt its strategy and business model to climate change over the short, medium and long term, including the availability of, and flexibility in, the entity's existing financial resources to respond to the effects identified in the climate-related scenario analysis, including to address climate-related risks and to take advantage of climate-related opportunities.

Verbatim · IFRS S2

What it means

Can the balance sheet absorb what the scenarios describe? The entity assesses its liquidity, leverage headroom, and funding options against the capital demands implied by each scenario.

Plain English · Greentryst

Illustrative Disclosure

"Our current £2.8bn of undrawn committed credit facilities plus our five-year operating cash flow forecast provide approximately £5bn of deployable capacity, against a peak scenario capital need of £1.8bn in the fast-transition case. Headroom is adequate under all three modelled scenarios."

What a good disclosure looks like

IFRS S2 22(a)(iii)(2)under 22(a)(iii)Lesson 3.4
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Requirement

The entity's ability to redeploy, repurpose, upgrade or decommission existing assets.

Verbatim · IFRS S2

What it means

Physical and capital flexibility. The disclosure assesses whether the asset base can be repositioned in time and at acceptable cost. Long-lived, location-specific assets are usually the binding constraint.

Plain English · Greentryst

Illustrative Disclosure

"Of the six production sites, three are capable of process retrofit within existing permits and lease windows; two require significant rebuild (estimated £140m each); and one would require site reconfiguration or partial retirement under the fast-transition case. The two coal-linked sites are on a contracted decommissioning pathway independent of scenario choice."

What a good disclosure looks like

IFRS S2 22(a)(iii)(3)under 22(a)(iii)Lesson 3.4
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Requirement

The effect of the entity's current and planned investments in climate-related mitigation, adaptation and opportunities for climate resilience.

Verbatim · IFRS S2

What it means

Investments are already shaping resilience. The entity quantifies how current and planned mitigation, adaptation, and opportunity investments reduce exposure or unlock upside under each scenario.

Plain English · Greentryst

Illustrative Disclosure

"Current and planned investments reduce our fast-transition-scenario operating cost impact by approximately £180m per year by 2030 and add approximately £220m of annual revenue from low-carbon product lines in the same year. Adaptation investments at the two water-stressed sites reduce expected production curtailment losses by approximately 65 per cent in the high-warming case."

What a good disclosure looks like

IFRS S2 22(b)(i)(1)under 22(b)(i)Lesson 3.4
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Requirement

Which climate-related scenarios the entity used for the analysis and the sources of those scenarios.

Verbatim · IFRS S2

What it means

Name the scenarios and say where they came from. Published scenarios (IEA, NGFS, IPCC-derived) are usual; internally built scenarios are acceptable if the entity documents methodology.

Plain English · Greentryst

Illustrative Disclosure

"We used three scenarios: the NGFS Net Zero 2050 (ambitious transition), the IEA Stated Policies Scenario (policy-lagged transition), and an internal high-warming physical scenario (RCP 8.5 calibrated to NGFS Current Policies for the economic layer). The internal scenario methodology is documented in our Climate Scenario Technical Note available on request."

What a good disclosure looks like

IFRS S2 22(b)(i)(2)under 22(b)(i)Lesson 3.4
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Requirement

Whether the analysis included a diverse range of climate-related scenarios.

Verbatim · IFRS S2

What it means

A single scenario is not resilience analysis. The standard wants diversity across the plausible outcome space: at minimum, a fast-transition case, a slower-transition or lagged-policy case, and a high-warming physical case.

Plain English · Greentryst

Illustrative Disclosure

"Our three scenarios span a diverse range: the NGFS Net Zero 2050 represents an ambitious orderly transition; the IEA Stated Policies Scenario represents a partial, policy-lagged transition; and our internal high-warming scenario represents a delayed-action future with elevated physical risk. Expected warming outcomes range from 1.4°C to above 3°C by 2100."

What a good disclosure looks like

IFRS S2 22(b)(i)(3)under 22(b)(i)Lesson 3.4
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Requirement

Whether the climate-related scenarios used for the analysis are associated with climate-related transition risks or climate-related physical risks.

Verbatim · IFRS S2

What it means

For each scenario, the entity declares whether it is primarily a transition-risk scenario, a physical-risk scenario, or both. This prevents readers from mismatching scenarios and exposures.

Plain English · Greentryst

Illustrative Disclosure

"The NGFS Net Zero 2050 and IEA Stated Policies scenarios are primarily transition scenarios, with a limited physical overlay. Our internal high-warming scenario is primarily a physical-risk scenario with a lagged-transition economic layer."

What a good disclosure looks like

IFRS S2 22(b)(i)(4)under 22(b)(i)Lesson 3.4
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Requirement

Whether the entity used, among its scenarios, a climate-related scenario aligned with the latest international agreement on climate change.

Verbatim · IFRS S2

What it means

At least one scenario must be Paris-aligned. "Latest international agreement on climate change" is the Paris Agreement; a scenario consistent with limiting warming to 1.5°C (or the 2°C upper bound) satisfies the test.

Plain English · Greentryst

Illustrative Disclosure

"The NGFS Net Zero 2050 scenario is consistent with limiting warming to 1.5°C with limited overshoot and is used as our Paris-aligned reference case, in accordance with paragraph 22(b)(i)(4)."

What a good disclosure looks like

IFRS S2 22(b)(i)(5)under 22(b)(i)Lesson 3.4
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Requirement

Why the entity decided that its chosen climate-related scenarios are relevant to assessing its resilience to climate-related changes, developments or uncertainties.

Verbatim · IFRS S2

What it means

Relevance is not self-evident. The entity explains why each chosen scenario materially stresses the exposures the entity actually has: sectoral profile, geographic footprint, policy environments, customer base.

Plain English · Greentryst

Illustrative Disclosure

"The NGFS Net Zero 2050 is the most stressing transition scenario for our carbon-intensive downstream product line. The IEA Stated Policies scenario tests policy-lag exposure, relevant because three of our largest markets have made slower climate commitments. The internal high-warming scenario tests physical exposure at our four concentrated-risk sites."

What a good disclosure looks like

IFRS S2 22(b)(i)(6)under 22(b)(i)Lesson 3.4
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Requirement

The time horizons the entity used in the analysis.

Verbatim · IFRS S2

What it means

The disclosure states the model horizons for each scenario. Transition scenarios typically extend to 2050; physical scenarios often extend to 2100 to capture chronic effects.

Plain English · Greentryst

Illustrative Disclosure

"Transition scenarios are modelled to 2050 with five-year milestones. The internal physical-risk scenario is modelled to 2100 with output snapshots at 2030, 2050, and 2100 to capture chronic and episodic effects."

What a good disclosure looks like

IFRS S2 22(b)(i)(7)under 22(b)(i)Lesson 3.4
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Requirement

What scope of operations the entity used in the analysis (for example, the operating locations and business units used in the analysis).

Verbatim · IFRS S2

What it means

Coverage transparency. The entity states which parts of the business were inside the scenario analysis and which were excluded. Partial coverage is acceptable but must be disclosed.

Plain English · Greentryst

Illustrative Disclosure

"The scenario analysis covers all owned and operated production sites (six plants, representing approximately 94 per cent of Scope 1 and 2 emissions) and the three revenue-largest product families (representing approximately 81 per cent of Group revenue). Joint-venture operations in Brazil and Mexico are covered qualitatively only."

What a good disclosure looks like

IFRS S2 22(b)(ii)(1)under 22(b)(ii)Lesson 3.4
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Requirement

The key assumptions the entity made in the analysis, including assumptions about climate-related policies in the jurisdictions in which the entity operates.

Verbatim · IFRS S2

What it means

The entity names the policy assumptions driving the scenarios: carbon pricing, sectoral mandates, subsidy regimes, border adjustments. Where scenarios disagree with current policy direction, the entity says so.

Plain English · Greentryst

Illustrative Disclosure

"We assume the EU carbon price reaches €120/t by 2030 and €200/t by 2040 in the Net-Zero case; the CBAM ramp to 2034 as legislated; and a Section 45X-style incentive for low-carbon manufacturing in our two US states through 2033 under the Stated Policies case."

What a good disclosure looks like

IFRS S2 22(b)(ii)(2)under 22(b)(ii)Lesson 3.4
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Requirement

The key assumptions the entity made in the analysis, including assumptions about macroeconomic trends.

Verbatim · IFRS S2

What it means

GDP growth, inflation, discount rates, labour market, and commodity-price paths are all scenario-sensitive. The entity discloses the key macro inputs, ideally aligned with the underlying scenario source to avoid inconsistency.

Plain English · Greentryst

Illustrative Disclosure

"We use the macroeconomic outputs bundled with the NGFS scenarios: global GDP growth of 2.4 per cent per year to 2030 in Net-Zero, 2.7 per cent in Stated Policies, with inflation converging to 2 per cent in both cases. Discount rates are aligned with our Group weighted-average cost of capital held constant at 8.2 per cent across scenarios."

What a good disclosure looks like

IFRS S2 22(b)(ii)(3)under 22(b)(ii)Lesson 3.4
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Requirement

The key assumptions the entity made in the analysis, including assumptions about national- or regional-level variables (for example, local weather patterns, demographics, land use, infrastructure and availability of natural resources).

Verbatim · IFRS S2

What it means

Physical risk lives at the country and catchment level. The entity discloses the regional variables most relevant to its sites: precipitation patterns, sea-level projections, water availability, grid infrastructure, labour migration.

Plain English · Greentryst

Illustrative Disclosure

"For the Chennai site we assume a 12 to 18 per cent reduction in JJAS rainfall by 2050 (CMIP6 ensemble median) and a 30 per cent increase in extreme rainfall frequency. For the Gulf of Mexico sites we assume a 45cm sea-level rise by 2050 and an intensification of Category 3+ hurricanes consistent with NCA5."

What a good disclosure looks like

IFRS S2 22(b)(ii)(4)under 22(b)(ii)Lesson 3.4
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Requirement

The key assumptions the entity made in the analysis, including assumptions about energy usage and mix.

Verbatim · IFRS S2

What it means

The entity discloses assumed changes in its own energy demand and the assumed composition of energy supply (grid mix, contracted renewables, on-site generation, fuel switching).

Plain English · Greentryst

Illustrative Disclosure

"Under the Net-Zero case we assume our on-site electricity demand grows 18 per cent by 2035 from electrification of heat, sourced 95 per cent from contracted renewable power by that date. Under Stated Policies we assume 72 per cent renewable sourcing by 2035. Fuel gas demand declines to below 10 per cent of current volume in Net-Zero and 45 per cent in Stated Policies."

What a good disclosure looks like

IFRS S2 22(b)(ii)(5)under 22(b)(ii)Lesson 3.4
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Requirement

The key assumptions the entity made in the analysis, including assumptions about developments in technology.

Verbatim · IFRS S2

What it means

Technology paths can make or break a transition plan. The entity names the technology assumptions most material to its strategy: storage costs, electrolyser capex, direct reduction availability, CCUS readiness.

Plain English · Greentryst

Illustrative Disclosure

"Our Net-Zero scenario assumes commercial green hydrogen at below €3/kg landed by 2030 and direct-reduction iron via hydrogen ready for deployment by 2032. Our Stated Policies case delays both by five years. Our internal physical scenario makes no strong technology assumptions beyond current commercial availability."

What a good disclosure looks like

IFRS S2 22(b)(iii)under 22(b)Lesson 3.4
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Requirement

The reporting period in which the climate-related scenario analysis was carried out (see paragraph B18).

Verbatim · IFRS S2

What it means

The entity states when the scenario analysis was last run. Scenario outputs age quickly; the reader needs to know whether the numbers rest on a current run or a prior-year exercise.

Plain English · Greentryst

Illustrative Disclosure

"The transition scenario analysis presented in this report was refreshed during the 2024 financial year using NGFS Phase V (released September 2024). The physical-risk analysis was last fully refreshed in 2023 and updated in 2024 for the two newly acquired sites; the next full refresh is scheduled for the 2026 cycle."

What a good disclosure looks like

Requirement

In preparing disclosures to meet the requirements in paragraphs 13 to 22, an entity shall refer to and consider the applicability of cross-industry metric categories, as described in paragraph 29, and industry-based metrics associated with disclosure topics defined in the Industry-based Guidance on Implementing IFRS S2 as described in paragraph 32.

Verbatim · IFRS S2

What it means

The Strategy pillar is not metric-free. Where the entity quantifies, it should use the cross-industry metric categories from paragraph 29 (GHG emissions, transition risk exposure, physical risk exposure, opportunities, capital deployment, internal carbon price, remuneration) and any applicable industry-based metrics.

Plain English · Greentryst

Illustrative Disclosure

"Quantitative Strategy disclosures in this section use the cross-industry metric categories in paragraph 29: our reported transition risk exposure, physical risk exposure, capital deployed against climate opportunities, and applicable internal carbon price. Industry-based metrics relevant to our sector are integrated where applicable."

What a good disclosure looks like