Para 6. Governance: board oversight and management’s role
An entity must identify the body or individual responsible for climate-related oversight, and disclose how their mandate, skills, information cadence, transaction-decision integration, and target oversight reflect that responsibility. Para 6(b) covers the management-level position or committee that handles day-to-day climate management, and how it integrates with other internal controls.
Standard text (verbatim, IFRS S2 Para 6)
To achieve this objective, an entity shall disclose information about:
(a) the governance body(s) (which can include a board, committee or equivalent body charged with governance) or individual(s) responsible for oversight of climate-related risks and opportunities. Specifically, the entity shall identify that body(s) or individual(s) and disclose information about:
(i) how responsibilities for climate-related risks and opportunities are reflected in the terms of reference, mandates, role descriptions and other related policies applicable to that body(s) or individual(s);
(ii) how the body(s) or individual(s) determines whether appropriate skills and competencies are available or will be developed to oversee strategies designed to respond to climate-related risks and opportunities;
(iii) how and how often the body(s) or individual(s) is informed about climate-related risks and opportunities;
(iv) how the body(s) or individual(s) takes into account climate-related risks and opportunities when overseeing the entity’s strategy, its decisions on major transactions and its risk management processes and related policies, including whether the body(s) or individual(s) has considered trade-offs associated with those risks and opportunities;
(v) how the body(s) or individual(s) oversees the setting of targets related to climate-related risks and opportunities, and monitors progress towards those targets (see paragraphs 33-36), including whether and how related performance metrics are included in remuneration policies (see paragraph 29(g)).
(b) management’s role in the governance processes, controls and procedures used to monitor, manage and oversee climate-related risks and opportunities, including information about:
(i) whether the role is delegated to a specific management-level position or management-level committee and how oversight is exercised over that position or committee;
(ii) whether management uses controls and procedures to support the oversight of climate-related risks and opportunities and, if so, how these controls and procedures are integrated with other internal functions.
The Board of Directors has ultimate responsibility for climate-related risks and opportunities. The Sustainability Committee of the Board (a standing Board committee) has explicit oversight of the climate strategy and meets six times a year; the Audit & Risk Committee receives a climate update at every meeting. [IFRS S2.6(a)(i), (iii)]
Board skills. Three of nine directors have prior real-estate-and-climate experience (one through prior CSO role, two through asset-management positions in REIT vehicles with established disclosure regimes). A skills matrix is included in the annual report. [IFRS S2.6(a)(ii)]
Major-transaction oversight. All acquisitions, dispositions and major developments above CU 50m require a climate-risk memo covering physical-risk hazard exposure of the underlying property over a 30-year horizon and transition-risk exposure (energy-rating, regulatory exposure, tenant-mix). Two acquisitions were declined in the past 24 months on the basis of unmitigable physical-risk exposure. [IFRS S2.6(a)(iv)]
Target oversight. Operational Scope 1+2 emissions targets, planned adaptation capex of CU 115m to 2030, and the percentage of the portfolio meeting the highest energy-rating tier are reviewed quarterly. [IFRS S2.6(a)(v)]
Management. The Chief Sustainability Officer reports jointly to the CEO and the Sustainability Committee Chair. A Group Climate Steering Group, chaired by the COO, includes asset-management, leasing, development, finance, treasury, and procurement leads, and meets monthly. Three working groups (adaptation, decarbonisation, tenant engagement) carry execution. [IFRS S2.6(b)(i)–(ii)]
Illustrative governance structure.
Cohort findings: what reporters typically skip on Para 6
Typically skipped. Whether Board-level approval is actually required for property-level climate-risk reviews. Many real-estate disclosures describe a Sustainability Committee but do not specify whether climate-vulnerability classification of single assets escalates to the Board.
What good looks like. Explicit transaction thresholds, declined-transaction counts, named adaptation-capex commitment, and a clear escalation pathway from asset-level vulnerability to Board oversight.
Para 7. Avoiding governance duplication with IFRS S1
Para 7 permits — but does not require — integrating climate governance with broader sustainability governance under IFRS S1’s B42(b) integration permission. The disclosure should be explicit about the integration choice and surface the climate-specific governance elements that survive integration as a separate, named list.
Standard text (verbatim, IFRS S2 Para 7)
In preparing disclosures to fulfil the requirements in paragraph 6, an entity shall avoid unnecessary duplication in accordance with IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) (see paragraph B42(b) of IFRS S1). For example, although an entity shall provide the information required by paragraph 6, if oversight of sustainability-related risks and opportunities is managed on an integrated basis, the entity would avoid duplication by providing integrated governance disclosures instead of separate disclosures for each sustainability-related risk and opportunity.
Climate-related governance disclosures are integrated with the Group’s broader sustainability-related governance under IFRS S1, in line with the integrated-management approach across climate, nature, water, biodiversity, and social-impact themes. The same Board, Sustainability Committee, Group Climate Steering Group, and divisional working groups oversee all sustainability-related risks and opportunities. [IFRS S2.7; IFRS S1 B42(b)]
Climate-specific governance elements that are not duplicated in the broader Sustainability Report are surfaced directly in this section: the property-level climate-risk-memo threshold (CU 50m), the adaptation-capex commitment (CU 115m to 2030), and the climate-linked component of the Long-Term Incentive Plan (12% weighting).
Disclosure approach consistent with IFRS S1 paragraph B42(b).
Cohort findings: what reporters typically skip on Para 7
Typically skipped. The list of climate-specific elements that are not duplicated. Without that list, the reader cannot tell whether the integrated disclosure has lost the climate-specific elements that Para 6 requires.
What good looks like. Explicit statement of integration plus a list of the climate-specific carve-outs that are surfaced separately.
Para 10. Climate-related risks and opportunities: identification, classification, time horizons
The entity must describe its identified climate-related risks and opportunities, classify each risk as physical or transition, specify the time horizon over which each could affect the entity, and define what ‘short, medium, long term’ mean in the entity’s planning context. Time-horizon definitions must link to actual strategic-decision horizons.
Standard text (verbatim, IFRS S2 Para 10)
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:
(a) describe climate-related risks and opportunities that could reasonably be expected to affect the entity’s prospects;
(b) 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;
(c) 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;
(d) 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.
The Group’s identification of climate-related risks and opportunities operates at the portfolio level and the asset level. Risks are classified as physical or transition and mapped to time horizons aligned with the Group’s investment cycle (short: 1–3 years; medium: 3–10 years; long: 10–30 years, the typical hold period for institutional real estate). [IFRS S2.10(a)–(d)]
| Risk / opportunity | Type | Time horizon |
|---|---|---|
| Property-level acute physical exposure (flood, cyclone, wildfire) | Physical | Short to long |
| Property-level chronic physical exposure (extreme heat, drought, sea-level rise) | Physical | Medium to long |
| Insurance-availability risk for highest-exposure properties | Physical | Short to medium |
| Stranded-asset risk for low-energy-rated office and retail | Transition | Medium to long |
| Tenant-attribution risk: ESG-driven tenant flight from non-rated buildings | Transition | Short to medium |
| Green-rated development premium and tenant-cost-recovery alignment | Opportunity | Medium to long |
| Adaptation services and circular-economy supply chain offerings | Opportunity | Long |
The 30-year long-term horizon is deliberately aligned with the typical real-estate hold period and with the lifespan of major building systems (HVAC, glazing, structure). [IFRS S2.10(d)]
Illustrative risk universe drawn from sector practice.
Cohort findings: what reporters typically skip on Para 10
Typically skipped. Insurance-availability and tenant-attribution risks. The default disclosure focuses on physical hazard exposure and energy-efficiency targets without naming the transmission channels through which physical and transition exposure actually impair earnings.
What good looks like. A risk universe that names every transmission channel from hazard to earnings, with explicit horizon mapping.
Para 13. Effects of climate-related risks and opportunities on the business model and value chain
Disclose the current and anticipated effects of climate-related risks and opportunities on the business model and value chain, and where in the value chain those risks and opportunities are concentrated — by geography, facility, asset type. Concentration disclosure is the load-bearing element; high-level narrative without geography or asset specificity does not satisfy the standard.
Standard text (verbatim, IFRS S2 Para 13)
An entity shall disclose information that enables users of general purpose financial reports to understand the current and anticipated effects of climate-related risks and opportunities on the entity’s business model and value chain. Specifically, the entity shall disclose:
(a) a description of the current and anticipated effects of climate-related risks and opportunities on the entity’s business model and value chain;
(b) 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).
The Group’s business model is asset-level and direct: the Group owns, develops, and operates investment-grade property. Climate-related risks and opportunities therefore concentrate at the property level and aggregate to the portfolio level. [IFRS S2.13(a)–(b)]
Concentration of climate-related risks.
| Concentration dimension | Detail |
|---|---|
| By geography | 62% of carrying amount in two metropolitan markets; 22% in regions with high-or-extremely-high baseline water stress; 18% in coastal flood-or-cyclone exposure zones |
| By property sector | Industrial / logistics 36% (largest exposure to riverine flood and cyclone); office 28% (largest exposure to extreme heat and stranded-asset transition risk); retail 19%; multi-family residential 17% |
| By asset cohort | The 12% of operating portfolio carrying amount classified vulnerable under SSP2-4.5 / 2050 (see Para 29(c)) is concentrated in 73 single-asset cohorts, of which 14 are in the highest-severity band |
| Value-chain upstream | Construction supply chain (steel, cement) carries embodied-carbon exposure; sourcing concentration in three major suppliers |
| Value-chain downstream | Tenant industries: ~28% in carbon-intensive industries (oil & gas, mining, heavy industry), exposed to tenant-cyclical default risk under transition scenarios |
Anticipated effects. Concentration in industrial / logistics drives physical-risk financial-effect channel (asset damage, business interruption, insurance premium). Concentration in office sector drives transition-risk channel (energy-rating regulation, stranded-asset valuation impairment). [IFRS S2.13(a)]
Illustrative concentration figures.
Cohort findings: what reporters typically skip on Para 13
Typically skipped. Tenant-industry concentration. Real-estate disclosures often describe physical-risk concentration but rarely the transition-risk concentration that comes from tenant-mix exposure to carbon-intensive industries.
What good looks like. Multi-dimensional concentration disclosure with geography, sector, asset cohort, and tenant-industry breakdowns.
Para 14. Strategy and decision-making, including transition plan
Disclose how the entity has responded to and plans to respond to climate-related risks in its strategy and decision-making — including business-model changes, direct and indirect mitigation and adaptation efforts, and any transition plan with its assumptions and dependencies. Disclose how the entity is resourcing these activities and progress against prior-period plans.
Standard text (verbatim, IFRS S2 Para 14)
An entity shall disclose information that enables users of general purpose financial reports to understand the effects of climate-related risks and opportunities on its strategy and decision-making. Specifically, the entity shall disclose:
(a) information about how the entity has responded to, and plans to respond to, climate-related risks and opportunities in its strategy and decision-making, including how the entity plans to achieve any climate-related targets it has set and any targets it is required to meet by law or regulation. Specifically, the entity shall disclose information about:
(i) current and anticipated changes to the entity’s business model, including its resource allocation, to address climate-related risks and opportunities (for example, 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 research and development; and acquisitions or divestments);
(ii) 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);
(iii) current and anticipated indirect mitigation and adaptation efforts (for example, through working with customers and supply chains);
(iv) 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;
(v) how the entity plans to achieve any climate-related targets, including any greenhouse gas emissions targets, described in accordance with paragraphs 33-36.
(b) information about how the entity is resourcing, and plans to resource, the activities disclosed in accordance with paragraph 14(a).
(c) quantitative and qualitative information about the progress of plans disclosed in previous reporting periods in accordance with paragraph 14(a).
The Group’s strategic response is structured around portfolio adaptation, decarbonisation of operating buildings, and tenant-aligned product offerings. [IFRS S2.14(a)]
Business model changes (Para 14(a)(i)). Portfolio rebalancing through 2030: 28% reduction in office sub-portfolio in two highest-stranded-asset markets; 18% increase in industrial / logistics sub-portfolio in low-carbon-supply-chain markets. Disposal of two coastal-flood-exposed assets in the prior reporting period for CU 178m. Acquisition pipeline screened for climate-vulnerability prior to bid.
Direct mitigation and adaptation (Para 14(a)(ii)). CU 115m planned adaptation capex through 2030 across flood defences, glazing upgrades, HVAC re-sizing, and on-site renewables. CU 95m operational decarbonisation capex (LED lighting, building-management systems, electrification of heating in cold-climate properties).
Indirect mitigation (Para 14(a)(iii)). Tenant engagement programme: cost-recovery clauses for efficiency capex now in 41% of new leases (target 65% by 2027); tenant-engagement on Scope-3 emissions; supply-chain procurement standards for embodied-carbon-intensive materials (steel, cement).
Transition plan (Para 14(a)(iv)). SBTi-validated 2030 emissions target; net zero by 2050 (Scope 1+2 absolute, Scope 3 partial coverage). Key assumptions: building-energy regulations tighten on the Paris-aligned trajectory; tenant ESG-procurement standards continue to strengthen; on-site renewable generation costs continue current decline. Key dependencies: low-embodied-carbon construction materials become available at competitive cost; grid decarbonisation in operating jurisdictions; insurance-market continued willingness to cover adapted properties.
Resourcing (Para 14(b)). CU 271m capital deployed during the period (see Para 29(e)).
Progress against prior-period plans (Para 14(c)). Prior commitments: 100% energy-rating-certified portfolio by 2027 (current 78%, on track); 50% absolute Scope 1+2 reduction by 2030 (current 24%, ahead of trajectory); CU 115m cumulative adaptation capex commitment (CU 34m year-one, on track).
Illustrative response framework drawn from sector practice.
Cohort findings: what reporters typically skip on Para 14
Typically skipped. Embodied-carbon dependency disclosure. Real-estate transition plans focus on operating-emissions decarbonisation and rarely surface the dependency on supply-chain decarbonisation for new development to remain feasible.
What good looks like. Named dependencies including supply-chain decarbonisation, grid decarbonisation, and insurance-market behaviour.
Para 15–21. Anticipated financial effects on financial position, performance and cash flows
Disclose how climate-related risks and opportunities have affected financial position, performance, and cash flows for the reporting period (current effects), and anticipated effects over short, medium, and long term. Para 19-21 permit qualitative-only disclosure where quantification is not separately identifiable, measurement uncertainty is too high, or the entity lacks skills and resources — but the qualitative substitute must explain the omission and identify affected line items.
Standard text (verbatim, IFRS S2 Para 15–21)
An entity shall disclose information that enables users to understand:
(a) 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);
(b) 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 (anticipated financial effects).
Specifically, an entity shall disclose quantitative and qualitative information about:
(a) how climate-related risks and opportunities have affected its financial position, financial performance and cash flows for the reporting period;
(b) 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;
(c) 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:
(i) its investment and disposal plans, including plans the entity is not contractually committed to;
(ii) its planned sources of funding to implement its strategy;
(d) 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.
In providing quantitative information, an entity may disclose a single amount or a range.
In preparing disclosures about the anticipated financial effects of a climate-related risk or opportunity, an entity shall:
(a) use all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort;
(b) use an approach that is commensurate with the skills, capabilities and resources that are available to the entity for preparing those disclosures.
An entity need not provide quantitative information about the current or anticipated financial effects of a climate-related risk or opportunity if the entity determines that:
(a) those effects are not separately identifiable; or
(b) the level of measurement uncertainty involved in estimating those effects is so high that the resulting quantitative information would not be useful.
In addition, an entity need not provide quantitative information about the anticipated financial effects of a climate-related risk or opportunity if the entity does not have the skills, capabilities or resources to provide that quantitative information.
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 19-20, the entity shall:
(a) explain why it has not provided quantitative information;
(b) 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;
(c) 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.
Climate-related risks and opportunities have current and anticipated effects on the Group’s financial position, performance, and cash flows. Quantitative information is disclosed as ranges under Para 17. [IFRS S2.15–17]
Current financial effects (Para 16(a)). Adaptation capex deployed during the period: CU 34m. Climate-attributable insurance-premium increase: CU 9m year-on-year. Operational-decarbonisation capex: CU 41m. Property-write-down attributable to climate-driven obsolescence (one office asset re-classified to long-term hold and revalued): CU 22m.
Significant risk of material adjustment (Para 16(b)). Two property cohorts are flagged: (i) the 14 single-asset highest-severity-band cohorts identified in Para 29(c) (CU 119m carrying amount; potential impairment range CU 18–55m); (ii) office assets in two metropolitan markets where energy-rating regulation tightens within 24 months (CU 215m carrying amount; potential valuation impact range CU 25–95m).
Anticipated effects on financial position (Para 16(c)). Adaptation-capex commitment of CU 115m to 2030 and decarbonisation-capex commitment of CU 95m. Acquisition pipeline screened for climate vulnerability; planned dispositions of two coastal-flood-exposed assets in the next 24 months for proceeds of CU 280m.
Anticipated effects on financial performance and cash flows (Para 16(d)). Short term (1–3 years): adaptation capex CU 30–45m per year; gross-rental-income impact from extreme-weather business interruption CU 4–9m per year. Medium term (3–10 years): green-rated-development premium contribution to NOI CU 25–65m cumulative; operating-cost increase from rising insurance and utility costs CU 35–80m cumulative. Long term (10–30 years): physical-risk-driven property-impairment range CU 40–150m under SSP2-4.5 / 2050 (gross of further adaptation); CU 80–300m under SSP5-8.5.
Para 17 use of range. Range disclosure used given uncertainty in scenario inputs and asset-class adaptation responses.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 15–21
Typically skipped. The bridge from Para 16(b) to IAS 36. Real-estate disclosures often discuss climate impairment risk without explicitly tying it to the IAS 36 impairment indicator framework that the financial statements use.
What good looks like. Range-disclosure for at least two horizons, named cohorts at risk of material adjustment, and explicit cross-reference to IAS 36 impairment indicators.
Para 22. Climate resilience: scenario analysis disclosure ★
Para 22 requires the entity to assess and disclose how resilient its strategy and business model are to climate-related changes, using climate-related scenario analysis. The standard calls for a ‘diverse range’ of scenarios including one aligned with the latest international climate agreement, with disclosure covering scenario inputs, key assumptions, time horizons, and the entity’s capacity to adapt. This is the load-bearing strategy paragraph.
Standard text (verbatim, IFRS S2 Para 22)
An entity shall disclose information that enables users of general purpose financial reports to understand the resilience of the entity’s strategy and business model to climate-related changes, developments and uncertainties, taking into consideration the entity’s identified climate-related risks and opportunities. The entity shall use climate-related scenario analysis to assess its climate resilience using an approach that is commensurate with the entity’s circumstances (see paragraphs B1-B18). In providing quantitative information, the entity may disclose a single amount or a range. Specifically, the entity shall disclose:
(a) the entity’s assessment of its climate resilience as at the reporting date, which shall enable users to understand:
(i) 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;
(ii) the significant areas of uncertainty considered in the entity’s assessment of its climate resilience;
(iii) the entity’s capacity to adjust or adapt its strategy and business model to climate change over the short, medium and long term, including:
(1) 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;
(2) the entity’s ability to redeploy, repurpose, upgrade or decommission existing assets;
(3) the effect of the entity’s current and planned investments in climate-related mitigation, adaptation and opportunities for climate resilience;
(b) how and when the climate-related scenario analysis was carried out, including:
(i) information about the inputs the entity used, including:
(1) which climate-related scenarios the entity used for the analysis and the sources of those scenarios;
(2) whether the analysis included a diverse range of climate-related scenarios;
(3) whether the climate-related scenarios used for the analysis are associated with climate-related transition risks or climate-related physical risks;
(4) whether the entity used, among its scenarios, a climate-related scenario aligned with the latest international agreement on climate change;
(5) why the entity decided that its chosen climate-related scenarios are relevant to assessing its resilience to climate-related changes, developments or uncertainties;
(6) the time horizons the entity used in the analysis;
(7) what scope of operations the entity used in the analysis (for example, the operating locations and business units used in the analysis);
(ii) the key assumptions the entity made in the analysis, including assumptions about:
(1) climate-related policies in the jurisdictions in which the entity operates;
(2) macroeconomic trends;
(3) national- or regional-level variables (for example, local weather patterns, demographics, land use, infrastructure and availability of natural resources);
(4) energy usage and mix;
(5) developments in technology;
(iii) the reporting period in which the climate-related scenario analysis was carried out (see paragraph B18).
The Group assessed the resilience of its strategy and business model by running asset-level scenario analysis on every property in the operating and development portfolio at the reporting date. Coverage is 100% of portfolio carrying amount across all geographies. Analysis was carried out during the current reporting period as part of the bi-annual scenario refresh. [IFRS S2.22; B1–B18]
| Scenario | Source | Key assumptions | Time horizon | Physical risk magnitude | Transition risk magnitude | Resilience implication |
|---|---|---|---|---|---|---|
| Aggressive mitigation | NGFS Net Zero 2050 + IPCC SSP1-2.6 | Energy-rating regulation tightens on Paris-aligned trajectory; embodied-carbon pricing introduced; rapid grid decarbonisation | 2030 / 2050 | Mild (heat-stress moderate; flood frequency stable to slightly rising) | Elevated (stranded-asset risk for unrated office; embodied-carbon retrofit-or-rebuild capex) | Office sub-portfolio decarbonisation completes within capex envelope; CU 35–80m cumulative gross-rental impact through 2050 |
| Current pledges | NGFS NDC + IPCC SSP2-4.5 | Energy-rating regulation tightens but at slower pace; chronic physical exposure continues to rise; insurance-market continues to price climate | 2030 / 2050 | Moderate by 2030; elevated by 2050 | Moderate | Adaptation capex of CU 115m to 2030 sufficient; gross-rental impact CU 22–38m per year by 2040 without further capex; CU 8–14m with planned adaptation |
| Limited action | NGFS Current Policies + IPCC SSP5-8.5 | Little new climate policy; physical exposure dominates; insurance-availability stress in highest-risk regions | 2030 / 2050 | Severe (acute event frequency rises materially; insurability stress on coastal and wildfire-exposed assets) | Low regulatory; elevated tenant-attribution risk if tenant ESG standards persist independent of policy | Adaptation capex range expands to CU 200–280m through 2050 to maintain insurability; gross-rental impact CU 60–140m cumulative; 2 single-asset cohorts may become uninsurable absent further adaptation |
Resilience assessment. The Group’s strategy assumes property-level adaptation capex of CU 115m by 2030 to maintain insurability and operating capacity in the most-affected sub-portfolios; under SSP2-4.5 this is sufficient, under SSP5-8.5 incremental capex is required. The 2027–2030 portfolio re-balancing reduces exposure to the highest-severity sub-portfolio by approximately one-third. Significant areas of uncertainty: insurance-market response to chronic exposure trends, tenant-mix shifts under transition pathways, embodied-carbon regulatory trajectory. [IFRS S2.22(a)(ii)–(iii)]
Scope of operations. 100% of operating and development portfolio carrying amount, all geographies. Reporting period: bi-annual refresh completed in current period.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 22
Typically skipped. The without-adaptation baseline. Many real-estate disclosures show only the with-adaptation residual figure, which understates the strategic question. The reader cannot evaluate whether the adaptation strategy is well-calibrated without seeing the gap it closes.
What good looks like. Both numbers under each scenario, both ranges, both horizons. Para 22 expressly contemplates ranges; using a range is not a weakness.
Para 25. Risk management: processes for identifying, assessing, prioritising and monitoring climate-related risks
Disclose the processes the entity uses to identify, assess, prioritise, and monitor climate-related risks (and separately, opportunities) — including data sources, scope of operations covered, scenario-analysis use in identification, materiality criteria, and how climate-risk processes integrate into the overall risk-management framework. Disclose any process changes from the prior reporting period.
Standard text (verbatim, IFRS S2 Para 25)
To achieve this objective, an entity shall disclose information about:
(a) the processes and related policies the entity uses to identify, assess, prioritise and monitor climate-related risks, including information about:
(i) the inputs and parameters the entity uses (for example, information about data sources and the scope of operations covered in the processes);
(ii) whether and how the entity uses climate-related scenario analysis to inform its identification of climate-related risks;
(iii) how the entity assesses the nature, likelihood and magnitude of the effects of those risks (for example, whether the entity considers qualitative factors, quantitative thresholds or other criteria);
(iv) whether and how the entity prioritises climate-related risks relative to other types of risk;
(v) how the entity monitors climate-related risks;
(vi) whether and how the entity has changed the processes it uses compared with the previous reporting period;
(b) the processes the entity uses to identify, assess, prioritise and monitor climate-related opportunities, including information about whether and how the entity uses climate-related scenario analysis to inform its identification of climate-related opportunities;
(c) the extent to which, and how, the processes for identifying, assessing, prioritising and monitoring climate-related risks and opportunities are integrated into and inform the entity’s overall risk management process.
Climate-related physical and transition risks are identified, assessed, prioritised, and monitored through processes embedded in the Group’s enterprise Risk Management Framework, the asset-management cycle, and the capital-allocation governance. [IFRS S2.25]
Identification. Every property is screened quarterly against twelve physical hazards (riverine flood, coastal flood, tropical cyclone, extreme wind, wildfire, extreme heat, drought, water stress, hail, landslide, sea-level rise, subsidence) at the asset coordinate. New acquisitions screened pre-bid. Energy-rating regulatory exposure tracked at jurisdiction level for transition risk.
Use of scenario analysis. Scenario outputs (Para 22) feed asset-level adaptation prioritisation: properties with modelled SSP2-4.5 / 2050 hazard intensity exceeding the asset adaptation threshold are flagged for capital review within 12 months.
Assessment. Quantitative thresholds (1-in-100-year hazard return-period or chronic-exposure exceeding asset-class adaptation threshold trigger vulnerability classification; energy-rating below B in regulated markets triggers stranded-asset review). Qualitative: tenant concentration, lease tenor, insurance availability, local-authority adaptation plans.
Prioritisation. Climate is a Tier 1 risk in the Group’s Risk Appetite Statement, alongside market-cycle risk and tenant-credit risk.
Monitoring. Quarterly hazard re-screening; annual independent review of top-decile-vulnerability portfolio; continuous monitoring through property management system; material changes reported to Board Risk Committee within 30 days.
Process changes. Subsidence and sea-level-rise added to the hazard list in the current period. The energy-rating-below-B trigger was added in response to regulatory-tightening trajectory in two key markets.
Integration. Climate-risk results feed the Group’s investment-committee process (acquisitions, dispositions, major capex) and the impairment-review process.
Illustrative process drawn from sector practice.
Cohort findings: what reporters typically skip on Para 25
Typically skipped. The connective tissue between identification and action. Many disclosures describe hazard screening and risk-tiering as parallel facts without connecting them.e.g. ‘we screen for floods’ and ‘climate is a Tier 1 risk’.leaving the reader to infer the process.
What good looks like. Identification-to-action traceability with named triggers and timeframes. The reader should be able to follow a hazard signal from the dataset, through the threshold, to the governance action.
Para 29(a). Greenhouse gas emissions: Scope 1, 2, 3 (with financed-emissions limitation 29A-C)
Disclose absolute gross GHG emissions in CO2-equivalent for Scope 1, 2, and 3, measured per the GHG Protocol Corporate Standard. For Scope 1 and 2, disaggregate consolidated group from associates, joint ventures, and unconsolidated subsidiaries. For Scope 2, disclose location-based emissions plus contractual-instrument detail. For Scope 3, disclose categories per the GHG Protocol Value Chain Standard, with additional financed-emissions detail for asset managers, banks, and insurers (Para 29A-C optional limitation applies).
Standard text (verbatim, IFRS S2 Para 29(a))
Greenhouse gases. The entity shall:
(i) disclose its absolute gross greenhouse gas emissions generated during the reporting period, expressed as metric tonnes of CO2 equivalent, classified as:
(1) Scope 1 greenhouse gas emissions;
(2) Scope 2 greenhouse gas emissions;
(3) Scope 3 greenhouse gas emissions;
(ii) measure its greenhouse gas emissions in accordance with the Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard (2004) unless the entity is required, in whole or in part, by a jurisdictional authority or an exchange on which it is listed to use a different method for measuring its greenhouse gas emissions;
(iii) disclose the approach it uses to measure its greenhouse gas emissions, including:
(1) the measurement approach, inputs and assumptions the entity uses;
(2) the reason why the entity has chosen those;
(3) any changes the entity made to the measurement approach, inputs and assumptions during the reporting period and the reasons for those changes;
(iv) for Scope 1 and Scope 2 greenhouse gas emissions, disaggregate emissions between:
(1) the consolidated accounting group;
(2) other investees excluded from paragraph 29(a)(iv)(1) (associates, joint ventures and unconsolidated subsidiaries);
(v) for Scope 2 greenhouse gas emissions, disclose its location-based Scope 2 greenhouse gas emissions, and provide information about any contractual instruments that is necessary to inform users’ understanding of the entity’s Scope 2 greenhouse gas emissions;
(vi) for Scope 3 greenhouse gas emissions disclose:
(1) the categories included within the entity’s measure of Scope 3 greenhouse gas emissions, in accordance with the Scope 3 categories described in the GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard (2011);
(2) additional information about the entity’s financed emissions (which are part of Category 15 greenhouse gas emissions), if its activities include asset management, commercial banking or insurance. Paragraphs 29A-29C govern an optional limitation of Category 15 to financed emissions.
The Group’s gross greenhouse-gas emissions for the reporting period, measured per the GHG Protocol. [IFRS S2.29(a)]
| Scope | Emissions (tCO2e) | Notes / YoY change |
|---|---|---|
| Scope 1 (on-site fuel combustion: gas heating, generators) | 11,800 | −9% |
| Scope 2 (market-based; electricity for landlord-controlled common areas) | 1,400 | −74% (renewable-electricity contracting) |
| Scope 2 (location-based) | 32,100 | −4% |
| Scope 3 Cat. 1 (purchased goods and services — including embodied carbon in development) | 74,500 | +12% (development pipeline activity) |
| Scope 3 Cat. 13 (downstream leased assets — tenant emissions) | 289,000 | −5% |
| Scope 3 other categories (Cat. 5 waste, Cat. 6 business travel, Cat. 11 use-phase if applicable) | 21,000 | −3% |
Approach. Scope 1+2 measured per GHG Protocol Corporate Standard; data coverage 89% of operating portfolio floor area (target 95% by 2027). Embodied carbon in development calculated using EPD data for steel, cement, and aluminium; modelled where EPDs unavailable. Tenant emissions (Cat. 13) measured using submetered electricity data for 64% of tenant floor area; modelled for the remainder using sector intensity factors.
Disaggregation. Scope 1+2 disaggregated: 87% consolidated; 13% joint ventures (development partnerships).
Scope 3 categories included. Categories 1, 5, 6, 13. Categories 11 (use of sold products) and 15 (financed) not material to the business model.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(a)
Typically skipped. Tenant Scope 3 (Category 13). Real-estate disclosures often quantify Scope 1+2 thoroughly but treat tenant emissions as ‘tenant responsibility’ and omit. Para 29(a) does not allow omission for material categories; disclosure of measurement approach and data coverage is the minimum.
What good looks like. All material Scope 3 categories quantified; data coverage disclosed for each; embodied-carbon methodology named; submetering coverage rate for tenant emissions.
Para 29(b). Climate-related transition risks: assets and business activities vulnerable
The amount and percentage of assets or business activities vulnerable to climate-related transition risks. Vulnerability must be defined against named transition-risk drivers (carbon pricing, technology shifts, demand decline, regulation tightening) under specified scenarios. Without a defined threshold and named scenario, the percentage figure is unverifiable.
Standard text (verbatim, IFRS S2 Para 29(b))
Climate-related transition risks. The amount and percentage of assets or business activities vulnerable to climate-related transition risks.
The Group discloses the carrying amount and percentage of the property portfolio classified as vulnerable to climate-related transition risks. Vulnerability is defined as exposure to energy-rating regulatory tightening, tenant-attribution risk, or embodied-carbon-intensive build-or-renovate exposure where modelled valuation impact under the scenario exceeds 5% of asset carrying amount. [IFRS S2.29(b); 30]
| Property sector | SSP1-2.6 (CU m) | SSP2-4.5 (CU m) | SSP5-8.5 (CU m) | Dominant transition driver |
|---|---|---|---|---|
| Office (low-energy-rated) | 410 | 185 | 60 | Energy-rating regulation in two key markets |
| Retail (legacy non-rated) | 122 | 62 | 22 | Tenant ESG-driven flight; rating regulation |
| Industrial / logistics | 40 | 25 | 8 | Carbon-pricing on operations; embodied-carbon retrofit |
| Multi-family residential | 40 | 18 | 5 | Heating decarbonisation regulation |
Office concentration is the largest single driver and is concentrated in the highest-stranded-asset-risk metropolitan markets; the Group’s portfolio re-balancing strategy reduces this concentration through 2030. Para 30 reasonable-and-supportable: figures based on third-party stranded-asset analysis vendor; Group has not yet integrated proprietary tenant-mix-conditioned models.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(b)
Typically skipped. Tenant-attribution risk. Real-estate disclosures often capture energy-rating exposure but rarely the tenant-attribution channel, which is the leading-indicator transition risk for retail and office.
What good looks like. Three-scenario presentation; sector breakdown; named transition drivers including tenant-attribution; alignment with portfolio rebalancing strategy.
Para 29(c). Climate-related physical risks: assets and business activities vulnerable ★
The amount and percentage of assets or business activities vulnerable to climate-related physical risks. The most-skipped disclosure across every first-wave reporter cohort globally — about a third to a half of reporters either omit the quantitative figure or substitute a qualitative hedge. The amount-and-percentage form is the load-bearing element; vulnerability threshold, scenario, and time horizon must be disclosed alongside. Iris unpacks the four definitional ambiguities buried in the standard’s amount-and-percentage language in a separate Para 29(c) deep-dive.
Standard text (verbatim, IFRS S2 Para 29(c))
Climate-related physical risks. The amount and percentage of assets or business activities vulnerable to climate-related physical risks.
The Group discloses the carrying amount and percentage of property portfolio vulnerable to climate-related physical risks, by property sector and dominant hazard, under each scenario in the Para 22 set. [IFRS S2.29(c); 30]
| Property sector | Vulnerable amt SSP2-4.5 (CU m) | Vulnerable amt SSP5-8.5 (CU m) | Dominant hazard |
|---|---|---|---|
| Office | 164 | 270 | Coastal flood, extreme heat |
| Industrial / logistics | 208 | 372 | Riverine flood, tropical cyclone |
| Retail | 71 | 118 | Wildfire, hail |
| Multi-family residential | 35 | 60 | Coastal flood, sea-level rise |
Vulnerability is determined at the asset coordinate using a 1-in-100-year hazard return period under the named scenario as the threshold for acute hazards, and asset-class chronic-adaptation thresholds for chronic hazards. The figure is gross of planned adaptation capex (CU 115m to 2030). The Group’s IBG industry-based metric IF-RE-450a.1 (Area of properties in 100-year flood zones, by property sector) reports an aggregate of 1.94 million sq ft, equivalent to 8.7% of total floor area; the IBG metric is by floor area, the Para 29(c) metric is by carrying amount; both are disclosed because they answer different questions.
Illustrative figures. Continuuiti’s Climate Risk service produces both the carrying-amount and floor-area metrics for any portfolio of locations.
Cohort findings: what reporters typically skip on Para 29(c)
Typically skipped. The gross-of-adaptation framing. Real-estate disclosures often default to with-adaptation residual figures, or omit the threshold and scenario underlying vulnerability classification. ESRS E1-9 explicitly requires the gross figure (before adaptation actions); IFRS S2 leaves it to the entity but the gross figure is what reflects portfolio-level exposure.
What good looks like. Carrying amount and percentage; threshold disclosed; scenario and horizon disclosed; gross-of-adaptation; sub-portfolio disaggregation; clear bridge between Para 29(c) figure and IBG IF-RE-450a.1.
Para 29(d). Climate-related opportunities: assets aligned with opportunities
The amount and percentage of assets or business activities aligned with climate-related opportunities. The opportunity-side counterpart to Para 29(b) and 29(c). Disclosure should pair the quantitative figure with revenue, capacity, or other operational metrics that contextualise the alignment claim.
Standard text (verbatim, IFRS S2 Para 29(d))
Climate-related opportunities. The amount and percentage of assets or business activities aligned with climate-related opportunities.
The Group discloses the carrying amount and percentage of property portfolio aligned with climate-related opportunities, defined as assets meeting green-rated certification, contributing to circular-economy supply chains, or generating green-building premium. [IFRS S2.29(d); 30]
| Opportunity category | Carrying amount (CU m) | Notes |
|---|---|---|
| ENERGY STAR / equivalent-rated office | 720 | Achieving green-building premium of 4–7% on rents |
| Net-zero-aligned new development | 340 | SBTi-aligned construction; embodied-carbon optimised |
| Tenant cost-recovery clause coverage | 240 (associated leased floor area) | Aligned-incentive efficiency capex |
| On-site renewable generation properties | 120 | Rooftop solar at 47 sites |
Alignment uses ENERGY STAR / NABERS / EPC / equivalent national rating-system thresholds and the Group’s Net-Zero Carbon Buildings Commitment criteria. Cost-recovery clauses are not directly aligned with carrying amount but are reported on a leased-floor-area basis (under IBG IF-RE-410a.1).
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(d)
Typically skipped. The green-building premium quantification. Real-estate disclosures often state that certified buildings command rent premiums but rarely quantify them.
What good looks like. Carrying amount by category, alignment criteria (rating systems + own framework), quantified premium.
Para 29(e). Capital deployment toward climate-related risks and opportunities
The amount of capital expenditure, financing, or investment deployed toward climate-related risks and opportunities. Disclosure should disaggregate by category (mitigation, adaptation, opportunity) and ideally by sub-portfolio. The figure must reconcile with the entity’s strategy and decision-making disclosures (Para 14) and target-progress disclosures (Para 33-36).
Standard text (verbatim, IFRS S2 Para 29(e))
Capital deployment. The amount of capital expenditure, financing or investment deployed towards climate-related risks and opportunities.
Capital deployment toward climate-related risks and opportunities during the reporting period: [IFRS S2.29(e)]
| Category | Amount (CU m) | Risk vs. opportunity |
|---|---|---|
| Adaptation capex on existing operating portfolio | 34 | Physical risk |
| Operational decarbonisation capex | 41 | Transition risk |
| Green-rated development capex (new builds and major renovations) | 187 | Opportunity |
| Insurance-premium increase attributable to climate (year-on-year, all-perils) | 9 | Physical risk |
The CU 34m adaptation capex covers the highest-severity band of properties identified in the Para 29(c) screening. The Group has committed CU 115m of adaptation capex through 2030 (cumulative), with CU 34m deployed this year, CU 28m planned next year, and the balance phased through 2027–2030. The CU 9m insurance-premium increase is attributable to climate per the Group’s insurer’s stated rate uplift on climate-exposed properties.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(e)
Typically skipped. The insurance-cost line. Most real-estate disclosures report only direct capex spend, not the climate-attributable insurance-premium increase. The latter is often the largest cash-flow consequence of physical risk in the short term.
What good looks like. Direct adaptation capex; transition-side capex; opportunity-side investment in green-rated development; second-order consequences such as insurance, refinancing margin, and tenant-default attributable to climate.
Para 29(f). Internal carbon prices
Disclose whether and how the entity applies an internal carbon price in decision-making (investment, transfer pricing, scenario analysis), and the per-tonne price used. Disclosure should distinguish between prices applied to operational decisions and prices used in strategic and scenario contexts. Sectors with material own-emissions exposure typically apply different prices for different decision contexts.
Standard text (verbatim, IFRS S2 Para 29(f))
Internal carbon prices. The entity shall disclose:
(i) an explanation of whether and how the entity is applying a carbon price in decision-making (for example, investment decisions, transfer pricing and scenario analysis);
(ii) the price for each metric tonne of greenhouse gas emissions the entity uses to assess the costs of its greenhouse gas emissions.
The Group applies an internal carbon price across capital allocation and operational decision-making. [IFRS S2.29(f)]
| Application | Price (CU per tonne CO2e) | Notes |
|---|---|---|
| New-development capex evaluation | 100 | Applied to embodied carbon in materials selection and to projected operational emissions over building life |
| Acquisition due diligence | 120 | Used in modelled stranded-asset valuation impact |
| Tenant cost-recovery clause negotiation | 50 | Embedded in operating-cost projections used in lease pricing |
The development carbon-price was increased from CU 80 to CU 100 in the current period to reflect tightening jurisdictional carbon-pricing trajectories in two key markets.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(f)
Typically skipped. Embodied-carbon application of internal pricing. Real-estate disclosures often apply carbon pricing to operational emissions but rarely to embodied carbon in development decisions.
What good looks like. Multiple-price disclosure; explicit treatment of embodied carbon; year-on-year change with reason.
Para 29(g). Remuneration: climate-linked executive compensation
Disclose whether and how climate-related considerations factor into executive remuneration, and the percentage of executive compensation in the current reporting period that is climate-linked. The percentage should reconcile with the climate KPIs disclosed under Para 33-36 and the governance-oversight disclosures under Para 6(a)(v).
Standard text (verbatim, IFRS S2 Para 29(g))
Remuneration. The entity shall disclose:
(i) a description of whether and how climate-related considerations are factored into executive remuneration (see also paragraph 6(a)(v));
(ii) the percentage of executive management remuneration recognised in the current period that is linked to climate-related considerations.
Climate-related considerations factored into executive remuneration: [IFRS S2.29(g); 6(a)(v)]
| Component | % of variable remuneration linked to climate | Notes |
|---|---|---|
| Group CEO Long-Term Incentive Plan | 12% | Tied to operational Scope 1+2 reduction trajectory and SBTi-validated targets |
| Chief Sustainability Officer LTIP | 30% | Tied to portfolio-energy-rating progression and adaptation-capex execution |
| Other executive committee average | 6–10% | Function-specific weighting |
Aggregate: 9.0% of executive management remuneration recognised in the current period is linked to climate-related considerations. The linkage is reviewed annually by the Remuneration Committee of the Board.
Illustrative figures.
Cohort findings: what reporters typically skip on Para 29(g)
Typically skipped. The aggregate-percentage figure. Disclosures that quote per-role percentages without the aggregate fail Para 29(g)(ii).
What good looks like. Per-role + aggregate; oversight body named; trajectory of weighting over multiple years.
Para 32. Industry-based metrics
Disclose industry-based metrics associated with the entity’s business model and activities. The standard refers entities to the SASB Industry-Based Guidance (IBG) on implementing IFRS S2 — applicability is per industry. The IBG metrics complement (not replace) the cross-industry Para 29 disclosures; both must be reconciled where they overlap.
Standard text (verbatim, IFRS S2 Para 32)
An entity shall disclose industry-based metrics that are associated with one or more particular business models, activities or other common features that characterise participation in an industry. In determining the industry-based metrics that the entity discloses, the entity shall refer to and consider the applicability of the industry-based metrics associated with disclosure topics described in the Industry-based Guidance on Implementing IFRS S2.
The Group applies IBG industry-based metrics for Real Estate (vol-36, IF-RE). All applicable Climate Change Adaptation, Energy Management, and Water Management metrics are reported below. [IFRS S2.32]
| Metric | Value |
|---|---|
IF-RE-450a.1 Area in 100-year flood zones, by sector |
Office: 0.42m sq ft (8.1%); Industrial: 0.98m sq ft (12.7%); Retail: 0.31m sq ft (7.4%); Multi-family: 0.23m sq ft (9.8%) |
IF-RE-450a.2 Climate-change risk exposure analysis |
Provided in Para 22 and Para 25 disclosures above. |
IF-RE-130a.4 % portfolio with energy rating; certified to ENERGY STAR or equivalent, by sector |
Office: 78% rated (62% certified); Industrial: 64% rated (41% certified); Retail: 71% (52%); Multi-family: 53% (38%) |
IF-RE-140a.2(2) % of water withdrawn in regions with High or Extremely High Baseline Water Stress, by property sector |
Office: 18.3%; Industrial: 9.4%; Retail: 14.7%; Multi-family: 6.1% |
IF-RE-140a.4 Water-management risks and mitigation strategies |
Rainwater harvesting in 47 properties; greywater systems in 12 multi-family assets; drought-tolerant landscaping policy across all new developments. |
IF-RE-410a.1 % new leases with cost-recovery clauses, associated leased floor area |
41% of new leases; 1.2m sq ft associated |
Illustrative figures.
Cohort findings: what reporters typically skip on Para 32
Typically skipped. The water-stress metric (IF-RE-140a.2). Real-estate reporters tend to focus on flood-zone area and energy ratings; chronic-physical-risk metrics like water stress are under-reported.
What good looks like. All applicable IBG metrics reported, with sector breakdown where the IBG specifies, and clear narrative linkage between the IBG metrics and the cross-industry Para 29(c) disclosure.
Para 33–36. Climate-related targets: quantitative and qualitative
Disclose the quantitative and qualitative climate-related targets set to monitor strategic progress, including any targets required by law or regulation. For each target: the metric, objective, scope, period, base, milestones, absolute-vs-intensity classification, and how the latest international climate agreement informed it. Performance against targets must be disclosed; for GHG targets, gases covered, scopes, gross-vs-net classification, and any planned use of carbon credits with verification scheme detail.
Standard text (verbatim, IFRS S2 Para 33–36)
An entity shall disclose the quantitative and qualitative climate-related targets it has set to monitor progress towards achieving its strategic goals, and any targets it is required to meet by law or regulation, including any greenhouse gas emissions targets. For each target, the entity shall disclose:
(a) the metric used to set the target;
(b) the objective of the target (for example, mitigation, adaptation or conformance with science-based initiatives);
(c) the part of the entity to which the target applies;
(d) the period over which the target applies;
(e) the base period from which progress is measured;
(f) any milestones and interim targets;
(g) if the target is quantitative, whether it is an absolute target or an intensity target;
(h) how the latest international agreement on climate change, including jurisdictional commitments that arise from that agreement, has informed the target.
An entity shall disclose information about its approach to setting and reviewing each target, and how it monitors progress against each target, including:
(a) whether the target and the methodology for setting the target has been validated by a third party;
(b) the entity’s processes for reviewing the target;
(c) the metrics used to monitor progress towards reaching the target;
(d) any revisions to the target and an explanation for those revisions.
An entity shall disclose information about its performance against each climate-related target and an analysis of trends or changes in the entity’s performance.
For each greenhouse gas emissions target the entity shall disclose:
(a) which greenhouse gases are covered by the target;
(b) whether Scope 1, Scope 2 or Scope 3 greenhouse gas emissions are covered by the target;
(c) whether the target is a gross greenhouse gas emissions target or net greenhouse gas emissions target. If the entity discloses a net greenhouse gas emissions target, the entity is also required to separately disclose its associated gross greenhouse gas emissions target;
(d) whether the target was derived using a sectoral decarbonisation approach;
(e) the entity’s planned use of carbon credits to offset greenhouse gas emissions to achieve any net greenhouse gas emissions target, including
(i) the extent to which, and how, achieving any net greenhouse gas emissions target relies on the use of carbon credits;
(ii) which third-party scheme(s) will verify or certify the carbon credits;
(iii) the type of carbon credit, including whether the underlying offset will be nature-based or based on technological carbon removals, and whether the underlying offset is achieved through carbon reduction or removal;
(iv) any other factors necessary for users to understand the credibility and integrity of the carbon credits the entity plans to use.
The Group has set the following climate-related targets. [IFRS S2.33–36]
| Target | Metric | Objective | Scope | Period | Base year | Milestones | Absolute / intensity | Paris-aligned? |
|---|---|---|---|---|---|---|---|---|
| Operational Scope 1+2 | tCO2e | Mitigation | Group operations | 2030 | 2022 | FY26 -30%; FY28 -42% | Absolute (-50%) | SBTi-validated |
| Operational Scope 1+2 | tCO2e | Mitigation (long-term) | Group operations | 2050 | 2022 | FY30 -50%; FY40 -75% | Absolute (-90%) | SBTi net-zero |
| Renewable electricity (operations) | % | Mitigation | Group operations + landlord-controlled tenant areas | 2025 (achieved) | n/a | FY24 88%; FY25 100% | Absolute (100%) | Yes |
| Embodied carbon (new development) | kgCO2e per sq m | Mitigation | New development pipeline | 2030 | 2022 | FY26 -12%; FY28 -22% | Intensity (-30%) | Aligned with WGBC Net Zero Carbon Buildings Commitment |
| Adaptation capex deployment | CU million cumulative | Adaptation | Operating portfolio | 2030 | n/a | FY27 CU 50m; FY29 CU 90m | Absolute (CU 115m) | n/a |
| Tenant cost-recovery clause coverage | % new leases | Adaptation / opportunity | Leasing pipeline | 2027 | n/a | FY25 25%; FY26 45% | Absolute (65%) | n/a |
Validation and review (Para 34). Operational targets SBTi-validated 1.5°C aligned. Embodied-carbon target aligned with World Green Building Council Net Zero Carbon Buildings Commitment. Annual external assurance by independent assurance provider; targets reviewed by Sustainability Committee annually.
Performance (Para 35).
| Target | 2025 | 2024 | 2023 | Base year | Status |
|---|---|---|---|---|---|
| Operational Scope 1+2 (-50% by 2030) | -24% | -14% | -7% | 2022 baseline | Ahead of 2030 trajectory |
| Operational Scope 1+2 (-90% by 2050) | -24% | -14% | -7% | 2022 baseline | On track |
| Renewable electricity (100% by 2025) | 100% | 88% | 65% | n/a | Achieved |
| Embodied carbon (-30% by 2030) | -8% | -4% | -1% | 2022 baseline | On track (development-pipeline-dependent) |
| Adaptation capex deployment (CU 115m by 2030) | CU 34m cumulative | CU 18m cumulative | CU 6m cumulative | 0 (2022) | On track |
| Tenant cost-recovery clause coverage (65% by 2027) | 25% | 12% | 4% | 0% (2022) | On track |
GHG-target detail (Para 36). All seven Kyoto-Protocol gases (CO2, CH4, N2O, HFCs, PFCs, NF3, SF6) included in measurement. All GHG targets gross. Carbon credits not used against operational targets. Sectoral decarbonisation approach not used (whole-Group target).
Illustrative target set.
Cohort findings: what reporters typically skip on Para 33–36
Typically skipped. Embodied-carbon and adaptation-capex targets. Real-estate disclosures often cover only operational Scope 1+2 and miss the development-pipeline embodied-carbon target and the adaptation-capex commitment that determines portfolio resilience.
What good looks like. Multi-objective target set including mitigation, adaptation, embodied carbon, and tenant alignment; explicit validation framework; performance against base year.
Commentary