Who signs off on a climate disclosure figure

Ask a first-cycle reporting team who approved the Scope 2 number and you usually get a name within seconds. Ask them to show you where that approval is recorded and the conversation slows down considerably.

Both facts are true at once: the approval happened, and it cannot be evidenced. That gap is a control deficiency even though nobody did anything wrong.

The three roles behind any disclosed figure

The preparer builds the figure. They hold the working, know where the data came from, and are the wrong person to confirm it — not because they are untrustworthy, but because they cannot see their own assumptions.

The reviewer checks it independently. The word doing the work there is independently: someone who did not build the number and is capable of disagreeing with it.

The approver accepts accountability. This is not a quality check. It is a person with authority saying this figure can be published under their name.

In smaller groups these collapse into one or two people, which is understandable and still a weakness. If your Group Financial Controller prepares, reviews and approves the Scope 2 figure, you do not have a three-stage control. You have one person and a diagram.

What a sign-off record has to contain

Five fields separate a record from a recollection.

Who — a named individual. Not "Group Finance", not a shared inbox.

Role — the authority under which they approved. This is what lets an assurer decide whether the approval was competent.

What — the specific figure and the specific version. "Approved the emissions data" is not the same as approving Scope 2 at 4,796.3 tCO2e in version 3.

When — a timestamp recorded at the moment. A date typed into a cell afterwards is an assertion about the past.

Basis — what they actually checked. One line. "Recalculated against invoices; factor vintage confirmed" tells an assurer more than a signature does.

Where the board and audit committee actually sit

IFRS S2 requires disclosure about the governance body or individual responsible for oversight of climate-related risks and opportunities, and about how those responsibilities are reflected in terms of reference, mandates and policies.

Read that as a documentation instruction. If your report says the audit committee oversees climate disclosure, the terms of reference should say so, and the minutes should show it happening.

The common failure is a governance section written aspirationally — describing the oversight the company intends to have — against a minute book that never mentions climate. That mismatch is trivially easy to find and difficult to explain.

The failure mode: everyone touched it, nobody owns it

A figure moves through four hands. A site manager sends consumption data. An analyst converts it. A manager sanity-checks it against last year. The controller includes it in the pack.

Every one of those people would say they were not the approver. And they would each be right.

This is the specific thing an assurer is looking for when they ask who approved it. Not a signature for its own sake — a point where accountability visibly attached to a person.

The diagnostic question is blunt: if this figure turned out to be materially wrong, whose name is on it? If the honest answer is that several people contributed and nobody accepted it, the control gap is real regardless of how carefully each of them did their part.

Groups tend to discover this at consolidation, where a subsidiary submits a total with no working and the group team accepts it because chasing it costs a week. Both sides assume the other holds the evidence.

Making sign-off a record rather than an email

You do not need a system to fix this, though a system makes it harder to skip. What you need is for approval to produce an artefact linked to the figure.

At minimum: a row in a controlled log naming the person, the figure, the version, the timestamp and the basis. Kept somewhere that cannot be quietly edited afterwards — you can test what an append-only record behaves like if the idea is unfamiliar.

The reason this matters more than it looks: an approval you can alter later is not an approval. It is a note. The whole value of the record is that its own history is fixed, which is the same property covered in The audit trail behind your climate numbers.

The opinion: sign-off is the cheapest control you are not running. Source documents take effort to collect and reproducibility takes discipline to maintain. Recording who approved what, when, costs about thirty seconds per figure — and it is the test that first cycles fail most often.

Common questions

Who should approve a climate disclosure figure?

Someone with the authority to accept accountability for it, who did not prepare it. In most groups that is the Group Financial Controller or Head of Group Reporting for individual figures, with the audit committee or board approving the disclosure as a whole. The specific title matters less than the separation: the person who built the number should not be the person who confirms it.

What makes a sign-off record valid?

Five fields: who approved it as a named individual rather than a team, the role under which they had authority, the specific figure and version approved, a timestamp recorded at the moment of approval, and the basis on which they approved. An email saying it looks fine has none of these except loosely the first.

Does the board have to approve climate disclosures?

IFRS S2 requires disclosure about the governance body responsible for oversight of climate-related risks and opportunities, including how responsibilities are reflected in mandates and terms of reference. If your disclosure states that a body oversees climate reporting, an assurer will expect evidence that the oversight occurred, such as minutes naming climate on the agenda.

Is an email approval enough?

It is better than nothing and worse than a record. An email is not attached to the figure, rarely identifies which version was being approved, and lives in one person’s mailbox. Eighteen months later it is usually unfindable. The problem is not the medium so much as the absence of a link between the approval and the specific number.