Enough IFRS S2 disclosures have now been filed to see a pattern, and it is not the one most implementation guides prepare you for. The failures are not technical. They are about sequencing.
The most expensive mistake we have seen is starting with data collection. Teams gather everything they can reach, then work out what was material — by which point they have spent months reconciling emissions data for categories that were never going to be reported.
Materiality is the first decision, not the last. It determines the scope of everything downstream.
Scope 3 is fifteen categories with fifteen different data problems. Groups that treated it as a single workstream stalled. Groups that triaged it by category, and were honest about which ones they could not yet measure, filed on time and said so in the disclosure.
The governance disclosures were routinely the weakest section, because they were drafted last, describing arrangements that had been set up for the reporting exercise rather than for managing the risk. Auditors noticed.
Decide materiality, triage Scope 3 honestly, and write the governance section describing what actually happens. The technical accounting is the easy part.