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TAC March 2025 Paper 2: March General Reporting Update
UK Sustainability Disclosure Technical Advisory Committee
Executive summary
| Date | 25 March 2025 |
| Paper reference | TAC-Update-March-2025 |
| Project | Monitoring |
| Topic | March 2025 General Reporting Update |
Objective of the paper
This paper provides key updates since the update paper provided at the February 2025 TAC meeting.
This includes a summary of the ISSB meetings and related developments, in addition to jurisdictional developments in relation to the adoption of IFRS Sustainability Disclosure Standards to date.
The information in this paper is provided as at 11 March 2025 and does not include any developments after this date.
Decisions for the TAC
There are no decisions required. This paper is for information only.
Appendices
Appendix 1 - Jurisdictional developments.
Context
1The objective of this paper is to inform the TAC of international and jurisdictional developments in sustainability-related reporting. It is for information purposes only and does not ask the TAC to make any decisions.
2The TAC will be provided with an update of UK-specific, international and jurisdictional developments on sustainability-related reporting at each of its meetings.
International Sustainability Standards Board
3The following paragraphs provide a summary of updates from the International Sustainability Standards Board (ISSB) since the last update paper presented at the February 2025 TAC meeting.
4On 13 February, the IFRS Foundation hosted the seventh webinar in their Perspectives on sustainability disclosure series, titled "Using the GHG Protocol for climate-related disclosures'. The webinar outlined how the ISSB Standards support GHG emissions disclosures that are accurate, reliable and decision-useful, and provided an overview of carbon accounting and how the Greenhouse Gas Protocol (GHGP) and IFRS S2 Climate-related Disclosures align.
5On 18 February the IFRS Foundation convened the Sustainability Standards Advisory Forum. The agenda covered proposed amendments to the IFRS Foundation Due Process Handbook; supporting implementation of IFRS S1 and IFRS S2; enhancing the SASB Standards; and Biodiversity, Ecosystems and Ecosystems Services (BEES) and Human Capital Research projects.
6The IASB and ISSB met on 19 February. This meeting was for information only, and the IASB technical staff presented a summary of stakeholder feedback on their Exposure Draft Climate-related and Other Uncertainties in the Financial Statements. The meeting was an opportunity to consider the implications of the feedback on the Board's connectivity-related activities.
7The ISSB met 20-21 February. The Board discussed research on BEES and Human Capital. This included a comparison of other BEES-related standards and frameworks to IFRS S1 and SASB Standards, and an analysis of investor interest in human capital-related information.
8ISSB Updates were published summarising the January and February ISSB meetings. A joint IASB-ISSB Update was also published summarising the Boards' joint meeting on 19 February.
9The Q1 2025 episode of the ISSB's Implementation Insights podcast was released. The episode includes discussion around educational materials and the Transition Implementation Group's (TIG's) 2024 meetings.
10The ISSB held a webcast on proportionality mechanisms in IFRS Sustainability Disclosure Standards, to explain what the proportionality mechanisms within IFRS S1 and IFRS S2 are and how they support the Standards' application.
11On 25 February the IFRS Foundation held a stakeholder event to obtain information from stakeholders to inform the Transition Plan Taskforce (TPT) materials. The event was attended by representatives from 27 organisations, and found agreement for the IFRS Foundation to develop a guidance document building on TPT material and providing further examples to improve disclosures about transition plans.
12The IFRS Foundation have launched a new SASB Standards Navigator, which is free of charge for non-commercial use in both PDF and HTML formats.
13The ISSB will meet 19-20 March. Scheduled agenda items include research projects on BEES and Human Capital, focusing on the current state of disclosures, and an update on the SASB Standards enhancement project.
14On 20 March the IFRS Foundation will hold its eighth Perspectives on sustainability disclosure webinar, titled ‘The future of integrated reporting and integrated thinking'.
Jurisdictional developments
15The following paragraphs provide a summary of updates from other jurisdictions in relation to sustainability-related reporting since the last update paper presented at the February 2025 TAC meeting.
16Appendix 1 contains the summary tables of the different jurisdictional decisions relating to the IFRS Sustainability Disclosure Standards. The tables have been updated since the February 2025 TAC meeting to reflect the most recent developments.
European Union
17Debates have begun in the European parliament on the European Commission's omnibus proposals, which aim to simplify and streamline sustainability reporting, focusing on the Corporate Sustainability Reporting Directive (CSRD), the European Sustainability Reporting Standards (ESRS), and the Corporate Sustainability Due Diligence Directive (CSDDD).
18The omnibus package was launched on 26 February 2025. The goal of the omnibus package is to reduce administrative and reporting burdens on companies, and therefore unlock their investment potential and enhance European economic competitiveness. It aims to cut reporting burdens by 25% (35% for SMEs).
19Proposed changes to CSRD include (but are not limited to):
- Postponing the application of reporting requirements for 'wave 2' and 'wave 3' companies by two years
- Reducing the scope of CSRD to large undertakings, and parent undertakings of a large group (with >1000 employees, and > €25m balance sheet or > €50m turnover)
20Proposed changes to ESRS include (but are not limited to):
- Changing thresholds applicable to a third country to > €450m turnover generated within the EU, or a large subsidiary or brand generating > €50m
- Greater flexibility for certain undertakings to report on EU taxonomy
- Removing the obligation to adopt a reasonable assurance standard
- Substantially reducing the number of mandatory ESRS datapoints by: removing those deemed least important; prioritising quantitative data over narrative; distinguishing further between mandatory and voluntary datapoints
- Clarifying unclear provisions
- Improving consistency with other EU legislation
- Providing clearer instructions on applying the principle of double materiality
- Simplifying the standard's structure and presentation
- Enhancing interoperability with global sustainability reporting standards
- Making other modifications based on the experience of the first ESRS reports being published now
21Proposed changes to CSDDD include (but are not limited to):
- Narrowing the definition of 'stakeholder' to exclude consumers, and national human rights, civil society and environmental organisations
- Restricting member states from introducing more stringent rules around human rights and environmental issues
- Limiting value chain due diligence to direct suppliers
- Reducing monitoring frequency from once a year to once every five years
- Removing the obligation to put into effect a transition plan
- Removing the requirement to report financial undertakings
22Meanwhile, the first set of 'wave 1' CSRD reports have been published. According to the Sustainability Reporting Navigator 1, 156 companies have now published CSRD reports, including three UK based companies (IAG, RELX, and Barclays Bank PLC).
Japan
23The Sustainability Standards Board of Japan (SSBJ) has released its finalised sustainability disclosure standards in alignment with the ISSB Standards. There are three final standards: Universal Sustainability Disclosure Standard Application of the Sustainability Disclosure Standards, Theme-based Sustainability Disclosure Standard No. 1 General Disclosures, and Theme-based Sustainability Disclosure Standard No. 2 Climate-related Disclosures. These standards will form the basis for mandatory reporting for listed companies, though they do not prescribe scope or timing for reporting within themselves.
24The first two standards correlate to IFRS S1, while the third correlates to IFRS S2. The application standard prescribes the basic requirements for preparing sustainability-related financial disclosures, and the general standard covers the core content of IFRS S1. The final standards reduce discrepancies with the ISSB Standards from the exposure drafts, following feedback received. The SSBJ is planning to publish a schedule of differences between its standards and the ISSB Standards.
Rwanda
25The Institute of Certified Public Accountants of Rwanda (ICPAR) has opened a consultation on a draft adoption roadmap for IFRS Sustainability Disclosure Standards. The consultation will close on 19 March.
United States
26The acting Chair of the US Securities and Exchange Commission (SEC), Mark Uyeda, has indicated that he will not defend the SEC's climate-related disclosure requirement in court. The requirement was bought in last year under his predecessor, and is currently being reviewed by the Eighth Circuit Court of Appeals following legal challenges from businesses associations. Uyeda has requested the court refrain from scheduling a hearing for the SEC's defence of the requirement, thereby withdrawing legal defence of the requirement.
27However, certain states are moving forward with adopting mandatory climate-related disclosures. Bills are currently being considered at state legislatures in Colorado and New York, both mirroring California's 2023 Corporate Climate Accountability Act, and applying to companies with > $1bn revenue operating within the states.
Appendix 1 – Jurisdictional developments
G20 jurisdictions committed to adopting IFRS Sustainability Disclosure Standards
Table 1 summarises the status of G20 jurisdictions publicly committed to adoption or other use of the IFRS Sustainability Disclosure Standards.
| Jurisdiction | Current status | Both IFRS S1 & IFRS S2? | Reporting commencing from | Companies in scope |
|---|---|---|---|---|
| African Union: Ghana | Endorsed | Both | 2027-2028 | Listed & unlisted |
| African Union: Kenya | Consultation closed Published roadmap |
Both | 2025-2027 | Banks |
| African Union: Morocco | Publicly committed | - | - | - |
| African Union: Nigeria | Endorsed | Both | 2028-2030 | Listed & unlisted |
| African Union: Rwanda | Consultation open | Both | 2025-2026 | Listed & unlisted |
| African Union: Tanzania | Endorsed | Both | 2025 | Listed & unlisted |
| African Union: Uganda | Endorsed | Both | 2026-2028 | Listed |
| African Union: Zambia | Endorsed | Both | 2025 | Listed |
| African Union: Zimbabwe | Publicly committed | - | - | - |
| Australia | Endorsed | Both: IFRS S1-voluntary | 2025 | Listed & unlisted |
| Brazil | Endorsed | Both: IFRS S2 - mandatory | 2026 | Listed |
| Canada | Endorsed | Both | 2025 | To be confirmed |
| China | Consultation closed | Both | 2026-2030 | Listed & unlisted |
| India | Consultation closed | IFRS S2 only | 2025-2029 | Banking & finance |
| Indonesia | Consultation open – draft standards | Both | 2027 | To be confirmed |
| Japan | Endorsed | Both | - | Listed |
| Mexico | Consultation closed | Both | 2026 | Listed and private |
| South Korea | Consultation closed | Both | 2026-2030 | Listed |
| Turkey | Endorsed | Both | 2024 | Regulated financial institutions & large companies |
Other jurisdictions committed to adopting IFRS Sustainability Disclosure Standards
Table 2 summarises the status of non-G20 jurisdictions publicly committed to adoption or other use of the IFRS Sustainability Disclosure Standards.
| Jurisdiction | Current status | IFRS S1 & IFRS S2? | Reporting commencing from | Companies in scope |
|---|---|---|---|---|
| Bangladesh | Endorsed | Both | 2024-2027 | Banking & finance |
| Bolivia | Endorsed | Both | 2027 | Listed & unlisted |
| Chile | Endorsed | Both | 2026 | Listed |
| Costa Rica | Endorsed | Both | 2025-2026 | Listed & unlisted |
| Hong Kong | Endorsed | Both | 2025 | Listed |
| Jordan | Endorsed | Both: IFRS S1 – voluntary FRS S2-Mandatory | 2027 | All entities listed in the ASE20 index |
| Malaysia | Endorsed | Both | 2025-2027 | Listed & large unlisted |
| Panama | Publicly committed | - | - | - |
| Pakistan | Endorsed | Both | 2025-2027 | Listed & unlisted public interest companies |
| Philippines | Consultation closed | Both | 2025 | Listed |
| Qatar | Consultation open | Both | 2026 | Listed |
| Singapore | Endorsed | IFRS S2 only | 2025-2027 | Listed |
| Sri Lanka | Endorsed | Both | 2025 | To be confirmed |
| Switzerland | Consultation open- amending the Ordinance on Climate Disclosures | Both | 2026 | Listed & unlisted |
| Taiwan | Endorsed | Both | 2026-2028 | Listed |
| Thailand | Endorsed | Both | 2026-2030 | Listed |
G20 jurisdictions not publicly committed to adopting IFRS Sustainability Disclosure Standards
Table 3 summarises the status of G20 jurisdictions not publicly committed to adoption or other use of the IFRS Sustainability Disclosure Standards.
| Jurisdiction | Current status | Topics | Reporting commencing from | Companies in scope |
|---|---|---|---|---|
| Argentina | Unconfirmed | - | - | - |
| European Union (EU)* | European Sustainability Reporting Standards (ESRS) & Corporate Sustainability Reporting Directive (CSRD) | Ten topical standards including a general and climate change standard | 2024-2028 | Listed & unlisted |
| Russia | Unconfirmed | - | - | - |
| Saudi Arabia | Unconfirmed | - | - | - |
| South Africa | Unconfirmed | - | - | - |
| United States of America (USA) | Climate disclosure rules by the US Securities and Exchange Commission (SEC) – on hold | Climate | SEC: 2025-2033 (currently on hold) | Listed |
| California Corporate Climate Accountability Act (SB 253 and SB 261) - adopted | California: 2026 | California: Listed & unlisted | ||
| New York Climate Corporate Data Accountability Act (SB 3456) - bill | New York: 2027 - 2028 | New York: Listed & unlisted | ||
| Colorado Corporate Climate Accountability Act (House Bill 25-119) - bill | Colorado: 2028 - 2031 | Colorado: Listed & unlisted |
* Although European Sustainability Reporting Standards are required to be used by EU member states, the IFRS Foundation and EFRAG issued interoperability guidance in 2024 illustrating the high level of alignment achieved between ISSB Standards and ESRS.
This paper has been prepared by the Secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC). It does not represent the views of the TAC or any individual TAC member.
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The TAC Secretariat is not endorsing the Sustainability Reporting Navigator’s content or analysis for accuracy or completeness. ↩