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TAC Public Meeting May 2025 Paper 4: IFRS S2 amendments project plan
AGENDA PAPER 4
Executive summary
| Date | 13 May 2025 |
|---|---|
| Paper reference | 2025-TAC-034 |
| Project | Proposed amendments to IFRS S2 |
| Topic | Project plan and assessment approach |
Objective of the paper
This paper provides a proposed overview of the project plan, including a target timeline, to be used by the UK Sustainability Disclosure Technical Advisory Committee (TAC) for the submission of a comment letter on the ISSB's Exposure Draft Amendments to Greenhouse Gas Emissions Disclosures, proposing targeted amendments to IFRS S2. This paper also includes a discussion of the assumptions, constraints and risks that have been taken into account in developing the project plan.
Decisions for the TAC
The TAC is asked to approve the project plan and assessment approach, including the target timeline and to provide any comments on the assumptions, constraints and risks outlined in this paper.
Appendices
There are no appendices to this paper.
This paper has been prepared by the Secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC) to discuss in a public meeting. This paper does not represent the views of the TAC or any individual TAC member.
Context
1The UK Sustainability Disclosure Technical Advisory Committee (TAC) was formed in 2024 to undertake technical assessments of the IFRS Sustainability Disclosure Standards for use in the UK and to provide independent recommendations to the Department of Business and Trade's Secretary of State. The TAC also has responsibility to undertake outreach with, and provide a focal point for, UK stakeholders to influence the technical development of IFRS Sustainability Disclosure Standards.
2The UK Sustainability Disclosure TAC received a commission in 2024 from the Department for Business and Trade (DBT) to undertake a technical assessment of the IFRS Sustainability Disclosure Standards issued in 2023—specifically, IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) and IFRS S2 Climate-related Disclosures (IFRS S2), The objective of this assessment was to advise the Secretary of State whether endorsement of the Standards would be conducive to the long-term public good in the UK. The TAC's endorsement recommendations were issued in December 2024.
3Subsequently, the International Sustainability Standards Board (ISSB) published an Exposure Draft Amendments to Greenhouse Gas Emissions Disclosures proposing targeted amendments to IFRS S2 on 28 April 2025. The proposed amendments would provide reliefs to ease application requirements related to the disclosure of greenhouse gas (GHG) emissions. The Exposure Draft is open for comment from 28 April for 60 days, with the comment period closing on 27 June 2025.
4The UK Sustainability Disclosure TAC plans to respond to the Exposure Draft with a comment letter. This paper outlines the proposed project plan for the submission of a comment letter by the TAC.
Project overview
5The objective of this project is to provide comments to the ISSB as to whether the proposed amendments to IFRS S2 would be suitable for application in the UK context based on the perspectives of UK stakeholders. The TAC has a responsibility to provide a focal point for UK stakeholders to influence the technical development of IFRS Sustainability Disclosure Standards as outlined in the TAC's Terms of Reference.
6The TAC will follow its Due Process Policy, which is to be approved in its May 2025 meeting, in completing this project. As this Policy is subject to final approval by the TAC, the references in this paper are to the draft Policy in Paper 2025-TAC-033 and final paragraph references are subject to change. The Due Process Summary provided at project closure will be referenced to the final approved Policy.
7To provide comments to the ISSB on these matters, the TAC is expected to understand the views of UK stakeholders. The TAC will conduct stakeholder analysis and outreach. In relation to the latter, the Secretariat proposes to engage with banks, investors, insurers, trade associations, NGOs, and a guidance-setting body on the emissions reliefs and GICS proposals. Engagement will take the form of one-to-one interviews and roundtables. The TAC is also required to hold public meetings when conducting technical discussions regarding the IFRS Sustainability Disclosure Standards, subject to the exceptions specified in Section B of the Terms of Reference.
8The TAC's process for preparing the comment letter will include the following stages:
| Project stage | Description | Due Process Policy | Indicative timeline |
|---|---|---|---|
| Project initiation: Prepare proposed project plan and assessment approach | - This paper, prepared by the Secretariat and presented for May 2025 TAC meeting - Members will have a week prior to the May meeting to review the paper and submit comments to the Chair and Secretariat |
Due Process Policy Paragraphs 27-28 | Published 6 May |
| Project delivery: Initial assessment of proposed amendments | - Paper 2025-TAC-035, prepared by Secretariat and presented for May 2025 TAC meeting - Secretariat assessment of the ISSB's proposed amendments to IFRS S2 - Members will have a week prior to the May meeting to review paper and submit comments to the Chair and Secretariat |
Due Process Policy Paragraph 29 | Published 6 May |
| Project initiation: approve project plan and assessment approach | - TAC discussion and approval on this paper in May 2025 TAC meeting - TAC technical discussion on Paper 2025-TAC-035 in May TAC meeting |
Due Process Policy Paragraphs 27-28 | 13 May TAC meeting |
| Project delivery: Stakeholder outreach and analysis | - Carried out by Secretariat - Identify key stakeholders and engage via interviews and roundtables - Conduct desk-based research analysis on PCAF signatories |
Due Process Policy Paragraph 29 | To be completed by end of May |
| Project delivery: Prepare analysis of stakeholder engagement findings for the TAC | - Prepared by Secretariat - Analysis presented for June 2025 TAC meeting - Members will have a week prior to the June meeting to review the analysis and submit comments to the Chair and Secretariat |
Due Process Policy Paragraph 29 | Published 3 June |
| Project delivery: Prepare draft comment letter | - Prepared by Secretariat - Draft presented for June 2025 TAC meeting - Members will have a week prior to the June TAC meeting to review the draft and submit comments to the Chair and Secretariat |
Due Process Policy Paragraph 29 | Published 3 June |
| Project delivery: TAC to discuss findings of stakeholder engagement | - TAC discussion on Secretariat's analysis in June 2025 meeting | Due Process Policy Paragraph 29 | 10 June |
| Project delivery: TAC to approve comment letter for submission | - TAC discussion and approval on draft prepared by Secretariat in June 2025 meeting | Due Process Policy Paragraph 29 | 10 June |
| Project closure | - Draft Due Process summary prepared and approved by the TAC in July 2025 meeting - Summary published on the FRC website |
Due Process Policy Paragraphs 35-37 | Draft published 1 July Approved 8 July TAC meeting Final published 15 July |
9To facilitate these stages and support the TAC, the Secretariat will complete the following tasks:
- Engage with stakeholders to understand views on the proposed amendments.
- Develop a project plan and review the assessment approach.
Assumptions, constraints and risks
10When developing the project plan, the Secretariat has taken into consideration the following assumptions and constraints:
10.1The capacity of the TAC, including the agenda capacity and recognition that the TAC members are volunteers. It is anticipated that the TAC will be able to discuss the draft of the comment letter and approve it within one meeting. Since the TAC members are volunteers, there is a limited amount of work that they can be expected to complete in the time allocated.
10.2The execution of the plan relies upon the capacity of the TAC Secretariat. Currently about 1.0 full-time equivalent resources and 0.3 full-time equivalent oversight resources are allocated to this project for its duration. The Secretariat will be expected to write papers for public TAC meetings in addition to conducting research and ongoing stakeholder engagement to inform the final comment letter.
Project plan and target timeline
11The deadline for comments set by the ISSB is 27 June 2025. This will require the TAC to approve the comment letter at its June meeting, currently scheduled for 10 June 2025.
12The target timeline below displays the Secretariat's proposed sequence of events that will lead to the finalisation of the TAC's comment letter. It is expected that all these activities are to be completed whilst going through appropriate due process with the whole committee.
13This target timeline takes into consideration known events that have potential to delay the delivery of the final endorsement recommendations. However, the timeline does not take into consideration the assumptions, constraints and risks that are uncertain. This means that the target timeline may need to be amended during the project.
This diagram illustrates the project timeline:
Stakeholder engagement & desk-based analysis by TAC Secretariat Public meeting: 13 May Project initiation & technical discussion of Secretariat's assessment of the proposed amendments
Drafting comment letter
Comment letter submitted
Public meeting: 10 June Approve comment letter
Deadline for comments letters: 27th June
Timeline progresses from May 2025 to June 2025.
Assessment approach
14This technical assessment will only consider the contents of the Exposure Draft Amendments to Greenhouse Gas Emissions Disclosures published by the ISSB on 28 April 2025.
15As described in the Terms of Reference, the purpose of the TAC's work is to provide rigorous technical analysis of the standards issued by the ISSB and provide clear, well-reasoned and evidence-based recommendations accordingly, with the overall aim of assessing whether the IFRS Sustainability Disclosure Standards should be endorsed for use in the UK. In order to assess whether a UK Sustainability Reporting Standard aligned with the IFRS Sustainability Disclosure Standards would be conducive to the long-term public good in the UK, the TAC has developed a number of assessment criteria to assess the IFRS Sustainability Disclosure Standards against. These will apply to the proposed amendments being suggested in the Exposure Draft.
16The following paragraphs set out a proposed assessment approach for the Exposure Draft, to be applied in the drafting and finalisation of the comment letter responding to the Exposure Draft.
17While the assessment criteria in the TAC's Terms of Reference are required to be applied when responding to commissions for endorsement advice from DBT, the criteria serve as a useful guide for the TAC's assessment of ISSB's proposed amendments to IFRS S2. The TAC will therefore assess whether these amendments are conducive to the long-term public good in the UK as follows:
17.1whether the proposed amendments to IFRS S2 are likely to result in an improvement in the international comparability of sustainability-related reporting in the UK;
17.2whether use of the amended version of IFRS S2 is likely to support companies in making disclosures that are understandable, relevant, reliable and comparable;
17.3whether use of the amended version of IFRS S2 is likely to improve the quality of corporate reporting within the UK in the long-term; and
17.4whether companies are likely to be able to provide the disclosures required by the amended version of IFRS S2 within the timeframes that a company normally reports without undue cost or effort.
18The objective of the International Sustainability Standards Board (ISSB) is to develop sustainability standards that will result in high-quality, comprehensive global baseline of disclosures that focuses on the needs of primary users and the financial markets. The ISSB's standard-setting work is subject to due process and oversight procedures that should ensure it takes into consideration the views from stakeholders across multiple jurisdictions. Whilst the ISSB has issued international standards to serve as the global baseline, the TAC's technical assessment will consider the requirements in the context of the UK and views obtained from UK stakeholders. There are likely to be some issues that have been raised by UK stakeholders that are also relevant to the international application of the requirements, and the TAC will consider these issues as they pertain to the UK. For example, challenges with Scope 3 greenhouse gas emissions reporting are not unique to the UK, but there may be some considerations that the TAC needs to make, for example, about current practice in the UK and interoperability with other jurisdictions.
19When applying the criteria in the technical assessment, the TAC should be cognisant that satisfying one criterion may compromise another, and there is a balance to be struck. The criteria will be assessed individually and in combination to ensure a full assessment has been completed. Additionally, if the TAC expresses disagreement with any of the proposed amendments for use in the UK, these disagreements will need to be on the basis of the assessment criteria.
20This project is one of limited scope, and therefore the extent of stakeholder outreach, technical assessment, and TAC discussions are expected to be limited.
Next steps
21Once the project plan and assessment approach have been approved by the TAC, the Secretariat will commence its work to enable the TAC's submission of a comment letter on the ISSB's Exposure Draft proposing targeted amendments to IFRS S2 by the 27 June 2025 deadline.
Questions for the TAC
- Does the TAC approve the project plan?
- Does the TAC have any comments on the proposed assessment approach?