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TAC Public Meeting July 2025 Paper 3: Proposed amendments to SASB standards

Executive summary

Date	08 July 2025
Paper reference	2025-TAC-038
Project	Proposed amendments to SASB Standards
Topic	Proposed project management plan and assessment approach
Objective of the paper	This paper presents proposed project management plans to guide the UK Sustainability Disclosure Technical Advisory Committee (TAC)'s review and response to the ISSB's two Exposure Drafts. The first Exposure Draft proposes amendments to nine priority SASB Standards including consequential amendments to 41 other standards, and the other proposes consequential amendments to the Industry-based Guidance on Implementing IFRS S2 Climate-related Disclosures.

Decisions for the TAC

The TAC is asked to approve one of the three proposed project management plans and assessment approaches.

Appendices

• Appendix 1 – Climate-focussed approach
• Appendix 2 – Hybrid approach (climate-focussed plus two key topics – biodiversity and human capital)
• Appendix 3 – Full review of all proposed amendments and nine prioritised SASB standards that fall in the scope of the Exposure Drafts.

Context

SASB Standards enhancement project

1 At its meeting held on 18 June 2025, the International Sustainability Standards Board (ISSB) discussed proposed Exposure Drafts and the Basis for Conclusions for phase 1 of its project to enhance the SASB Standards. The SASB Standards were initially published in 2018. The ISSB assumed responsibility for the SASB Standards in 2022 when the Value Reporting Foundation, which previously maintained them, merged with the IFRS Foundation. At the 18 June meeting, the ISSB decided to ratify the proposed amendments to the SASB Standards and tentatively decided to publish two Exposure Drafts in early July:

• one on the proposed amendments to 9 priority SASB Standards and targeted amendments to another 41 standards (Exposure Draft Proposed Amendments to the SASB Standards); and
• the other on consequential amendments to the Industry-based Guidance on Implementing IFRS S2 Climate-related Disclosures (Exposure Draft Proposed Amendments to the Industry-based Guidance on Implementing IFRS S2).

2 The objective of the ISSB's SASB enhancement project is to strengthen the SASB Standards in a way that:

• improves their international applicability, including to emerging markets;
• aligns more closely with IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2, ensuring clearer integration with the ISSB's broader framework;
• increases interoperability with other standards and global frameworks, such as the European ESRS, Global Reporting Initiative (GRI), and the Taskforce on Nature-related Financial Disclosures (TNFD);
• reflects current sustainability challenges related to biodiversity, ecosystems and ecosystem services (BEES), and human capital; and
• maintains a focus on investor-relevant information and decision-useful metrics.

3 The SASB enhancement plan, involves twelve priority industries that were selected due to their sustainability significance and international usage. Of the twelve prioritised industry-specific standards, nine standards (eight from the extractives and minerals processing sector, and one from the food and beverage sector) as listed below are included in the Exposure Draft Proposed Amendments to the SASB Standards to be released in July 2025:

• Coal operations
• Construction materials
• Iron & steel producers
• Metals & mining
• Oil & gas – exploration & production
• Oil & gas – midstream
• Oil & gas - refining & marketing
• Oil & gas – services
• Processed foods

4 Amendments to the remaining three priority industries (Agricultural Products, Meat, Poultry & Dairy, and the Electric Utilities & Power Generators SASB Standards) are expected to be addressed in a second phase of the enhancement project in late 2025.

5 In addition to industry-specific changes to the nine priority standards, the Proposed Amendments to the SASB Standards Exposure Draft proposes targeted amendments to 41 other SASB Standards. These amendments are designed to promote consistent treatment of key disclosure topics that appear across multiple industries. The targeted areas include:

• Greenhouse gas (GHG) emissions
• Energy management
• Water management
• Labour practices
• Workforce health and safety

Role of the TAC in the SASB Standards enhancement project

6 In 2024, the UK Sustainability Disclosure Technical Advisory Committee ('TAC', or 'Committee') undertook a technical assessment of the IFRS Sustainability Disclosure Standards, IFRS S1 and IFRS S2 following a commission from the Department for Business and Trade. The objective of this assessment was to advise the Secretary of State on whether endorsement of IFRS S1 and IFRS S2 would be conducive to the long-term public good in the UK. The TAC's endorsement recommendations were issued in December 2024 and found that endorsing IFRS S1 and IFRS S2 for use under UK Sustainability Reporting Standards (UK SRS) would be conducive to long-term public good.

7 Paragraphs 55(a) and 58(a) of IFRS S1, require that entities ‘shall refer to and consider' the applicability of the disclosure topics in the SASB Standards when identifying sustainability-related risks and opportunities, and, in the absence of a topic-specific IFRS Sustainability Disclosure Standard, the associated metrics to identify disclosure requirements.

8 In the UK, a Government consultation on draft UK SRS issued on 25 June 2025 proposes to amend the requirements in paragraphs 55(a) and 58(a) in UK SRS 1 to allow that 'entities may refer to and consider' the applicability of content in the SASB Standards. Although the exact requirement related to the use of the SASB Standards in the final issued UK SRS is still under consideration, the proposed amendments to the SASB Standards remain relevant within the UK context, especially as IFRS S1 and IFRS S2 are intended to be adopted as UK SRS 1 and UK SRS 2 respectively.

9 Although the TAC has not assessed the UK-wide usage of the SASB Standards, it is aware that some UK-based multinational companies voluntarily apply these Standards. As such, the ISSB's project to enhance the SASB Standards is directly relevant to the current reporting landscape in the UK. It therefore has implications for those entities currently referencing these standards and is also important in the context of the ISSB's longer-term integration plans as it brings content from the SASB Standards into its own IFRS Sustainability Disclosure Standards.

10 The TAC has been asked by the Department for Business and Trade to understand the ISSB's enhancements to the SASB Standards and the implications of this for UK SRS, in a priorities letter dated 3 June 2025. The DBT letter does not commission a full assessment of all enhancements to the SASB Standards in the scope of the proposed Exposure Drafts. Accordingly, and given that the SASB Standards are currently applied on a voluntary basis in the UK, the TAC is expected to adopt a proportionate approach which will need to be aligned with available resources.

11 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 as outlined in the TAC's Terms of Reference.

12 This paper presents proposed project management plans to guide the TAC's review and response to the SASB Standards amendments Exposure Draft and IFRS S2 industry-based guidance amendments Exposure Draft.

13 The proposed project management plans span 20 weeks, structured into three phases: project initiation, project delivery, and project closure. They include estimated resource requirements, stakeholder engagement strategies, and risk mitigation approaches. The paper presents three options of project approaches which are: a climate-focussed review, a full standards review, and a hybrid targeted review for the TAC's consideration, each with different resourcing needs.

Project overview

14 In the context of the TAC's remit, the objective of this project is to provide a proportionate review and response to the ISSB's Exposure Drafts on enhancements to the SASB Standards. The project will involve an analysis of the two proposed Exposure Drafts and the Basis for Conclusions, stakeholder engagement, research, and preparation of comment letters.

15 The TAC will follow its Due Process Policy, and the Due Process Summary will be provided at project closure.

16 To provide comments to the ISSB on these matters, the TAC is expected to understand the views of UK stakeholders. The TAC will conduct stakeholder outreach and analysis. In relation to the latter, the Secretariat proposes to engage with preparers in the extractives sector, food processing industries, investor groups and some industry experts, when relevant. The stakeholder engagement could take the form of one-to-one interviews, roundtables and surveys, as appropriate. The TAC is also required to hold public meetings when conducting technical discussions regarding key materials associated with IFRS Sustainability Disclosure Standards, with the exception of when discussion involves confidential or administrative matters, at the discretion of the Chair.

17 Considering the scope and complexity of the proposed Exposure Drafts, the Secretariat has considered various approaches for the project including whether to review only a sample of the nine industry standards or review key themes across these nine standards. These considerations are discussed in the sections that follow.

Reviewing a sample of selected standards

18 Reviewing a selected sample of the nine priority standards allows for a deeper analysis of selected standards. However, it limits understanding of how key themes such as GHG emissions, energy and water management are addressed across the broader set of standards. This, in turn, constraints the ability to assess the targeted amendments to the remaining 41 standards. Given the TAC's public-good mandate, selectively omitting standards particularly in sectors significant to the UK economy (e.g., metals, midstream energy, construction) could appear arbitrary. It may also weaken the UK's influence on international standard-setting if global counterparts adopt a more comprehensive review. For these reasons, the Secretariat has not adopted this approach in the proposed project plan.

Review of key themes across the nine standards

19 Reviewing key themes across the nine priority standards provides better coverage across these standards while maintaining a strategic focus on key thematic areas. By expanding the assessment of a number of themes across these nine standards, it also creates an opportunity to expand insights on the concerns previously raised regarding the IFRS Foundation's Due Process in maintaining the SASB Standards and any possibility of mitigating action.

20 To support the TAC's decision-making process, the Secretariat has presented three options of project management plan approaches for the TAC's consideration. These approaches, which are presented in more detail in appendices 1 to 3, include the following:

• Climate-focussed approach - focuses only on climate-related disclosures aligned with IFRS S2, interoperability with other relevant standards and frameworks.
• Hybrid targeted approach - prioritises three high-impact themes like climate, human capital and biodiversity while conducting light-touch review in other areas.
• Full review of standards in the scope of the Exposure Draft - covers all nine priority SASB Standards, 41 targeted cross-industry amendments and consequential amendments to IFRS S2 industry-based guidance. This approach is resource-intensive, and the Secretariat does not have the capacity to do this.

Assessment approach

21 The table below summarises the benefits and risks associated with each of the three approaches considered:

No	Approach	Benefits	Risks
(i)	Climate-focussed	- Less resource intensive and outreach can be tightly focused.	- Excludes other high-impact sustainability areas like labour practices, biodiversity, and others.
		- Enables detailed analysis of high-impact sectors like Oil & Gas, Coal, Construction and others.	- Focussing solely on climate may constrain the UK's ability to adequately contribute to the development of the SASB Standards. While these are industry focussed and not currently mandated in the UK, they may gain greater significance in future regulatory or market contexts. Thus, limiting engagement at this stage could reduce the UK's influence on important emerging topics such as labour practices, biodiversity, and supply chains.
		- Benefits from reference to UK Transition Plan Taskforce (TPT) sector-based guidance.
		- Supports the implementation of IFRS S2 in a proportionate and targeted way.
		- Benefits the work on IFRS S2 industry-based guidance.
		- Given the proportionate volume of work, this provides an opportunity for a public consultation on a draft comment letter.
(ii)	Hybrid targeted	- Balanced and pragmatic - targets key themes aligned with UK and global sustainability reporting agendas, including emerging ISSB research streams (human capital, BEES)	- Justifying inclusion/exclusion of themes might invite criticism or confusion from stakeholders.
		- Allows depth in the most impactful areas, while still permitting engagement with the standards in scope of the Exposure Draft.	- Risk of reviewing several topics moderately well but with less depth.
		- Offers some flexibility for adjustments (e.g. reduce depth on biodiversity if needed due to time and resource constraints)	- Limits the possibility to conduct a public consultation on a draft comment letter due to time constraints.
(iii)	Full standards review	- Enables the TAC to influence all amendments to the prioritised SASB Standards.	- Resource intensive risking quality of output as staff will be spread more thinly.
		- Provides opportunity for the TAC to influence harmonisation between SASB Standards, and other standards and frameworks such as ESRS, GRI, and TNFD.	- Risk of stakeholder fatigue due to the breath of feedback required resulting in potentially lower quality.
		- Generates technical materials that may support future UK sustainability standards development.	- Limits the possibility to conduct a public consultation on a draft comment letter due to time constraints.

22 Considering the above, the Secretariat recommends a hybrid approach (with no public consultation on a draft comment letter, though there will be other stakeholder input through roundtables and one-to-one interviews, and possibly a survey). This strikes a fair balance between resource demands and a reasonable coverage, and aligns with DBT's commission to the TAC. In addition, it offers flexibility for adjustment to suit circumstances as the project progresses, for instance the ability to reduce the amount of coverage in certain areas. However, the Secretariat welcomes the TAC's views on the options presented above and detailed in the appendices.

23 This technical assessment will only consider the content of the proposed amendments to the nine SASB Standards including targeted amendments to 41 other standards and proposed consequential amendment to IFRS S2 industry-based guidance to be published in early July 2025. The proposed Exposure Drafts were presented to the ISSB board at 18 June meeting and were ratified.

24 As 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 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 Drafts, on the understanding that in time the content of the SASB Standards will come to form part of IFRS Sustainability Disclosure Standards, or provide guidance to an existing Standard, as in the case of the proposed amendments to the Industry-based Guidance on Implementing IFRS S2.

25 The following paragraphs set out a proposed assessment approach for the Exposure Drafts, to be applied in the drafting and finalisation of the comment letters responding to the Exposure Drafts.

26 While 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 also serve as a useful guide for the TAC's assessment of the IFRS Foundation's proposed amendments to the SASB Standards. Although it is expected that the position for UK companies is that they 'may consider' using SASB Standards, the more the SASB Standards result in high-quality decision-useful information, we expect it more likely that UK companies will apply them. Therefore, the TAC will assess whether these amendments are conducive to the long-term public good in the UK as follows:

• whether the proposed amendments to the SASB Standards are likely to result in an improvement in the international comparability of sustainability-related reporting in the UK;
• whether use of the amended version of the SASB Standards is likely to support companies in making disclosures that are understandable, relevant, reliable and comparable;
• whether use of the amended version of the SASB Standards is likely to improve the quality of corporate reporting within the UK in the long-term; and
• whether companies are likely to be able to provide the disclosures required by the amended version of the SASB Standards within the timeframes that a company normally reports without undue cost or effort.

27 The objective of the 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.

28 When 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 views on the proposed amendments for use in the UK, they will be made in the context of the TAC's assessment criteria.

Assumptions, constraints and risks

29 When developing the project management plans, the Secretariat has taken into consideration the following assumptions and constraints:

• the capacity of the TAC, including the agenda capacity and recognition that the TAC members are volunteers. Since the TAC members are volunteers, there is a limited amount of work that they can be expected to complete in the time allocated;
• the execution of the plan relies upon the capacity of the TAC Secretariat. 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 letters. The expected available resources are 1.8 FTE project directors, supported by an associate and with oversight from the Head of the Secretariat for the duration of the project;
• the capacity of stakeholders to engage with interviews and roundtables, as well as in a public consultation on a draft comment letter. The period of time available for both types of stakeholder engagement is likely to fall during the summer months when there may be decreased availability for engagement and interested stakeholders are also likely to be responding to other sustainability reporting related government consultations; and
• this is the first time that the TAC and Secretariat will be engaging with the SASB Standards in depth. Apart from forming industry-based guidance accompanying IFRS S2, the SASB Standards content has not formed part of previous detailed technical papers. There is therefore an investment of time to become familiarised with the content which covers specific industries in depth but is also of a large volume.

Project management plans and target timeline

30 Since the consultation on SASB enhancements is forthcoming, we understand that the ISSB will issue its consultation on 3 July. The ISSB agreed a 150-day comment period, and the deadline is therefore projected to be 29 November for the purposes of our plan. This will require the TAC to approve the comment letters at its November meeting, currently scheduled for 11 November 2025.

31 The attached appendices detail three different proposed sequences of events that would lead to the finalisation of the TAC's comment letters. It is expected that all these activities are to be completed while going through appropriate due process with the whole committee.

32 While the nature and depth of the analysis will depend on the initial review of the Exposure Drafts and input from stakeholders, the technical work is expected to include:

• a proportionate review of the standards with proposed amendments and related Basis for Conclusions;
• review of available ISSB outputs including staff papers published for previous meetings;
• assessment of relevant third-party commentary and publications;
• review of a selected sample of FTSE companies' annual reports that are currently referencing SASB Standards;
• cross-jurisdictional comparisons of findings with other standard-setters; and
• evaluation of interoperability with other frameworks such as the EU ESRS, GRI, TNFD, and others as appropriate.

33 Considering the volume of work and resource capacity, the project does not propose to conduct a public consultation in the UK on a draft comment letter if the hybrid or full standards review approach is taken due to time constraints. However, the climate-focussed approach provides the optional flexibility for a public consultation on a draft comment letter. A public consultation can provide valuable and structured stakeholder input. However, it also requires additional time and effort from both stakeholders and the Secretariat to process and synthesise the proposals effectively, particularly under the hybrid or full standards review, and will require time for the Secretariat to analyse this set of feedback. While our recommended approach in paragraph 22 proposes no public consultation, we have considered the time impact of performing a public consultation on each of the three approaches presented in appendices 1 to 3 to provide the TAC with sufficient information in deciding on its preferred approach.

34 If the project proceeds with the approach we recommend, we have proposed not to conduct a formal public consultation. Alternative mechanisms will be explored to ensure reasonable stakeholder coverage, particularly in relation to the breadth of the targeted amendments across the 41 additional SASB Standards. For example, a survey could be designed to capture some of the key questions that would otherwise have been included in a public consultation.

35 The timelines presented in the appendices take into consideration known events that have potential to impact the delivery of the final comment letters. 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, within the scope of the deadline once set by the ISSB.

Next steps

36 Once the project management plan and assessment approach have been approved by the TAC, the Secretariat will commence its work to enable the TAC's submission of the comment letters on the ISSB's Exposure Drafts proposing amendments to the SASB Standards.

Questions for the TAC

1. Does the TAC have any comments on the proposed assessment approach?
2. Which project management plan approach does the TAC support, taking into account the Secretariat's recommendations in paragraph 22?
3. Does the TAC approve the selected project management plan?

Appendix 1 – Climate-focussed approach

Climate-related disclosures are a cornerstone of the UK's sustainability reporting landscape. Under current regulations, Task Force on Climate-related Financial Disclosures (TCFD)-aligned reporting is mandatory for FCA-regulated entities, and large private companies and LLPs are also subject to statutory climate disclosure requirements.

In this context, the proposed climate-related amendments to the SASB standards, particularly those focused on aligning with IFRS S2 and IFRS S1 are of direct relevance to UK stakeholders. Notable changes include refining greenhouse gas (GHG) metrics, adjusting methane disclosures to report absolute emissions, and clarifying sector-specific energy and transition-related indicators. Although the SASB Standards are used on a voluntary basis, these proposed amendments aim to enhance their interoperability with the UK's broader climate reporting framework. For UK companies that already reference the SASB Standards, particularly those operating internationally, the changes should offer a more streamlined and consistent pathway to meet both domestic and global reporting expectations. The table below set out details of the climate-focussed approach.

Dates (week commencing)	Key activity	Output	TAC meeting checkpoint
23 June	Project initiation: Review approach and budgeting considerations	Proposed project management plan	8 July
30 June	Project initiation: Work allocation and determining milestones	Final project management plan	16 September
30 June	Project delivery: Technical review (across nine standards) of:	Draft technical summary of review findings	16 September
	- Greenhouse gas emissions (GHG)
	- Climate-related risks (e.g., methane)
	- Alignment with IFRS S1 and IFRS S2
	- Transition planning
	- Energy management
	- Water management (e.g water stress)
7 July	Project delivery: Review of consequential updates to IFRS S2	Draft technical summary of review findings	16 September
7 July – 25 August	Project delivery: One-to-one interviews: investors, utilities, oil majors, select TPT members (x3 each)	Feedback log and summary of themes	16 September
7 July – 25 August	Project delivery: Roundtable 1: Extractives sectors	Feedback log and summary of themes	16 September
7 July – 25 August	Project delivery: Roundtable 2: Food processing	Feedback log and summary of themes	16 September
25 August – 1 September	Project delivery: Drafting comment letter on SASB amendments	Draft comment letter	16 September
25 August – 1 September	Project delivery: Drafting comment letter IFRS S2 consequential amendments	Draft comment letter	16 September
22 September – 20 October	Project delivery: Engagement with other national and international bodies	Input summaries from joint calls	14 October
With public consultation: 15 September	Project delivery: Make consequential amendments to draft comment letters after TAC discussion on 16 September	Draft comment letter (final)	N/A
22 September – 20 October	Project delivery: Consultation on draft comment letter – 30 days running 22 September to 22 October	Update – preliminary analysis of emerging themes	14 October
20 October – 27 October	Project delivery: Stakeholder feedback summary	Stakeholder feedback summary	11 November
20 October – 27 October	Project delivery: Drafting final comment letter on SASB amendments	Final comment letter	11 November
20 October – 27 October	Project delivery: Drafting final comment letter on IFRS S2 consequential amendments	Final comment letter	11 November
3 November – 10 November	Project delivery: TAC review of final comment letters	Final comment letter	11 November
10 November – 17 November	Project delivery: Final amendments to comment letters	Final comment letter	N/A
24 November	Project delivery: Submission of comment letters	Final comment letter	N/A
24 November – 8 December	Project closure: Due process summary prepared and approved	Due process summary	9 December

Appendix 2 – Hybrid approach (climate-focussed plus 2 key topics – biodiversity and human capital)

Dates (week commencing)	Key activity	Output	TAC meeting checkpoint
23 June	Project initiation: Review approach and budgeting considerations	Proposed project management plan	8 July
30 June	Project initiation: Work allocation and determining milestones	Final project management plan	16 September
30 June	Project delivery: Technical review of climate themes – across nine standards:	Draft technical summary of review findings	16 September
	- Greenhouse gas emissions (GHG)
	- Energy management
	- Water management
7 July	Project delivery: Review of consequential updates to IFRS S2	Draft technical summary of review findings	16 September
7 July	Project delivery: Technical review of biodiversity (across nine standards):	Draft technical summary of review findings	16 September
	- Ecological metrics
	- BEES impact
7 July	Project delivery: Technical review of Human capital (across nine standards)	Draft technical summary of review findings	16 September
	- Health and safety
	- Labor practices
7 July	Project delivery: Interoperability	Draft technical summary of review findings	16 September
7 July – 25 August	Project delivery: One-to-one interviews: investors, utilities, oil majors, select TPT members (x3 each)	Feedback log and summary of themes	16 September
7 July – 25 August	Project delivery: Roundtable 1: Extractives sectors.	Feedback log and summary of themes	16 September
7 July – 25 August	Project delivery: Roundtable 2: Food processing	Feedback log and summary of themes	16 September
7 July – 29 September	Project delivery: Engagement with other national and international bodies	Input summaries from joint calls	14 October
25 August – 1 September	Project delivery: Drafting comment letter on SASB amendments	Draft comment letter	16 September
25 August – 1 September	Project delivery: Drafting comment letter IFRS S2 consequential amendments	Draft comment letter	16 September
15 September	Project delivery: Make consequential amendments to draft comment letters after TAC discussion on 16 September	Draft comment letter (final)	N/A
22 September – 20 October	Project delivery: Consultation on draft comment letter – 30 days running 22 September to 22 October	Update - preliminary analysis of emerging themes	14 October
20 October – 27 October	Project delivery: Stakeholder feedback summary	Stakeholder feedback summary	11 November
20 October – 27 October	Project delivery: Drafting final comment letter on SASB amendments	Final comment letter	11 November
20 October – 27 October	Project delivery: Drafting final comment letter on IFRS S2 consequential amendments	Final comment letter	11 November
3 November – 10 November	Project delivery: TAC review of final comment letter	Final comment letter	11 November
10 November – 17 November	Project delivery: Final amendments to comment letter	Final comment letter	N/A
24 November	Project delivery: Submission of comment letter	Final comment letter	N/A
24 November – 8 December	Project closure: Due process summary prepared and approved	Due process summary	9 December

Appendix 3 – Full standards review approach

Dates (week commencing)	Key activity	Output	TAC meeting checkpoint
23 June	Project initiation: Review approach and budgeting considerations	Proposed project management plan	8 July
30 June	Project initiation: Work allocation and determining milestones	Final project management plan	16 September
30 June – 7 July	Project delivery: Technical review of the following themes across all standards:	Draft technical summary of review findings	16 September
	- Greenhouse gas emissions (GHG)
	- Energy management
	- Water management
	- Workforce and safety
	- Labor practices
7 July	Project delivery: Review of consequential updates to IFRS S2	Draft technical summary of review findings	16 September
7 July	Project delivery: Interoperability review	Draft technical summary of review findings	16 September
7 July – 25 August	Project delivery: One-to-one interviews: investors, utilities, oil majors, select TPT members (x3 each)	Feedback log and summary of themes	16 September
7 July – 25 August	Project delivery: Roundtable 1: Extractives sectors	Feedback log and summary of themes	16 September
7 July – 25 August	Project delivery: Roundtable 2: Food processing	Feedback log and summary of themes	16 September
7 July – 29 September	Project delivery: Engagement with other national and international bodies	Input summaries from joint calls	14 October
25 August – 1 September	Project delivery: Drafting draft comment letter on SASB amendments	Draft comment letter	16 September
25 August – 1 September	Project delivery: Drafting draft comment letter IFRS S2 consequential amendments	Draft comment letter	16 September
15 September	Project delivery: Make consequential amendments to draft comment letters after TAC discussion on 16 September	Draft comment letter (final)	N/A
22 September – 20 October	Project delivery: Consultation on draft comment letter – 30 days running 22 September to 22 October	Update - preliminary analysis of emerging themes	14 October
20 October – 27 October	Project delivery: Stakeholder feedback summary	Stakeholder feedback summary	11 November
20 October – 27 October	Project delivery: Drafting final comment letter on SASB amendments	Final comment letter	11 November
20 October – 27 October	Project delivery: Drafting final comment letter on IFRS S2 consequential amendments	Final comment letter	11 November
3 November – 10 November	Project delivery: TAC review of final comment letter	Final comment letter	11 November
10 November – 17 November	Project delivery: Final amendments to comment letter	Final comment letter	N/A
24 November	Project delivery: Submission of comment letter	Final comment letter	N/A
24 November – 8 December	Project closure: Due process summary prepared and approved	Due process summary	9 December

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1. This approach is the least resource intensive to execute when compared to the other approaches. ↩

2. This approach is moderately resource intensive to execute. ↩

3. This approach is the most resource intensive to execute and estimated to be beyond the available capacity of the TAC Secretariat. ↩

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