The content on this page has been converted from PDF to HTML format using an artificial intelligence (AI) tool as part of our ongoing efforts to improve accessibility and usability of our publications. Note:
- No human verification has been conducted of the converted content.
- While we strive for accuracy errors or omissions may exist.
- This content is provided for informational purposes only and should not be relied upon as a definitive or authoritative source.
- For the official and verified version of the publication, refer to the original PDF document.
If you identify any inaccuracies or have concerns about the content, please contact us at [email protected].
TAC Public Meeting September 2025 Paper 3: Final project management plan and assessment approach
AGENDA PAPER 3
Executive summary
| Header | Value |
|---|---|
| Date | 16 September 2025 |
| Paper reference | 2025-TAC-040 |
| Project | Proposed amendments to SASB Standards |
| Topic | Final project management plan and assessment approach |
Objective of the paper
This paper presents the finalised project management plan 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 the final project management plan and assessment approach.
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). It does not represent the views of the TAC or any individual TAC member.
Context
SASB Standards enhancement project
1The SASB Standards were initially published in 2018. The International Sustainability Standards Board (ISSB) assumed responsibility for the SASB Standards in 2022 when the Value Reporting Foundation, which previously maintained them, was consolidated into the IFRS Foundation.
2On 3 July 2025, the ISSB published two exposure drafts, proposing amendments to the SASB Standards, and proposing consequential amendments to the Industry-based Guidance on Implementing IFRS S2. A Basis for Conclusions was also published. This is phase one of the ISSB's project to enhance the SASB Standards, focused on nine priority Standards with targeted amendments to another 41 Standards.
3The objective of the ISSB's SASB enhancement project, explored further in Paper 2025-TAC-041, is to support the implementation of IFRS S1 and IFRS S2. This will be achieved by enhancements to the SASB Standards with the following areas of focus:
- enhancing international applicability;
- improving interoperability with other sustainability-related standards and frameworks;
- amendments related to biodiversity, ecosystems and ecosystem services (BEES) and human capital; and
- alignment with IFRS Sustainability Disclosure Standards.1
4The SASB enhancement plan involves 12 priority industries that were selected due to their sustainability significance and international usage. Of the 12 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 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
5Amendments 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.
6In 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 emissions
- Energy management
- Water management
- Labour practices
- Workforce health and safety
Role of the TAC in the SASB Standards enhancement project
7In 2024, the UK Sustainability Disclosure Technical Advisory Committee (‘TAC’) 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 the long-term public good.
8Paragraphs 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.
9In 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 so 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.
10Although the TAC has not yet assessed the extent of SASB Standards' use across the UK, it is aware that some UK-based multinational companies apply them voluntarily. As such, the ISSB's project to enhance the SASB Standards is directly relevant to the current reporting landscape in the UK. It has implications for entities currently referencing the standards and is also important in the context of the ISSB's longer-term integration plans, which may potentially incorporate the content from the SASB Standards into its own IFRS Sustainability Disclosure Standards. Further, under IFRS S2 (Paragraphs 28(b) and 32), which the UK intends to adopt under UK SRS S1, companies are required to report industry-based disclosures and the SASB Standards would offer support in addressing this requirement.
11The TAC 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.
12The 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.
13Building on the TAC discussions at the July 2025 meeting, this paper presents a project management plan to guide the TAC's review and response to the SASB Standards amendments Exposure Draft and IFRS S2 industry-based guidance amendments Exposure Draft.
14The project management plan spans 20 weeks, structured into three phases: project initiation, project delivery, and project closure. It includes estimated resource requirements, stakeholder engagement strategies, and risk mitigation approaches.
Project overview
15In 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.
16The TAC will follow its Due Process Policy, and a Due Process Summary will be provided at project closure.
17Considering the scope and complexity of the proposed Exposure Drafts, the Secretariat considered various approaches to the project and presented three for consideration to the TAC at the July 2025 meeting (Paper 2025-TAC-038). The TAC recognised the need to adopt a proportionate approach given the voluntary nature of the SASB Standards and the quantity of information covered by the Exposure Drafts. It was agreed that a principles-based approach would be most appropriate, and beneficial in influencing the ISSB's approach to enhancing further SASB Standards.
18The adopted approach would follow the Hybrid Approach presented in Paper 2025-TAC-038, considering climate-related amendments and further targeting key themes aligned with UK and global sustainability reporting agendas. Regarding scope, the TAC agreed that it was important to the UK market to review all nine of the priority industries, on a principles-focused basis.
19The TAC's process for preparing the comment letters will include the following stages:
| Project stage | Description | Due Process Policy | Indicative timeline |
|---|---|---|---|
| Project initiation: present potential project management plan and assessment approach | - Paper 2025-TAC-038, presented for July 2025 TAC meeting, containing three proposed approaches | Due Process Policy Paragraphs 29–30 | Published 1 July |
| Project initiation: discuss project management plan and assessment approach | - TAC discussion on Paper 2025-TAC-038 in July 2025 TAC meeting | Due Process Policy Paragraphs 29–30 | 8 June TAC meeting |
| Project initiation: present finalised project management plan and assessment approach | - This paper, presented for September 2025 TAC meeting | Due Process Policy Paragraphs 29–30 | Published 9 September |
| Project initiation: approve project management plan and assessment approach | - TAC discussion on this paper in September 2025 TAC meeting | Due Process Policy Paragraphs 29–30 | 16 September TAC meeting |
| Project delivery: Initial technical assessment | - Papers 2025-TAC-041 and 2025-TAC-042 and 2025-TAC-043 (Agenda Papers 4, 5 and 6), prepared by the Secretariat and presented for September 2025 TAC meeting - Secretariat assessment of the ISSB’s proposed amendments to the SASB Standards including: the objectives of the amendments, over-arching themes, and industry-level analysis of the nine priority industries |
Due Process Policy Paragraph 31 | Published 9 September |
| Project delivery: discussion of initial technical assessment | - TAC discussion on Papers 2025-TAC-041 and 2025-TAC-042 and 2025-TAC-043 (Agenda Papers 4, 5 and 6), in September 2025 TAC meeting | Due Process Policy Paragraph 31 | 16 September TAC meeting |
| Project delivery: Stakeholder outreach and analysis | - Carried out by the Secretariat - Launch public survey on amendments - Identify key stakeholders and engage via interviews and roundtables - Conduct desk-based research analysis on reporting by UK companies currently using SASB standards |
Due Process Policy Paragraph 31 | To be completed by end of September |
| Project delivery: Prepare analysis of stakeholder engagement findings for the TAC | - Prepared by the Secretariat - Analysis presented for October 2025 TAC meeting |
Due Process Policy Paragraph 31 | Published 7 October |
| Project delivery: technical analysis (climate-related thematic review) | - Paper to be prepared by the Secretariat analysing amendments to climate-related disclosure topics, to the nine priority industries, targeted amendments to further standards, and the consequential amendments to IFRS S2 guidance | Due Process Policy Paragraph 31 | Published 7 October |
| Project delivery: Prepare draft comment letters | - Prepared by the Secretariat - Drafts presented for October 2025 TAC meeting |
Due Process Policy Paragraph 31 | Published 7 October |
| Project delivery: discussion of findings of stakeholder engagement | - TAC discussion on Secretariat’s analysis in October 2025 meeting | Due Process Policy Paragraph 31 | 14 October TAC meeting |
| Project delivery: discussion of technical analysis (IFRS S2 guidance) | - TAC discussion on Secretariat’s analysis in October 2025 meeting | Due Process Policy Paragraph 31 | 14 October TAC meeting |
| Project delivery: discussion of draft comment letters | - TAC discussion of draft comment letters prepared by Secretariat in October 2025 meeting | Due Process Policy Paragraph 31 | 14 October TAC meeting |
| Project delivery: re-drafting of comment letters | - Secretariat incorporates TAC discussions on the initial drafts and stakeholder engagement findings in to comment letter drafts | Due Process Policy Paragraph 31 | Published 4 November |
| Project closure: draft due process summary | - Prepared by the Secretariat - Drafts presented at November TAC meeting |
Due Process Policy Paragraphs 37–40 | Published 4 November |
| Project delivery: approval of comment letters | - TAC discusses and approves the re-drafted comment letters in November TAC meeting | Due Process Policy Paragraph 31 | 11 November TAC meeting |
| Project closure: review due process summary | - TAC discusses draft due process summary | Due Process Policy Paragraphs 37–40 | 11 November TAC meeting |
| Project delivery: TAC submits comment letters | - Subject to any edits agreed in the November TAC meeting, the TAC Secretariat will submit the approved comment letters to the ISSB | Due Process Policy Paragraph 31 | By 28 November |
| Project closure | - TAC Secretariat will publish the letters on the FRC website - Due Process summary approved by the TAC in December 2025 meeting - Summary published on the FRC website |
Due Process Policy Paragraphs 37–40 | Draft published 2 December Approved 9 December TAC meeting |
20As shown in the above table, the analysis presented to the TAC by the Secretariat will be provided across multiple papers, presented at the September and October TAC meetings. Based on the Secretariat’s current work programme, this will include:
- A summary and analysis of the objectives behind the proposed amendments, presented at the September 2025 TAC meeting.
- An analysis of overarching themes impacting the SASB enhancement project, to allow the TAC to review the ISSB’s underlying principles and methodology, presented at the September 2025 TAC meeting.
- An industry-level analysis of the proposed amendments to the nine priority industry standards, presented at the September 2025 TAC meeting.
- A focused analysis of the proposed amendments to the climate-related disclosure topics, which impact targeted amendments to further Standards and the Industry-based Guidance on Implementing IFRS S2 as well as the nine priority industries, presented at the October 2025 TAC meeting.
- A summary and analysis of stakeholder feedback on the Exposure Drafts, alongside current UK reporting practices using the SASB Standards, to be presented at the October 2025 TAC meeting.
21It should be noted that the papers for the September TAC meeting will reflect the Secretariat’s work completed to date. They may not represent a final position, as further review of the Exposure Drafts, additional research, and continued stakeholder engagement may highlight further issues for consideration.
Assessment approach
22This 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, as published on 3 July 2025.
23As described in its 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 on the grounds of supporting long-term public good in the UK.
24The following paragraphs set out a proposed assessment approach for the Exposure Drafts, to be applied in the drafting and finalisation of the comment letters in order to achieve the TAC’s purpose.
25The assessment criteria in the TAC’s Terms of Reference are required to be applied when responding to commissions for endorsement advice from DBT, and were considered by the TAC to not be directly applicable to this project as it is a consultation response rather than an endorsement process. As such, a new set of criteria have been developed, focused on facilitating a principles-based analysis. The TAC will assess whether the proposed amendments are conducive to the long-term public good in the UK by:
- identifying the objective behind the proposed amendments;
- assessing whether the objective would support improvement in the quality of corporate reporting within the UK in the long-term;
- assessing whether the amendments successfully support the identified objective; and
- to the extent necessary, identifying any gaps in the amendments against the stated objectives, primarily through stakeholder engagement.
26The 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.
27The 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
28When developing the project management plan, the Secretariat has taken into consideration the following assumptions and constraints:
- The capacity of the TAC, including 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 capacity of the TAC Secretariat. The Secretariat will be expected to write papers for public TAC meetings in addition to conducting research and stakeholder engagement to inform the final comment letters.
- The expected available resources are 1.8 FTE project directors, 1 FTE associate, and oversight from the Head of the Secretariat.
- The capacity of stakeholders to engage with interviews and roundtables. The period of time available for stakeholder engagement is likely to fall during the summer months, when there may be decreased availability for engagement. Interested stakeholders are also likely to be busy responding to other government consultations relating to sustainability reporting.
- This is the first time that the TAC and Secretariat will be engaging with the SASB Standards in depth. Apart from the industry-based guidance accompanying IFRS S2, the SASB Standards content has not formed part of previous detailed technical papers. Therefore, significant time may need to be invested to become familiar with the material, which is extensive and covers specialised industries in detail.
Project management plans and target timeline
29The ISSB agreed a 150-day comment period, and the working deadline is 28 November, as the last working day before the official deadline (30 November). Therefore the TAC will need to approve the comment letters at its November meeting, currently scheduled for 11 November 2025.
30The following paragraphs detail the sequence 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 in accordance with appropriate due process.
31While 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. However, this is expected to be limited given the absence of public deliberations during the development of the Exposure Draft;
- 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
- to the extent necessary, evaluation of interoperability with other frameworks such as the EU ESRS, GRI, TNFD, and others as appropriate.
32Considering the volume of work and resource capacity, the project does not include conducting a public consultation in the UK on a draft comment letter. This also ensures the assessment is proportionate, given the voluntary nature of the SASB Standards.
33Instead, the Secretariat will carry out other forms of stakeholder engagement, including a survey which has been designed to capture some of the key questions that would otherwise have been included in a public consultation. The survey will be publicly promoted, and any interested stakeholders will be able to submit their opinions.
34The timelines presented below takes 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.
Project Timeline: September 2025 - December 2025
This diagram illustrates the project timeline with key public meetings, deadlines, and project phases.
Key Meetings & Deadlines: * Public meeting: 8 July (Project initiation: proposed project management approaches) * Public meeting: 16 September (Project initiation: finalise project management plan; Project delivery: initial technical analysis) * Public meeting: 14 October (Project delivery: stakeholder engagement feedback & first draft comment letters) * Public meeting: 11 November (Project delivery: approve comment letters) * Deadline for comments letters: 28 November * Public meeting: 9 December (Project closure)
Phases: * Technical analysis spans from July 2025 to September 2025. * Stakeholder engagement spans from August 2025 to October 2025. * Preparing comment letters spans from September 2025 to November 2025.
Next steps
35Once the project management plan and assessment approach have been approved by the TAC, the Secretariat will continue 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
- Does the TAC have any comments on the proposed assessment approach?
- Does the TAC approve the finalised project management plan?
-
Paragraph IN6 of the Exposure Draft ↩