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TAC Public Meeting September 2025 Paper 2: TAC Update September 2025
Executive summary
| Date | 16 September 2025 |
|---|---|
| Paper reference | TAC-Update-Sept-2025 |
| Project | Monitoring |
| Topic | Aug and Sept 2025 General Reporting Update |
Objective of the paper
This paper provides key updates since the update paper published for the July 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 31 August 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.
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.
This publication contains copyright material of the IFRS Foundation® (Foundation). All rights reserved. Reproduced and distributed by the Financial Reporting Council (FRC) in its role as the secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC) with the permission of the Foundation. No rights granted to third parties without permission of the Foundation and the TAC. For more information about the Foundation and the rights to use its materials please visit www.ifrs.org.
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.
UK developments
3The following paragraphs provides a summary of updates from the UK in relation to sustainability-related reporting since the last update paper published for the July 2025 TAC meeting.
4Following the UK Government's consultations published on 25 June 2025, including the draft UK Sustainability Reporting Standards (UK SRS), the Financial Conduct Authority (FCA) published an update of its intention to consult later in 2025 on how listed companies will adopt UK SRS, promoting international alignment and the growth of the UK as a centre for sustainable finance. This would include the FCA's proposed approach to the disclosure of transition plans. The FCA also indicated that it will begin work to streamline and enhance the sustainability reporting framework for asset managers and FCA-regulated asset owners.
5On 15 July 2025, the UK Government published its Green Taxonomy consultation responses, announcing that it will no longer pursue a UK Green Taxonomy. It will instead focus on progressing work on UK Sustainability Reporting Standards (UK SRS), transition plans and assurance oversight.
6In July 2025, HM Treasury issued a thematic review of sustainability reporting in central government annual reports and accounts, focusing on the disclosures' effectiveness, usability, relevance and compliance with the Treasury's guidance. It found variation in reporting quality and scope, and support for simplified mandatory reporting, more consistent requirements and alignment with international standards.
7On 31 July 2025, the consultation on adopting ISSA (UK) 5000 standard - General Requirements for Sustainability Assurance Engagement in the UK closed. The FRC proposes issuing a UK version of the International Auditing and Assurance Standard Board (IAASB)'s ISSA 5000, for use on a voluntary basis by UK assurance providers.
8On 15 July 2025, Deloitte published its Corporate Reporting Insights 2025 Climate-Related Reporting survey of FTSE 100 companies' annual reports. The results showed that:
9On 28 August 2025, Deloitte published its latest analysis of FTSE 100 sustainability disclosures restatements. It found that nearly half of companies (46 out of 100) restated their metrics for the second consecutive year, with 77% of the restatements related to greenhouse gas emissions highlighting persistent reporting challenges but also improvements in data quality and scope.
- 63% of companies referred to the forthcoming UK Sustainability Reporting Standards or ISSB Standards, though only 7% explicitly said ISSB Standards influenced their disclosures;
- All companies assigned board-level oversight of climate or sustainability matters, and each conducted scenario analysis, with between two and nine scenarios used;
- Almost half (47%) disclosed identifiable transition plans to a low-carbon economy, while 43% provided only partial information;
- In terms of financial effects, 77% addressed climate issues, mainly qualitatively and every company disclosed at least one climate target covering Scope 1 and 2, with 80% also setting Scope 3 targets; and
- Nearly all (97%) reported Scope 3 emissions metrics, though 77% cited challenges in obtaining reliable Scope 3 emissions data, and 90% reported some form of external assurance over their sustainability metrics.
International Sustainability Standards Board developments
10The following paragraphs provide a summary of updates from the International Sustainability Standards Board since the last update paper published for the July 2025 TAC meeting.
11On 2 July 2025 the IFRS Foundation published a summary note of its annual Conference held on 23–24 June 2025, attended by over 500 delegates from 69 jurisdictions under the theme ‘Knowledge in Practice'. The programme featured investor panels, a joint IASB-ISSB update on improving connectivity between financial and sustainability reporting and workshops on transition plan disclosures, and interoperability between ISSB Standards and European Sustainability Reporting Standards. Across plenaries and workshops, the event emphasised real-world application, the need for reliable, comparable sustainability disclosures, and practical examples of linking financial statements with sustainability information.
12On 10 July 2025, the IFRS Foundation published educational material to help companies understand the role of the ISSB industry-based guidance, which collectively refers to the SASB Standards and the Industry-based Guidance on Implementing IFRS S2, when applying IFRS Sustainability Disclosure Standards. The educational material explains:
- requirements in ISSB Standards that companies ‘shall refer to and consider the applicability of the ISSB industry-based guidance;
- considerations related to applying the ISSB industry-based guidance; and
- disclosure requirements about how an entity has used the ISSB industry-based guidance.
13On 23–24 July 2025, the ISSB held its monthly meeting to review its work plan and active projects. The Board agreed to commence its next agenda consultation in late 2026, with a request for information to follow in 2027, aligned with the IASB's process. It also received updates on research into Biodiversity, Ecosystems and Ecosystem Services (BEES), with discussion on the relevance of Taskforce on Nature-related Financial Disclosures recommendations and interoperability with SASB Standards and Global Reporting Initiative (GRI) Standards, and on the human capital project, which is focusing on the organisation of disclosure concepts. In addition, the ISSB considered initial feedback on its Exposure Draft of amendments to IFRS S2 greenhouse gas disclosures, which proposed targeted changes to address application challenges, but made no decisions. Next steps include continuing discussions on biodiversity and human capital and beginning redeliberation on the greenhouse gas disclosures targeted amendments following further analysis of stakeholder feedback.
14On 24 July 2025, the IFRS Foundation published near-final illustrative examples showing how companies can enhance reporting of uncertainties in financial statements, using climate-related fact patterns as practical cases. Developed by the IASB in collaboration with the ISSB, the examples are intended to address stakeholder concerns about insufficient and inconsistent disclosure of uncertainties and are designed to support timely and consistent application alongside ISSB sustainability disclosure requirements.
15On 18 August 2025, the ISSB published educational material on disclosure of anticipated financial effects under its IFRS Sustainability Disclosure Standards. The piece emphasises the importance of linking sustainability-related risks and opportunities to an entity's financial position, performance and cash flows, covering both current and future periods. Drawing on the Taskforce on Climate-related Financial Disclosures framework, the ISSB clarified that such disclosures are intended to complement information in the financial statements and provide investors with a clearer understanding of the financial implications of sustainability issues.
Jurisdictional developments
16The following paragraphs provide a summary of updates from other jurisdictions in relation to sustainability-related reporting since the last update paper published for the July 2025 TAC meeting.
European Union
17On 24 July 2025, the European Financial Reporting Advisory Group (EFRAG) released its State of Play 2025 report on the first wave of European Sustainability Reporting Standards (ESRS) disclosures, reviewing 656 statements. It found significant variation in report length and style, uneven adoption across topical standards, strong on climate, workforce and business conduct, but weak on biodiversity and community issues. Stakeholder engagement disclosures were found to be largely limited to business partners. The findings will inform EFRAG's ongoing simplification of the ESRS.
18On 31 July 2025, EFRAG released revised ESRS exposure drafts and opened a 60-day public consultation to simplify the Corporate Sustainability Reporting Directive (CSRD) reporting while preserving the Green Deal objectives. The package shaped by the European Commission's (EC) ‘Omnibus' mandate and stakeholder input cuts mandatory datapoints by 57% (full set of disclosures, mandatory plus voluntary by 68%) and shortens the standards by over 55%. Key levers include a simplified double-materiality assessment, streamlined and more readable statements, removal of overlaps, clearer language, new burden-reduction reliefs (e.g., undue cost/effort), and enhanced interoperability with IFRS Sustainability Disclosure Standards. The consultation period runs until 29 September 2025, with EFRAG's technical advice due by end-November 2025.
19While the EFRAG's revisions to ESRS aim to both simplify and enhance interoperability, EFRAG itself has acknowledged the inherent tension between the two objectives. In the Basis for Conclusions (BC) of Draft Amended ESRS – page 4 paragraph 11(6) it notes the need to ‘identify cases where interoperability significantly hinders the simplification exercise' and consider the possibility for ISSB to simplify IFRS S1 and IFRS S2. It further notes in the BC paragraphs 89-100 that certain simplification measures ‘negatively affect the level of interoperability'.
20In the 'final thoughts section' of its published article on anticipated financial effects, the ISSB emphasised that 'interoperability between ISSB Standards and ESRS remains a high priority,' while cautioning that excessive simplification, particularly of quantitative information about disclosures on anticipated financial effects could weaken interoperability.
Indonesia
21On 11 August 2025, the Institute of Indonesia Chartered Accountants launched two final ISSB-aligned Indonesia Sustainability Disclosure Standards (SPK 1 and 2), which will come into effect on 1 January 2027. This comes, following a four-month public consultation earlier this year.
22The regulatory framework to implement SPK 1 and SPK 2, which will specify the scope of the requirements and sustainability assurance provisions will be determined by the Indonesia Financial Services Authority in collaboration with the government-led Sustainable Finance Committee.
Nepal
23On 17 July 2025, the Accounting Standards Board of Nepal launched a public consultation on the draft Nepal Sustainability Reporting Standards, aligning with IFRS S1 and IFRS S2. The comment period to receive feedback from stakeholders across government, industry and the reporting ecosystem closed on 16 August 2025.
24The draft outlines a phased approach to implementation, addressing challenges such as data collection, awareness, and technological capacity. Relief measures are included for first-time adopters, including temporary exemptions from Scope 3 emissions and comparative disclosures.
Philippines
25On 8 August 2025, the Philippine Financial Reporting Standards Council (FRSC) began a public consultation, regarding their local versions of the ISSB's IFRS S1 and IFRS S2 standards, signalling a significant move toward adopting global sustainability disclosure requirements. The FRSC's consultation seeks public input on implementing these local sustainability standards, which are based on the ISSB standards and are set to apply to publicly listed companies and large non-listed entities in the Philippines.
Singapore
26On 25 August 2025, the Accounting and Corporate Regulatory Authority (ACRA) and Singapore Exchange Regulation (SGX RegCo) granted a substantial extension of up to five years for most climate-related reporting obligations aligned with the International Sustainability Standards Board (ISSB), applying primarily to smaller listed companies outside the Straits Times Index (STI) and those with market capitalisations under S$1 billion, which are now required to comply starting FY 2030, while larger non-STI firms will begin in FY 2028. Meanwhile, STI-listed companies would continue to report ISSB-aligned disclosures, including Scope 1 and 2 emissions from FY 2025 and Scope 3 (voluntary for others) from FY 2026, though external assurance for Scope 1 and 2 emissions has been delayed until FY 2029 across all issuers, and a parallel three-year deferment applies to large non-listed companies. This revised phasing aims to balance readiness and capability-building across different market segments.
Switzerland
27At the end of June 2025, the Swiss Federal Council paused the revision of its ordinance on corporate climate disclosures. While broadly supported in consultation, the proposals are being reassessed to explore more pragmatic amendments and to await clarity on EU sustainability reporting developments. The decision reflects both alignment with the evolving ESRS framework and responsiveness to company concerns.
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.
Table 1: G20 jurisdictions (countries and regional bodies) summary as at 31 August 2025.
| 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 | Endorsed and published roadmap | Both | 2025-2027 | Banks |
| African Union: Morocco | Publicly committed | - | - | - |
| African Union: Nigeria | Endorsed and published roadmap | Both | 2028-2030 | Listed & unlisted |
| African Union: Rwanda | Consultation closed Roadmap published | 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 | 2026 | Listed |
| Canada | Endorsed | Both | 2025 | To be confirmed (currently voluntary) |
| China | Consultation on Climate ED closed | Both (but uses a double materiality approach) | 2026-2030 | Listed & unlisted |
| India | Consultation closed | IFRS S2 only | 2025-2029 | Banking & finance |
| Indonesia | Consultation closed | 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.
Table 2: Other jurisdictions summary as at 31 August 2025.
| 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 | 2026 | Listed |
| Qatar | Consultation closed | Both | 2026 | Listed |
| Singapore | Endorsed | IFRS S2 only | 2025-2027 | Listed |
| Sri Lanka | Endorsed | Both | 2025 | To be confirmed |
| Switzerland | Consultation closed - amending the Ordinance on Climate Disclosures | Both | 2026 | Listed & unlisted |
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.
Table 3: G20 jurisdictions (countries and regional bodies) not publicly committed to adopting ISSB as at 31 August 2025.
| 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 | California Corporate Climate Accountability Act (SB 253 and SB 261) - adopted | New York Climate Corporate Data Accountability Act (SB 3456) - bill Colorado Corporate Climate Accountability Act (House Bill 25-119) - bill | California: 2026 New York: 2027 – 2028 Colorado: 2028 – 2031 | California: Listed & unlisted New York: Listed & unlisted Colorado: Listed & unlisted |
| Taiwan | Endorsed | Both | 2026-2028 | Listed |
| Thailand | Endorsed | Both | 2026-2030 | Listed |
- 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. Note that this is subject to change as EFRAG finalises amendments to its standards arising from the simplification project.