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TAC Public Meeting September 2025: Meeting Summary
PUBLIC MEETING SUMMARY
Date: 16 September 2025
Time: 10:30am – 2:45pm
Location: Financial Reporting Council, 13th Floor, 1 Harbour Exchange Square, London, E14 9GE
Attendance
| Name | Designation |
|---|---|
| Sally Duckworth | Chair |
| Craig Mackenzie | Member (Present for agenda items 1-5; partly present for agenda item 6) |
| David Harris | Member |
| Dia Desai | Member (online) |
| Hilary Eastman | Member |
| Jeremy Osborn | Member (online 10:30am-11:15am and 1:45pm-2:45pm) |
| Madeleine Evans | Member |
| Nick Rowbottom | Member |
| Peter Hogarth | Member |
| Scott Barlow | Member |
| Supriya Sobti | Member |
| Jenny Carter | Member appointed by the Financial Reporting Council (FRC) |
| Paul Lee | Member appointed by the UK Endorsement Board (UKEB) |
| Michael Ashby | Observer from the Department for Business and Trade (DBT) (online) |
| Laura Kennedy | Observer from the Bank of England (BoE) (online) |
| Matilda Robinson | Observer from the Financial Conduct Authority (FCA) |
| Sarah-Jayne Dominic | Secretariat |
Apologies
| Name | Designation |
|---|---|
| Harriet Cullum | Member |
1 Welcome and apologies
The Chair welcomed all attendees to the September meeting of the UK Sustainability Disclosure Technical Advisory Committee (TAC). Apologies were received from Harriet Cullum.
No conflicts of interest relating to the agenda were declared.
2 General reporting update
The following points were noted from the general update paper:
- that some jurisdictions which had previously moved quickly to adopt sustainability-related reporting are now slowing their pace.
- that a similar slowdown was also being observed in the UK, where the Financial Conduct Authority (FCA) has pushed back its consultation on amending the Listing Rules for use of UK Sustainability Reporting Standards (UK SRS) from Q3 2025 to end of year. As a result, it is unlikely that the FCA will mandate reporting under the UK SRS for listed companies for 2026 reporting periods.
3 Project management plan on ISSB consultations
The final project management plan was noted, and the following were discussed and agreed:
- That due to time constraints it was suggested that the Secretariat present bullet-pointed proposals summarising the intended content of the response letters. This approach would allow members to focus on substance without the need to review fully drafted text which could change resulting in inefficiencies.
- That such bullet points be sufficiently detailed to clearly convey the messages intended for inclusion in the eventual response letters to the ISSB.
- A question was raised about the timing of the three additional priority standards (Agricultural Products, Meat, Poultry & Dairy; and Electric Utilities – phase two exposure Draft) that the ISSB intends to publish by the end of the year, and the risks of overlap with the ongoing consultation on the nine priority standards. It was agreed that this will be followed up with the ISSB to understand the proposed timing considering the ongoing consultation.
- On stakeholder engagement, the Secretariat confirmed that outreach had targeted preparers in the nine priority industries, investor groups, industry associations, and other interested parties. However, given the number of concurrent consultations (UK government consultations and EFRAG's), stakeholders' engagement with the SASB Standard enhancements Exposure
4 Review of SASB Exposure Draft objectives and focus areas
Draft has been limited. The Secretariat indicated it may reflect this limitation in the draft response.
- It also noted that the release of further ISSB phase two Exposure Draft may coincide with the UK SRS endorsement process. Hence the need to factor this into the TAC's upcoming TAC activities.
The TAC considered Agenda Paper 4 on the objective and focus areas of the ISSB's project, Enhancing the SASB Standards.
The TAC strongly agreed with the overall objective of the ISSB's project to enhance the SASB Standards, which is to support the implementation of IFRS S1 and IFRS S2. However, the TAC was not convinced that the ISSB's project to enhance the SASB Standards is the best way of achieving that objective.
The TAC recommended that the ISSB develops a clear vision for its project to enhance the SASB Standards. The vision should prioritise simplification, alignment with IFRS Sustainability Disclosure Standards and the continuance of the global baseline of sustainability disclosures for capital markets established by IFRS S1 and IFRS S2. The vision should also prioritise international applicability and connectivity with IFRS Accounting Standards.
Members also noted that:
- The SASB Standards could be restructured to distinguish between core or industry-agnostic disclosures and additional industry-specific disclosures.
- The SASB Standards, in their current form, will have to keep pace with changes to fast moving sustainability issues, such as climate change, and other sustainability-related standards and frameworks.
The TAC had mixed views about the ISSB's aim of improving interoperability with other sustainability-related standards and frameworks and believes interoperability should be a secondary driver of the changes. Interoperability should focus on simplifying and supporting the navigation of the different sustainability-related standards and frameworks, rather than being additive, and should focus on complementarity, rather than convergence or alignment.
The TAC does not support the ISSB's aim of aligning the enhancements with the ISSB's research projects on BEES and human capital given the ISSB's research projects have not been completed yet.
The TAC would value greater clarity on the ISSB's future strategy and development of future topic-specific IFRS Sustainability Disclosure Standards.
5 Initial analysis – overarching themes
The TAC considered Agenda Paper 5 on overarching themes that have been identified in desk-based research concerning the ISSB's project, Enhancing the SASB Standards.
Due process
- The TAC continues to have concerns about the due process being applied in the ISSB's project to enhance the SASB Standards.
- The TAC agrees that the absence of public deliberations on the technical content during the development of the SASB Exposure Draft meant stakeholders were not as familiar with the rationale for the proposals, substantiveness of the changes and any points of contention as they would have been otherwise.
- The TAC considers public deliberations to be particularly important in relation to sensitive areas, such as human rights.
Supporting analysis
- The TAC agrees that, in the absence of a greater level of due process (and therefore transparency), the ISSB could provide a greater level of supporting analysis for the proposed amendments.
Industry classification system
- The TAC had mixed views on the Sustainable Industry Classification System (SICS).
- The TAC raised concerns about comparability across different industry classification systems and noted that there would be challenges for conglomerates or entities with complex or diverse activities.
- The TAC agreed that there should be mappings from SICS to other industry classification systems and guidance for conglomerates.
Phased approach and selection of industries
- The TAC considers a phased approach to be inevitable / unavoidable given the scope and scale of the project to enhance the SASB Standards.
- It is useful to consider changes to all standards in a sector together, as has been the case for standards for industries in the Extractives sector, but has not been the case for the standards for industries in the Food & Beverage Sector (one out of eight industry standards in this first consultation, and two to follow in the second consultation).
- The TAC encourages the ISSB to publicise and seek views on the selection of future industries.
Climate-related amendments and targeted amendments
- The TAC agrees in principle with the climate-first approach and the ISSB's proposal to amend the climate-related content in the SASB Standards.
- However, the TAC cautions against making numerous changes, particularly in relation to the other industries.
- The ISSB could amend the climate-related content first and then move onto other topics.
Effective date
- The TAC agrees that the ISSB should decide the effective date for the amendments after considering the feedback on the proposed amendments, but the TAC's initial view on the effective date for the amendments is that it should be 18 rather than 12 months.
Other comments
- The ISSB could reconsider the name of the SASB Standards.
6 Analysis of proposed amendments to the nine priority SASB Standards
The Secretariat presented a high-level overview of the proposed amendments to the nine priority standards, particularly highlighting changes in metrics at sector level. Such changes involve modifications to existing metrics, removal of metrics, additions to metrics, metrics relocated between topics, and unchanged metrics.
Extractives sector SASB Standards
The following items were discussed and agreed:
- A member questioned why certain topics appear in some standards but not others (e.g. Air Quality is not included in the Coal Operations Standard, and Waste Management is absent from most extractives sector standards despite its relevance given waste is a major by-product of extractives industries). This inconsistency was considered arbitrary, and it was suggested that the Secretariat consider raising this in the response letter to the ISSB.
- Concerns were expressed about the lack of transparency regarding the rationale for proposed changes to metrics, including additions and deletions.
- Specific concern was also raised about the proposed change in the Oil & Gas – Exploration & Production and Oil & Gas - Services Standards, where the description for ‘catastrophic and tail-end risks' has been replaced with ‘low probability, serious accidents'. Members felt the revised wording may not capture the cumulative impact of frequent incidents and could weaken the original intent. A member suggested that this point be included in the response letter to the ISSB.
- Questions were raised about the basis of materiality used to determine inclusion or exclusion of topics and metrics across industries. For example, the Labour Practices topic was noted to appear in only some industries and not in others despite all industries in the extractives sector having a workforce.
- Similarly, references to human rights and child labour were noted to have been removed or diluted. Several members stressed that the term 'human rights' is a recognised and widely understood concept, and replacing it risks altering meaning. A member suggested that the Secretariat review ISSB's human capital research papers to see if there are useful insights on its approach to human rights and other human capital amendments.
- Regarding disclosure of legal risks (paragraphs 20–47, specifically paragraph 38), it was suggested that such risks are already covered under financial reporting requirements given the shared IFRS materiality framework. Some members emphasised the need to demonstrate connectivity between sustainability and financial disclosures and did not see the need for additional disclosure if financial information for sustainability-related legal risks is captured in the financial statements.
Processed Foods SASB Standard
The following items were discussed and agreed regarding the Processed Foods SASB Standard:
- Members discussed whether to respond to the amendments to the Processed Food Standard given the piecemeal nature release of the Exposure Drafts of related standards in the Food and Beverages Sector. A member suggested waiting until the other Food and Beverage Standards are consulted on, but others warned that not responding could mean missing the opportunity to influence outcomes and would disadvantage UK companies relying on these standards. A member suggested that the Secretariat recommend in the response letter that the ISSB should not finalise the Processed Foods Standard until all Food and Beverage Standards are reviewed together.
- Some members questioned whether topics such as product labelling and marketing are genuine sustainability issues, noting their unclear relevance to investor decision-making and risk of producing boilerplate disclosures.
- Concerns were raised about the expansion of disclosure requirements without sufficient consideration of data availability or reliability, particularly for supply chain-related information, which may be difficult to assure. It was suggested that stakeholder input should be sought to better understand concerns in this area, particularly regarding supply chain management.
- Members questioned the removal of genetically modified organisms (GMO) disclosure requirements from the Processed Foods Standard, noting the cross-linkage to biodiversity. It was agreed that further clarification and rationale should be sought from the ISSB.
7 AOB
There was no other business.
The Chair thanked attendees and presenters and confirmed that the next meeting is scheduled for 14 October 2025.
The meeting ended at 14:46.