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TAC Public Meeting October 2025 Paper 4: SASB Exposure Draft Comment Letter Points

Logo for the UK Sustainability Disclosure Technical Advisory Committee.

AGENDA PAPER 4

Executive summary


Date	14 October 2025
Paper reference	2025-TAC-045
Project	Proposed amendments to SASB Standards
Topic	SASB Exposure Draft Comment Letter Points

Objective of the paper

The paper presents points discussed by the TAC to include in its response to the Exposure Draft Proposed Amendments to the SASB Standards (the SASB Exposure Draft).

Decisions for the TAC

The TAC is asked for its views on the points to include in the TAC's response to the SASB Exposure Draft and, in particular, the:

General points to include in Paragraphs 6 to 38
Answers to the questions in the SASB Exposure Draft in the appendix.

Appendices

Appendix: Answers to the questions in the SASB Exposure Draft.

This paper has been prepared by the Secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC) to discuss in a public meeting. This paper does not represent the views of the TAC or any individual TAC member.

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 ISSB's project Enhancing the SASB Standards involves enhancing the 77 industry-specific SASB Standards. In July 2025, the ISSB published the Exposure Draft Proposed Amendments to the SASB Standards (the SASB Exposure Draft). The SASB Exposure Draft sets out proposed amendments to the SASB Standards in nine of the priority industries: all eight industries in the Extractives & Minerals Processing sector and one in the Processed Foods industry. The SASB Exposure Draft also proposes targeted amendments to 41 other SASB Standards. The ISSB also published the Exposure Draft Proposed Amendments to the Industry-based Guidance on Implementing IFRS S2, which proposes making consequential amendments to the IFRS S2 industry-based guidance. The comment periods for the exposure drafts close on 30 November 2025.

2In its July 2025 meeting, the TAC agreed to adopt a proportionate approach to develop its response to the SASB Exposure Draft. In its September 2025 meeting, the TAC reviewed the objectives, focus areas and overarching themes of the ISSB's project. The TAC also considered an analysis of the proposed amendments to the nine priority SASB Standards.

3This paper develops the areas covered in the TAC's July and September meetings and presents points to include in the TAC's response to the SASB Exposure Draft for discussion in this meeting. TAC Paper 2025-TAC-043 includes points about proposed amendments to the nine priority SASB Standards which are not included in this paper as they were subject to discussions with stakeholders. If stakeholders agree with these points, these can be added to the TAC's response.

4In the accompanying TAC paper 2025-TAC-046 IFRS S2 Industry-based Guidance Consultation: Comment Letter Key Points, we present the points to include in the TAC's response to the consultation on the consequential amendments to the IFRS S2 Industry-based Guidance.

Comment letter points

5The TAC is asked for its views on the following points, which are not direct answers to the questions in the SASB Exposure Draft but are important points relating to the ISSB's project to enhance the SASB Standards. The answers to the questions in the SASB Exposure Draft are included in the appendix.

General points

6The TAC notes that UK stakeholders generally welcomed sources of guidance, including the SASB Standards and the IFRS S2 Industry-based Guidance, in helping companies identify and disclose material information about sustainability-related risks and opportunities, especially in the absence of specific IFRS Sustainability Disclosure Standards. The TAC also believes that the SASB Standards and the IFRS S2 Industry-based Guidance could play an important role in supporting the implementation of IFRS S1 and IFRS S2.

7However, the TAC has a number of concerns about the ISSB's approach to its project to enhance the SASB Standards.

As noted in paragraphs 30 to 33, the TAC is also concerned about the adequacy of its engagement with UK stakeholders during the current consultation and in the development of its response to the ISSB. The TAC is therefore not convinced it has the evidence to conclude on whether it agrees with the proposed amendments to individual SASB Standards and cautions that its response may not fully reflect the views of the UK market. However, the TAC is sharing its own views, which have been developed with reference to desk-based research and the views of the UK stakeholders it has succeeded in engaging with.

Communicating a clear vision

8The TAC recommends that the ISSB develop a clear vision for its project to enhance the SASB Standards.

9The 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. Without simplification and alignment with IFRS Sustainability Disclosure Standards IFRS S1 and IFRS S2, stakeholders could lose interest in the SASB Standards and disengage with them. Additionally, without simplification and alignment, there is a risk that the reporting could become more complex and the cost of implementation for preparers could be significant.

10The vision should also prioritise international applicability and connectivity with IFRS Accounting Standards.

11The TAC notes that the SASB Standards were developed before IFRS Sustainability Disclosure Standards. The TAC believes that industry-based guidance developed following the issue of IFRS S1 and IFRS S2 would have differed considerably from the SASB Standards and would have been simpler and better aligned with IFRS Sustainability Disclosure Standards. We comment further on alignment with IFRS Sustainability Disclosure Standards in our answer to Question 1 in the appendix.

12The TAC believes that the ISSB would ideally develop a clear vision for its project to enhance the SASB Standards first, and then consider detailed amendments to the Standards. For example, in developing its vision for the project, the ISSB could consider restructuring the SASB Standards to distinguish between core, industry-agnostic disclosures and additional, industry-specific disclosures. To bring this to life, the following are examples of each of these types of metrics:

Core disclosure: Scope 2 greenhouse gas emissions. Most reporting entities would be expected to disclose these.
Industry-agnostic disclosure: water withdrawal. This metric can be used in an identical manner for any industry that has identified risks related to water consumption.
Industry-specific disclosure: in the area of health and nutrition for food processing companies, the amount of revenue generated from healthy products. This issue relates to a select number of industries, and the metric is bespoke to these industries and cannot be measured in other industries.

Status of the SASB Standards and architecture for IFRS Sustainability Disclosure Standards

13In its 2023 response to the ISSB's Request for Information on Agenda Priorities, the FRC recommended that the ISSB considers and communicates the envisaged architecture for the full suite of standards, including information about how the industry-based materials fits into the architecture. In its March 2025 response to Exposure Draft IFRS/DPH/ED/2024: Proposed Amendments to the IFRS Foundation Due Process Handbook, the FRC also stated that it would value greater clarity from the ISSB and the IFRS Foundation on the status of, and intentions for, the SASB Standards and the incorporation of industry-based disclosure requirements into IFRS Sustainability Disclosure Standards. The TAC agrees with these points and believes that the ISSB should communicate a clear strategy for how the SASB Standards fit into the future architecture of IFRS Sustainability Disclosure Standards.

14The ISSB could also reconsider the name of the SASB Standards to better reflect their status. The July 2025 Educational Material Using ISSB Industry-based Guidance when applying ISSB Standards, for example, refers to the SASB Standards and the IFRS S2 Industry-based Guidance collectively as the 'ISSB industry-based guidance'. In a March 2025 ISSB Staff Paper (paragraphs 32 and 33), the ISSB Staff suggests that this consultation could be a good opportunity to rename the SASB Standards to clearly demonstrate the link to the ISSB Standards and also to reaffirm the status of these materials as 'guidance'. The TAC agrees with these points and recommends that the SASB Standards could be collectively renamed as the ‘ISSB Industry-based Guidance'.

Ongoing enhancement process and future updates

15As part of the vision for its project to enhance the SASB Standards, the TAC recommends the ISSB considers how the SASB Standards are updated in the future. The SASB Standards will have to keep pace with changes to fast moving and evolving sustainability issues, such as climate change, and other sustainability-related standards and frameworks.

16The ISSB may have to devise an annual update process for the SASB Standards in their current form so that they keep pace with the changes. However, constantly updating the SASB Standards and the IFRS S2 Industry-based Guidance could be extremely resource intensive for preparers in particular, but also for other stakeholders, including investors and standard-setters, as well as for the ISSB. This is likely to be particularly significant where updates to the SASB Standards result in consequential amendments to the IFRS S2 Industry-based Guidance.

17Therefore, the TAC encourages the ISSB to radically reconsider its project to enhance the SASB Standards in the light of these comments, and develop an approach to enhance the SASB Standards so that they can keep pace with changes without being overly burdensome for preparers. The TAC recommends that the ISSB adopts a principles-based, not rules-driven, approach so that the standards and guidance can adapt.

Pursuing a phased approach

18The TAC considers a phased approach to the ISSB's project to enhance the SASB Standards to be inevitable and unavoidable given the scope and scale of the project, including the number of SASB Standards and individual and unique disclosure requirements.

19If the ISSB continues to prioritise industries, the TAC notes that:

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 & Minerals Processing sector. This has not been possible for the Processed Foods SASB Standard, which is only one of nine standards for industries in the Food & Beverage sector, and two further standards for industries in the Food & Beverage sector are expected to be consulted on later this year. One of the reasons it is useful to consider changes to all standards in a sector together is because industries in a given sector often have common activities leading to common risks and opportunities and therefore disclosure requirements. It is also helpful to consider the value chain as different industries in a given sector may cover different aspects of a production process. Considering changes to all standards in a sector together means the location and disclosure of risks and opportunities can be compared for different standards. The TAC therefore encourages the ISSB to issue proposed amendments to all standards in a sector together.
it is not convinced about the rationale for the prioritisation of industries so far. The TAC therefore encourages the ISSB to publicise and seek views on the selection of future priority industries, as well as its approach to revising them.

20The ISSB could alternatively consider taking a thematic approach, by amending the climate-related content in the standards first and then moving onto the content related to other topics in the standards. In prioritising topics for the thematic approach, the ISSB could focus on the core, industry-agnostic disclosures first and then additional, industry-specific disclosures.

21The TAC recommends the ISSB evaluates the pros and cons of these two approaches (continuing to prioritise industries versus taking a thematic approach) and decide which one to adopt.

Providing a robust due process

22The TAC continues to have concerns about the due process being applied in the ISSB's project to enhance the SASB Standards. The FRC's March 2025 response to Exposure Draft IFRS/DPH/ED/2024: Proposed Amendments to the IFRS Foundation Due Process Handbook noted that UK stakeholders and the TAC raised concerns where materials were not developed using the same conceptual basis, and have not been or are not subject to - the usual IFRS Foundation due process.

23As noted in the FRC's June 2025 letter to the ISSB's Chair asking for an extension to the proposed comment period for the SASB Exposure Draft, and a similar June 2025 letter sent by the TAC and PIC Chairs, the absence of public deliberations on the technical content during the development of the SASB Exposure Draft meant stakeholders were not familiar with the approach being taken to develop the proposed amendments, the rationale for the proposals, the substantiveness of the changes and any points of contention.

24The TAC considers public deliberations to be particularly important in relation to sensitive areas, such as human rights.

25The TAC notes that the ISSB's project to review its Due Process Handbook is still underway, however, given the concerns expressed by stakeholders about the proposed due process arrangements, the IFRS Foundation could have enhanced the due process arrangements for the ISSB's project to enhance the SASB Standards. The TAC further notes that other projects to develop non-mandatory guidance have been subject to a greater level of due process at the IFRS Foundation, such as the Climate-related and Other Uncertainties in the Financial Statements guidance being developed by the IASB. The IFRS S1 and IFRS S2 requirements that entities ‘shall refer to and consider the applicability of the SASB Standards and the IFRS S2 Industry-based Guidance mean that the SASB Standards have a unique role in IFRS Standards which could justify a greater level of due process.

26Further, the extant due process arrangements and lack of public deliberations may have contributed to the lack of a clear vision for the ISSB's project.

27In the absence of a greater level of due process, and to encourage stakeholder engagement, the ISSB could provide a greater level of supporting analysis and methodology used for the proposed amendments. Suggestions for the ISSB to consider include:

providing tables, similar to those published by the European Financial Reporting Advisory Group (EFRAG), with logs of amendments showing the proposed revision and reason for it. This would be more accessible than the narrative provided in the Basis for Conclusions and would provide assurance that a reason has been given for each amendment. This would also be useful for the purpose of understanding the most common reasons for the proposed amendments.
providing summaries of stakeholders the ISSB has engaged with, even if by group. For example, this might include presenting the number of companies that were engaged within each industry and the specific jurisdiction in which the companies are based. This would be a greater level of detail than is in the December 2024 ISSB Staff Paper and would provide greater level of assurance that the project has incorporated international perspectives. Additionally, when amendments have been made due to stakeholder feedback, the stakeholder type and the basis for their suggestions are not always clear. Further information about the stakeholders the ISSB engaged with would be helpful to also understand why some of the amendments have been made.
sharing an analysis of desk-based research on which metrics in the SASB Standards are commonly adjusted or omitted by companies, and the reasons why. Of particular interest would be those not considered relevant to specific jurisdictions and the use of common alternatives, including those from other sustainability-related standards and frameworks.
explaining key omissions in relation to disclosure topics with a view to providing a holistic cross-sector picture. It is unclear why, for example, certain disclosures topics which could be relevant to all standards in a sector are only included in certain standards.
providing tables or indicating more clearly where the same amendment had been made across multiple standards, e.g. the amendments to the water-related metrics are the same. A substantial amount of time has been spent working through the material to understand what changes have been made and why.

28As this is the first time the SASB Standards have undergone consultation via the IFRS Foundation, it might also have been helpful to provide some of the initial reasoning for the metrics, including why the disclosure is considered important. The Basis for Conclusions does not provide details on the underlying phenomenon being measured nor why the metric is considered useful for investors. This explanation could then be useful for companies to understand whether the metrics apply to other industries. Some of this information can be found in historical SASB documentation, but these documents are difficult to locate and stakeholders may not know where they are. The ISSB should provide an explanation of the purpose of the disclosures so that companies and investors can understand the relevance of the metrics.

29It is also not clear whether consideration was made as to whether the metrics that were amended across all 77 standards are still relevant to the non-priority industries. In the event that the metric is considered no longer relevant, then there is a possibility that the amended metrics could ultimately be removed.

Improving engagement with the SASB Exposure Draft

30One of the TAC's guiding principles is to provide a focal point for UK stakeholders to share their views, and the TAC has a responsibility to undertake outreach with such stakeholders. However, the TAC has concerns about the adequacy of its engagement with UK stakeholders during the current consultation and in the development of its response to the ISSB.

31The FRC encouraged the IFRS Foundation to give greater consideration to enabling stakeholders to contribute to the development of the SASB Standards in its March 2025 response to Exposure Draft IFRS/DPH/ED/2024: Proposed Amendments to the IFRS Foundation Due Process Handbook and, as noted, the FRC, and TAC and PIC Chairs asked for an extension to the proposed comment period for the SASB Exposure Draft with a view to encouraging stakeholder engagement with the proposed amendments.

32While the TAC welcomed the 30-day extension of the comment period, the TAC has experienced challenges engaging with UK stakeholders who have had the opportunity to consider the specifics of the proposals during the consultation period. These challenges may be due to:

the significant volume of materials that were published as part of the SASB Exposure Draft.
lack of capacity given the timing of the consultation during the UK's summer period, but also at the same time as other major consultations on the draft UK Sustainability Reporting Standards (UK SRS), and the European Financial Reporting Advisory Group (EFRAG)'s revised European Sustainability Reporting Standards (ESRS).
not enough supporting materials being made available at the start of the consultation. The ISSB could have provided articles, webinars or presentations at the start of the consultation, or delayed the consultation until these materials were ready, to allow stakeholders to more easily engage with the materials.
stakeholder consultation fatigue from the number of consultations relating to sustainability reporting that have been published over the last few years.
difficulties reaching varied industry stakeholders and accessing specialist skills and knowledge given the nature of the materials.
the TAC's Terms of Reference, which means that it has to approve its response in a public meeting, limiting its timeframe to develop its response.

33As mentioned in Paragraph 27, the ISSB may consider changes to the presentation of the SASB Exposure Draft to make it more accessible for stakeholders, which might also encourage stakeholder engagement with it.

Industry classification system

34The TAC has mixed views on the Sustainable Industry Classification System (SICS) and overall considers the issues around industry classification systems to be important but difficult. The TAC noted that a workstream to consider the industry classification system could be a big project in its own right.

35The FRC's 2023 response to the ISSB Exposure Draft Methodology for Enhancing the International Applicability of the SASB Standards and SASB Standards Taxonomy Updates noted that SICS is based on US market research conducted by SASB. There has been no work completed to assess whether SICS is relevant or appropriate for other jurisdictions.

36Although TAC members consider SICS to be a legacy system with problems, it was also considered to be an imperfect but adequate system. It may therefore make sense for the ISSB to continue with SICS.

37The TAC raised concerns about comparability across different industry classification systems and noted that there would be particular challenges for conglomerates or entities with complex or diverse activities.

38The TAC suggests that there could be mappings from SICS to other industry classification systems and guidance for conglomerates.

Questions for the TAC

(i) What are the TAC's views on the general points to include in the TAC's response to the SASB Exposure Draft and, in particular, the points in relation to:

communicating a clear vision;

status of the SASB Standards and architecture for IFRS Sustainability Disclosure Standards;

ongoing enhancement process and future updates;

pursuing a phased approach;

providing a robust due process;

publicly sharing the supporting analysis and methodology;

improving engagement with the SASB Exposure Draft; and

industry classification system?

(ii) What are the TAC's views on the answers to the questions in the SASB Exposure Draft in the appendix in relation to the:

proposed approach to the amendments;

proposed amendments to individual SASB Standards; and

proposed targeted amendments to other SASB Standards?

Appendix: Answers to the questions in the SASB Exposure Draft

39The TAC is asked for its views on the following proposed answers to the questions in the SASB Exposure Draft. The SASB Exposure Draft notes that respondents need not answer all the questions in the invitation to comment, and so the TAC could also consider whether it would choose not to answer any of the questions.

Proposed approach to the amendments

QUESTION 1—OBJECTIVE

(a) Do you agree with the objective of the proposed amendments to the SASB Standards and related areas of focus?

(b) Do the proposed amendments meet this objective? Why or why not?

40The TAC strongly agrees with the overall objective of the ISSB's project Enhancing the SASB Standards, which is to support the implementation of IFRS S1 and IFRS S2.

41However, the TAC is not convinced that the ISSB's project to enhance the SASB Standards is the best way of achieving that objective. This is particularly the case in the UK given the UK Government's proposed amendments to IFRS S1 and IFRS S2 requirements that entities ‘shall refer to and consider the applicability of the SASB Standards and the IFRS S2 Industry-based Guidance. The UK Government proposes to amend 'shall refer to and consider the applicability of...' to 'may refer to and consider the applicability of...', in both draft UK SRS S1 and draft UK SRS S2.

42The TAC notes that the ISSB's project to enhance the SASB Standards could support the implementation of IFRS S1 and IFRS S2 were it to prioritise simplification and alignment with IFRS Sustainability Disclosure Standards IFRS S1 and IFRS S2.

43The TAC agrees with the ISSB's intention of enhancing the clarity, conciseness and cost-effectiveness for preparers. The TAC encourages the ISSB to share an evaluation of the impact of the proposed amendments on preparers and, as noted in the general points above, develop a clear vision for its project to enhance the SASB Standards, so that they can keep pace with the changes without being overly burdensome for preparers.

44There are also some instances where terminology used in the SASB Standards could be more consistent. For example, the SASB Standards refer to 'operating facilities', 'operational facilities' and 'active sites' (Oil & Gas Exploration & Production: EM-EP-140a.6, EM-EP-160a.1 and EM-EP-160a.4), which appear to be the same concept. Clarifying the terminology and ensuring consistency will improve interpretation and application of the requirements.

45We have ordered the following related areas of focus to reflect the TAC's view of their importance in relation to the ISSB's project to enhance the SASB Standards, and comment further on each of them in the text that follows:

alignment with IFRS Sustainability Disclosure Standards;
enhancing international applicability;
improving interoperability with other sustainability-related standards and frameworks; and
amendments related to biodiversity, ecosystems and ecosystem services (BEES) and human capital.

Alignment with IFRS Sustainability Disclosure Standards

46The TAC strongly supports the ISSB's aim of aligning the language and concepts with IFRS Sustainability Disclosure Standards and believes that alignment with IFRS Sustainability Disclosure Standards should be the primary driver of the changes.

47A focus on alignment with IFRS Sustainability Disclosure Standards would better support the implementation of IFRS S1 and IFRS S2 and the TAC would value greater clarity on the interaction, including linkages, between IFRS Sustainability Disclosure Standards and the SASB Standards.

48One area that has not been addressed in the ISSB's project is the structure of the SASB Standards. To better align with the structure of IFRS Standards, the SASB Standards should clearly distinguish between disclosure requirements and additional guidance. The protocols in the SASB Standards often include definitions or guidance to support the disclosure requirements. However, the protocols also include additional disclosure requirements that supplement the initial metric. The TAC recommends that the ISSB align the structure of the SASB Standards with IFRS Sustainability Disclosure Standards.

49There are also conceptual differences between the SASB Standards and the IFRS Sustainability Disclosure Standards. The SASB Standards are structured around disclosure topics and metrics which differ from the terminology used in IFRS Sustainability Disclosure Standards, which focuses on risks and opportunities. Given that the SASB Standards are referenced in IFRS S1 as guidance for companies to identify risks and opportunities, it would be helpful for the ISSB to clarify the architectural relationship between the different terms, or for the SASB Standards to be reframed around risks and opportunities. This would greatly support the application of IFRS S1 and IFRS S2, as the SASB Standards would then provide more accessible guidance as to the types of sustainability-related risks and opportunities that might affect a company.

50We understand that the ISSB objective is also not to repeat requirements already included in IFRS S1 and IFRS S2. However, there have been some inconsistencies in how this objective is applied. For example, as described in Paragraph 87, Scope 1 requirements across the various standards may be seen to essentially restate IFRS S2 requirements. This is also the case with requirements to identify risks and opportunities related to social matters in other standards (for example, Metals & Mining: EM-MM-430a.1, Construction Materials: EM-CM-430a.1 and Iron & Steel Producers: EM-IS-430a.1). In Paragraph 12, the TAC suggests that the ISSB considers restructuring the SASB Standards to distinguish between core, industry-agnostic disclosures and additional, industry-specific disclosures. Differentiating between the industry-agnostic and industry-specific disclosures is likely to reduce the amount of duplication between IFRS Sustainability Disclosure Standards and the SASB Standards.

Enhancing international applicability

51The TAC also supports the ISSB's aim of enhancing the international applicability of industry groupings, disclosure topics, metrics and supporting technical protocols. UK-based investors invest globally and global companies are headquartered in the UK, so being international applicability is key for the UK market.

52The FRC's 2023 response to the ISSB Exposure Draft Methodology for Enhancing the International Applicability of the SASB Standards and SASB Standards Taxonomy Updates noted that disclosure topics, metrics and supporting technical protocols contained within the SASB Standards were developed using research based on the US market and may therefore not be fully applicable across all jurisdictions. We recognise the current consultation is a way of obtaining further jurisdictional views. However, as noted in Paragraph 7, we have concerns about engagement with the SASB Exposure Draft and the consequential limitations to fully representing the views of the UK market and industries.

53A December 2024 ISSB Staff Paper noted that, of the sector-specific bilateral engagements undertaken during the development of the proposed amendments to the SASB Standards, 45% were in North America and 33% were in Europe.

54The TAC therefore recommends that the ISSB consider ways of improving engagement with the SASB Exposure Draft and conducting further outreach in markets beyond North America and Europe.

55The TAC has mixed views about the ISSB's aim of improving interoperability with other sustainability-related standards and frameworks, such as the Global Reporting Initiative (GRI) Standards, European Sustainability Reporting Standards (ESRS), and the recommendations published by the Taskforce on Nature-related Financial Disclosures (TNFD) and does not believe interoperability with other sustainability-related standards and frameworks should be the primary driver of the changes.

56Interoperability should instead be a secondary driver of the changes, with the primary focus being on the ISSB's Standards, and the focus areas of alignment with IFRS Sustainability Disclosure Standards and enhancing international applicability.

57The ISSB should be clear on its definition of interoperability. Interoperability should focus on simplifying and supporting the navigation of the different sustainability-related standards and frameworks rather than being additive, as the ISSB's Standards aim to provide a global baseline of sustainability disclosures. If interoperability were about being additive, then the SASB Standards could become burdensome for preparers.

58Alignment with other sustainability-related standards and frameworks is particularly challenging because those standards and frameworks are continuing to evolve. For example, EFRAG's revised ESRS exposure drafts, which could enhance or weaken interoperability. A lack of alignment could result in extra work for preparers and other stakeholders as explanations may have to be provided for any similar, but not identical, disclosures.

59Interoperability should therefore focus on complementarity rather than convergence or alignment.

60The ISSB should also consider the final desired vision for, or outcome of, interoperability - or whether it will be a continual process.

61Interoperability could compromise the ISSB's focus on the needs of primary users of general purpose financial reports. One of the key challenges with interoperability is different approaches to materiality and identifying sustainability-related matters. We agree that the ISSB should approach interoperability by first determining that disclosure requirements in other sustainability-related standards and frameworks fit with the ISSB's materiality lens, and then considering adopting those disclosure requirements.

62Interoperability with TNFD may be premature given the ISSB's research project on BEES has not been completed yet, as noted in Paragraphs 64 to 66.

63Mappings to other sustainability-related standards and frameworks showing the similarities and differences could also support interoperability, as could joint consultations with other standard-setters and framework developers.

64The 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, and we do not know whether any standard-setting or guidance will arise from those projects. It is premature for the ISSB to make amendments to the SASB Standards without the overall architecture for IFRS Sustainability Disclosure Standards.

65The TAC is unclear about whether the SASB Standards are intended to be a foundation for future topic-specific IFRS Sustainability Disclosure Standards or a substitute for future topic-specific IFRS Sustainability Disclosure Standards. The TAC would value greater clarity on the ISSB's future strategy and development of future topic specific IFRS Sustainability Disclosure Standards, particularly given its concerns about the due process being applied in the ISSB's project to enhance the SASB Standards.

66Additionally, a number of the BEES and human capital metrics in the SASB Standards could be considered industry-agnostic and therefore are more appropriate in a topical standard. The TAC recommends that industry-agnostic disclosures are addressed in topical standards, which will mean that SASB Standards are focused on industry-specific disclosures, i.e. metrics that only arise and can be measured in specific industries.

Other priorities

67As noted in paragraph 41, the TAC is not convinced that this project is the best way of achieving the objective of supporting the implementation of IFRS S1 and IFRS S2. Instead of using its resources to enhance the SASB Standards, the ISSB could focus on supporting the implementation of IFRS S1 and IFRS S2 by developing illustrative examples (e.g. in relation to disaggregation) and guidance (e.g. in relation to measurement).

68The ISSB could then pursue other activities, such as progressing its research projects on BEES and human capital.

QUESTION 2—ENHANCEMENTS TO INTEROPERABILITY WITH OTHER STANDARDS AND FRAMEWORKS

(a) Do you agree with the proposed approach to enhancing interoperability and alignment with other sustainability-related standards and frameworks? Why or why not?

(b) Do you agree that the proposed amendments to the nine priority industries and targeted amendments to other SASB Standards will result in improved interoperability and thus achieve the objectives of improving the decision-usefulness of disclosed information for primary users and cost-effectiveness for preparers? Why or why not?

(c) Could the interoperability and alignment of any disclosure topics or metrics be further enhanced while achieving the objectives of improving the decision-usefulness and cost-effectiveness of the information? What amendments would you propose and why?

69As noted in Paragraphs 55 to 63, the TAC has mixed views about the ISSB's aim of improving interoperability with other sustainability-related standards and frameworks.

QUESTION 3—AMENDMENTS TO THE CLIMATE-RELATED CONTENT IN THE SASB STANDARDS

(a) Do you agree that the ISSB should amend the climate-related content in the SASB Standards for the priority industries and make targeted amendments to the climate-related content in the SASB Standards for other industries, as proposed in this Exposure Draft? Why or why not?

(b) Do you agree that the proposed amendments would enhance the decision-usefulness of the industry-specific information about climate-related risks and opportunities? Why or why not?

(c) Do you agree that the proposed amendments would further clarify how the climate-related content in the SASB Standards and the IFRS S2 industry-based guidance relates to the requirements in IFRS S2?

70Please refer to our general points above, our answer to Question 15 on climate-linked targeted amendments, and to the comments in this paper covering specific climate-related amendments.

QUESTION 4—INFORMATION RELATED TO BIODIVERSITY, ECOSYSTEMS AND ECOSYSTEM SERVICES AND HUMAN CAPITAL

(a) Do the SASB Standards, including the proposed amendments, enable entities to provide decision-useful information about their BEES-related risks and opportunities to users of general purpose financial reports? Why or why not?

(b) In the nine industries that the ISSB has prioritised for enhancement in the Exposure Draft, are there other BEES-related disclosures not addressed through the proposed amendments that would be useful for users of general purposes financial reports in their decision-making? If so, please explain which disclosures and why.

(c) Do the SASB Standards, including the proposed amendments, enable entities to provide decision-useful information about their human capital-related risks and opportunities to users of general purpose financial reports? Why or why not?

(d) In the nine industries that the ISSB has prioritised for enhancement in the Exposure Draft, are there other human capital-related disclosures not addressed through the proposed amendments that would be useful for users of general purposes financial reports in their decision-making? If so, please explain which disclosures and why.

71As noted in Paragraphs 64 to 66, 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.

QUESTION 5—EFFECTIVE DATE

Do you agree with the proposed approach for setting the effective date of the amendments and permitting early application? Why or why not?

72The TAC agrees that the ISSB should decide the effective date for the amendments after considering the feedback on the proposed amendments.

73The TAC's initial view on the effective date for the amendments is that it should occur 18 months after their issuance and permit early application.

Proposed amendments to individual SASB Standards

74We are grouping our answers to Questions 6 to 13 together to reflect linkages between the standards for industries in the Extractives & Minerals Processing sector.

Overall agreement

QUESTION 6—COAL OPERATIONS SASB STANDARD

(a) Do you agree with the proposed amendments to the Coal Operations SASB Standard? Why or why not?

QUESTION 7—CONSTRUCTION MATERIALS SASB STANDARD

(a) Do you agree with the proposed amendments to the Construction Materials SASB Standard? Why or why not?

QUESTION 8—IRON & STEEL PRODUCERS SASB STANDARD

(a) Do you agree with the proposed amendments to the Iron & Steel Producers SASB Standard? Why or why not?

QUESTION 9—METALS & MINING SASB STANDARD

(a) Do you agree with the proposed amendments to the Metals & Mining SASB Standard? Why or why not?

QUESTION 10—OIL & GAS – EXPLORATION & PRODUCTION SASB STANDARD

(a) Do you agree with the proposed amendments to the Oil & Gas – Exploration & Production SASB Standard? Why or why not?

QUESTION 11—OIL & GAS – MIDSTREAM SASB STANDARD

(a) Do you agree with the proposed amendments to the Oil & Gas – Midstream SASB Standard? Why or why not?

QUESTION 12—OIL & GAS – REFINING & MARKETING SASB STANDARD

(a) Do you agree with the proposed amendments to the Oil & Gas – Refining & Marketing SASB Standard? Why or why not?

QUESTION 13—OIL & GAS – SERVICES SASB STANDARD

(a) Do you agree with the proposed amendments to the Oil & Gas – Services SASB Standard? Why or why not?

75As noted in Paragraph 7, the TAC is concerned about the adequacy of its engagement with UK stakeholders during the current consultation and in the development of its response to the ISSB. The TAC is therefore not convinced it has the evidence to conclude on whether it agrees with the proposed amendments to the standards for industries in the Extractives & Minerals Processing sector and cautions that its response may not fully reflect the views of the UK market.

Industry descriptions

76The TAC does not have any concerns about the updated industry descriptions [subject to any stakeholder feedback to the contrary].

77Please refer to our comments on the industry classification system in Paragraphs 34 to 38.

QUESTION 6—COAL OPERATIONS SASB STANDARD

(b) Do you agree with the Coal Operations industry description, and does it accurately describe the business activities of this industry? Do you agree with the industry classification that forms the basis of this Standard? Why or why not?

QUESTION 7—CONSTRUCTION MATERIALS SASB STANDARD

(b) Do you agree with the Construction Materials industry description, and does it accurately describe the business activities of this industry? Do you agree with the industry classification that forms the basis of this Standard? Why or why not?

QUESTION 8—IRON & STEEL PRODUCERS SASB STANDARD

(b) Do you agree with the Iron & Steel Producers industry description, and does it accurately describe the business activities of this industry? Do you agree with the industry classification that forms the basis of this Standard? Why or why not?

QUESTION 9—METALS & MINING SASB STANDARD

(b) Do you agree with the Metals & Mining industry description, and does it accurately describe the business activities of this industry? Do you agree with the industry classification that forms the basis of this Standard? Why or why not?

QUESTION 10—OIL & GAS – EXPLORATION & PRODUCTION SASB STANDARD

(b) Do you agree with the Oil & Gas – Exploration & Production industry description, and does it accurately describe the business activities of this industry? Do you agree with the industry classification that forms the basis of this Standard? Why or why not?

QUESTION 11—OIL & GAS – MIDSTREAM SASB STANDARD

(b) Do you agree with the Oil & Gas – Midstream industry description, and does it accurately describe the business activities of this industry? Do you agree with the industry classification that forms the basis of this Standard? Why or why not?

QUESTION 12—OIL & GAS – REFINING & MARKETING SASB STANDARD

(b) Do you agree with the Oil & Gas – Refining & Marketing industry description, and does it accurately describe the business activities of this industry? Do you agree with the industry classification that forms the basis of this Standard? Why or why not?

QUESTION 13—OIL & GAS – SERVICES SASB STANDARD

(b) Do you agree with the Oil & Gas – Services industry description, and does it accurately describe the business activities of this industry? Do you agree with the industry classification that forms the basis of this Standard? Why or why not?

Disclosure topics

QUESTION 6—COAL OPERATIONS SASB STANDARD

(c) Do you agree with the disclosure topics in the Coal Operations SASB Standard? Do they accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry?

QUESTION 7—CONSTRUCTION MATERIALS SASB STANDARD

(c) Do you agree with the disclosure topics in the Construction Materials SASB Standard? Do they accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry?

(e) Do you agree with the proposed addition of the Supply Chain Management disclosure topic and associated metric? If you disagree, which aspects do you disagree with and what would you suggest instead?

QUESTION 8—IRON & STEEL PRODUCERS SASB STANDARD

(c) Do you agree with the disclosure topics in the Iron & Steel Producers SASB Standard? Do they accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry?

QUESTION 9—METALS & MINING SASB STANDARD

(c) Do you agree with the disclosure topics in the Metals & Mining SASB Standard? Do they accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry?

(e) Do you agree with the proposed addition of a Supply Chain Management disclosure topic and associated metric? Why or why not? If not, what would you suggest instead and why?

QUESTION 10—OIL & GAS – EXPLORATION & PRODUCTION SASB STANDARD

(c) Do you agree with the disclosure topics in the Oil & Gas – Exploration & Production SASB Standard? Do they accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry?

QUESTION 11—OIL & GAS – MIDSTREAM SASB STANDARD

(c) Do you agree with the disclosure topics in the Oil & Gas – Midstream SASB Standard? Do they accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry?

QUESTION 12—OIL & GAS – REFINING & MARKETING SASB STANDARD

(c) Do you agree with the disclosure topics in the Oil & Gas – Refining & Marketing SASB Standard? Do they accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry?

QUESTION 13—OIL & GAS – SERVICES SASB STANDARD

(c) Do you agree with the disclosure topics in the Oil & Gas – Services SASB Standard? Do they accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry?

78The ISSB has not provided information on why certain disclosure topics are included in some standards but not in others. While we would not expect detailed explanations for the exclusion of specific topics, it would be helpful to understand the rationale or prioritisation process used to determine their inclusion or exclusion in these circumstances when only one or two industries in a sector have a certain topic excluded.

Coal Operations SASB Standard: Air Quality

79For example, the ‘Air Quality' disclosure topic is included in all standards for industries in the Extractive & Mineral Processing sector except for the Coal Operations SASB Standard. This is despite the standards for the other industries in the Extractive & Mineral Processing sector being aligned with GRI air quality disclosures and there being a topic in the GRI Sector Standard for Coal, GRI 12: Coal Sector 2022, which states 'Air emissions from coal activities include CO, NOx, PM, and SO2. These emissions can occur in the form of evaporation from tailings ponds or waste areas; fugitive dust emissions from drilling, blasting, storage, transportation, loading, and unloading; refining and processing activities; transportation of supplies and products; and incidents, such as mine fires'. The TAC believes there is a case for including the 'Air Quality' disclosure topic in the Coal Operations SASB Standard [subject to considering stakeholder feedback].

Oil & Gas – Midstream SASB Standard: Water Management

80The 'Water Management' disclosure topic is included in all standards Extractive & Mineral Processing sector except for the Oil & Gas – Midstream SASB Standard. The TAC believes there may be a case for including the ‘Water Management' disclosure topic in the Oil & Gas – Midstream SASB Standard [subject to our discussions with the ISSB and considering stakeholder feedback].

All Oil & Gas SASB Standards: Energy Management

81The 'Energy Management' disclosure topic is only included in three of the Extractives & Minerals Processing standards. However, it could be argued that energy management is key for transition planning and managing climate-related transition risks. In the ISSB's guidance on transition plans there are examples of energy management for the Oil & Gas industry as it could be considered a material indicator for that industry. It is therefore surprising that this disclosure topic is not included in any of the Oil & Gas SASB Standards. The TAC believes there may be a case for including the ‘Energy Management' disclosure topic in certain Oil & Gas SASB Standards [subject to TAC views and considering stakeholder feedback].

Additional disclosure topics

83As noted in TAC Paper 2025-TAC-043 (Paragraphs 14 and 15), we are also seeking stakeholder views on disclosure topics which have been added to certain industries in the Extractive & Mineral Processing sector and the TAC could include any stakeholder comments in its response. For example, the:

'Supply Chain Management' disclosure topic has been added to the Construction Materials and Metals & Mining SASB Standards.
'Labour Practices' disclosure topic has been added to the Iron & Steel Producers SASB Standard.

Metals & Mining and Oil & Gas – Exploration & Production SASB Standards: Security, Human Rights & Rights of Indigenous People

84As noted in TAC Paper 2025-TAC-043 (Paragraph 17), the TAC is concerned that the term 'Human Rights' is no longer present within the disclosure topics following the removal of the 'Security, Human Rights & Rights of Indigenous People' disclosure topic. [The TAC could include this point in its response, subject to considering stakeholder feedback.]

Disclosure topic summaries

85The ISSB has explained that any amendments to disclosure topic summaries were intended to clarify existing information, rather than make substantive changes. As such, no explanations for any disclosure topic summary amendments are included within the Basis for Conclusions. The following potentially substantive amendments to disclosure topic summaries are therefore noted as potentially unintended consequences of the SASB Exposure Draft:

85.1 Oil & Gas – Exploration & Production SASB Standard: Ecological Impacts. The proposed removal of this sentence could be seen to substantively change the meaning of the topic summary: ‘Depreciation in the future value of reserves may be mitigated by considering the proximity of reserves in or near protected areas as part of the decision-making process.' There are no proposed additions or replacement text to the summary which would tie consideration of ecological impact to the valuation of the company or its assets in the way that this sentence does. [The TAC could include this point in its response, subject to our discussions with the ISSB.]

85.2 Oil & Gas – Midstream SASB Standard: Ecological Impacts. The references to jurisdictional demands for mitigation or remediation plans related to ecological impact have been updated, from stating that authorities 'may require' such plans, to reflect current legal and regulatory landscapes. The topic summary now states that jurisdictional legal and regulatory authorities 'are demanding' such plans. While this is a minor adjustment to reflect changes in the landscape, the proposed amendments to the following sentences state that early implementation of such plans is beneficial to entities in avoiding costs, whereas the standard previously stated that regulatory compliance would pose a cost in itself. A new sentence reads: 'Integrating this detailed planning early in project development can help entities avoid significant delays and incremental operational, compliance and capital costs'. The draft proposes deleting a sentence reading: ‘Together with regulatory compliance costs, these plans may require significant capital and operational expenditures.' [The TAC could include this point in its response, subject to our discussions with the ISSB.]

86Disclosure topic summaries across industries are identical for some disclosure topics but tailored to each industry for others. For example, the wording in the 'Community Relations & Rights of Indigenous Peoples' disclosure topic summaries is now identical across the three standards where it is included (having previously differed in each industry), but the wording in the 'Air Quality' disclosure topic summaries is specific to the activities and related risks and opportunities for each of the seven industries it applies to. While the difference in approach may be warranted on a topic-by-topic basis, again, it would be helpful to understand the rationale for it.

Metrics and technical protocols

QUESTION 6—COAL OPERATIONS SASB STANDARD

(d) Do you agree with the metrics and technical protocols in the Coal Operations SASB Standard? Do the metrics help an entity to provide information about sustainability-related risks and opportunities that is useful to primary users in making decisions relating to providing resources to the entity? If not, what would you suggest instead and why?

(e) Do you agree with the proposed addition of metric EM-CO-110a.3 Total Scope 1 methane emissions? Why or why not? If not, what would you suggest instead and why?

QUESTION 7—CONSTRUCTION MATERIALS SASB STANDARD

(d) Do you agree with the metrics and technical protocols in the Construction Materials SASB Standard? Do the metrics help an entity to provide information about sustainability-related risks and opportunities that is useful to primary users in making decisions relating to providing resources to the entity? If not, what would you suggest instead and why?

(e) Do you agree with the proposed addition of the Supply Chain Management disclosure topic and associated metric? If you disagree, which aspects do you disagree with and what would you suggest instead?

QUESTION 8—IRON & STEEL PRODUCERS SASB STANDARD

(d) Do you agree with the metrics and technical protocols in the Iron & Steel Producers SASB Standard? Do the metrics help an entity to provide information about sustainability-related risks and opportunities that is useful to users in making decisions relating to providing resources to the entity? If not, what would you suggest instead and why?

QUESTION 9—METALS & MINING SASB STANDARD

(d) Do you agree with the metrics and technical protocols in the Metals & Mining SASB Standard? Do the metrics help an entity to provide information about sustainability-related risks and opportunities that is useful to users in making decisions relating to providing resources to the entity? If not, what would you suggest instead and why?

(e) Do you agree with the proposed addition of a Supply Chain Management disclosure topic and associated metric? Why or why not? If not, what would you suggest instead and why?

QUESTION 10—OIL & GAS – EXPLORATION & PRODUCTION SASB STANDARD

(d) Do you agree with the metrics and technical protocols in the Oil & Gas – Exploration & Production SASB Standard? Do the metrics help an entity to provide information about sustainability-related risks and opportunities that is useful to users in making decisions relating to providing resources to the entity? If not, what would you suggest instead and why?

(e) Do you agree that the proposed amendments to the Water Management disclosure topic would provide useful information to primary users in a cost-effective manner for preparers?

(f) Do you agree with the proposed addition of metric EM-EP-160a.4 (1) Total spatial footprint of operations, (2) area disturbed and (3) area restored and with the content of that metric? Why or why not? If not, what do you recommend and why?

QUESTION 11—OIL & GAS – MIDSTREAM SASB STANDARD

(d) Do you agree with the metrics and technical protocols in the Oil & Gas – Midstream SASB Standard? Do the metrics help an entity to provide information about sustainability-related risks and opportunities that is useful to users in making decisions relating to providing resources to the entity? If not, what would you suggest instead and why?

(e) Do you agree with the proposed addition of metric EM-MD-110a.3 Total Scope 1 methane emissions? Why or why not? If not, what would you suggest instead and why?

QUESTION 12—OIL & GAS – REFINING & MARKETING SASB STANDARD

(d) Do you agree with the metrics and technical protocols in the Oil & Gas – Refining & Marketing SASB Standard? Do the metrics help an entity to provide information about sustainability-related risks and opportunities that is useful to users in making decisions relating to providing resources to the entity? If not, what would you suggest instead and why?

QUESTION 13—OIL & GAS – SERVICES SASB STANDARD

(d) Do you agree with the metrics and technical protocols in the Oil & Gas – Services SASB Standard? Do the metrics help an entity to provide information about sustainability-related risks and opportunities that is useful to users in making decisions relating to providing resources to the entity? If not, what would you suggest instead and why?

(e) The proposed amendments discussed in paragraphs BC126–BC130 would revise, add and remove a series of metrics in the Oil & Gas – Services SASB Standard to better reflect an entity's business activities while ‘off-contract'. Do you agree with these proposed amendments? Why or why not? If not, what would you suggest instead and why?

Greenhouse Gas Emissions

87One of the proposed amendments to metrics within the eight priority standards in the Extractives & Minerals Processing sector is for entities to consider reporting their Scope 1 emissions in accordance with IFRS S2, paragraph 29(a). The ISSB's view is that Scope 1 emissions represent a significant component of total emissions in these eight priority industries, thereby justifying an industry-specific disclosure requirement. However, IFRS S2 already requires disclosure of Scope 1 emissions when material, raising questions about how this additional requirement aligns with the ISSB's intention of avoiding duplication of provisions already contained within IFRS S1 and IFRS S2. If this approach were to be extended to other sectors, for example the Financials sector, where Scope 3 emissions are typically the most material, it is unclear whether the standards for industries in the Financials sector would require the same disclosures on financed emissions that are already in IFRS S2. It could be the case that this is intended for companies that use SASB as standalone standards and not complementary to IFRS S1 and IFRS S2. However, the Basis for Conclusions is not clear on the rationale.

88Oil & Gas – Exploration & Production: EM-EP-110a.4 and Oil & Gas – Midstream: EM-MD-110a.3 are new metrics which request Scope 1 methane emissions. Within the technical protocol, entities are also asked to disclose whether they participate in methane management frameworks, such as the Oil and Gas Methane Partnership (OGMP) 2.0. A similar metric has been added to Coal Operations: EM-CO-110a.3, however, the technical protocol does not ask for information relating to methane management framework membership. The TAC agrees in principle with the addition of these metrics. [However, the TAC could suggest the ISSB considers incorporating frameworks relevant to the Coal industry in the technical protocol for the Coal Operations SASB Standard, subject to considering stakeholder feedback.]

89The ISSB could also consider the addition of metrics on Scope 3 emissions. In its January 2025 letter to the ISSB Chair on the UK endorsement of IFRS S1 and IFRS S2, the TAC noted that it would be helpful to encourage more consistency in how Scope 3 emissions are presented within sectors, while allowing entities the flexibility to adapt their reporting based on their own specific contexts. Scope 3 emissions are likely to benefit from industry-based guidance that reflects the types of assets or business activities that could determine which Scope 3 categories are material. Therefore, the TAC recommended that the ISSB collaborate with GHG Protocol and other global standard setters to develop further industry-based guidance for Scope 3 emissions reporting, specifically about which of the Scope 3 categories might be relevant to different industries and sectors, and how leased assets are treated to improve the quality and consistency of reporting. The ISSB's project to enhance the SASB Standards also presents an opportunity to develop industry-based guidance on Scope 3 emissions.

90Oil & Gas – Services: EM-SV-110a.1 relating to total fuel consumed and renewable fuel consumed is covered under the ‘Energy Management' disclosure topic in most of the standards except for Oil & Gas – Services SASB Standard, where the same metric is part of the ‘Greenhouse Gas Emissions' disclosure topic. It is not clear why there is a difference in the way this metric is classified.

Other metric revisions

91As noted in TAC Paper 2025-TAC-043 (Paragraphs 23 to 25 and 33 to 36), we are also seeking stakeholder views on the following changes to metrics, and the TAC could include any stakeholder comments in its response.

91.1 The 'Energy Management' Metals and Mining metric EM-MM-130a.1 has been revised to remove disclosure of percentage grid electricity and percentage renewable electricity, and now proposes to require purchased electricity consumed, renewable electricity consumed from self-generation and direct contracts and also disclosure of natural gas consumed. Similar changes have been made to the 'Energy Management' metrics in the Construction Materials, Iron & Steel Producers and Processed Foods SASB Standards.

91.2 The 'Water Management' Oil & Gas – Exploration & Production metrics EM-EP-140a.5 (total water discharged by destination and level of treatment) and EM-EP-140a.6 (water related risks, opportunities and strategies to manage them) have been added. These metrics are also included in the Coal Operations, Metals & Mining, and Processed Foods SASB Standards, and the water discharge metric is only being incorporated into the Oil & Gas - Refining & Marketing and Oil & Gas – Services SASB Standards.

91.3 The 'Ecological Impacts' Oil & Gas – Exploration & Production metric EM-EP-160a.4; Metals & Mining metric EM-MM-160a.4 and Coal Operations metric EM-CO-160a.4 are new metrics which request total spatial footprint of operations, area disturbed and area restored.

91.4 The 'Waste & Hazardous Materials Management' Metal & Mining metric EM-MM-150a.7 has been revised and there is now a proposed new requirement for entities that are subject to more than one jurisdictional law or regulation that defines hazardous waste, for such entities to disclose whether and how variations between these frameworks affect the reported data for hazardous waste generated, hazardous waste recycled and number of incidents associated with hazardous materials and waste management.

91.5 The 'Climate Resilience' Coal Operations metric EM-CO-420a.1 on coal reserve sensitivities, which previously required an entity to disclose how future scenarios might affect whether reserves are proved or probable, is proposed for amendment. Entities will now be required to use climate-related scenario analysis to assess how transition risk scenarios, reflecting changes in coal market demand and prices linked to greenhouse gas emissions, could affect the quantity of proved and probable reserves that can be produced before reaching their economic limit. The revised technical protocols note that this disclosure may be included as part of Paragraph 22 of the IFRS S2 disclosures, which requires disclosure of the resilience of an entity's strategy and business model to climate-related changes, developments and uncertainties, taking into account identified climate-related risks and opportunities.

Security, Human Rights & Rights of Indigenous People

92As noted in Paragraph 84, the TAC is concerned that the term 'Human Rights' is no longer present within the disclosure topics following the removal of the 'Security, Human Rights & Rights of Indigenous People' disclosure topic.

93As noted in TAC Paper 2025-TAC-043 (Paragraphs 26 to 29), Metals and Mining: EM-MM-210a.3 and Oil & Gas – Exploration & Production: EM-EP-210a.3 are metrics which are marked to be deleted as part of the removal of the disclosure topic and the TAC is concerned in particular about the loss of Part Two of the technical protocol, which requested that:

The entity shall describe its due diligence practices and procedures with respect to upholding the principles covered in human rights frameworks, such as the: 2.1. International Labour Organization/Organisation (ILO) Declaration on Fundamental Principles and Rights at Work and the fundamental ILO conventions on freedom of association (No. 87), collective bargaining (No. 98), forced labour (No. 29 and No. 105), child labour (No. 138 and No. 182), fair wages (No. 100), and discrimination (No. 111); 2.2. United Nations Guiding Principles on Business and Human Rights, specifically Human Rights Due Diligence (Principle 17a-c); and 2.3. Voluntary Principles on Security and Human Rights.

94[The TAC could include this point in its response, subject to our discussions with the ISSB and considering stakeholder feedback.]

Workforce Health and Safety

95Construction Materials: EM-CM-320a.1 is a revised metric which had no 'fatality rate' sub-metric, but includes a new sub-metric requesting the number of fatalities. However, as there is a similar sub-metric in other standards for industries in the sector, we do not have any concerns about the proposed addition [subject to our discussions with the ISSB and any stakeholder feedback to the contrary].

Critical Incident Risk Management

96Oil & Gas – Exploration & Production: EM-EP-540a.2, Oil & Gas – Midstream: EM-MD-540a.6 and Oil & Gas – Services: EM-SV-540a.1 are metrics which have been revised or included with a view to reporters disclosing a description of management systems used to identify and mitigate ‘low probability, serious accidents'. The revisions replace the words 'catastrophic and tail-end risks' and may have an unintended consequence of being both interpreted and applied in a way that narrows the metric's scope by potentially excluding high probability, high impact accidents and emergencies – these appear to have been included within the scope of the original metric. Disclosure of high probability, high impact accidents and emergencies may be seen as even more material to primary users when assessing risks under IFRS S1 and IFRS S2.

97Oil & Gas – Midstream: EM-MD-540a.3 is a metric which requires the disclosure of non-accident releases from rail transport which may not be internationally applicable. This metric originated from the US where rail transport is a prominent mode of transport. Companies in other jurisdictions may rely on other modes of transport including pipeline or marine transport. There is no specific requirement or description in the associated protocol that specifies why this metric is only for rail transportation, and therefore the ISSB could remove ‘from rail transport' to make the metric internationally applicable.

Management of the Legal and Regulatory Environment

98Oil & Gas – Exploration & Production: EM-EP-530a.1, Oil & Gas – Refining & Marketing: EM-RM-530a.1 and Oil & Gas – Services: EM-SV-530a.1 are metrics which require the disclosure of positions related to government regulations or policy proposals affecting the industry. However, they, and other metrics in the SASB Exposure Draft, do not capture litigation risks. TAC members had mixed views about whether the metrics should reference litigation risks, as litigation risks may already be captured in IFRS Accounting Standards. However, the TAC agrees that connectivity between both sets of IFRS Standards is key. [Further information on this point is available in TAC Paper 2025-TAC-043 (Paragraphs 37 to 41) and the TAC could include this point in its response, subject to considering stakeholder feedback.]

Climate physical risks

99The TAC could suggest the ISSB considers whether acute and chronic climate physical risks (outside of water-related risks) are adequately reflected across the standards for industries in the Extractives & Minerals Processing sector [subject to considering stakeholder feedback]. [Further information on this point is available in TAC Paper 2025-TAC-043 (Paragraphs 42 to 44).]

Just transition risks

100The TAC could suggest the ISSB considers whether the Oil & Gas – Refining & Marketing SASB Standard, in particular, should be expanded to include metrics on just transition risks, with a view also to facilitating a more consistent approach with nature, and better aligning with IFRS S2 in an incremental way [subject to considering stakeholder feedback]. [Further information on this point is available in TAC Paper 2025-TAC-043 (Paragraphs 45 to 47).]

Jurisdictional considerations

QUESTION 6—COAL OPERATIONS SASB STANDARD

(f) Are there any jurisdictional considerations related to the Coal Operations SASB Standard that have not been addressed in the proposals that should be taken into account? If so, please explain.

QUESTION 7—CONSTRUCTION MATERIALS SASB STANDARD

(f) Are there any jurisdictional considerations related to the Construction Materials SASB Standard that have not been addressed in the proposals that should be taken into account? If so, please explain.

QUESTION 8—IRON & STEEL PRODUCERS SASB STANDARD

(e) Are there any jurisdictional considerations related to the Iron & Steel Producers SASB Standard that have not been addressed in the proposals that should be taken into account? If so, please explain.

QUESTION 9—METALS & MINING SASB STANDARD

(f) Are there any jurisdictional considerations related to the Metals & Mining SASB Standard that have not been addressed in the proposals that should be taken into account? If so, please explain.

QUESTION 10—OIL & GAS – EXPLORATION & PRODUCTION SASB STANDARD

(g) Are there any jurisdictional considerations related to the Oil & Gas – Exploration & Production SASB Standard that have not been addressed in the proposals that should be taken into account? If so, please explain.

QUESTION 11—OIL & GAS – MIDSTREAM SASB STANDARD

(f) Are there any jurisdictional considerations related to the Oil & Gas – Midstream SASB Standard that have not been addressed in the proposals that should be taken into account? If so, please explain.

QUESTION 12—OIL & GAS – REFINING & MARKETING SASB STANDARD

(e) Are there any jurisdictional considerations related to the Oil & Gas – Refining & Marketing SASB Standard that have not been addressed in the proposals that should be taken into account? If so, please explain.

QUESTION 13—OIL & GAS – SERVICES SASB STANDARD

(f) Are there any jurisdictional considerations related to the Oil & Gas – Services SASB Standard that have not been addressed in the proposals that should be taken into account? If so, please explain.

101Please refer to our comments on international applicability in Paragraphs 51 to 54.

QUESTION 6—COAL OPERATIONS SASB STANDARD

(g) Do you have any comments on how the proposed amendments would affect the Coal Operations SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? (Note that the ISSB is focused on providing material information for users about the effects of sustainability-related risks and opportunities on an entity's prospects.)

QUESTION 7—CONSTRUCTION MATERIALS SASB STANDARD

(g) Do you have any comments on how the proposed amendments would affect the Construction Materials SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? (Note that the ISSB is focused on providing material information for users about the effects of sustainability-related risks and opportunities on an entity's prospects.)

QUESTION 8—IRON & STEEL PRODUCERS SASB STANDARD

(f) Do you have any comments on how the proposed amendments would affect the Iron & Steel Producers SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? (Note that the ISSB is focused on providing material information for users about the effects of sustainability-related risks and opportunities on an entity's prospects.)

QUESTION 9—METALS & MINING SASB STANDARD

(g) Do you have any comments on how the proposed amendments would affect the Metals & Mining SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? (Note that the ISSB is focused on providing material information for users about the effects of sustainability-related risks and opportunities on an entity's prospects.)

QUESTION 10—OIL & GAS – EXPLORATION & PRODUCTION SASB STANDARD

(h) Do you have any comments on how the proposed amendments would affect the Oil & Gas – Exploration & Production SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? (Note that the ISSB is focused on providing material information for users about the effects of sustainability-related risks and opportunities on an entity's prospects.)

QUESTION 11—OIL & GAS – MIDSTREAM SASB STANDARD

(g) Do you have any comments on how the proposed amendments would affect the Oil & Gas – Midstream SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? (Note that the ISSB is focused on providing material information for users about the effects of sustainability-related risks and opportunities on an entity's prospects.)

QUESTION 12—OIL & GAS – REFINING & MARKETING SASB STANDARD

(f) Do you have any comments on how the proposed amendments would affect the Oil & Gas – Refining & Marketing SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? (Note that the ISSB is focused on providing material information for users about the effects of sustainability-related risks and opportunities on an entity's prospects.)

QUESTION 13—OIL & GAS – SERVICES SASB STANDARD

(g) Do you have any comments on how the proposed amendments would affect the Oil & Gas – Services SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? (Note that the ISSB is focused on providing material information for users about the effects of sustainability-related risks and opportunities on an entity's prospects.)

102Please refer to our comments on interoperability and alignment with other sustainability-related standards or frameworks in Paragraphs 55 to 63.

QUESTION 14—PROCESSED FOODS SASB STANDARD

(a) Do you agree with the proposed amendments to the Processed Foods SASB Standard? Why or why not?

103As noted in Paragraphs 7 and 19, not only is the TAC concerned about the adequacy of its engagement with UK stakeholders during the current consultation and in the development of its response to the ISSB, but it is also not ideal to consider changes to only one of nine standards for industries in the Food & Beverage sector, particularly given that two further standards for industries in the Food & Beverage sector are expected to be consulted on later this year. The TAC therefore encourages the ISSB to finalise the Processed Foods SASB Standard with the two further standards for industries in the Food & Beverage sector which are expected to be consulted on later this year or, ideally, with all the other standards for industries in the Food & Beverage sector.

104The TAC is therefore not ready to conclude on whether it agrees with the proposed amendments to the Processed Foods SASB Standard.

QUESTION 14—PROCESSED FOODS SASB STANDARD

(b) Do you agree with the Processed Foods industry description, and does it accurately describe the business activities of this industry? Do you agree with the industry classification that forms the basis of this Standard? Why or why not?

105The TAC does not have any concerns about the expanded industry description [subject to any stakeholder feedback to the contrary].

106Please refer to our comments on the industry classification system in Paragraphs 34 to 38.

QUESTION 14—PROCESSED FOODS SASB STANDARD

(c) Do you agree with the disclosure topics in the Processed Foods SASB Standard? Do they accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry?

107Again, the ISSB has not provided information on why certain disclosure topics are included in some standards in the Food & Beverage sector but not in others and it would be helpful to understand the prioritisation process used to determine their inclusion or exclusion. For example, there may be a case for including the following disclosure topics in the Processed Foods SASB Standard [subject to considering stakeholder feedback]:

'Air Emissions from Refrigeration' in the Food Retailers & Distributors SASB Standard as food processing companies produce ready-to-eat meals and frozen foods which require refrigeration.
'Food Waste Management' in the Food Retailers & Distributors SASB Standard as food processing companies also generate significant levels of food waste.

108The TAC has mixed views about whether all the disclosure topics in the Processed Foods SASB Standard are particularly relevant to sustainability, for example the 'Product Labelling & Marketing' disclosure topic. [The TAC could include this point in its response, subject to considering stakeholder feedback.]

QUESTION 14—PROCESSED FOODS SASB STANDARD

(d) Do you agree with the metrics and technical protocols in the Processed Foods SASB Standard? Do the metrics help an entity to provide information about sustainability-related risks and opportunities that is useful to users in making decisions relating to providing resources to the entity? If not, what would you suggest instead and why?

109The TAC has concerns about the significance of the changes to the metrics and technical protocols in the Processed Foods SASB Standard and the consequent challenges in terms of data availability and assurance. [The TAC could include this point in its response, subject to considering stakeholder feedback.]

110TAC members are concerned about a missing metric around ultra-processed foods and the removed metric around GMO products. Qualitative metrics in relation to these areas may work better than quantitative metrics. However, the TAC notes these could be jurisdiction-specific concerns. [The TAC could include this point in its response, subject to our discussions with the ISSB and considering stakeholder feedback.]

111[As noted in TAC Paper 2025-TAC-043 (Paragraphs 54 to 68), we are seeking stakeholder views on other changes to metrics and the TAC could include any such comments in its response.]

QUESTION 14—PROCESSED FOODS SASB STANDARD

(e) Are there any jurisdictional considerations related to the Processed Foods SASB Standard that have not been addressed in the proposals that should be taken into account? If so, please explain.

112Please refer to our comments on international applicability in Paragraphs 51 to 54.

(f) Do you have any comments on how the proposed amendments would affect the Processed Foods SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? (Note that the ISSB is focused on providing material information for users about the effects of sustainability-related risks and opportunities on an entity's prospects.)

113Please refer to our comments on interoperability and alignment with other sustainability-related standards or frameworks in Paragraphs 55 to 63.

Proposed targeted amendments to other SASB Standards

QUESTION 15—PROPOSED TARGETED AMENDMENTS TO THE SASB STANDARDS

(a) Do you agree with the proposal to align corresponding metrics in other SASB Standards beyond the nine priority industries to maintain consistent disclosures on these common topics in industries subject to equivalent disclosure requirements? Do you agree that doing so would improve the comparability of information? Why or why not?

(b) Do you agree that these proposed targeted amendments should be implemented before completing a comprehensive review of each of the SASB Standards affected by these amendments? Do you agree that this approach would support the objective of enhancing the SASB Standards to provide timely support to entities in applying IFRS S1? Why or why not?

(c) Do you agree with the proposed targeted amendments associated with greenhouse gas emissions? Why or why not?

(d) Do you agree with the proposed targeted amendments associated with energy management? Why or why not?

(e) Do you agree with the proposed targeted amendments associated with water management? Why or why not?

(f) Do you agree with the proposed targeted amendments associated with labour practices? Why or why not?

(g) Do you agree with the proposed targeted amendments associated with workforce health and safety? Why or why not?

(h) Are the proposed targeted amendments to the additional 41 industries appropriate and relevant for the individual SASB Standards? Are there any jurisdictional considerations related to these SASB Standards that have not been addressed in the proposals for targeted amendments that should be taken into account? If so, please explain.

(i) Do you agree that the proposed targeted amendments to the SASB Standards would enhance the interoperability and alignment with other sustainability-reporting standards and frameworks? Why or why not? (Note that the ISSB is focused on providing material information for users about the effects of sustainability-related risks and opportunities on an entity's prospects.)

114Subject to the general points above and in Paragraph 87 regarding the necessity of disclosing Scope 1 emissions within the SASB Exposure Draft, the TAC supports climate-linked targeted amendments for the 41 additional industries covering greenhouse gas emissions, energy management, and water management, before the completion of a comprehensive review. While there are both advantages and disadvantages to this approach, on balance the TAC believes that making targeted amendments can provide timely support for the implementation of IFRS S1 and IFRS S2, whilst also fostering consistency and comparability across industries.

115However, the TAC also takes the view that:

it would also have been helpful if the ISSB had publicly outlined, in its Basis for Conclusions, the criteria it used to determine whether topics and metrics qualify as a 'targeted amendment.'
it is not clear whether consideration was made as to whether the proposed climate-linked targeted amendment metrics are still relevant to the non-priority industries. In the event that the metric is considered no longer relevant, then there is a possibility that the amended metrics could ultimately be removed. The TAC recommends that the ISSB share an evaluation of the relevance of the proposed climate-linked targeted amendment metrics to the non-priority industries.
as noted in Paragraph 99, as IFRS S2 covers both climate physical and transition risks, it would also have been beneficial for the ISSB to have undertaken both research and engagement on climate physical risks (beyond water-related topics), with a view to considering whether or not corresponding climate-linked targeted amendments should also have been made. The point here is not that these topics automatically qualify for targeted amendment status, but rather that consideration should have been given to this, given that IFRS S2 extends to both climate physical and transition risks.
the methodology underpinning these targeted amendments is also somewhat limited given that targeted amendments would appear to have been made only where there are pre-existing topics and metrics. It would instead have been preferable to prioritise the topic of climate across all standards, or to adopt the sectoral approach whilst also considering whether such climate-linked targeted amendments should also have been extended to the other SASB Standards, such as the Gas Utilities & Distributers and Home Builders or Automobiles SASB Standards. This approach could help to ensure that climate-linked targeted amendments not only improve existing disclosures, but also promptly address any climate-related topic-level omissions, thereby enhancing both the relevance and completeness of climate reporting under IFRS S2.
with respect to targeted amendments relating to labour practices (which are typically more context specific) and human capital, the TAC considers such amendments to be premature. The ISSB's human capital project is ongoing, and there is arguably less global market consensus than exists for those climate-related topics discussed above.

116Please refer to our comments on interoperability and alignment with other sustainability-related standards or frameworks in Paragraphs 55 to 63.

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Name TAC Public Meeting October 2025 Paper 4: SASB Exposure Draft Comment Letter Points

Publication date 07 October 2025

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