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TAC Public Meeting October 2025 Paper 2: TAC Update October 2025
Executive summary
| Date | 14 October 2025 |
| Paper reference | TAC-Update-Oct-2025 |
| Project | Monitoring |
| Topic | October 2025 General Reporting Update |
Objective of the paper
This paper provides key updates since the update paper published for the September 2025 TAC meeting.
This includes a summary of the ISSB meetings and related developments, in addition to jurisdictional developments in relation to the adoption of IFRS Sustainability Disclosure Standards to date.
The information in this paper is provided as at 30 September 2025 and does not include any developments after this date.
Decisions for the TAC
There are no decisions required. This paper is for information only.
Appendices
Appendix 1 – Jurisdictional developments.
This paper has been prepared by the Secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC). It does not represent the views of the TAC or any individual TAC member.
Context
1The objective of this paper is to inform the TAC of international and jurisdictional developments in sustainability-related reporting. It is for information purposes only and does not ask the TAC to make any decisions.
2The TAC will be provided with an update of UK-specific, international and jurisdictional developments on sustainability-related reporting at each of its meetings.
UK developments
3The following paragraphs provide a summary of updates from the UK in relation to sustainability-related reporting since the last update paper published for the September 2025 TAC meeting.
4The UK Government's consultations on UK Sustainability Reporting Standards (UK SRS), sustainability assurance, and transition plans closed on 17 September. The Government will now consider responses before finalising plans. In responses made public by their authors, both the GRI and ICAS have called on the Government to adopt a double materiality approach rather than the financial materiality approach followed by UK SRS in line with the ISSB Standards. In its response to the consultation, ICAEW also supported the endorsement of UK SRS S1 and S2, calling for proportionate implementation, a phased approach to transition planning, and a clear pathway to mandatory assurance registration. On the assurance consultation, the ACCA has supported the Government's plan to introduce voluntary registration rules for sustainability assurance, but recommended a 'clear pathway towards mandatory registration' is set.
5The Bank of England PRA has proposed simplifications to regulatory reporting requirements for banks. This includes deleting 37 individual reporting templates, which the PRA says cover data that is no longer necessary, or available elsewhere. Consultation of the proposed amendments is open until 22 October.
International Sustainability Standards Board & other international body developments
6The following paragraphs provide a summary of updates from the International Sustainability Standards Board since the last update paper published for the September 2025 TAC meeting.
7On 24-26 September 2025, the ISSB held its monthly meeting to advance work on nature-related disclosures and greenhouse gas emissions reporting. The Board discussed how IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures, alongside SASB Standards and the Climate Disclosure Standards Board framework, could address user needs around biodiversity and ecosystems, with further consideration of Taskforce on Nature-related Financial Disclosures recommendations planned. It also reviewed proposed amendments to selected SASB Standards and continued redeliberations on targeted changes to IFRS S2, including Scope 3 Category 15 emissions, industry classification systems, and jurisdictional relief. On IFRS S2, Scope 3 targeted amendments consultation feedback the Board tentatively approved the followings amendments:
- to provide relief from disclosing certain Scope 3 emissions beyond financed activities;
- allow flexibility in industry classification systems, effectively removing the previous proposal to follow the classification hierarchy that would mandate the use of Global Industry Classification Standard (GICS) in certain cases; and
- extend jurisdictional relief to alternative GHG measurement methods and global warming potential values.
The amendments are set to take effect from 1 January 2027, with final issuance expected by the end of 2025.
8The IFRS Foundation announced that Sue Lloyd has been reappointed to serve a second term of four years as Vice-Chair of the ISSB starting 1 March 2026. Board members Elizabeth Seeger and Hiroshi Komori have both been reappointed. Michael Jantzi and Tae-Young Paik will both also step down from their roles when their terms end on 30 September 2025, as the ISSB transitions from 14 members to 10 members over the next three years.
9The Greenhouse Gas Protocol and International Organisation for Standardisation (ISO) have announced a strategic partnership, under which they will combine their GHG emissions accounting and reporting standards, and work on a joint carbon footprint standard.
10The Greenhouse Gas Protocol have published a blog post detailing their upcoming consultation on revisions to Scope 2 Guidance (2015). This will be released in October 2025, with a 60-day public consultation period. The consultation proposes retaining the existing structure of the Scope 2 Framework and will focus on the location-based method, market-based method, and implementation measures for feasibility. The overall timeline is available here.
Jurisdictional developments
11The following paragraphs provide a summary of updates from other jurisdictions in relation to sustainability-related reporting since the last update paper published for the September 2025 TAC meeting.
Australia
12The Australian Accounting Standards Board (AASB) has published educational material on Greenhouse Gas emissions measurement and disclosure requirements in line with AASB S2, which is aligned to IFRS S2.
European Union
13A joint statement from the French and German governments has been published, asking the EU to introduce a ‘1 for 1' rule whereby any new reporting requirements are balanced by an equivalent cost reduction.
14The vice chair of EFRAG has commented on the omnibus proposal to change the scope for Corporate Sustainability Reporting Directive, so that where before companies with more than 250 employees would have to report under it, now only firms with more than 1000 employees would have to report under it. Kerstin Lopatta, EFRAG vice chair, has told Responsible Investor that this is 'counterproductive' as 'even companies that previously had to report under the Non-Financial Reporting Directive are now partially out of scope'.
15On 30 September, EFRAG's public consultation to simplify the European Sustainability Reporting Standards (ESRS) closed for public comments. Following the close, EFRAG will review the results and provide its final technical advice on the ESRS to the European Commission by 30 November 2025.
16The German government has tabled a bill related to its national supply chain due diligence law, the LkSG, designed to 'limit administrative burdens'. The law is closely aligned to the EU's Corporate Sustainability Due Diligence Directive, which must be transposed into national law by 2027. Changes to the LkSG will therefore only apply during the transitional period.
17A joint statement from 265 academics has been published, asking the EU to pursue omnibus simplifications ‘without compromising the integrity and ambition of these vital regulations'.
18Meanwhile, the US Securities and Exchange Commission Chair Paul Atkins raised 'significant concerns' over the EU's double materiality approach during a keynote speech at the Organisation for Economic Co-operation and Development roundtable on Global Financial Markets on 10 September.
Switzerland
19Switzerland has also announced that they are looking at EU-aligned corporate sustainability due diligence, and will publish a draft in March 2026.
Thailand
20The Securities and Exchange Commission of Thailand has proposed provisions to establish a climate reporting regime aligned with the ISSB for listed companies for the next five years, before transitioning to disclosures on other sustainability topics.
Appendix 1 – Jurisdictional developments
G20 jurisdictions committed to adopting IFRS Sustainability Disclosure Standards
Table 1 summarises the status of G20 jurisdictions publicly committed to adoption or other use of the IFRS Sustainability Disclosure Standards.
Table 1: G20 jurisdictions (countries and regional bodies) summary as at 30 September 2025.
| Jurisdiction | Current status | Both IFRS S1 & IFRS S2? | Reporting commencing from | Companies in scope |
|---|---|---|---|---|
| African Union: Ghana | Endorsed | Both | 2027-2028 | Significant Public Interest Entities (Listed & unlisted) |
| African Union: Kenya | Endorsed and published roadmap | Both | 2025-2027 | Public Interest Entities; Non-Public Interest Entities (large entities); Small- to Medium-Sized Entities |
| African Union: Morocco | Publicly committed | - | - | - |
| African Union: Nigeria | Endorsed and published roadmap | Both | 2028-2030 | Public Interest Entities; Small- to Medium-Sized Entities |
| African Union: Rwanda | Endorsed and published roadmap | Both | 2025-2026 | Listed & unlisted |
| African Union: Tanzania | Endorsed | Both | 2025 | Listed & unlisted |
| African Union: Uganda | Endorsed | Both | 2026-2028 | Listed |
| African Union: Zambia | Endorsed | Both | 2025 | Listed |
| African Union: Zimbabwe | Publicly committed | - | - | - |
| Australia | Endorsed | Both: IFRS S1-voluntary IFRS S2 - mandatory |
2025 | Listed & unlisted |
| Brazil | Endorsed | Both | 2026 | Listed |
| Canada | Endorsed | Both | 2025 | Currently voluntary |
| China | Consultation on Climate ED closed | Both (but uses a double materiality approach) | 2026-2030 | Listed & unlisted |
| India | Consultation closed | IFRS S2 only | 2025-2029 | Banking & finance |
| Indonesia | Endorsed | Both | 2027 | To be confirmed |
| Japan | Endorsed | Both | - | Listed |
| Mexico | Endorsed | Both | 2026 | Listed and private |
| South Korea | Consultation closed | Both | 2026-2030 | Listed |
| Turkey | Endorsed | Both | 2024 | Regulated financial institutions & large companies |
Other jurisdictions committed to adopting IFRS Sustainability Disclosure Standards
Table 2 summarises the status of non-G20 jurisdictions publicly committed to adoption or other use of the IFRS Sustainability Disclosure Standards.
Table 2: Other jurisdictions summary as at 30 September 2025.
| Jurisdiction | Current status | IFRS S1 & IFRS S2? | Reporting commencing from | Companies in scope |
|---|---|---|---|---|
| Bangladesh | Endorsed | Both | 2024-2027 | Banking & finance |
| Bolivia | Endorsed | Both | 2027 | Listed & unlisted |
| Chile | Endorsed | Both | 2026 | Listed |
| Costa Rica | Endorsed | Both | 2025-2026 | Listed & unlisted |
| Hong Kong | Endorsed | Both | 2025 | Listed |
| Jordan | Endorsed | Both: IFRS S1 – voluntary FRS S2-Mandatory |
2027 | All entities listed in the ASE20 index |
| Malaysia | Endorsed | Both | 2025-2027 | Listed & large unlisted |
| Panama | Publicly committed | - | - | - |
| Pakistan | Endorsed | Both | 2025-2027 | Listed & unlisted public interest companies |
| Philippines | Consultation open | Both | 2026 | Listed |
| Qatar | Consultation closed | Both | 2026 | Listed |
| Singapore | Endorsed | IFRS S2 only | 2025-2027 | Listed |
| Sri Lanka | Endorsed | Both | 2025 | To be confirmed |
| Switzerland | Consultation closed - amending the Ordinance on Climate Disclosures | Both | 2026 | Listed & unlisted |
| Taiwan | Endorsed | Both | 2026-2028 | Listed |
| Thailand | Endorsed | Both | 2026-2030 | Listed |
G20 jurisdictions not publicly committed to adopting IFRS Sustainability Disclosure Standards
Table 3 summarises the status of G20 jurisdictions not publicly committed to adoption or other use of the IFRS Sustainability Disclosure Standards.
Table 3: G20 jurisdictions (countries and regional bodies) not publicly committed to adopting ISSB as at 30 September 2025.
| Jurisdiction | Current status | Topics | Reporting commencing from | Companies In scope |
|---|---|---|---|---|
| Argentina | Unconfirmed | - | - | - |
| European Union (EU)* | European Sustainability Reporting Standards (ESRS) & Corporate Sustainability Reporting Directive (CSRD) | Ten topical standards including a general and climate change standard | 2024-2028 | Listed & unlisted |
| Russia | Unconfirmed | - | - | - |
| Saudi Arabia | Unconfirmed | - | - | - |
| South Africa | Unconfirmed | - | - | - |
| United States of America | California Corporate Climate Accountability Act (SB 253 and SB 261) - adopted | California: 2026 | California: Listed & unlisted | |
| New York Climate Corporate Data Accountability Act (SB 3456) - bill | New York: 2027 - 2028 | New York: Listed & unlisted | ||
| Colorado Corporate Climate Accountability Act (House Bill 25-119) - bill | Colorado: 2028 - 2031 | Colorado: Listed & unlisted |
- Although European Sustainability Reporting Standards are required to be used by EU member states, the IFRS Foundation and EFRAG issued interoperability guidance in 2024 illustrating the high level of alignment achieved between ISSB Standards and ESRS. Note that this is subject to change as EFRAG finalises amendments to its standards arising from the simplification project.