The content on this page has been converted from PDF to HTML format using an artificial intelligence (AI) tool as part of our ongoing efforts to improve accessibility and usability of our publications. Note:

No human verification has been conducted of the converted content.
While we strive for accuracy errors or omissions may exist.
This content is provided for informational purposes only and should not be relied upon as a definitive or authoritative source.
For the official and verified version of the publication, refer to the original PDF document.

If you identify any inaccuracies or have concerns about the content, please contact us at [email protected].

TAC Public Meeting October 2025 Paper 3: Current SASB Standards reporting by UK Companies

AGENDA PAPER 3

Executive summary


Date	14 October 2025
Paper reference	2025-TAC-044
Project	Proposed amendments to the SASB Standards
Topic	Current SASB Standards reporting by UK Companies

Objective of the paper

This paper presents findings from a review of selected UK-registered and UK-listed companies, operating within the nine priority industries, which utilise the SASB Standards for their sustainability reporting. The objective of the review is to explore how these companies are currently applying the existing topics and associated metrics outlined in these standards, in order to gain insight into the potential impact of the proposed amendments on their reporting practices.

Decisions for the TAC

This paper is for information purposes only and no decision is required.

Appendices

There are no appendices to this paper.

This paper has been prepared by the Secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC) 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

SASB Standards enhancement project

1The International Sustainability Standards Board (ISSB) is undertaking a phased enhancement of the SASB Standards. The phased approach begins with nine priority industries that cover both the Extractives & Mineral Processing, and Food & Beverage sectors. The primary objective is to strengthen the SASB Standards in a way that:

improves their international applicability, including to emerging markets;
aligns more closely with IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures, ensuring clearer integration with the ISSB's broader framework;
increases interoperability with other standards and global frameworks, such as the European Sustainability Reporting Standards (ESRS), Global Reporting Initiative (GRI), and the Taskforce on Nature-related Financial Disclosures (TNFD);
reflects current sustainability challenges related to biodiversity, ecosystems and ecosystem services (BEES), and human capital; and
maintains a focus on investor-relevant information and decision-useful metrics.

2Supporting the effective implementation of IFRS S1 and IFRS S2 is a key priority of the ISSB, as noted in its 2024-2026 work plan. The SASB Standards are referenced in IFRS S1 as a source of guidance for identifying sustainability-related risks and opportunities where a topic-specific IFRS Sustainability Disclosure Standard does not yet exists.

3Although the draft UK Sustainability Reporting Standards (UK SRS) have proposed to amend IFRS S1 to state that entities 'may' (rather than 'shall') consider and refer to the SASB Standards, they remain an important resource for preparers and investors in the UK.

Purpose and methodology for reviewing UK companies' SASB Standards reporting practices

4The TAC Secretariat selected a targeted sample of UK-registered or UK-listed companies that use the priority SASB Standards that are subject to the ISSB's proposed amendments. Companies were identified using a combination of internal selection tools and the SASB website's list of companies reporting using SASB Standards. Market capitalisation was also considered to prioritise companies with significant market value.

5The number of companies selected per industry ranged from none to three, depending on the availability of UK companies using the relevant SASB Standards and the extent of their use.

6The table below summarises the number of representative companies we identified in each industry.

SASB Standard industry	Description of company representative	Sample size	Comments
Metals & Mining	FTSE 100 companies	2	Multiple users identified. Selection based on market capitalisation.
Coal Operations	-	-	No UK company identified in our search.
Construction Materials	2 FTSE 250 and 1 LSE/NYSE dual listed	3	Multiple users identified. Selection based on market capitalisation.
Iron & Steel Producers	Non-listed company	1	Limited use of the Standard in this industry. Only one private company identified.
Oil & Gas – Exploration & Production	FTSE 100	2	Multiple users identified. Selection based on market capitalisation.
Oil & Gas – Midstream	-	-	No UK company identified in our search.
Oil & Gas – Refining & Marketing	FTSE 100	1	Limited use of the Standard in the industry. Only one company identified in our search.
Oil & Gas – Services	FTSE 250	1	Limited use of the Standard. Only one company identified in our search.
Processed Foods	FTSE 250	2	Multiple users identified. Selection based on market capitalisation.

7As shown in the table above, no company was identified by our search process (which was basic in nature) to be using the Coal Operations and Oil & Gas – Midstream SASB Standards. The mining companies identified either do not use the SASB Standards, or where they do, the Coal Operations SASB Standard was not used for their reporting.

8For Iron & Steel Producers, a representative company was identified, but it had not published recent SASB-related disclosures. Its last SASB-related reporting year was 2023.

9The Secretariat's review was conducted at a high level and was not intended to assess compliance with the SASB Standards nor to provide a comprehensive analysis or definitive trends in SASB reporting practices among UK companies. Instead, the primary objective was to gain a broad understanding of how selected companies across priority industries are currently applying the existing SASB Standards topics and metrics in their reporting. The high-level review considered whether UK companies:

use more than one SASB Standard in their sustainability reporting;
demonstrate relevance of the reported topics and associated metrics to the UK context;
integrate SASB Standards topics and associated metrics into discussions of sustainability-related risks, opportunities, and other narrative disclosures;
have SASB Standards topics and associated metrics they commonly or rarely report;
use other sustainability standards or frameworks alongside their respective SASB Standards; and
disclose SASB Standards-related information in locations, such as annual reports, standalone sustainability reports, SASB indices, or other reporting channels.

10The findings, together with feedback from stakeholder outreach and desk research, are intended to support evaluation of the appropriateness of the ISSB's proposed SASB Standards amendments in the UK context and to inform the TAC's response to the Exposure Draft Proposed Amendments to the SASB Standards (the SASB Exposure Draft).

Findings

Overview of use of priority SASB Standards by UK companies

11The Secretariat observed notable use of the priority SASB Standards among UK companies. Within the Oil & Gas industries, the Oil & Gas – Exploration & Production SASB Standard is the most used Standard. Use of the Oil & Gas – Refining & Marketing; and Oil & Gas – Services SASB Standards is more limited with only a single company identified in each of these two industries. Our basic company search process did not identify any UK companies currently applying the Oil & Gas – Midstream SASB Standard. One entity listed on the SASB website as a UK user of the Oil & Gas – Midstream SASB Standard actually uses the Marine Transportation SASB Standard instead.

12The Secretariat also noted limited used of the Iron & Steel Producers SASB Standard among UK companies. One private company in administration was identified. However, it last published SASB-related disclosures in 2023.

13The Metals & Mining, Construction Materials, and Processed Foods industries include several companies using the SASB Standards. Companies using the Metals & Mining SASB Standard typically operate globally. In contrast, those in Construction Materials are predominantly domestic, though some have international operations. Companies using the Processed Foods SASB Standard tend to have a substantial domestic focus.

14All companies in our sample use SASB Standards voluntarily.

15Except for one company that reported using both the Oil & Gas – Services and the Industrial Machinery & Equipment SASB Standards, all others used a single SASB Standard for their reporting.

16Locations of reported disclosures were varied among the companies. Companies in the Processed Foods, Metals & Mining, and Oil & Gas – Exploration & Production industries typically published a separate SASB index report, with some of the information also incorporated into other reports such as a sustainability report or annual report. The other companies using the Oil & Gas – Services and Refining & Marketing; and the Construction Materials SASB Standards reported their SASB-related disclosures within a standalone sustainability report with other items in the annual report.

17Apart from two companies using the Construction Materials SASB Standard that indicated that they had made relevant SASB Standards disclosures, but did not clearly identify the specific SASB metric codes, all other companies in the sample provided a table that explicitly listed the SASB metric codes and cross-referenced them to the corresponding disclosure locations.

18The Secretariat noted that, in some cases, companies across industries made sustainability-related disclosures that go beyond those required by the SASB Standards, based on entity-specific financial materiality assessments. For example, food waste is not a required disclosure topic under the Processed Foods SASB Standard. However, both companies in our sample reported on this topic, demonstrating how entity-level materiality can lead to disclosures that span across different SASB Standards. Similarly, companies using the Oil & Gas – Exploration & Production; and Construction Materials SASB Standards reported on employee attraction and retention - topics not required by their respective Standards - linking these disclosures to the importance of maintaining and developing a skilled workforce.

19While companies in other industries disclosed SASB metrics with comparative information, those applying the Processed Foods SASB Standard did not include comparatives in the SASB index where such data was presented. This lack of comparatives makes it challenging for readers to assess trends. It may be that the inclusion of comparative figures is not explicitly required under the SASB Standard.

Reporting practices across SASB topics and associated metrics

Overview

20Disclosure topics and associated metrics that are commonly reported across all the priority SASB Standards include Processed Foods¹ SASB index), Energy Management, Water Management and Workforce Health & Safety.

21By contrast, disclosure topics such as Security, Human Rights & Rights of Indigenous Peoples showed significant disclosure variability among companies using the Metals and Mining and Oil & Gas – Exploration & Production SASB Standards. In particular, metrics relating to percentage of (1) proved and (2) probable reserves in/near Indigenous land or near areas of conflict were generally not reported. These were often marked as 'none' or 'not reported', as they were not considered relevant to the geographic context of the companies' operations.

Oil & Gas – Exploration & Production

22The companies using the Oil & Gas – Exploration & Production SASB Standard reported the following disclosure topics in a largely consistent manner:

Greenhouse Gas Emissions were reported similarly by both companies. However, both companies did not disclose the percentage of global Scope 1 emissions covered under emissions-limiting regulations. It should be noted that the SASB Exposure Draft introduces a new metric for total Scope 1 methane emissions under this topic;
Air Quality;
Water Management metrics EM-EP-140a.3 (percentage of hydraulically fractured wells with public disclosure of fracturing fluid chemicals) and EM-EP-140a.4 (percentage of hydraulic fracturing sites with deterioration in ground or surface water quality) were not reported by either company. The SASB Exposure Draft proposes to introduce new metric under this disclosure topic requiring total water discharged by (1) destination and (2) level of treatment;
Management of the Legal and Regulatory Environment;
Critical Incident Risk Management; and
Workforce Health & Safety.

23Biodiversity Impacts and Community Engagement related topics were generally disclosed narratively. However, Biodiversity Impacts metric EM-EP-160a.3 (percentage of petroleum reserves in or near conservation sites/endangered species habitats) was not reported by either company. For this disclosure topic, the SASB Exposure Draft proposes a new metric requiring (1) total spatial footprint of operations, (2) area disturbed and (3) area restored.

24Similarly, on Security, Human Rights & Rights of Indigenous People disclosure topic, both companies did not disclose the two metrics EM-EP-210a.1 (percentage of reserves in or near areas of conflict) and EM-EP-210a.2 (percentage in or near indigenous land), indicating either non-applicability or that there are no relevant sites. The SASB Exposure Draft proposes relocating these metrics under the disclosure topics Operations in Conflict Areas (EM-EP-210c.1) and Community Relations & Rights of Indigenous People (EM-EP-210b.3) respectively, despite the proposed removal of the Security, Human Rights & Rights of Indigenous People disclosure topic.

Oil & Gas – Refining & Marketing, and Services

25Companies using the Oil & Gas – Refining & Marketing and Services SASB Standards reported Greenhouse Gas Emissions, Water Management, and Health and Safety data quantitatively. However, many metrics under these SASB Standards topics presuppose asset ownership (e.g., refineries, pipeline kilometres, rig sites). Therefore, UK companies with asset-light business models note these metrics as not applicable.

Construction Materials

26One company using the Construction Materials SASB Standard reported all metrics across all topics required by this SASB Standard. The other two companies commonly reported Greenhouse Gas Emissions, Energy Management, Waste Management and Workforce Health & Safety. Some disclosures showed use of intensity measures (e.g., kg CO2 per tonne of cement) rather than absolute figures specified in the SASB Standard protocols. This approach is described by companies as aligning with benchmarking needs.

27While the SASB Exposure Draft proposes some changes to the commonly reported topics, major changes relate to Energy Management, where in addition to disclosing total energy consumed; further disaggregation of purchased electricity; alternative energy consumed; and renewable electricity consumed (from self-generation and direct contracts) would be required. Significant changes are also proposed to Water Management requiring disaggregation of total water withdrawal by source, total water consumed percentages of water (a) withdrawn and (b) consumed from water-stressed locations.

28Biodiversity Impact disclosures were mainly reported through narrative descriptions of quarry restoration and site management. One company did not provide SASB related biodiversity disclosures and no explanation was provided. It should be noted that the SASB Exposure Draft proposes a revised metric on Biodiversity Impacts requiring (1) total spatial footprint of operations, (2) area disturbed and (3) area restored.

29Disclosures relating to Air Quality and Pricing Integrity & Transparency, along with their associated metrics, were not provided by two companies, with no explanation given for their omission. While the SASB Exposure Draft does not propose significant changes to the Pricing Integrity & Transparency topic, it does introduce refinements to Air Quality disclosure.

30Supply chain disclosures are not currently required. However, the SASB Exposure Draft proposes a new topic on Supply Chain Management, requiring a description of processes for managing supply chain risks arising from environmental and social issues.

Metals & Mining

31The companies using the Metals & Mining SASB Standard commonly disclose Greenhouse Gas Emissions, Water Management, Waste & Hazardous Materials Management, Air Quality and Tailings Storage metrics quantitatively.

32While the SASB Exposure Draft proposes some changes to some of these topics, the changes are generally not extensive. More significant amendments relate to Water Management where new disaggregated metrics would be required. In addition, the SASB Exposure Draft also proposes the Energy Management disclosures showing (1) total energy consumed (2) purchased electricity consumed, (3) renewable electricity consumed (from self-generation and director contracts) and natural gas consumed.

33Health & Safety statistics are also reported predominantly quantitatively in areas of fatalities, recordable incident rates while processes and safety events are qualitative. However, neither company reported data about the average hours of health, safety, and emergency response training provided to (a) direct employees and (b) contract employees as required by the Standard. One company cited a lack of available information, while the other did not provide any explanation for the omission.

34Biodiversity Impacts are typically discussed qualitatively, with narratives on land rehabilitation, acid rock drainage, or protected area engagement, but without consistent quantitative metrics. For this disclosure topic, the SASB Exposure Draft proposes a new metric relating to (1) total spatial footprint of operations, (2) area disturbed and (3) area restored that companies would be required to report.

35Both companies in the sample did not currently report two metrics under the Security, Human Rights & Rights of Indigenous Peoples disclosure topic, EM-MM-210a.2 (Percentage of (1) proved and (2) probable reserves in or near Indigenous land) and EM-MM-210a.1 (Percentage of (1) proved and (2) probable reserves in or near areas of conflict). There were varied explanations for not disclosing these including having no reserves in or near conflict areas to having no data available. The SASB Exposure Draft proposes to still require these disclosures though now located under separate topics.

36In terms of Business Ethics & Transparency disclosures both companies explained that they had no production in the countries that have the 20 lowest rankings in Transparency International's Corruption Perception Index.

37Similar to the Construction Materials SASB Standard, the current Standard does not require supply chain related disclosures. However, the SASB Exposure Draft proposes a new Supply Chain Management disclosure topic which would require companies to describe their process for managing supply chain risks arising from environmental and social issues.

Processed Foods

38The companies using the Processed Foods SASB Standard commonly reported the following disclosure topics and their associated metrics: Energy Management, Water Management, Packaging Lifecycle Management, and Food Safety data quantitatively. All these topics have significant changes proposed in the SASB Exposure Draft.

39Ingredient Sourcing and Environmental and Social Impacts of Ingredient Supply Chain disclosures were largely qualitative, with selective quantitative indicators for both companies. The Exposure Draft proposes changes merging the Ingredient Sourcing into Supply Chain disclosure and further disaggregating the supply chain disclosure topic into social related and environment related supply chain topics. Considering that companies in this industry operate at the tail end of the food supply chain, they addressed many aspects relevant to the disclosure requirements in this area. One company provided qualitative but detailed reporting on topics such as human rights, supplier engagement, food waste, and sustainable and regenerative agriculture.

40Health & Nutrition and Product Labelling & Marketing disclosures varied. One company did not report Product Labelling & Marketing or revenue from health-related labelling, noting that its business model does not involve product labelling. Therefore, the metrics were explained as 'not applicable.'

Iron & Steel Producers

41The use of the Iron & Steel Producers SASB Standard among UK companies is less prevalent. One company that reported under this Standard focused on energy intensity and emissions per tonne of steel. Reporting frequency in the sector has been inconsistent, in part due to corporate restructuring.

Coal Operations and Oil & Gas – Midstream

42There are no observation to report for the Coal Operations and Oil & Gas – Midstream SASB Standards, as our basic search and selection process did not identify any UK companies using these Standards.

Jurisdictional relevance of SASB Standards, topics and associated metrics

43The companies in the sample using the Processed Foods SASB Standard disclosed Water Management, Food Safety and Health and Nutrition with a UK focus. While one company reported metrics relating to Product Labelling and Marketing, the other company did not, and it explained the non-reporting as a reflection of its specific business model where it does not label products under its own brand, rather than indicating irrelevance to the UK context.

44The companies using the Metals & Mining SASB Standard typically have global operations and do not have a direct UK operational footprint. Disclosures covered Greenhouse Gas Emissions, Energy Management, Water Management, Tailings Storage, Biodiversity Impacts and Community-related relations. As the companies do not have UK operations, the reported metrics could not be directly assessed for UK relevance. These were observed to be explained in the context of areas of primary business operations.

45The company using the Construction Materials SASB Standard, and those using the Oil & Gas Standards typically had international operations with partial UK presence. The reporting reflected jurisdictional diversity, with metrics such as Biodiversity Impacts, Community relations, Waste and Hazardous Materials Management, and Water Management tailored to the risks and opportunities in their primary business regions.

46The company reporting under the Iron & Steel Producers SASB Standard operates globally, in addition to its UK operations. Its quantitative metrics were presented as intensity figures, for example, emissions per tonne of steel rather than absolute values. This presentation was explained as providing relevant industry benchmarking information rather than representing jurisdictional adaptation.

47The multi-jurisdictional nature of many extractive sector companies underscores the importance of the ISSB's objective to ensure that enhanced SASB Standards are internationally applicable, including in emerging markets. It also highlights the need for technical protocols and reconciliation guidance to support consistent reporting across jurisdictions and different business models.

48All companies reviewed used the SASB Standards alongside other sustainability frameworks, with the Global Reporting Initiative (GRI) Standards and Taskforce on Climate-related Financial Disclosures (TCFD) being the most common. One major FTSE 100 mining company applying the Metals & Mining SASB Standard also reported under GRI Standards (as required by International Council on Mining and Metals membership), TCFD (as required by UK listing rules), and indicated plans to adopt the Australian Sustainability Reporting Standard AASB S2 Climate-related Disclosures from 2026. It also mentioned monitoring developments in the EU's Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD).

49Other companies including those using the Processed Foods, Construction Materials, and Oil & Gas Standards similarly use the SASB Standards alongside GRI Standards and TCFD. However, the company using the Iron & Steel SASB Standard reported its SASB Standard disclosures alongside GRI disclosures and no other framework was identified.

50The widespread use of multiple frameworks/standards reinforces the importance of interoperability between SASB Standards and other standards and frameworks to reduce burdens to preparers. It also underscores the risk of metric duplication and definitional divergence, which the ISSB should address through its mapping and harmonisation processes in its SASB Standards enhancement project.

51Most of the companies using the seven researched priority standards reported all climate-related topics, including Greenhouse Gas Emissions, Energy Management and Water Management, and associated metrics. Only one company in the Construction Materials industry did not report energy management metrics in its list of SASB disclosures and did not provide a comment on the commission.

52The company using the Iron & Steel SASB Standard reported all climate-related topics and metrics but used intensity measures which differ from some SASB Standard unit of measure specifications.

53The notable climate reporting seems consistent with the ISSB's objective to support the implementation of IFRS S1 and S2 and proposal for targeted amendments on climate related topics and metrics to other 41 industries. It's also consistent with ISSB plan for targeted amendments to IFRS S2 Industry-based Guidance.

54Not all nature and human capital topics and associated metrics in current SASB Standards were reported by companies in the sample. Biodiversity Impacts disclosures tended to be narrative, with selective quantitative data (for example, land disturbed/restored; acid rock drainage mitigation). Human capital metrics such as Health & Safety were reported quantitatively, but training hours and diversity metrics were often incomplete or described as 'work in progress'. Companies cited data limitations and definitional inconsistencies (for example, how contractors are treated versus direct employees) as constraints.

55Disclosures that include security, human rights and rights of indigenous people were normally not reported, or were indicated as none, particularly by companies using the Metals & Mining and Oil & Gas – Exploration & Production SASB Standards.

Integration of SASB topics and associated metrics into risks and opportunities reporting

56SASB Standards topics were integrated into risks and opportunities disclosures in varying ways. Some companies embedded SASB topics into principal risks and uncertainties disclosures. While this review did not assess every linkage in detail, asset-intensive companies using the Metals & Mining and Oil & Gas – Exploration & Production Standards discussed climate-related judgements in the context of asset impairment within the financial statements notes.

57Companies across industries also discussed materiality assessments, with most reporting the use of a double materiality framework. SASB Standards disclosure topics in these industries generally aligned with the materiality assessments. However, the double materiality process often surfaced additional topics beyond those covered by SASB disclosure topics. This reflects the broader scope of double materiality, which considers both financial relevance and societal and environmental impact.

Next steps

58The Secretariat will supplement these findings with stakeholder outreach feedback and, where relevant, desktop research to inform a response to the Proposed amendments to the SASB Exposure Draft.

It should be noted that although the Processed Foods SASB Standard does not require GHG emissions and it was therefore not included in the company's SASB index, the company did report extensive climate disclosures including GHG emissions in its annual report. ↩

File

Name TAC Public Meeting October 2025 Paper 3: Current SASB Standards reporting by UK Companies

Publication date 07 October 2025

Format PDF, 292.8 KB

Download original

TAC Public Meeting October 2025 Paper 3: Current SASB Standards reporting by UK Companies

File

Is this page useful?