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TAC Public Meeting November 2025 Paper 6: SASB Phase 1 Due Process Summary

AGENDA PAPER 6
Executive summary
| Date | 11 November 2025 |
| Paper reference | 2025-TAC-050 |
| Project | Proposed amendments to SASB Standards |
| Topic | Due process summary |
Objective of the paper
This paper presents a brief summary of the due process followed in the development of the TAC's comment letters on phase one of the proposed amendments to the SASB Standards issued by the International Sustainability Standards Board (ISSB).
Decisions for the TAC
The TAC is asked whether it has any comments on and tentatively approves the due process summary.
Appendices
Appendix – Due process summary
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.
Due process summary
1The TAC's Due Process Policy (DPP)1 states that the TAC would usually publish a due process summary for its work developing a comment letter.
2A draft due process summary is tabled alongside the TAC's final comment letters on phase one of the proposed amendments to the SASB Standards for discussion and tentative approval in this meeting.
3The appendix includes a copy of the draft due process summary.
Next steps
4The final due process summary will be tabled at a future meeting for discussion and approval.
Questions for the TAC
- Does the TAC have any comments on the due process summary in the appendix?
- Does the TAC tentatively approve the due process summary?
Appendix – Due process summary
Project initiation
| Due process tasks | Status | Comments |
|---|---|---|
| A project management plan, including target timeline, is prepared and approved by the TAC. The project management plan is published on the FRC website. | Expected | The project management plan was published (Paper 2025-TAC-040) and approved at a public meeting on 16 September 2025. It is available on the FRC website via the above link. |
Project delivery, including performing technical analysis
| Due process tasks | Status | Comments |
|---|---|---|
| The TAC, and FRC as TAC Secretariat, undertake outreach with UK stakeholders. | Expected | The FRC as TAC Secretariat undertook outreach with UK stakeholders by identifying key stakeholders and engaging with them via interviews and a roundtable. A public survey was also open for responses for nine weeks. Stakeholders reached included investors, preparers from the nine priority industries, accountancy firms, professional bodies, academics, not-for-profits, and other consultancies. |
| A draft comment letter with an invitation to comment is prepared, approved by the TAC and published on the FRC website. | Optional | The TAC decided not to undertake a public consultation given the volume of material and limited resource capacity in the Secretariat. This also ensured the assessment was proportionate, given the voluntary nature of the SASB Standards. The TAC undertook targeted outreach with UK stakeholders instead. |
| Research activities are reviewed and noted by the TAC. | Optional | The TAC Secretariat's research activities included: - performing a desktop analysis of the proposed amendments, including their Basis for Conclusions; - reviewing available ISSB outputs including staff papers and meetings; - assessing relevant third-party commentary and publications; - and - reviewing selected companies' use of the SASB Standards in their annual reports. These activities informed the development of the TAC's technical papers, available on the FRC website. |
| A final comment letter is prepared and approved by the TAC. | Mandatory | The TAC is asked whether it has any comments on and approves the comment letters in Paper 2025-TAC-048 and Paper 2025-TAC-049. |
| The final comment letter is submitted to the ISSB or other consultative body and published on the FRC website. | Mandatory | The final comment letter will be submitted to the ISSB once it has been approved and it will also be published on the FRC website. |
| A stakeholder feedback summary is prepared and approved by the TAC. The stakeholder feedback summary is published on the FRC website. | Expected if a draft comment letter has been published for consultation | Although the TAC decided not to undertake a public consultation on the draft comment letters, a summary of stakeholder feedback from the roundtable, survey and one-to-one interviews has been published (Paper 2025-TAC-047). |
Project closure
| Due process tasks | Status | Comments |
|---|---|---|
| A due process summary is prepared and approved by the TAC. The due process summary is published on the FRC website. | Expected | The TAC is asked whether it has any comments on and tentatively approves the draft due process summary. The final due process summary will be tabled at a future meeting. |
| A lessons learnt exercise is performed by the TAC. | Optional | The TAC will perform a lessons learnt exercise in private at the November meeting. |
TAC meetings
| Due process tasks | Status | Comments |
|---|---|---|
| There are a number of requirements in the TAC's ToR relating to meetings, including that: - meetings are quorate; - recordings are available on the FRC website within 5 working days; - agendas and technical papers are agreed by the TAC Chair, circulated to |
Mandatory | The project was discussed in public meetings held on 8 July, 16 September, 14 October 2025. It will be discussed in a public meeting held 11 November 2025. As of 29 October 2025 (the date of preparing this draft summary), the meetings have complied with due process. Meetings agendas, technical papers, summaries and recordings, are available on the FRC website. All agendas, papers and recordings were published within the timeframe specified by the TAC's Terms of Reference. An administrative delay meant the summary for the October meeting was published online slightly past the ten working day deadline, at 10:45am on the eleventh working day. - members at least 5 working days in advance and published on the FRC website; and - summaries are approved by the TAC Chair and published on the FRC website within 10 working days. |
Conclusion
As at 29 October 2025, the development of the comment letter has complied with due process.
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The TAC's DPP is available at: https://www.frc.org.uk/library/external-groups/uk-sustainability-disclosure-tac/uk-sustainability-disclosure-tac-terms-of-reference/ ↩