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

Logo for the UK Sustainability Disclosure Technical Advisory Committee.

AGENDA PAPER 4

Executive summary
Date 11 November 2025
Paper reference 2025-TAC-048
Project Proposed amendments to SASB Standards
Topic SASB Exposure Draft Comment Letter

Objective of the paper

The paper presents the TAC's draft response to the Exposure Draft Proposed Amendments to the SASB Standards (the SASB Exposure Draft) for discussion and approval in the meeting.

Decisions for the TAC

The TAC is asked for its views on the draft response to the SASB Exposure Draft and, in particular, the draft:

  • Covering letter in Paragraphs 7 to 14
  • General points in Appendix 1
  • Answers to the questions in Appendix 2.

The TAC is asked to approve the draft response.

Appendices

  • Appendix 1: Draft general points in relation to the SASB Exposure Draft.
  • Appendix 2: Draft answers to the questions in the SASB Exposure Draft.
  • Appendix 3: Summary of stakeholder outreach and research activities.

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 out of twelve priority industries: all eight industries in the Extractives & Minerals Processing sector and one in the Processed Foods industry. The ISSB 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 discussed an analysis of the proposed amendments to the nine priority SASB Standards. In its October 2025 meeting, the TAC shared it views on the points to include in the TAC's response to the SASB Exposure Draft.

3This paper develops the areas covered in the TAC's previous papers and presents the TAC's draft response to the SASB Exposure Draft for discussion and approval in the meeting.

4If the TAC approves the draft response to the SASB Exposure Draft—subject to any final comments—and authorises the Chair to resolve any edits arising from those comments, the document will then undergo final proofreading and formatting. Once completed, the TAC's final response to the SASB Exposure Draft will be submitted to the ISSB and published on the FRC website.

5The accompanying TAC paper 2025-TAC-049 IFRS S2 Industry-based Guidance Exposure Draft Comment Letter presents the TAC's draft response to the consultation on the consequential amendments to the IFRS S2 Industry-based Guidance.

6TAC paper 2025-TAC-047 Summary of stakeholders' feedback presents a stakeholder feedback summary and TAC paper 2025-TAC-050 Due process summary presents a draft due process summary for the TAC's project.

Covering letter

Exposure Draft SASB/ED/2025/1: Proposed Amendments to the SASB Standards

7The UK Sustainability Disclosure Technical Advisory Committee (TAC) welcomes the opportunity to provide comments on the ISSB's Exposure Draft of Proposed Amendments to the SASB Standards (the SASB Exposure Draft).

8This letter sets out our key points for consideration and is accompanied by appendices containing our general points in relation to the SASB Exposure Draft and our detailed responses to the specific questions posed by the ISSB.

9The TAC is an independent expert advisory body, established by the UK Government, whose purpose is to assess IFRS Sustainability Disclosure Standards on a technical basis and provide independent recommendations on endorsement to the Business and Trade Secretary. The TAC also has responsibility to undertake outreach with, and provide a focal point for, UK stakeholders to influence the technical development of IFRS Sustainability Disclosure Standards. This includes the way the ISSB develops its future standards and the ISSB's choices to amend or produce guidance on existing standards.

10The TAC is formed of a chair and members from a range of relevant professional backgrounds. The TAC's response to the SASB Exposure Draft has been developed following the discussions of TAC members in public meetings. It takes into account the views of UK stakeholders and is accompanied by an appendix summarising the stakeholder outreach and research activities contributing to the development of the TAC's response to the ISSB.

11The TAC's response has been developed considering the UK context and, in particular, the UK Government's recent consultation on draft UK Sustainability Reporting Standards (UK SRS). While the TAC had differing views about 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, it recommended maintaining the requirements without amendment in its December 2024 report UK Endorsement of IFRS S1 and IFRS S2. Our stakeholder outreach and research activities, however, suggest that there continues to be confusion about the status of the SASB Standards in the ISSB's Standards. The word 'shall' in the context of the IFRS S1 and IFRS S2 requirements was considered to be prescriptive and having the potential to cause reporting burdens and assurance challenges. The UK Government then consulted on proposals to amend 'shall' to 'may' in the draft UK SRS S1 and draft UK SRS S2 and preparers note that the proposed change enables entities to apply judgement in determining the extent of use of the SASB Standards for their reporting.

12The TAC's response therefore focuses on the SASB Standards being industry-based guidance. However, the TAC notes that entities are also applying the SASB Standards in a standalone way, regardless of whether they are applying IFRS S1 and IFRS S2. The TAC encourages the ISSB to also consider the impact of its proposals on these entities.

The value of industry-based guidance

13The TAC notes that UK stakeholders generally welcomed sources of guidance, including the SASB Standards, 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 believes that the SASB Standards could play an important role in supporting the implementation of IFRS S1 and IFRS S2. Our stakeholder outreach and research activities also suggest that there are some concerns about the current SASB Standards, along with general support for an ISSB project to enhance them – albeit the majority of views were from entities currently using the SASB Standards, rather than those yet to use them.

14The ISSB's project to enhance the SASB Standards is important, providing the ISSB with the opportunity to ensure that its industry-based guidance aligns with and complements the IFRS Sustainability Disclosure Standards, as well as adapting and keeping pace with changes. The TAC encourages the ISSB to be brave with its proposals and cautions that being overly attached to the status quo could result in stakeholder disengagement. In particular, the TAC recommends that:

  • as a priority, the ISSB communicates the future architecture of IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture;
  • the ISSB considers restructuring the SASB Standards to distinguish between core disclosures, industry-agnostic disclosures and industry-specific disclosures;
  • the ISSB considers including core and industry-agnostic disclosures in IFRS S1, IFRS S2 and any further topic-specific IFRS Sustainability Disclosure Standards, while the SASB Standards are focused on industry-specific disclosures;
  • the ISSB adopts a principles-based, not rules-driven, approach so that the standards and guidance can adapt and keep pace with changes;
  • the ISSB considers adopting a climate-first thematic approach by enhancing the climate-related content in the SASB Standards first and then enhancing the content related to other topics in the SASB Standards; and
  • the ISSB could also consider prioritising the development of further topic-specific materials.

Questions for the TAC

(i) The TAC is asked for its views on the draft response to the SASB Exposure Draft and, in particular, the draft:

  • Covering letter in Paragraphs 7 to 14
  • General points in Appendix 1
  • Answers to the questions in Appendix 2, including:
    • Paragraph 77 on Scope 1 methane emissions
    • Paragraphs 79 to 81 on human rights
    • Paragraphs 82 and 83 on litigation risks
    • Paragraph 84 on climate physical and just transition risks.

(ii) Does the TAC approve the draft response?

Appendix 1: Draft general points in relation to the SASB Exposure Draft

Architecture of IFRS Sustainability Disclosure Standards, including the incorporation of SASB Standards

15The TAC recommends that, as a priority, the ISSB communicates the future architecture of IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture. The architecture should prioritise the continuance of the global baseline of sustainability disclosures for capital markets established by IFRS S1 and IFRS S2. In its 2023 response to the ISSB's Request for Information on Agenda Priorities, the FRC similarly recommended that the ISSB considers and communicates the envisaged architecture for the full suite of standards, including information about how the industry-based materials fit into that 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 its intentions for the SASB Standards and the incorporation of industry-based disclosure requirements into IFRS Sustainability Disclosure Standards.

16Clarity around the future architecture of IFRS Sustainability Disclosure Standards is likely to support the development of the ISSB's priorities. For example, the ISSB could conclude that instead of using its resources to continue enhancing the SASB Standards, it could pursue other activities, such as progressing its research projects on biodiversity, ecosystems and ecosystem services (BEES) and human capital.

Strategy for enhancing the SASB Standards

17The 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. However, the TAC is not convinced that the ISSB's approach to the project is the best way of achieving that objective.

18The TAC notes that the SASB Standards were developed before the 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.

19The TAC recommends that the ISSB develops a clear strategy for enhancing the SASB Standards. The strategy would link to the architecture of the IFRS Sustainability Disclosure Standards and should prioritise simplification, meaning it is straightforward to apply and easy to understand the output, and that it is aligned with the IFRS Sustainability Disclosure Standards. Without simplification and alignment with IFRS S1 and IFRS S2, stakeholders could lose disengage from the SASB Standards because they may not have a clear relevance to the overarching principles and disclosures in IFRS S1 and IFRS S2. The industry-based guidance should naturally flow from, and be a deeper dive into, the general disclosures in the IFRS Sustainability Disclosure Standards and should focus on how those general disclosures specifically relate to an entity's industry and related activities. The strategy should also prioritise international applicability and connectivity with IFRS Accounting Standards. Overall, the TAC believes that the ISSB's industry-based guidance should be a global baseline, that jurisdictions can add to as is relevant to their specific situation.

20Our stakeholder outreach and research activities also suggest that there is general support for an ISSB focus on enhancing the SASB Standards to improve alignment with the IFRS Sustainability Disclosure Standards, international applicability and the interoperability of the IFRS Sustainability Disclosure Standards with other sustainability-related standards and frameworks. Entities currently seem to use a wide range of sustainability-related standards and frameworks, and may be both using specific SASB Standards as a checklist, and applying judgement to identify the most relevant metrics from the array of sustainability-related standards and frameworks, including the SASB Standards, available to them. Stakeholders expressed concerns about the prescriptive nature of the current SASB Standards, viewing them as a potential reporting burden and believing they lack the materiality and judgement principles in the IFRS Sustainability Disclosure Standards. The majority of stakeholders recommended a shift towards a principles-based and proportionate approach consistent with IFRS S1 and IFRS S2. Preparers cautioned that an overly prescriptive approach may discourage disclosure, particularly in cases where entities do not possess the necessary data or rely on alternative measurement methodologies. They emphasised the need for industry standards that accommodate varying levels of data availability and reporting maturity.

21The TAC believes that the ISSB would ideally develop a clear strategy for enhancing the SASB Standards first, and then consider detailed amendments to the Standards. The TAC suggests that the ISSB considers restructuring the SASB Standards to distinguish between core disclosures, industry-agnostic disclosures and industry-specific disclosures. Examples of each of these types of disclosures are:

  • Core disclosure: governance and strategy. All entities would be required to disclose these.
  • Industry-agnostic disclosure: water withdrawal. This metric does not have to be tailored to an industry and can be used in an identical way for any industry that has identified risks related to water management.
  • Industry-specific disclosure: in the area of health and nutrition for entities in the Food & Beverage sector, the amount of revenue generated from healthy products. This issue relates to particular industries, and the metric is specific only to those industries. It is not relevant, and therefore would not be reported, in other industries.

22The TAC also suggests that the ISSB considers including core and industry-agnostic disclosures in IFRS S1, IFRS S2 and any further topic-specific IFRS Sustainability Disclosure Standards. The SASB Standards would then focus only on industry-specific disclosures.

23Finally, the TAC recommends that the ISSB reconsiders the name of the SASB Standards. In a March 2025 ISSB Staff Paper (Paragraphs 32 and 33), the ISSB Staff suggested that the current consultation could be a good opportunity to rename the SASB Standards to clearly demonstrate the link to the IFRS Sustainability Disclosure Standards and also to reaffirm the status of these materials as 'guidance'. The July 2025 Educational Material Using ISSB Industry-based Guidance when applying ISSB Standards then refers to the SASB Standards and the IFRS S2 Industry-based Guidance collectively as the 'ISSB industry-based guidance'. The TAC agrees with these points and recommends that the SASB Standards are renamed the ‘ISSB Industry-based Guidance'.

Enhancement process, including future updates

24As part of the strategy for enhancing the SASB Standards, the TAC recommends that the ISSB considers the way 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.

25The ISSB may have to devise a regular update process for the SASB Standards in their current form so that they keep pace with these 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. One current example is the potential consequential amendments to the SASB Standards resulting from the Amendments to Greenhouse Gas Emissions Disclosures, considered in the ISSB's October 2025 meeting.

26Therefore, the TAC encourages the ISSB to adopt a principles-based, not rules-driven, approach so that the Standards and guidance can adapt and keep pace with changes without requiring changes to the Standards and guidance themselves, and consequentially being overly burdensome for stakeholders.

Climate-first thematic approach

27The TAC considers a phased approach to enhancing the SASB Standards to be inevitable and unavoidable given the scope and scale of the project, including the number of Standards and disclosure requirements.

28The TAC recommends that the ISSB seeks stakeholder views on the architecture of the IFRS Sustainability Disclosure Standards and strategy for enhancing the SASB Standards. However, the TAC suggests that the ISSB considers adopting a climate-first thematic approach by enhancing the climate-related content in the SASB Standards first and then enhancing the content related to other topics in the SASB Standards. The ISSB could also consider prioritising the development of further topic-specific materials. One stakeholder we engaged with did not support enhancing the SASB Standards, but, instead, recommended that the ISSB focus on developing new topic-specific sustainability-related standards that are standalone, conceptually robust and not overly reliant on external frameworks and guidance materials.

A robust due process

29The TAC has significant concerns about the due process being applied in the ISSB's project to enhance the SASB Standards. The 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.

30The FRC's March 2025 response to Exposure Draft IFRS/DPH/ED/2024: Proposed Amendments to the IFRS Foundation Due Process Handbook similarly noted that UK stakeholders and the TAC raised concerns where materials were not developed using the same conceptual basis, and have not been – and technically are not subject to – the usual IFRS Foundation due process. The FRC's June 2025 letter to the ISSB 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 UK Sustainability Disclosures Policy and Implementation Committee (PIC) Chairs, further stated that 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. The TAC notes that public deliberations are likely to be particularly important in relation to sensitive areas, such as human rights. Possible concerns about ideological influences could be assuaged by public discussions focused on the core purpose of the ISSB Standards, i.e. to provide information necessary for investment decision making. The extant due process arrangements and lack of public deliberations may have contributed to the lack of communication on the future architecture of IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture.

Improving the consultation process

31The TAC also has concerns about the effectiveness of the ISSB's consultation process on the SASB Exposure Draft. In its March 2025 response to Exposure Draft IFRS/DPH/ED/2024: Proposed Amendments to the IFRS Foundation Due Process Handbook, the FRC encouraged the IFRS Foundation to give greater consideration to enabling stakeholders to contribute to the development of the SASB Standards and, as noted, the FRC, as well as the 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 on the proposed amendments. While the TAC welcomed the 30-day extension of the comment period, the TAC still experienced challenges engaging with UK stakeholders who have had the opportunity to consider the specifics of the proposals during the current consultation and in the development of its response to the ISSB.

32The challenges experienced by the TAC may be due to a combination of factors, such as: the volume of materials that were published as part of the SASB Exposure Draft and lack of resources supporting the navigation of those materials; a lack of capacity or stakeholder consultation fatigue due to the number of consultations relating to sustainability reporting that have been published over the last few years, including the concurrent consultations by the UK Government and on the European Financial Reporting Advisory Group (EFRAG)'s revised European Sustainability Reporting Standards (ESRS); and the difficulties reaching varied industry stakeholders and accessing specialist skills and knowledge given the nature of the materials.

33The TAC recommends that the ISSB considers improving the consultation materials. For example, the ISSB could provide tables, similar to those published by EFRAG, with logs of amendments showing the proposed revision and reason for it.

34The TAC also recommends that the ISSB publishes summaries of the origins of the metrics, particularly as this is the first time the SASB Standards have undergone extensive global consultation via the IFRS Foundation. The lack of knowledge of the historic reasoning makes the analysis of the proposed amendments challenging. The ISSB should particularly consider whether the metrics continue to be relevant, and the costs and benefits of the proposed reporting.

35If the ISSB continues to prioritise industries for enhancement, the TAC encourages the ISSB to issue proposed amendments to all standards in a sector together as was the case for the industry standards in the Extractives & Minerals Processing sector. The TAC notes that it has not been ideal to consider changes to only one of eight standards for industries in the Food & Beverage sector, particularly given that two further standards in the sector are expected to be consulted on later this year. The TAC is also not convinced about the rationale for the prioritisation of industries for enhancement so far, and encourages the ISSB to publicise and seek stakeholder views on the selection of future priority industries.

36The TAC stresses the importance of ensuring an effective consultation process is conducted on materials such as the SASB Standards. If stakeholders cannot engage with such materials, then they will be unlikely to endure. We stand ready to discuss and share further comments with the ISSB about our experience of its consultation process, with a view to improving the experience for stakeholders in the future.

The industry classification system

37The 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.

38The 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 and no work has been completed to assess whether SICS is relevant or appropriate for other jurisdictions. It also seems unusual to use a classification system - in a set of standards targeted at investors - that does not have the same basis as the industry classification systems investors use to assess companies when pricing securities.

39Overall, however, the TAC believes that there are challenges and complexities inherent in all industry classification systems and that SICS can make an important contribution given its distinctiveness in categorising sector groupings based on industrial activities with similar significant sustainability matters.

40The TAC notes that, as for any industry classification system, there are particular challenges for conglomerates or entities with complex or diverse activities and suggests that there should be guidance for conglomerates. Entities mostly seem to use a single SASB Standard. The TAC questions whether the challenges of reporting across multiple industries leads to entities not selecting the most appropriate industry standard or standards. This can result in entities not reporting relevant disclosures located in other SASB Standards, and a lack of consistency. One stakeholder we engaged with indicated that industry-specific information is not particularly useful for integrated Oil & Gas businesses. They stressed that sustainability-related risks and opportunities are better assessed for the integrated business as a whole, rather than at industry level.

41The TAC is also concerned about comparability across different industry classification systems and suggests that there should be support for reconciliations between industry classification systems, such as mappings from SICS to other industry classification systems.

Appendix 2: Draft answers to the questions in the SASB Exposure Draft

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?

42As noted in the general points above, the 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. However, the TAC is not convinced that the ISSB's approach to the project is the best way of achieving that objective. The TAC also 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.

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, enhance the SASB Standards, so that they can adapt and keep pace with changes.

44The ISSB could also consider making further improvements to the consistency of the terminology used in the SASB Standards. For example, the Oil & Gas – Exploration & Production SASB Standard uses the terms ‘operating facilities', 'operational facilities' and 'active sites' in metrics EM-EP-140a.6, EM-EP-160a.1 and EM-EP-160a.4 to seemingly represent the same concept. Clarifying the terminology and ensuring its consistency should support the 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 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 the IFRS Sustainability Disclosure Standards, and believes that alignment with the IFRS Sustainability Disclosure Standards should be the primary driver of the changes.

47A focus on alignment with the 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 the IFRS Sustainability Disclosure Standards and the SASB Standards.

48In particular, the TAC suggests that the ISSB considers:

  • clearly distinguishing between disclosure requirements and guidance in the SASB Standards to better align with the structure of the IFRS Sustainability Disclosure Standards. The technical protocols in the SASB Standards often include definitions or guidance to support the disclosure requirements. However, the technical protocols also include additional disclosure requirements that supplement the metrics.
  • clarifying the architectural relationship between the different terms used in the SASB Standards and the IFRS Sustainability Disclosure Standards, or reframing the SASB Standards around risks and opportunities. The SASB Standards are referenced in IFRS S1 as guidance for entities to identify risks and opportunities and IFRS Sustainability Disclosure Standards focus on risks and opportunities. However, the SASB Standards are structured around disclosure topics and metrics.
  • the duplication between the SASB Standards and the IFRS Sustainability Disclosure Standards, for example, the requirements to identify risks and opportunities related to social matters in various 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 21, the TAC suggests that the ISSB considers restructuring the SASB Standards to distinguish between core disclosures, industry-agnostic disclosures and industry-specific disclosures. Differentiating between the disclosures is likely to help eliminate duplication between the SASB Standards and the IFRS Sustainability Disclosure Standards.

Enhancing international applicability

49The 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 internationally applicability is key for the UK market.

50The 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 that the current consultation is a way of obtaining further jurisdictional views. However, as noted in Paragraph 31, the TAC has concerns about the effectiveness of the ISSB's consultation process on the SASB Exposure Draft. For example, Oil & Gas – Midstream: EM-MD-540a.3 is a metric which relates to the disclosure of non-accident releases from rail transport. The metric originated from the US, where rail transport is a prominent mode of transport, and may not be internationally applicable as entities in other jurisdictions may use other modes of transport, including pipeline or marine transport. There is no requirement or description in the technical protocol specifying that this metric is only relevant for rail transport and therefore the ISSB could consider removing 'from rail transport' to make the metric internationally applicable.

51A 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. However, the TAC suggests that the ISSB provides a greater level of detail than in the ISSB Staff Paper, so as to provide a greater level of assurance that the project has incorporated international perspectives. The ISSB could consider:

  • sharing summaries of stakeholders the ISSB has engaged with in a greater level of detail than is in the ISSB Staff Paper. For example, the ISSB could include the number of preparers, investors and other stakeholder groups that were engaged with in each industry and the specific jurisdiction in which the stakeholders are based.
  • consistently providing the stakeholder type, jurisdiction and basis for their suggestions, where proposed amendments result primarily from stakeholder feedback.
  • sharing an analysis of desk-based research on which metrics in the SASB Standards are commonly adjusted or omitted by companies, along with 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.

52The TAC also has concerns that certain SASB Standard metrics seem to assume the reporting entity operates in a single jurisdictional context, with a lack of guidance on reconciling differences in metrics across jurisdictions. For example, in the Oil & Gas – Refining & Marketing SASB Standard, Paragraphs 2.2, 3.2 and 4.1 of the technical protocol for metric EM-RM-120a.1 refer to 'the jurisdiction in which the entity operates'. Paragraph 1.2 of the technical protocol for metric EM-RM-150a.1 includes the same phrasing, but Paragraphs 3 and 3.1 include guidance for an entity that 'is subject to more than one jurisdictional law or regulation'. The TAC believes that the approaches in Paragraphs 3 and 3.1 of the technical protocol for metric EM-RM-150a.1 are sensible for entities operating in more than one jurisdiction and avoid the risk of disclosures of numbers based on different standards which therefore cannot reasonably be aggregated. Therefore the ISSB could consider including equivalent guidance throughout the SASB Standards.

53Overall, the TAC recommends that the ISSB considers ways of improving engagement with the SASB Exposure Draft and conducting further outreach in markets beyond North America and Europe, so that the SASB Standards fit into a global baseline of sustainability disclosures.

54The TAC generally supports the ISSB's aim of improving interoperability with other sustainability-related standards and frameworks and notes that it has significant overlaps with enhancing international applicability because of the widespread use of Global Reporting Initiative (GRI) Standards, in particular.

55As noted in Paragraph 20, our stakeholder outreach and research activities suggest that entities currently use a wide range of sustainability-related standards and frameworks. A majority of stakeholders stressed the importance of alignment with other sustainability-related standards and frameworks, particularly the GRI Standards, ESRS and Task Force on Nature-related Financial Disclosures (TNFD). A minority of stakeholders also commented that interoperability should prioritise alignment with mandated sustainability-related standards and frameworks over voluntary ones. The TAC recognises that entities may have to continue using other sustainability-related standards and frameworks alongside ISSB Standards (and therefore SASB materials) and that entities may choose to do so for guidance on new and emerging issues.

56The TAC therefore believes that the ISSB's focus should be harmonisation rather than interoperability. Interoperability is about the sustainability-related standards and frameworks working together, whereas harmonisation is about gradually minimising the differences between sustainability-related standards and frameworks. If the focus is on interoperability rather than harmonisation, then there is a risk that the SASB Standards could become additive and burdensome for preparers. Harmonisation should instead focus on simplifying and supporting the navigation of the different sustainability-related standards and frameworks, as the IFRS Sustainability Disclosure Standards aim to provide a global baseline of sustainability disclosures.

57One of the key challenges with interoperability and harmonisation is the continuing evolution of other sustainability-related standards and frameworks, for example EFRAG revising the ESRS. A lack of alignment of disclosures could result in extra work for stakeholders as explanations may have to be provided for any similar, but not identical, disclosures.

58Another challenge with interoperability and harmonisation is different approaches to materiality and identifying sustainability-related matters to disclose. We agree that the ISSB should first determine that disclosure requirements in other sustainability-related standards and frameworks fit with the ISSB's materiality lens and then consider adopting those disclosure requirements.

59Mappings to other sustainability-related standards and frameworks showing similarities and differences could also support interoperability and harmonisation, as could joint consultations with other standard-setters and framework developers.

60The TAC also cautions that a focus on interoperability and harmonisation with TNFD may be premature given that the ISSB's research project on BEES has not been completed yet, as noted in Paragraph 61.

61The TAC does not support the ISSB's aim of aligning the enhancements with the ISSB's research projects on BEES and human capital given that 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 may therefore be premature for the ISSB to make amendments to the SASB Standards without communicating the future architecture of IFRS Sustainability Disclosure Standards, including the way the SASB Standards fit into that architecture. In particular, the TAC would value greater clarity about whether the SASB Standards are intended to be a foundation or substitute for future topic-specific IFRS Sustainability Disclosure Standards.

62The TAC notes that a number of the BEES and human capital metrics in the SASB Standards could be considered industry-agnostic disclosures. As noted in Paragraph 22, the TAC suggests that the ISSB considers including core and industry-agnostic disclosures in IFRS S1, IFRS S2 and any further topic-specific IFRS Sustainability Disclosure Standards, with the SASB Standards focusing on industry-specific disclosures. As noted in Paragraph 28, the ISSB could also consider prioritising the development of further topic-specific materials.

QUESTION 2—ENHANCEMENTS TO INTEROPERABILITY WITH OTHER STANDARDS AND FRAMEWORKS

  1. Do you agree with the proposed approach to enhancing interoperability and alignment with other sustainability-related standards and frameworks? Why or why not?
  2. 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?
  3. 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?

63As noted in Paragraphs 54 to 60, 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

  1. 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?

64The TAC agrees in principle 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. However, as noted in Paragraphs 27 to 28, the TAC suggests that the ISSB considers adopting a climate-first thematic approach. This would involve a comprehensive review of the climate-related content across all 77 SASB Standards rather than the partial approach entailed in the proposed targeted amendments to other SASB Standards. This piecemeal approach means that the IFRS S2 industry-based guidance is going to be continuously revised.

65Please also refer to our answer to Question 15 on proposed targeted amendments to other SASB Standards and the comments in this paper covering specific climate-related amendments, including in Paragraphs 77, 78 and 84.

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

  1. 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?
  2. 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.
  3. 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?
  4. 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.

66As noted in Paragraphs 61 to 62, 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 that 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?

67The TAC agrees that the ISSB should decide the effective date for the amendments after considering the extent and nature of feedback on the proposed amendments.

68The TAC's initial view on the effective date for the amendments is that it should occur at least 18 months after their issuance and permit early application.

Proposed amendments to individual SASB Standards

69We 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

  1. Do you agree with the proposed amendments to the Coal Operations SASB Standard? Why or why not?

QUESTION 7—CONSTRUCTION MATERIALS SASB STANDARD

  1. Do you agree with the proposed amendments to the Construction Materials SASB Standard? Why or why not?

QUESTION 8—IRON & STEEL PRODUCERS SASB STANDARD

  1. Do you agree with the proposed amendments to the Iron & Steel Producers SASB Standard? Why or why not?

QUESTION 9—METALS & MINING SASB STANDARD

  1. 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

  1. 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

  1. 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

  1. 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

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

70As noted in Paragraph 31, the TAC experienced challenges engaging with UK stakeholders who had had the opportunity to consider the specifics of the proposals during the current consultation and in the development of its response to the ISSB. The TAC notes that two preparers were engaged with in relation to the Metals & Mining SASB Standard; two preparers were engaged with in relation to the Oil & Gas – Exploration & Production SASB Standard; one preparer was engaged with in relation to the Construction Materials SASB Standard; and one investor was engaged with in relation to the Metals & Mining and Oil & Gas – Exploration & Production SASB Standards. The stakeholder feedback collected is therefore not likely to fully reflect the UK market and the TAC cannot conclude on whether it agrees with the proposed amendments to the standards for industries in the Extractives & Minerals Processing sector.

Industry descriptions

QUESTION 6—COAL OPERATIONS SASB STANDARD

  1. 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

  1. 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

  1. 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

  1. 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

  1. 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

  1. 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

  1. 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

  1. 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?

71Our stakeholder outreach and research activities have not indicated that there are any concerns about the updated industry descriptions.

72Please refer to our comments on the industry classification system in Paragraphs 37 to 41.

Disclosure topics

QUESTION 6—COAL OPERATIONS SASB STANDARD

  1. 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

  1. 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?
  1. 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

  1. 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

  1. 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?
    1. 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

  1. 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

  1. 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

  1. 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

  1. 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?

Selection of disclosure topics

73The 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, it would be helpful to understand the rationale or prioritisation process used to determine the inclusion or exclusion of disclosure topics. In particular, the TAC suggests that the ISSB considers explaining key omissions in relation to disclosure topics with a view to providing a holistic cross-sector picture. It is unclear why certain disclosures topics which could be relevant to all industries in a sector are only included in certain industry standards. For example:

73.1 Coal Operations SASB Standard: Air Quality. The 'Air Quality' disclosure topic is included in all standards for industries in the Extractives & Mineral Processing sector except for the Coal Operations SASB Standard. This is despite the standards for the other industries in the Extractives & Mineral Processing sector being aligned with GRI's air quality disclosures and there being a topic in the GRI Sector Standard for Coal, GRI 12: Coal Sector 2022, which states ‘[a]ir 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 also notes that while air quality might be concentrated to the immediate area around the coal mine, that does not diminish the fact that air quality is a significant issue for those in that area, and what the company is doing to address this would therefore seem to be material information.

73.2 Construction Materials SASB Standard: Air Quality. Although there is an 'Air Quality' disclosure topic in the Construction Materials SASB Standard, the preparer from this industry that the TAC engaged with highlighted that their financial materiality assessment did not identify air quality as a topic for reporting.

73.3 Construction Materials and Oil & Gas – Exploration & Production SASB Standards: Labour Practices. The preparers from these industries that the TAC engaged with highlighted the omission of a 'Labour Practices' disclosure topic in the Construction Materials and Oil & Gas – Exploration & Production SASB Standards, despite the inclusion of a ‘Workforce Health and Safety' disclosure topic.

73.4 All Oil & Gas SASB Standards: Energy Management. The 'Energy Management' disclosure topic is only included in three of the SASB Standards in the Extractives & Minerals Processing sector and none of the Oil & Gas SASB 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.

73.5 Oil & Gas – Midstream SASB Standard: Water Management. The ‘Water Management' disclosure topic is included in all standards for industries in the Extractives & Mineral Processing sector except for the Oil & Gas – Midstream SASB Standard.

73.6 All standards for industries in the Extractives & Mineral Processing sector. The TAC is not sure why numerous other disclosure topics such as 'Waste Management/ Hazardous Materials Management/Waste & Hazardous Materials Management', 'Business Ethics and 'Competitive Behaviour' are included in some standards but not in others when they are potentially applicable to all industries in the Extractives & Mineral Processing sector.

74The TAC asks the ISSB to consider whether there is a case for including or excluding any of these disclosure topics.

Disclosure topic summaries

75Disclosure 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

  1. 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?
    1. 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

  1. 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?
  1. 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

  1. 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

  1. 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?
    1. 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

  1. 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?
    1. 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?
    2. 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

  1. 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?
  1. 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

  1. 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

  1. 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?
    1. 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?

76The TAC suggests that the ISSB considers providing tables or indicating more clearly where the same amendment has been made across multiple standards. For example, the amendments to the water-related metrics are identical. A substantial amount of time has been spent working through the material to understand the changes that have been made and why they have been made.

Greenhouse Gas Emissions

77Coal Operations: EM-CO-110a.3, Oil & Gas – Exploration & Production: EM-EP-110a.4 and Oil & Gas – Midstream: EM-MD-110a.3 are new metrics relating to Scope 1 methane emissions. The TAC agrees in principle with the addition of these metrics as being complementary to IFRS S1 and IFRS S2. However, two Oil & Gas - Exploration & Production preparers expressed concern about the level of detail required. In particular, they highlighted technical protocol paragraph 3 requiring disclosure of United Nations Environmental Programme Oil & Gas Methane Partnership 2.0 (OGMP 2.0) membership status and reporting level achieved (Levels 1-5), as well as detailed methodologies for calculating methane emissions, inspection frequency, technologies used and asset coverage. Such detailed requirements were viewed as potentially burdensome. The preparers recommended that the technical protocols should allow for the application of preparer judgement based on principles, rather than prescribing extensive details of the disclosure.

78The TAC asks the ISSB to consider the addition of industry-based guidance, including metrics, on Scope 3 greenhouse gas emissions to its proposed amendments in the standards in the Extractives & Minerals Processing sector. 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 greenhouse gas 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 Greenhouse Gas 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.

Security, Human Rights & Rights of Indigenous People

79The TAC has concerns that the term 'Human Rights' is no longer present in the disclosure topics in the Metals & Mining and Oil & Gas – Exploration & Production SASB Standards following the removal of the ‘Security, Human Rights & Rights of Indigenous People' disclosure topic.

80Metals 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 has concerns, in particular, about the loss of Part Two of the technical protocol, which referenced child labour, and stated:

2The entity shall describe its due diligence practices and procedures with respect to upholding the principles covered in human rights frameworks, such as the:

  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. United Nations Guiding Principles on Business and Human Rights, specifically Human Rights Due Diligence (Principle 17a-c); and
  3. Voluntary Principles on Security and Human Rights.

81The TAC asks the ISSB to consider whether there is a case for reinstating the term 'Human Rights' in the disclosure topics in the Metals & Mining and Oil & Gas – Exploration & Production SASB Standards, along with the references in the technical protocol to child labour, in particular. The stakeholder in the Oil & Gas sector expressed concern about the removal of references to the ILO and perceived this as weakening the language related to human rights.

82Oil & 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, neither the existing Standards nor the SASB Exposure Draft directly capture metrics relating to litigation risks, with the focus of the current draft on reputational risk from policy influencing activities. Litigation risks are a well-established risk, especially in the context of the Task Force on Climate-related Financial Disclosures (TCFD), and can have ongoing significant implications for entities in the Oil & Gas industry. For example:

  • in 2015, the resolution of civil claims against the British multinational oil and gas company BP led to a settlement of over $20 billion stemming from the Deepwater Horizon Oil Spill;
  • the London School of Economics (LSE) highlights growing evidence of a causal link between climate litigation and stock price movements, with the largest stock market responses observed for cases filed against carbon majors, reinforcing the investor relevance of legal and regulatory risk disclosures;
  • research from the Network for Greening the Financial System shows that such litigation cases can have significant financial implications not just for defendants, but those exposed to them;
  • the UK's Climate Financial Risk Forum notes in its Climate Litigation Risk Chapter that new types of cases are arising and creating novel duties of care and that 'legal 'tipping points' in coming years could exponentially expand... exposure as new bases for liability become established';
  • research from the LSE shows that climate litigation is increasingly common, with over 2,967 cases filed to date, globally by the end of 2024 and the UK ranking third in terms of filings; and
  • research from the Network for Greening the Financial System shows that cases against fossil fuel and energy companies have increased and are expected to continue to rise.

83Given the above, the importance of connectivity with financial statements, the fact that such disclosures can provide early indications of litigation matters that may subsequently crystalise within the financial statements, and the fact that this issue is not addressed consistently across standards1, the TAC recommends that the ISSB investigates whether to include metrics relating to climate/sustainability litigation risks in the context of its ‘Legal and Regulatory' disclosure topic. It should also consider the relevance of this issue for other Standards where litigation risks are significant – the UK's Climate Financial Risk Forum, for example, highlights other sectors that are increasingly subject to climate litigation.

Climate physical risks and just transition risks

By way of more general background on physical risks, the TAC may be aware of recent publications issued in October-November 2025 by Aviva, which addresses physical risks from climate change, outputs issued by the UK's Climate Financial Risk Forum on climate physical risk assessments, and the report issued by MSCI, entitled Hidden in Plain Sight: Physical Risk in Asset Owners' Portfolios.

84The TAC notes that certain climate risks2, notably climate physical risks (outside of water stress) and just transition risks3, receive limited consideration across the standards for industries in the Extractives & Minerals Processing sector. For example, preliminary research suggests that major oil refineries in the UK and elsewhere may often be located near coastlines. This coastal siting may increase refineries' exposure to acute and chronic physical risks, such as flooding and sea level rise. However, the draft Oil & Gas - Refining and Marketing SASB Standard does not appear to engage with these risks. Similarly, just transition metrics are altogether absent from the same Standard, yet such issues are already crystalising within this industry in the UK, with, for example, the recent termination of oil refining at the Grangemouth oil refinery in Scotland. The TAC asks the ISSB to consider giving greater consideration to climate physical risks (outside of water stress) and just transition risks across the standards for industries in the Extractives & Minerals Processing sector.

Stakeholder feedback

85A summary of stakeholder feedback on the metrics and technical protocols in the standards for industries in the Extractives & Minerals Processing sector is included in Appendix 3.

Jurisdictional considerations

QUESTION 6—COAL OPERATIONS SASB STANDARD

  1. 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

  1. 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

  1. 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

  1. 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

  1. 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

  1. 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

  1. 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

  1. 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.

86Please refer to our comments on international applicability in Paragraphs 49 to 53.

QUESTION 6—COAL OPERATIONS SASB STANDARD

  1. 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

  1. 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

  1. 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

  1. 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

  1. 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

  1. 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

  1. 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

  1. 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.)

87Please refer to our comments on interoperability and alignment with other sustainability-related standards or frameworks in Paragraphs 54 to 60.

QUESTION 14—PROCESSED FOODS SASB STANDARD

  1. Do you agree with the proposed amendments to the Processed Foods SASB Standard? Why or why not?

88As noted in Paragraphs 31 to 36, not only has the TAC experienced challenges engaging with UK stakeholders who have had the opportunity to consider the specifics of the proposals during the current consultation and in the development of its response to the ISSB, but it has also not been ideal to consider changes to only one of eight standards for industries in the Food & Beverage sector, particularly given that two further standards for industries in the sector are expected to be consulted on later this year. The TAC therefore encourages the ISSB to finalise the Processed Foods SASB Standard at the same time as the two further industry standards 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.

89The TAC has concerns about the significance of the changes to the Processed Foods SASB Standard and the consequent challenges in terms of data availability and assurance, however, the TAC notes that the three preparers it engaged with mostly supported the proposed amendments to the Processed Foods SASB Standard. The stakeholder feedback collected may not fully reflect the UK market and the TAC therefore cannot conclude on whether it agrees with the proposed amendments to the Processed Foods SASB Standard.

  1. 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?

90Our stakeholder outreach and research activities have not indicated that there are any concerns about the expanded industry description.

91Please refer to our comments on the industry classification system in Paragraphs 37 to 41.

  1. 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?

92Again, 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. 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 'Food Waste Management' in the Processed Foods SASB Standard as food processing companies generate significant levels of food waste. All three preparers consulted identified ‘Food Waste Management' as a relevant disclosure topic currently missing from the proposed amendments. They noted that they report on food waste targets in line with commitments made under the UK's Waste and Resources Action Programme (WRAP).

  1. 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?

93A summary of stakeholder feedback on the metrics and technical protocols in the Processed Foods SASB Standard is included in Appendix 3.

  1. 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.

94Please refer to our comments on international applicability in Paragraphs 49 to 53.

  1. 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.)

95Please refer to our comments on interoperability and alignment with other sustainability-related standards or frameworks in Paragraphs 54 to 60.

Proposed targeted amendments to other SASB Standards

QUESTION 15—PROPOSED TARGETED AMENDMENTS TO THE SASB STANDARDS

  1. 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?

96As noted in Paragraph 31, the TAC experienced challenges engaging with UK stakeholders who have had the opportunity to consider the specifics of the proposals during the current consultation and in the development of its response to the ISSB. The TAC therefore does not have the evidence to conclude on whether it agrees with the proposed targeted amendments to the SASB Standards, and cautions that its response may not fully reflect the views of the UK market.

  1. 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?

97As noted in Paragraph 64, the TAC agrees in principle that the ISSB should make targeted amendments to the climate-related content in the SASB Standards for other industries. However, as noted in Paragraphs 27 to 28, the TAC recommends the ISSB considers adopting a climate-first thematic approach. This would involve a comprehensive review of the climate-related content across all 77 SASB Standards rather than the partial approach entailed in the proposed targeted amendments to other SASB Standards, whereby targeted amendments are only being proposed to pre-existing metrics.

98The TAC also suggests that the ISSB:

  • publicly outlines the criteria it used to determine whether disclosure topics and metrics qualify as a 'targeted amendment'; and
  • shares an evaluation of the relevance of the proposed climate-related targeted amendment metrics to the non-priority industries. It is not clear whether consideration was made as to whether the proposed climate-related targeted amendment metrics are still relevant to the non-priority industries. If the metric is no longer considered to be relevant, the newly amended metrics could later be removed.
  1. Do you agree with the proposed targeted amendments associated with greenhouse gas emissions? Why or why not?
  1. Do you agree with the proposed targeted amendments associated with energy management? Why or why not?
    1. Do you agree with the proposed targeted amendments associated with water management? Why or why not?

99Subject to our general points above and the comments in this paper covering specific climate-related amendments, the TAC agrees that the ISSB should make targeted amendments to the climate-related content in the SASB Standards for other industries, including the targeted amendments associated with greenhouse gas emissions, energy management and water management.

  1. Do you agree with the proposed targeted amendments associated with labour practices? Why or why not?
    1. Do you agree with the proposed targeted amendments associated with workforce health and safety? Why or why not?

100The TAC does not agree that the ISSB should make targeted amendments associated with labour practices and workforce health and safety. As noted in Paragraph 61, the ISSB's research project on human capital has not been completed, and we do not know whether any standard-setting or guidance will arise from that project. It may therefore be premature for the ISSB to make amendments to the SASB Standards without communicating the future architecture of IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture.

  1. 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.

101Please refer to our comments on international applicability in Paragraphs 49 to 53.

  1. 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.)

102Please refer to our comments on interoperability and alignment with other sustainability-related standards or frameworks in Paragraphs 54 to 60.

Appendix 3: Summary of stakeholder outreach and research activities

103[To include extracts from TAC paper 2025-TAC-047 Summary of stakeholders' feedback.]

Footnotes

  1. For example, legal expenses associated with price fixing or price manipulation are already included through EM-RM-520a.1, (Oil & Gas Refining & Marketing) and so too are fines and other expenses incurred as a result of non-compliance with industry/regulatory labelling or marketing codes are included as per FB-PF-270a.3 (Processed Foods technical protocol, Paragraph 3). ↩

  2. Climate physical risks refer to those risks and losses arising from the adverse physical effects of climate change. Drivers of such risks include sea level rise, flooding, extreme rainfall, wildfires, droughts, heatwaves, cyclones/hurricanes/typhoons, temperature variability, and water stress (the latter is addressed under the Water Management topic). ↩

  3. Such risks can arise from, for example, the costs of redeployment programmes, severance payments, legal disputes, reputational damage, loss of Government subsidies/permits, and other operational disruptions arising from strikes. ↩

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Name TAC Public Meeting November 2025 Paper 4: SASB Exposure Draft Comment Letter
Publication date 04 November 2025
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