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TAC Public Meeting November 2025 Paper 3: SASB Stakeholder feedback summary
Executive summary
| Header | Header |
|---|---|
| Date | 11 November 2025 |
| Paper reference | 2025-TAC-047 |
| Project | Proposed amendments to the SASB Standards |
| Topic | Summary of stakeholders' feedback |
Objective of the paper
This paper provides a consolidated summary of stakeholders' feedback gathered through outreach activities on the Exposure Draft of Proposed Amendments to the SASB Standards.
Decisions for the TAC
This paper is for information purposes only and no decision is required.
Appendices
There are no appendices to this paper.
This paper has been prepared by the Secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC) to discuss in a public meeting. This paper does not represent the views of the TAC or any individual TAC member.
This publication contains copyright material of the IFRS Foundation® (Foundation). All rights reserved. Reproduced and distributed by the Financial Reporting Council (FRC) in its role as the secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC) with the permission of the Foundation. No rights granted to third parties without permission of the Foundation and the TAC. For more information about the Foundation and the rights to use its materials please visit www.ifrs.org
Context
Stakeholder engagement process
1Following the publication of the Exposure Draft Proposed Amendments to the SASB Standards (SASB Exposure Draft) in July 2025, the Financial Reporting Council (FRC), acting as the Secretariat to the UK Sustainability Disclosure Technical Advisory Committee (TAC), conducted stakeholder engagement activities through the following channels:
- a snapshot survey,
- a roundtable discussion, and
- one-to-one meetings.
2The purpose of these engagements was to gather stakeholder views on the International Sustainability Standards Board's (ISSB) proposed amendments to the SASB Standards, specifically focusing on the nine priority industries under consultation.
3This paper consolidates stakeholder views gathered through the three engagement channels. A total of 29 stakeholders participated, as shown in the chart below. For overall analysis purposes, each stakeholder is counted only once, even if they engaged via multiple channels. In the chart, ‘accountancy' refers to organisations offering professional services such as assurance, accounting, tax and financial advisory, while ‘other consultancy' includes those supporting sustainability initiatives through data provision, report preparation and general consulting.
All stakeholders analysis by type
- Preparers: 10
- Professional bodies: 4
- Sustainability-related network organisations: 1
- Investors/users of reports: 2
- Accountancy: 4
- Academics: 1
- Individuals: 2
- Not-for-profit: 1
- Other consultancy: 4
4The term 'stakeholders' refers to respondents to the snapshot survey and participants in the roundtable discussion as well as one-to-one meetings.
5All stakeholder views presented in this paper have been anonymised.
Challenges and limitations of the stakeholder feedback
6The analysis of stakeholder engagement by participation channel is presented in the later sections of this paper. Overall, the response and participation rates were notably low. The quality of feedback suggests that stakeholders had limited engagement with the ISSB's SASB Exposure Draft.
7The survey respondents and roundtable participants were generally not industry experts in relation to the nine priority SASB Standards under consultation. As a result, they were unable to provide substantive feedback on key technical aspects of the proposed amendments such as revised disclosure topics, metrics, technical protocols and other detailed areas. Instead, their input focused on broader themes like the relationship between the SASB Standards and the IFRS Sustainability Disclosure Standards, the ISSB's objectives for enhancing SASB Standards and other overarching elements of the SASB Exposure Draft.
8Although the roundtable included fourteen participants, only a minority actively contributed to the discussion.
9Obtaining input from industry experts through one-to-one meetings proved challenging. Despite outreach efforts to various investor network organisations, banks, insurers and other users, uptake was minimal, with only one investor accepting our requests for both a roundtable discussion and one-to-one meeting. Engagement from companies representing preparers using the Standards was also limited, with participation ranging from zero to three companies across each of the nine industries.
10Given the limited engagement and lack of diverse stakeholder representation, the feedback in this paper provides only indicative insights from a small subset of stakeholders. It does not reflect the broader views of the UK stakeholder community.
Snapshot survey
11The TAC Secretariat conducted a snapshot survey to gather a wide range of stakeholder views on the proposed amendments to the SASB Standards. Only nine responses were received and the breakdown by stakeholder type is illustrated in the chart below.
Snapshot survey respondents by stakeholder type
- Preparers: 1
- Investors/users of reports: 1
- Other consultancy: 2
- Not-for-profit: 1
- Individuals: 2
- Accountancy: 1
- Academics: 1
Roundtable discussion
12A roundtable was convened by the TAC Secretariat to engage with all stakeholder groups with an interest in the enhancement of the SASB Standards. The chart below illustrates the distribution of participants by stakeholder type.
Roundtable participants by stakeholder type
- Preparers: 2
- Professional bodies: 4
- Sustainability-related network organisations: 1
- Investors/users of reports: 2
- Accountancy: 3
- Other consultancy: 2
One-to-one meetings
13The TAC Secretariat also held one-to-one meetings with companies that use the SASB priority Standards in preparing their sustainability-related disclosures as well as an investor that uses such reports.
14The first chart below illustrates the distribution of stakeholders by type while the second presents a detailed breakdown of preparers by SASB Standards.
Stakeholders by type
- Preparers: 8
- Investors/users of reports: 1
Preparers by SASB Standards
- Processed Foods: 3
- Construction Materials: 1
- Oil & Gas - Exp & Prod: 2
- Metals & Mining: 2
15Although the SASB Exposure Draft covers nine priority industries, the TAC Secretariat was only able to get engagement from a very limited number of preparer participants ranging from zero to three across each of the nine SASB Standards.
Overview of the feedback
Stakeholder support for SASB Standards enhancement
16Although the number of respondents and participants was limited, those who engaged generally supported the ISSB's initiative to enhance the SASB Standards, with some concerns noted which are outlined below and in the industry-specific feedback sections.
17Stakeholders recognised the importance of improving the Standards' international applicability, interoperability and alignment with IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures. These enhancements were viewed as a necessary step toward increasing global relevance and promoting comparability across companies and jurisdictions.
18Interoperability was highlighted as important by a majority of preparers and investor. They stressed the importance of aligning the SASB Standards with other standards and frameworks, most notably the European Sustainability Reporting Standards (ESRS), Global Reporting Initiative (GRI) Standards and Taskforce on Nature-related Financial Disclosures (TNFD).
19A minority of stakeholders noted that interoperability efforts should prioritise alignment with mandated standards and frameworks over voluntary ones.
Key stakeholder concerns
20Stakeholders expressed concerns about the prescriptive nature of the current SASB Standards, viewing them as a potential reporting burden. They noted a lack of clarity within individual and standalone SASB Standards regarding the principles for applying materiality and exercising judgement when selecting relevant topics and metrics to report on. As a result, some preparers perceive that the Standards require reporting of all disclosure topics and metrics, as there is no evident mechanism within a specific standalone SASB Standard for applying materiality or judgement. Current disaggregated disclosures such as those for global Scope 1 emissions required by GHG emissions type and detailed disclosures in other areas are perceived to be prescriptive by some stakeholders. Thus, when considering a standalone SASB Standard, stakeholders believe it currently lacks the materiality and judgement principles embedded in the IFRS Sustainability Disclosure Standards.
21The majority of stakeholders recommended a shift towards a principles-based and proportionate approach in the enhanced SASB Standards, consistent with the principles in IFRS S1 and IFRS S2.
22Preparers highlighted 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.
23Some stakeholders expressed uncertainty regarding the intended role of SASB Standards, whether they serve as mandatory requirements or guidance. The use of the phrase 'shall refer to and consider' in IFRS S1 and IFRS S2 was cited as prescriptive and having the potential to increase reporting burdens and assurance challenges. Some stakeholders welcomed the proposed amendment in the draft UK Sustainability Reporting Standards from ‘shall refer to and consider' to ‘may refer to and consider' noting that it enables entities to apply judgement in determining the extent of use of the SASB Standards for their reporting.
Stakeholder feedback by SASB Standards
Oil & Gas – Exploration & Production SASB Standard
24The TAC Secretariat engaged with two preparers and one investor to discuss the proposed amendments to the Oil & Gas Exploration & Production SASB Standard. While two stakeholders expressed support for the ISSB's objectives to enhance the Standard, one stakeholder did not support the initiative. Instead, they recommended that the ISSB focus its efforts on developing new topic-specific sustainability-related standards that are standalone, conceptually robust and not overly reliant on external frameworks and guidance materials.
25The stakeholder disagreeing with the ISSB Standards enhancement project indicated that sector-specific information is not particularly useful for integrated Oil & Gas businesses. They highlighted that sustainability-related risks and opportunities are better assessed for the integrated business as a whole, rather than at industry level.
26The three stakeholders had a common view that integrated Oil & Gas companies face practical challenges in simultaneously applying multiple Oil & Gas SASB Standards relevant to their operations. The investor stakeholder also highlighted that the four Oil & Gas SASB Standards were outliers in the practical application of multiple SASB Standards relative to other sectors. The investor explained that while applying these in a single sustainability report may provide detailed value chain information it also risks duplication and clutter in the disclosures.
27The two preparers also raised concerns about the prescriptive nature of the SASB Standard, particularly in as much as they were unclear about the application of materiality and judgement when using standalone SASB Standards. They suggested that companies should be able to determine materiality independently and use the SASB Standards as input into that materiality assessment process.
28In relation to the Greenhouse Gas Emissions topic, metric EM-EP-110a.4, which requires the disclosure of total Scope 1 Methane Emissions, the two preparers expressed concern about the level of detail required. In particular, they highlighted technical protocol paragraph 3, requiring disclosure of the United Nations Environmental Programme Oil & Gas Methane Partnership 2.0 (OGMP 2.0) membership status and reporting level achieved (Levels1-5), 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.
29One preparer raised a concern on the Ecological Impact topic, specifically metric EM-EP-160a.3 requiring disclosure of percentage of (1) proved and (2) probable petroleum reserves in or near environmentally sensitive locations. They highlighted that disclosing probable reserves at the operational facility level as required in technical protocols paragraphs 1 and 2 could reveal commercially sensitive information. Additionally, they indicated that this requirement was seen as inconsistent with the U.S. Securities and Exchange Commission (SEC) disclosure requirement, which requires proved reserves with no mandate to disclose probable reserves. The stakeholder suggested that the ISSB consider reducing the level of detail and aligning with other existing mandatory requirements, when appropriate. The investor echoed the preparers' concerns, citing commercial sensitivity as a key issue when disclosing highly granular information for probable reserves.
30One preparer did not support the removal of references to the International Labour Organisation (ILO) in human rights disclosures and perceived this as weakening the language related to human rights.
31Stakeholders also noted inconsistencies, such as the omission of Labour Practices as a topic despite the inclusion of Workforce Health and Safety topic.
32The change in terminology from ‘Biodiversity Impacts’ to ‘Ecological Impacts’ was not seen as problematic for disclosure but was viewed as inconsistent with other standards and frameworks such as ESRS and TNFD respectively, that use the term 'biodiversity'.
33Three stakeholders emphasised the importance of interoperability. One noted that ISSB's efforts should prioritise interoperability with mandated standards and frameworks over voluntary ones.
Construction Materials SASB Standard
34The TAC Secretariat engaged with and received feedback from a single preparer who expressed general support for the proposed amendments to the Construction Materials SASB Standard with some comments as outlined below.
35The preparer noted that water reporting in their business involves significant estimation and judgement, as water usage varies considerably depending on the moisture content of raw materials, which in turn is influenced by seasonal factors and type of raw materials. While the stakeholder supported the proposed amendments and new metrics in the Water Management disclosure topic, they recommended consideration for flexibility in reporting requirements given the level of judgement and estimation involved.
36Although Air Quality is a required disclosure topic under this SASB Standard, the preparer highlighted that their financial materiality assessment did not identify Air Quality as a topic for reporting.
37Additionally, regarding Air Quality, the preparer noted that the UK Environment Agency is currently undertaking a major review of the air quality regulatory framework which may have implications for future disclosures under this topic.
38The preparer also highlighted that the proposed new topic of Product Innovation, particularly metric EM-CM-410a.2, which requires disclosure of total revenue from products that reduce environmental impacts during production or use may cause potential issues for companies. They explained that the criteria of qualifying products for this disclosure can be complex and potentially expose companies to greenwashing risks.
39The preparer further observed that key workforce-related topics such as Labour Practices, Skills Development, and Diversity, Equity, and Inclusion, were notably absent from the Standard. This was seen as a gap, especially given that a related topic, Workforce Health and Safety was included.
40No concerns were raised regarding the new topic of Supply Chain Management, as the stakeholder's supply chain is largely domestic with limited international exposure.
41There was no specific feedback received from the investor regarding the Construction and Materials SASB Standard.
Metals & Mining SASB Standard
42The TAC Secretariat engaged with two preparers and one investor to gather feedback on the proposed amendments to the Metals & Mining SASB Standard. One preparer provided input exclusively on climate-related disclosures and did not comment on other areas of the Standard. The stakeholders were generally supportive of the SASB Standards with some comments noted below.
43All three stakeholders emphasised the importance of interoperability between the Metals & Mining SASB Standard and other key frameworks and standards, including the GRI Standards, which is required for the International Council on Mining and Metals (ICMM) members, as well as the TNFD, ESRS, and the Global Industry Standard on Tailings Management (GISTM).
44One preparer expressed support for the proposed removal of the requirement under the Greenhouse Gas Emissions topic, to disclose Scope 1 emissions by greenhouse gas type (paragraph 1), welcoming the alignment with IFRS S2's approach to Scope 1 emissions disclosure.
45The same preparer also supported the proposed changes to the Energy Management topic, particularly those clarifying definitions related to renewable energy and the disclosure of self-generated energy and third-party energy contracts.
46Under the Energy Management topic, both preparers raised concerns about the proposed shift from using High Heating Values (HHV) to Low Heating Values (LHV) to calculate energy use from fuels and biofuels. Paragraph 1.3 of the technical protocols requires an entity to use LHV unless otherwise required by a jurisdictional authority or an exchange on which it is listed to use alternative heating values. The two stakeholders noted that this change diverges from the GHG Protocol Scope 1 & 2 Inventory Guidance, which requires HHV, thereby undermining interoperability. One preparer also viewed the use of HHV as a more conservative approach. The proposed shift was seen as potentially burdensome, requiring system reconfigurations and risking operational disruptions.
47The technical protocol paragraph 3.6.1 of the Energy Management topic references the GHG Protocol Scope 2 Guidance (2015). One stakeholder noted that this version is currently under review and suggested future-proofing the Standard by referencing the key principles outlined in the Scope 2 Quality Criteria table within the guidance, rather than a specific version of the guidance.
48One preparer highlighted that Air Quality does not feature as an output in their materiality assessment. In addition, the stakeholder pointed that, paragraph 1.3 of the technical protocols under the Air Quality topic requires entities operating in multiple jurisdictions to disclose how variations in local air quality regulations affect reported data. The preparer highlighted that considerable effort is required to determine such variations. They recommended that the ISSB remove this requirement as they consider it to be of limited value.
49In the Workforce Health & Safety topic, metric EM-MM-320a.1, which requires disclosure of (1) number of fatalities, (2) total recordable incident rate for (a) employees and (b) non-employees, and (3) average hours of health, safety, and emergency response training, was considered by both one preparer and the investor to be potentially of limited value. Specifically, item (3) and technical protocol 5 was viewed as having the potential to result in non-comparable data due to potentially inconsistent definitions of health and safety training among companies. The investor also noted that training requirements vary significantly across jurisdictions and operational sites depending on the riskiness of the environment and local regulations. Therefore, using the reported data to make comparisons between companies without context may potentially lead to misinterpretations.
50Regarding the Tailings Storage Facilities Management topic, both the investor and one preparer support the alignment with the GISTM and encouraged further harmonisation, given the detailed reporting requirements already under the GISTM.
Processed Foods SASB Standard
51The TAC Secretariat engaged with three preparers using the Processed Foods SASB Standard for their sustainability reporting. Overall, the preparers expressed general support for most of the proposed amendments with some comments as outlined below.
52All three preparers identified Food Waste as a relevant disclosure topic currently missing from the proposed amendments. They noted that they actively report on food waste targets, in line with commitments made under the UK's Waste and Resources Action Programme (WRAP).
53Feedback on metric FB-PF-260a.4 under the Health & Nutrition topic, which requires disclosure of revenue from products classified as healthy by a recognised nutrient profile model (NPM), was mixed. While two preparers supported the proposed disclosure, one preparer highlighted that their approach to health and nutrition is based on the nutritional value of a complete meal rather than individual products. As such, they deem this disclosure of revenue at the product level as an inaccurate reflection of their food nutritional considerations.
54One preparer flagged metric FB-PF-260a.5 which requires disclosure of revenue from products sold (1) in jurisdictions that require health warning labels and (2) that are required to carry a health warning label as lacking clarity. They noted that the definition of ‘health warning’ in technical protocols 1.1.1 & 1.1.2 which explain exclusion of allergens and warning labels directed to groups with specific health sensibilities such as pregnant women as not providing complete and clear principles on what should be included or excluded for a health warning. The preparer suggested clearer guidance, if for instance a traffic light labelling system was used.
55One preparer highlighted potential issues with the new proposed topic of Product Innovation, specifically metric FB-PF-410b.1, which requires disclosure of the use of innovation in food products addressing sustainability-related risks and opportunities. They indicated that without clearly defined boundaries for what constitutes product innovation in the context of sustainability, the requirement could lead to overly broad and potentially excessive narrative disclosures.
56One preparer highlighted potential issues with metric FB-PF-270a.6 under the Product Labelling & Marketing topic, which requires disclosure of revenue from products sold (1) in jurisdictions that restrict advertising of specific products to children and (2) subject to regulations that restrict the advertising of specific products to children. The preparer highlighted a lack of clarity around how companies would report revenue from products sold through distributors, particularly in cases where the company does not have visibility into the final consumer markets.
57No major concerns were raised regarding the reorganisation of the Environmental & Social Impacts of Ingredient Supply Chain and Ingredient Sourcing topics into Environmental Supply Chain Management and Social Supply Chain Management. However, two preparers noted potential duplication in disclosures related to certification schemes such as the Roundtable on Sustainable Palm Oil (RSPO) and the Rainforest Alliance, which address both environmental and social issues holistically.
58Further, in relation to the supply chain management topics, one preparer recommended breaking out key subjects such as deforestation, biodiversity, human rights, and regenerative agriculture into standalone disclosure topics. They highlighted that the current scope of the supply chain management topics is too broad and risks having companies report non-comparable data if not streamlined.
59All three preparers confirmed not having any issues with the exclusion of Ultra-Processed Foods (UPF) from the Standard, citing the lack of a universal definition and ongoing industry debate on what constitute UPF. As such, they highlighted that disclosures in this area would be inconsistent and of limited value to users at this time.
60All the three preparers confirmed that refrigerant gas emissions are reported as part of their Scope 1 emissions, and therefore, a separate disclosure topic was deemed not necessary.
61The three preparers also had no issues with the removal of Genetically Modified Organism disclosures from the Standard.
62One stakeholder explained the importance of interoperability particularly with ESRS.
SASB Standards without stakeholder feedback
63The TAC Secretariat have not been able to engage with stakeholders who could provide industry specific feedback on the proposed amendments to the following SASB Standards.
- Oil & Gas - Midstream,
- Oil & Gas – Refining & Marketing,
- Oil & Gas - Services,
- Coal Operations, and
- Iron & Steel Producers
64The Secretariat noted that the absence of Air Quality as a disclosure topic in the Coal Operations SASB Standard was identified by the TAC as a key issue. However, due to limitations in stakeholder outreach, particularly the inability to identify stakeholders currently applying the Coal Operations SASB Standard in the UK, the Secretariat was unable to obtain representative stakeholder perspectives. The investor engaged with indicated that they do not invest in the coal industry and therefore could not provide input on this matter.
Conclusion
65While the feedback received provides valuable insights, it is not fully representative of the broader UK stakeholders. This is due to the limited number of participants, a lack of diverse stakeholder representation, and the limited in-depth technical perspectives from those who contributed their views. Accordingly, the feedback should be considered for its relevance to specific areas, but it may not offer a definitive or comprehensive view on proposed amendments to a specific SASB Standard as a whole.