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TAC Public Meeting November 2025: Meeting Summary
PUBLIC MEETING SUMMARY
Date: 11 November 2025 Time: 09:30am – 1:35pm Location: Financial Reporting Council, 13th Floor, 1 Harbour Exchange Square, London, E14 9GE
Attendance
| Name | Designation |
|---|---|
| Sally Duckworth | Chair |
| Craig Mackenzie | Member |
| David Harris | Member (online) |
| Dia Desai | Member (online) |
| Harriet Cullum | Member (online) |
| Hilary Eastman | Member |
| Jeremy Osborn | Member |
| Madeleine Evans | Member (online for Agenda Items 1, 2, 3 & part of 4) |
| Nick Rowbottom | Member |
| Peter Hogarth | Member |
| Scott Barlow | Member |
| Supriya Sobti | Member (online for Agenda Items 1, 2, 3 & 4) |
| Jenny Carter | Member appointed by the Financial Reporting Council (FRC) |
| Paul Lee | Member appointed by the UK Endorsement Board (UKEB) |
| Michael Ashby | Observer from the Department for Business and Trade (DBT) (online) |
| Laura Kennedy | Observer from the Bank of England (BoE) (online) |
| Matilda Robson | Observer from the Financial Conduct Authority (FCA) |
| Sarah-Jayne Dominic | Secretariat |
1 Welcome and apologies
The Chair welcomed all attendees to the November meeting of the UK Sustainability Disclosure Technical Advisory Committee (TAC).
No conflicts of interest relating to the agenda were declared.
2 General reporting update
The TAC considered Agenda Paper 2 which provided key updates since the October 2025 TAC meeting. This paper was for information purposes only and no decision was required.
The following reflections were noted:
- There are several different developments taking place simultaneously across the world, which seem to be diverging from one another. For example, the GHG Protocol Scope 2 consultation, simplifications to ESRS, the SASB enhancement project, UK SRS.
- With the finalisation of ISSA 5000 for sustainability assurance, a question was raised as to how methodologies will be kept up to date.
- Consolidated group reporting may present some difficulties where a parent company is complying with UK SRS, but its subsidiaries are exempt or subject to a different jurisdictional implementation timeline. A question was raised as to how parent companies would obtain subsidiary data for group reporting in these instances.
3 SASB consultation: stakeholder feedback summary
The following comments were made regarding the stakeholder feedback summary:
- While preparers expressed a preference for interoperability to focus on mandated frameworks rather than voluntary ones, a member noted that some market participants view interoperability between SASB Standards and established frameworks such as the Global Reporting Initiative (GRI) as important.
- As the feedback is predominantly from preparers and very limited views from investors and other groups, there is a need for the TAC to be cautious in considering its use.
- A member noted stakeholder concerns regarding the application of materiality in SASB Standards. This is addressed in ISSB educational materials, which clarify that information on risks and opportunities in the Industry-Based Guidance is potentially material for entities within the industry. However, the ultimate responsibility for determining materiality rests with the reporting entity.
- Another member observed that while stakeholders commented on interoperability, the comment letter should clearly reflect what the TAC means with interoperability.
4 SASB consultation: draft comment letter on Exposure Draft Proposed Amendments to the SASB Standards
The TAC considered Agenda Paper 4, which presented the TAC's draft response to the Exposure Draft Proposed Amendments to the SASB Standards (the SASB Exposure Draft).
The TAC made several comments on the wording of its response to the SASB Exposure Draft. The comments included:
- In the covering letter, expanding the bullet points in paragraph 14.
- Under the general points in relation to the SASB Exposure Draft, refining the wording around numerous sections, but, in particular, the sections on the principles-based, not rules-driven, approach and the climate-first thematic approach.
- Under the proposed amendments to individual SASB Standards, removing the point on climate physical and just transition risks.
The TAC approved the draft response to the SASB Exposure Draft—subject to the comments discussed in the meeting—and authorised the Chair to resolve the edits arising from those comments.
The document will next 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.
5 SASB consultation: draft comment letter on Exposure Draft Proposed Amendments to the Industry-based Guidance on Implementing IFRS S2
The TAC considered Agenda Paper 5 covering the draft comment letter on the Exposure Draft Proposed Amendments to the Industry-based Guidance (IG ED) on Implementing IFRS S2.
The following comments were made:
- The updated SASB ED letter, as amended by the TAC should be reflected in this IFRS S2 IG ED response – reference was made to paragraph 14 and judgement and materiality.
- The term 'climate-related' should be clarified in the TAC's response letter.
- The ISSB should clarify the boundary for 'climate-related' and omit broader sustainability metrics from the IFRS S2 Industry Guidance.
- The approach to restatements is not addressed by the ISSB – the ISSB should coordinate with IASB on the establishment of a clear restatement protocol.
- The TAC's recommendations in its endorsement advice on IFRS S1 and IFRS S2 should be checked to ensure consistency with this and that approach put forward in the IFRS S2 IG response.
- Reference should be made to investors in addition to preparers when it comes to paragraph 1 on eliminating confusion.
6 SASB consultation: draft due process summary
The TAC considered Agenda Paper 6 which presents a draft due process summary for the TAC's project on phase one of the SASB enhancement project.
The TAC noted the use of the word 'voluntary' to describe the SASB Standards and decided to amend the language to 'non-mandatory'.
The TAC discussed what constitutes a project and therefore what each due process summary, and project management plan, should cover. It was questioned whether a plan and summary should be produced per comment letter. It was noted that the TAC has approached this project as a package of two comment letters (particularly as the two consultations are inextricably linked), and yet the language in the due process summary refers to a single comment letter. It was agreed that a single project may have multiple outputs, and that the due process summary should be amended to reflect that.
Subject to amendments, the due process summary was tentatively approved. It will be voted for final approval in the December 2025 TAC meeting.
7 GHG Protocol consultation: project management plan & timeline
The TAC considered Agenda Paper 7 on the project management plan and assessment approach to guide the TAC's review and response to the two consultations issued by the GHG Protocol in October 2025. The two consultations are on the revisions to the Scope 2 Guidance (2015) and a request for feedback on consequential accounting methods for estimating avoided emissions from electricity-sector actions.
The following comments were made:
- There is a lack of subject matter expertise within the TAC and there needs to be careful consideration as to where we can draw on expertise. This includes setting up appropriate stakeholder engagement in the time available, which is likely to be challenging. TAC members are asked to make any connections between relevant stakeholders and the Secretariat.
- The timeline for responding to the consultation (60 days) is inappropriate for an international standard setter, especially considering the implications that the changes will have across other reporting requirements. The TAC will register its concern and strongly recommend that future consultations should have longer timelines if the GHG Protocol want to meaningfully engage with stakeholders. The TAC agreed that a formal letter will be sent to the GHG Protocol on this matter, separate to the consultation response.
- Responding to the GHG Protocol consultation might be a step away from the TAC's role. However, due to the reference of the GHG Protocol Corporate Standard in IFRS S2 and [draft] UK SRS S2, it is appropriate for the TAC to engage with the consultation process, with a focus on the incorporation of GHG Protocol materials in these standards.
In relation to the assessment approach, TAC members that were present in the meeting opted for Option 3 which means the TAC will respond to the relevant questions in the online form and attach these to a formal letter which will be sent to the GHG Protocol and published on the FRC website.
8 GHG Protocol consultation: initial technical analysis
The TAC considered Agenda Paper 8 which provided a summary and initial analysis of the proposed revisions to the GHG Protocol's Scope 2 Guidance (2015). This paper also noted a second consultation that is requesting feedback on consequential accounting methods for the electricity sector.
The following comments were made:
- There was broad agreement that the proposed revisions will improve reporting by requiring more granular and accurate data, and attempts to resolve double counting challenges.
- The proposals are likely to improve comparability by requiring better disclosure of methodologies. However, it was noted that comparability doesn't mean that information is identical, and instead we might be taking about consistency in methodology.
- The proposals seem to only be focused on operational emissions and do not consider the needs of financial institutions. For example, promoting mixed methodologies is not helpful when consolidating data at different investment portfolio level.
- There is a difference between the proposed definition for 'accessible' in the GHG Protocol's Scope 2 guidance and ‘reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort' in IFRS Standards which could lead to a divergence in how data is prepared.
- The TAC agreed to also send a letter to the ISSB asking them how they intend to ensure the amendments to the GHG Protocol materials are aligned with the principles of IFRS S1.
- The GHG Protocol could consider IFRS 13 and how a data hierarchy is produced.
- In relation to the exemption for smaller companies, it is important to consider whether size thresholds or consumption thresholds are most appropriate. For example, a small company might have large energy consumption.
The TAC agreed that it will not provide a response to the consultation on consequential accounting methods, which is focused on the electricity sector, but also not directly relevant in the scope of IFRS S1 and IFRS S2.
9 AOB
There was no other business.
The Chair thanked attendees and presenters and confirmed that the next meeting is scheduled for 9 December 2025.
The meeting ended at 1:05pm.