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Letter to ISSB Chair: Exposure Draft SASB/ED/2025/1 - Proposed Amendments to the SASB Standards

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

This 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. It is also accompanied by an appendix summarising the views provided by stakeholders in one-to-one meetings for the ISSB's information.

This letter should be read alongside the accompanying TAC letter Exposure Draft ISSB/ED/2025/2: Proposed Amendments to the Industry-based Guidance on Implementing IFRS S2 (IFRS S2 Industry-based Guidance), which presents the TAC's response to the consultation on the consequential amendments to the IFRS S2 Industry-based Guidance. Our comments on the SASB Standards in this letter also apply to the IFRS S2 Industry-based Guidance where relevant.

The 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 Secretary of State for the Department for Business and Trade. The TAC also has a 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.

The 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.

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The value of industry-based sustainability disclosures

UK stakeholders generally welcomed sources of guidance, including the SASB Standards ¹. The TAC believes that the SASB Standards could play an important role in supporting the implementation of IFRS S1 and IFRS S2. The SASB Standards could help entities: (a) consider which sustainability-related risks and opportunities may be relevant to their industry; and (b) identify and disclose material information about sustainability-related risks and opportunities. This may be especially important in respect of issues for which topic-specific IFRS Sustainability Disclosure Standards have not (yet) been developed.

Our stakeholder outreach and research activities suggest that there are some concerns about the current SASB Standards, however, there is general support for an ISSB project to enhance them – albeit most views were from entities currently voluntarily using the SASB Standards, rather than those yet to use them. Stakeholders expressed concerns about the prescriptive nature of the current SASB Standards, viewing them as a potentially onerous reporting burden and believing they lack the materiality and judgement principles in the IFRS Sustainability Disclosure Standards. Most 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. The TAC supports these views and believes that preparers should be transparent about their approach so that users do not assume a different level of data availability and reporting maturity.

The TAC therefore believes that the ISSB's project to enhance the SASB Standards is important, providing the ISSB with the opportunity to ensure that its industry-based sustainability disclosures align with and complement the IFRS Sustainability Disclosure Standards, as well as keeping pace with changes. The TAC encourages the ISSB to be ambitious with its proposals and cautions that being overly attached to the status quo could result in stakeholder disengagement. The TAC recommends:

that, as a priority, the ISSB communicates the future architecture of the IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture. The future architecture should prioritise the continuance of the global baseline of sustainability disclosures for capital markets established by IFRS S1 and IFRS S2. 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. Further information is in paragraphs 1 to 2 of Appendix 1;
that the ISSB:
- considers restructuring the SASB Standards to distinguish between core disclosures, industry-agnostic disclosures and industry-specific disclosures;
- considers moving core and industry-agnostic disclosures out of the SASB Standards and into IFRS S1, IFRS S2 and any further topic-specific IFRS Sustainability Disclosure Standards. The SASB Standards would then focus only on industry-specific disclosures; and
- reconsiders the name of the SASB Standards and suggests that they are renamed the 'ISSB Guidance on the Industry-based Sustainability Disclosures'.

Further information is in paragraphs 3 to 9 of Appendix 1;

that the ISSB emphasises a principles-based approach so that the SASB Standards do not have to be adapted so much to keep pace with changes. In particular, entities should be encouraged not to disclose information otherwise suggested by a SASB Standard if the information is not material. Further information is in paragraphs 10 to 12 of Appendix 1;
that the ISSB considers adopting a climate-first thematic approach by incorporating core and industry-agnostic climate-related disclosures from the SASB Standards into IFRS S2 first, making any enhancements to industry-specific climate-related disclosures in the SASB Standards at the same time; and then enhancing the content related to other topics in the SASB Standards, alongside developing further topic-specific IFRS Sustainability Disclosure Standards. Further information is in paragraphs 13 to 14 of Appendix 1;
that the IFRS Foundation applies the level of due process to the SASB Standards that is commensurate to the role they will play in the future architecture of the IFRS Sustainability Disclosure Standards. Further information is in paragraphs 15 to 16 of Appendix 1; and
that there are mappings from SICS to other industry classification systems to support reconciliations between industry classification systems. Further information is in paragraphs 23 to 27 of Appendix 1.

In making these recommendations, we stress the importance of ensuring that an effective consultation process is conducted on the SASB Standards and other materials that the ISSB might develop. 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. One example is encouraging the ISSB to issue proposed amendments to all SASB Standards in a sector together. Further information is in paragraphs 17 to 22 of Appendix 1.

The TAC's response has been developed considering the UK context and the UK Government's recent consultation on draft UK Sustainability Reporting Standards (UK SRS). The IFRS Sustainability Disclosure Standards require entities to refer to and consider the applicability of the SASB Standards. However, the UK Government has consulted on proposals to amend ‘shall' to 'may' in the draft UK SRS. Our stakeholder outreach and research activities suggest that there continues to be confusion about the status of the SASB Standards in the ISSB's Standards. Some preparers considered the word 'shall' to be prescriptive and having the potential to cause reporting burdens and assurance challenges. Such preparers note that the UK Government's proposed change enables entities to apply judgement in determining the extent of use of the SASB Standards for their reporting.

The TAC's response therefore focuses on the role of the SASB Standards as industry-based sustainability disclosures that support the implementation of IFRS S1 and IFRS S2.

If you have any queries or would like to discuss our comments in more detail, please do not hesitate to contact me or the TAC Secretariat at [email protected].

Yours sincerely

Signature of Sally Duckworth.

Sally Duckworth Chair of the UK Sustainability Disclosure TAC Email: [email protected]

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

Future architecture of the IFRS Sustainability Disclosure Standards, including the incorporation of the SASB Standards

1The IFRS Foundation has communicated its vision for the IFRS Sustainability Disclosure Standards to provide the foundations for globally applicable disclosure requirements, thereby establishing a consistent and comprehensive global baseline. The TAC agrees with the IFRS Foundation's vision and recommends that, as a priority, the ISSB communicates the future architecture of the IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture. The future architecture should prioritise the continuance of the global baseline of sustainability disclosures for capital markets established by IFRS S1 and IFRS S2. 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. 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 disclosures into the IFRS Sustainability Disclosure Standards.

2Clarity around the future architecture of the IFRS Sustainability Disclosure Standards is likely to support the development of the ISSB's priorities, as well as the targeting of its resources. It is also likely to help the IFRS Foundation to determine the level of due process to apply to the SASB Standards. The TAC recommends that the ISSB seeks stakeholder views on the future architecture of the IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture, so that those views can shape the ISSB's approach.

Strategy for enhancing the SASB Standards

3The TAC strongly agrees with the overall objective of the ISSB's project Enhancing the SASB Standards, which the ISSB states 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.

4The SASB Standards were developed before the IFRS Sustainability Disclosure Standards. The TAC believes that industry-based sustainability disclosures 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.

5Entities 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. Our stakeholder outreach and research activities 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.

6The TAC recommends that the ISSB develops a clear strategy for enhancing the SASB Standards. The strategy would link to the future architecture of the IFRS Sustainability Disclosure Standards and should prioritise simplification (meaning that the SASB Standards are straightforward to apply and it is easy to understand their output) and alignment with the IFRS Sustainability Disclosure Standards. Without simplification and alignment with IFRS S1 and IFRS S2, stakeholders could 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 sustainability disclosures 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 sustainability disclosures should be a global baseline, that jurisdictions can add to as is relevant to their specific situation.

7The 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, strategy and risk management. These are relevant to all entities.
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.

8The TAC also suggests that the ISSB considers moving core and industry-agnostic disclosures out of the SASB Standards and into IFRS S1, IFRS S2 and any further topic-specific IFRS Sustainability Disclosure Standards. The SASB Standards would then focus only on industry-specific disclosures.

9Finally, 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 suggests that the SASB Standards are renamed the 'ISSB Guidance on the Industry-based Sustainability Disclosures'.

Keeping pace with changes

10As 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 accommodate changes to fast-moving and evolving sustainability issues, such as climate change, and other sustainability-related standards and frameworks.

11The 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 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.

12Therefore, the TAC encourages the ISSB to emphasise a principles-based, not rules-driven, approach so that the SASB Standards do not have to be adapted so much to keep pace with changes. A principles-based approach could include disclosure objectives relevant to investors followed by a list of disclosures. Entities should also be encouraged, in line with paragraph B25 of IFRS S1, albeit that paragraph applies to IFRS Sustainability Disclosure Standards, not to disclose information otherwise suggested by a SASB Standard if the information is not material. Instead, the SASB Standard disclosure topics and metrics could be presented as illustrative examples of disclosures.

Climate-first thematic approach

13The 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 SASB Standards and disclosures.

14The 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, the TAC suggests that the ISSB considers adopting a climate-first thematic approach by incorporating core and industry-agnostic climate-related disclosures from the SASB Standards into IFRS S2 first, making any enhancements to industry-specific climate-related disclosures in the SASB Standards at the same time; and then enhancing the content related to other topics in the SASB Standards, alongside developing further topic-specific IFRS Sustainability Disclosure Standards. 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. The proposed piecemeal approach means that the IFRS S2 industry-based guidance is going to be continuously revised, which, as noted in paragraph 11 of Appendix 1, could be extremely resource intensive.

A robust due process

15The 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 strengthened 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 justifies a greater level of due process.

16The 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. The TAC recommends that the IFRS Foundation applies the level of due process to the SASB Standards that is commensurate to the role they will play in the future architecture of the IFRS Sustainability Disclosure Standards.

Improving the consultation process

17The 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 had considered the specifics of the proposals during the consultation.

18The challenges experienced by the TAC may be due to a combination of factors, such as: the absence of public deliberations on the technical content during the development of the SASB Exposure Draft; 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 broad nature of the materials.

19The TAC recommends that the ISSB considers improving the consultation materials for future consultations. For example, the ISSB could provide tables, similar to those published by EFRAG, with logs of key amendments showing the proposed revisions and reason for them. Other suggestions that could be applied to future consultations are made in paragraphs 29, 37, 61, 63, 64, 84 and 85 of Appendix 2.

20The TAC also recommends that the ISSB publishes summaries of the origins of the disclosure topics and 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 historical reasoning makes the analysis of the proposed amendments challenging. The historical information would also support the ISSB with its consideration of whether the disclosure topics and metrics continue to be relevant, and the costs and benefits of the proposed reporting.

21If the ISSB continues to prioritise industries for enhancement, the TAC encourages the ISSB to issue proposed amendments to all SASB Standards in a sector together as was the case for the SASB Standards in the Extractives & Minerals Processing sector. The TAC notes that it has not been ideal to consider changes to only one of eight SASB Standards in the Food & Beverage sector, particularly given that two further SASB 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 with SASB Standards for enhancement so far, and encourages the ISSB to publicise and seek stakeholder views on the selection of future priority industries. However, the TAC's preferred option is the climate-first thematic approach set out in paragraphs 13 to 14 of Appendix 1.

22The TAC stresses the importance of ensuring that an effective consultation process is conducted on the SASB Standards and other materials that the ISSB might develop. 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

23The 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 notes that a workstream to consider the industry classification system could be a big project in its own right.

24The 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.

25Overall, 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.

26The 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(s). This can result in entities not considering relevant disclosures located in other SASB Standards and a lack of consistency. The preparers we engaged with had a common view that integrated Oil & Gas entities face practical challenges in simultaneously applying multiple Oil & Gas SASB Standards relevant to their operations. In paragraph 7 of Appendix 1, 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 conglomerates reporting across multiple industries, as is the ISSB emphasising a principles-based approach.

27The TAC is also concerned about comparability across different industry classification systems and recommends that there are mappings from SICS to other industry classification systems to support reconciliations between industry classification systems.

Appendix 2: 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?

28As noted in Appendix 1 on the general points in relation to the SASB Exposure Draft, the TAC strongly agrees with the overall objective of the ISSB's project Enhancing the SASB Standards, which the ISSB states 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 should support the implementation of IFRS S1 and IFRS S2 were it to prioritise simplification and alignment with the IFRS Sustainability Disclosure Standards. Our comments in Appendix 1 cover the TAC's recommendations in relation to the future architecture of the IFRS Sustainability Disclosure Standards, including the incorporation of the SASB Standards. These recommendations are also summarised in the covering letter. In contrast, our answer to Question 1 focuses on the TAC's views on the ISSB's stated intention of the proposed amendments and its related areas of focus.

29The TAC agrees with the ISSB's stated 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 Appendix 1, enhance the SASB Standards, so that they do not have to be adapted so much to keep pace with changes.

30The 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.

31We have ordered the ISSB's 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 the 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 the IFRS Sustainability Disclosure Standards

32The 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.

33A 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.

34In particular, the TAC suggests that the ISSB considers:

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 the IFRS Sustainability Disclosure Standards focus on risks and opportunities. However, the SASB Standards are structured around disclosure topics and metrics.
numbering each of the SASB Standards and using a paragraph style and format similar to the IFRS Sustainability Disclosure Standards.
providing an analytical bridge connecting the SASB metrics (which are largely backward looking) to the financial statements, including anticipated financial effects, i.e., how an entity's prospects could be affected.
clearly distinguishing between disclosures 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 disclosures. However, the technical protocols also include additional disclosures that supplement the 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 7 of Appendix 1, 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

35The 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 international applicability is important for the UK market.

36The 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 17 of Appendix 1, 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. The technical protocol does not specify 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.

37A 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 TAC suggests that the ISSB considers:

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. The TAC considers further engagement with portfolio managers and analysts to be particularly important.
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.

38The 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 should consider including equivalent guidance throughout the SASB Standards.

39Overall, 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.

40The 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 regulations in certain jurisdictions requiring the use of Global Reporting Initiative (GRI) Standards, in particular.

41As noted in paragraph 5 of Appendix 1, entities currently seem to use a wide range of sustainability-related standards and frameworks. Most 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 Standards) and that entities may choose to do so for guidance on new and emerging issues.

42The TAC believes that the ISSB's industry-based sustainability disclosures should be a global baseline, that jurisdictions can add to as is relevant to their specific situation. The ISSB should focus on simplifying and supporting the navigation of the different sustainability-related standards and frameworks so that the SASB Standards do not become additive and burdensome. The TAC further 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.

43One of the key challenges for the ISSB is the continuing evolution of other sustainability-related standards and frameworks, for example EFRAG revising 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. The ISSB aligning the SASB Standards to the standards of external bodies is also problematic and could result in the SASB Standards being continuously revised, which could be extremely resource intensive, or out-of-date. For example, the proposed amendments to revise the definition of 'employee' to align with that in the Exposure Draft Standard Interpretation 1 to GRI 2: General disclosures 2021, Control of work.

44Another challenge is the different approaches to materiality and identifying sustainability-related matters to disclose in other sustainability-related standards and frameworks. We agree that the ISSB should first determine that disclosures are relevant for investors (primary users), next determine that disclosures in other sustainability-related standards and frameworks fit with the ISSB's materiality lens, and then consider adopting those disclosures.

45Mappings 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.

46The TAC also cautions that a focus on alignment with TNFD may be premature, as noted in paragraph 48 of Appendix 2.

47The TAC does not support the ISSB's aim of aligning the enhancements with the ISSB's research projects on BEES and human capital. The ISSB's research project on BEES has not been completed, but the ISSB recently agreed to build on the TNFD recommendations in future nature-related work and agreed to move forward with standard-setting activities in relation to nature-related risks and opportunities. The form of those activities and the formal decision to begin them, however, will only be discussed at a future meeting. 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. The TAC also notes that a number of the SASB Standard BEES and human capital metrics could be considered to be industry-agnostic disclosures.

48The TAC therefore suggests it is premature for the ISSB to make amendments related to BEES or human capital to the SASB Standards without communicating the future architecture of the IFRS Sustainability Disclosure Standards, including how 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. The TAC notes that there is currently a more robust due process applied to the development of IFRS Sustainability Disclosure Standards than there is to the SASB Standards. As noted in paragraph 8 of Appendix 1, the TAC suggests that the ISSB considers moving core and industry-agnostic disclosures out of the SASB Standards and into IFRS S1, IFRS S2 and any further topic-specific IFRS Sustainability Disclosure Standards. The SASB Standards would then focus only on industry-specific disclosures. As noted in paragraph 14 of Appendix 1, the TAC also suggests that the ISSB considers adopting a climate-first thematic approach by incorporating core and industry-agnostic climate-related disclosures from the SASB Standards into IFRS S2 first, making any enhancements to industry-specific climate-related disclosures in the SASB Standards at the same time; and then enhancing the content related to other topics in the SASB Standards, alongside developing further topic-specific IFRS Sustainability Disclosure Standards.

QUESTION 2—ENHANCEMENTS TO INTEROPERABILITY WITH OTHER STANDARDS AND FRAMEWORKS

(a) Do you agree with the proposed approach to enhancing interoperability and alignment with other sustainability-related standards and frameworks? Why or why not?

(b) 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?

(c) 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?

49As noted in paragraphs 40 to 46 of Appendix 2, the TAC generally supports 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

(a) 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?

(b) Do you agree that the proposed amendments would enhance the decision-usefulness of the industry-specific information about climate-related risks and opportunities? Why or why not?

(c) Do you agree that the proposed amendments would further clarify how the climate-related content in the SASB Standards and the IFRS S2 industry-based guidance relates to the requirements in IFRS S2?

50As noted in paragraph 14 of Appendix 1, the 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, the TAC suggests that the ISSB considers adopting a climate-first thematic approach.

51Please 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 62, 65 and 66 of Appendix 2.

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

(a) 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?

(b) 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.

(c) 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?

(d) 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.

52As noted in paragraphs 47 to 48 of Appendix 2, the TAC does not support the ISSB's aim of aligning the enhancements with the ISSB's research projects on BEES and human capital.

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?

53The 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.

54The 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. The ISSB should also be clear about whether comparatives are required for newly revised metrics.

55The TAC believes that the timeline should be aligned with annual reporting cycles and provide preparers with sufficient lead time to update internal systems and processes. It should also support jurisdictions that rely on translated versions of the SASB Standards, allowing for consistent implementation across regulatory frameworks.

Proposed amendments to individual SASB Standards

56Please also refer to our comments in Appendix 1 on general points in relation to the SASB Exposure Draft, which cover the TAC's recommendations in relation to the future architecture of the IFRS Sustainability Disclosure Standards, including the incorporation of SASB Standards. These recommendations are also summarised in the covering letter. Our answers to Questions 6 to 14 are on the current SASB Standards rather than the industry-based disclosures which follow our recommendations.

57We are grouping our answers to Questions 6 to 13 together to reflect linkages between the SASB Standards in the Extractives & Minerals Processing sector.

Overall position

QUESTION 6—COAL OPERATIONS SASB STANDARD

(a) Do you agree with the proposed amendments to the Coal Operations SASB Standard? Why or why not?

QUESTION 7—CONSTRUCTION MATERIALS SASB STANDARD

(a) Do you agree with the proposed amendments to the Construction Materials SASB Standard? Why or why not?

QUESTION 8—IRON & STEEL PRODUCERS SASB STANDARD

(a) Do you agree with the proposed amendments to the Iron & Steel Producers SASB Standard? Why or why not?

QUESTION 9—METALS & MINING SASB STANDARD

(a) 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

(a) 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

(a) 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

(a) 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

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

58As noted in paragraph 17 of Appendix 1, the TAC experienced challenges engaging with UK stakeholders who had considered the specifics of the proposals. 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 reflect the UK market and the TAC does not have the evidence to 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

(b) 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

(b) 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

(b) 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

(b) 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

(b) 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

(b) 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

(b) 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

(b) 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?

59Our stakeholder outreach and research activities have not indicated that there are any concerns about the updated industry descriptions in the SASB Standards in the Extractives & Minerals Processing sector.

60However, the TAC has mixed views about the overall industry classification system. Please refer to our comments in paragraphs 23 to 27 of Appendix 1.

Disclosure topics

QUESTION 6—COAL OPERATIONS SASB STANDARD

(c) 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

(c) 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?

(e) 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

(c) 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

(c) 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?

(e) 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

(c) 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

(c) 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

(c) 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

(c) 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

61The ISSB has not provided information on why certain disclosure topics are included in some SASB Standards in the Extractive & Mineral Processing sector 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 original inclusion or subsequent 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 SASB Standards. For example:

61.1Coal Operations SASB Standard: Air Quality. The ‘Air Quality' disclosure topic is included in all SASB Standards in the Extractive & Mineral Processing sector except for the Coal Operations SASB Standard. This is despite the other SASB Standards in the Extractive & 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 capable of being material information.

61.2Construction 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 assessment did not identify air quality as financially material for reporting.

61.3Construction Materials and Oil & Gas – Exploration & Production SASB Standards: Labour Practices. There is no ‘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. The preparers from these industries that the TAC engaged with highlighted the omission as surprising.

61.4All 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.

61.5Oil & Gas – Midstream SASB Standard: Water Management. The 'Water Management' disclosure topic is included in all SASB Standards in the Extractive & Mineral Processing sector except for the Oil & Gas – Midstream SASB Standard.

61.6All SASB Standards for industries in the Extractive & 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 SASB Standards but not in others when they are potentially applicable to all industries in the Extractive & Mineral Processing sector.

62The TAC asks the ISSB to consider whether there is a case for including or excluding any of these disclosure topics. The issues could also be addressed by the TAC's recommendations in relation to the future architecture of the IFRS Sustainability Disclosure Standards, including the incorporation of the SASB Standards.

Disclosure topic summaries

63Disclosure 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 various ‘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

(d) 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?

(e) 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

(d) 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?

QUESTION 8—IRON & STEEL PRODUCERS SASB STANDARD

(d) 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

(d) 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?

(e) 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

(d) 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?

(e) 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?

(f) 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

(d) 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?

(e) 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

(d) 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

(d) 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?

(e) 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?

64The TAC suggests that the ISSB considers providing tables or indicating more clearly where the same amendment has been made across multiple standards to assist the process of considering the proposed amendments. For example, the amendments to the water-related metrics are identical. This would save time working through the material to understand the changes that have been made and why they have been made.

Greenhouse Gas Emissions

65Coal Operations: EM-CO-110a.3, Oil & Gas – Exploration & Production: EM-EP-110a.4 and Oil & Gas – Midstream: EM-MD-110a.3 are new metrics on 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 preparers in the Oil & Gas – Exploration & Production industry that the TAC engaged with expressed concern about the level of detail. In particular, they highlighted technical protocol paragraph 3 on 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 disclosures 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.

66The 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 SASB 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 to disclose. Therefore, the TAC recommended that the ISSB collaborates with the 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

67The 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.

68Metals 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:

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

69The 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. A stakeholder in the Oil & Gas sector that the TAC engaged with expressed concern about the removal of references to the ILO and perceived this as weakening the language related to human rights.

Management of the Legal and Regulatory Environment

70Oil & 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 on the disclosure of positions related to government regulations or policy proposals affecting the industry. However, neither the existing SASB 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.

71Given the above, the importance of connectivity with financial statements and the requirement to disclose anticipated financial effects, the fact that such disclosures can provide early indications of litigation matters that may subsequently crystalise within the financial statements (as a provision or contingent liability), and the fact that this issue is not addressed consistently across standards², 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 SASB 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.

Stakeholder feedback

72A summary of stakeholder feedback on the metrics and technical protocols in the SASB Standards in the Extractives & Minerals Processing sector is included in Appendix 3.

Jurisdictional considerations

QUESTION 6—COAL OPERATIONS SASB STANDARD

(f) 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

(f) 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

(e) 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

(f) 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

(g) 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

(f) 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

(e) 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

(f) 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.

73Please refer to our comments on international applicability in paragraphs 35 to 39 of Appendix 2.

QUESTION 6—COAL OPERATIONS SASB STANDARD

(g) 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

(g) 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

(f) 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

(g) 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

(h) 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

(g) 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

(f) 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

(g) 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.)

74Please refer to our comments on interoperability and alignment with other sustainability-related standards or frameworks in paragraphs 40 to 46 of Appendix 2.

QUESTION 14—PROCESSED FOODS SASB STANDARD

(a) Do you agree with the proposed amendments to the Processed Foods SASB Standard? Why or why not?

75As noted in paragraph 21 of Appendix 2, It has not been ideal to consider changes to only one of eight SASB Standards in the Food & Beverage sector, particularly given that two further SASB Standards 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 SASB Standards in the Food & Beverage sector which are expected to be consulted on later this year but, preferably, with all the other SASB Standards in the Food & Beverage sector.

76As noted in paragraph 17 of Appendix 1, the TAC experienced challenges engaging with UK stakeholders who had considered the specifics of the proposals. The TAC notes that three preparers were engaged with in relation to the Processed Foods SASB Standard. The stakeholder feedback collected may not therefore reflect the UK market and the TAC does not have the evidence to conclude on whether it agrees with the proposed amendments to the Processed Foods SASB Standard.

(b) 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?

77Our stakeholder outreach and research activities have not indicated that there are any concerns about the expanded industry description in the Processed Foods SASB Standard.

78However, the TAC has mixed views about the overall industry classification system. Please refer to our comments in paragraphs 23 to 27 of Appendix 1.

(c) 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?

79Again, the ISSB has not provided information on why certain disclosure topics are included in some SASB Standards in the Food & Beverage sector but not in others. It would be helpful to understand the prioritisation process used to determine their original inclusion or subsequent exclusion. For example, there may be a case for including the 'Food Waste Management' disclosure topic in the Processed Foods SASB Standard as food processing entities generate significant levels of food waste. All three preparers from this industry that the TAC engaged with identified ‘Food Waste Management' as a relevant disclosure topic currently missing from the proposed amendments. They noted that in the UK they report on food waste targets in line with commitments made under the Waste and Resources Action Programme (WRAP).

(d) 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?

80A summary of stakeholder feedback on the metrics and technical protocols in the Processed Foods SASB Standard is included in Appendix 3.

(e) 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.

81Please refer to our comments on international applicability in paragraphs 35 to 39 of Appendix 2.

(f) 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.)

82Please refer to our comments on interoperability and alignment with other sustainability-related standards or frameworks in paragraphs 40 to 46 of Appendix 2.

Proposed targeted amendments to other SASB Standards

QUESTION 15—PROPOSED TARGETED AMENDMENTS TO THE SASB STANDARDS

(a) 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?

83As noted in paragraph 17 of Appendix 1, the TAC experienced challenges engaging with UK stakeholders who had considered the specifics of the proposals. The TAC therefore does not have the evidence to conclude on whether it agrees with the proposed targeted amendments to the SASB Standards. It cautions that its response may not reflect the views of the UK market.

(b) 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?

84As noted in paragraph 14 of Appendix 1, 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, 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, whereby targeted amendments are only being proposed to pre-existing metrics.

85The TAC also suggests that the ISSB considers:

publicly outlining the criteria it used to determine whether disclosure topics and metrics qualify as a 'targeted amendment'; and
sharing 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.

(d) Do you agree with the proposed targeted amendments associated with energy management? Why or why not?

(e) Do you agree with the proposed targeted amendments associated with water management? Why or why not?

86Subject to our comments in Appendix 1 on the general points in relation to the SASB Exposure Draft 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.

(f) Do you agree with the proposed targeted amendments associated with labour practices? Why or why not?

(g) Do you agree with the proposed targeted amendments associated with workforce health and safety? Why or why not?

87The TAC does not agree that the ISSB should make targeted amendments associated with labour practices and workforce health and safety. As noted in paragraph 47 of Appendix 2, 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. The TAC therefore suggests it is premature for the ISSB to make amendments to the SASB Standards related to human capital without communicating the future architecture of the IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture.

(h) 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.

88Please refer to our comments on international applicability in paragraphs 35 to 39 of Appendix 2.

(i) 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.)

89Please refer to our comments on interoperability and alignment with other sustainability-related standards or frameworks in paragraphs 40 to 46 of Appendix 2.

Appendix 3: Summary of stakeholder feedback

90The FRC, in its role as the Secretariat for the TAC, conducted stakeholder outreach and research activities. The stakeholder outreach activities included a 'snapshot' survey, a roundtable discussion and one-to-one meetings.

91As noted in paragraph 17 of Appendix 1, the TAC experienced challenges engaging with UK stakeholders who had considered the specifics of the proposals.

92The TAC has chosen to include a summary of views provided by stakeholders in one-to-one meetings for the ISSB's information. However, the stakeholder feedback collected may not fully reflect the views of the UK market.

Metals & Mining SASB Standard

93The 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.

94All 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).

95One 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.

96The 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.

97Under 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. The 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.

99One 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.

100In 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.

101Regarding 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.

Oil & Gas – Exploration & Production SASB Standard

102The 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.

103The 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, rather than at industry level.

104The 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.

105The 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.

106In 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. In particular, they highlighted technical protocol paragraph 3, on disclosure of the 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 disclosures 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.

107One 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.

108One preparer expressed concern about 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.

109Stakeholders also noted inconsistencies, such as the omission of Labour Practices as a topic despite the inclusion of Workforce Health and Safety topic.

110The 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'.

Construction Materials SASB Standard

111Three stakeholders emphasised the importance of interoperability. One noted that ISSB's efforts should prioritise interoperability with mandated standards and frameworks over voluntary ones.

112The 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.

113The 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.

114Although Air Quality is a required disclosure topic under this SASB Standard, the preparer highlighted that their assessment did not identify Air Quality as financial material for reporting.

115Additionally, 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.

116The 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.

117The 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.

118No concerns were raised regarding the new topic of Supply Chain Management, as the stakeholder's supply chain is largely domestic with limited international exposure.

119There was no specific feedback received from the investor regarding the Construction Materials SASB Standard.

Processed Foods SASB Standard

120The 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.

121All three preparers identified Food Waste as a relevant disclosure topic currently missing from the proposed amendments. They noted that in the UK they actively report on food waste targets, in line with commitments made under the Waste and Resources Action Programme (WRAP).

122Feedback 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.

123One 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.

124One 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.

125One 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.

126No 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.

127Further, 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.

128All 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.

129All 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.

130The three preparers also had no issues with the removal of Genetically Modified Organism disclosures from the Standard.

131One stakeholder explained the importance of interoperability particularly with ESRS.

Footnotes

Please refer to the TAC's December 2024 report UK Endorsement of IFRS S1 and IFRS S2. ↩
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). ↩

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Name Letter to ISSB Chair: Exposure Draft SASB/ED/2025/1 - Proposed Amendments to the SASB Standards

Publication date 27 November 2025

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