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TAC Public Meeting December 2025 Paper 2: TAC Update December 2025
AGENDA PAPER 2
Executive summary
| Date | 9 December 2025 |
| Paper reference | TAC-Update-Dec-2025 |
| Project | Monitoring |
| Topic | December 2025 General Reporting Update |
Objective of the paper
This paper provides key updates since the update paper published for the November 2025 TAC meeting.
This includes a summary of the ISSB meetings and related developments, in addition to jurisdictional developments in relation to the adoption of IFRS Sustainability Disclosure Standards to date.
The information in this paper is provided as at 25 November 2025 and does not include any developments after this date.
Decisions for the TAC
There are no decisions required. This paper is for information only.
Appendices
- Appendix 1 – Jurisdictional developments.
This paper has been prepared by the Secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC). It does not represent the views of the TAC or any individual TAC member.
Context
1The objective of this paper is to inform the TAC of international and jurisdictional developments in sustainability-related reporting. It is for information purposes only and does not ask the TAC to make any decisions.
2The TAC will be provided with an update of UK-specific, international and jurisdictional developments on sustainability-related reporting at each of its meetings.
UK developments
3The following paragraphs provide a summary of updates from the UK in relation to sustainability-related reporting since the last update paper published for the November 2025 TAC meeting.
4The Financial Reporting Council (FRC) has issued a UK version of the IAASB's international sustainability assurance standards; ISSA (UK) 5000. The standard is now available for voluntary use by UK assurance providers.
5The UK Sustainability Disclosure Technical Advisory Committee (the TAC) has submitted its responses to the International Sustainability Standards Board's (ISSB's) consultation on Phase 1 of the SASB enhancement project. The letters are available to view online.
International Sustainability Standards Board & other international body developments
6The following paragraphs provide a summary of updates from the ISSB since the last update paper published for the November 2025 TAC meeting.
7The ISSB held a Symposium on 30 October to discuss the implementation of the ISSB Standards. In the Chair's keynote, a significant expansion of the Jurisdictional Working Group was announced, to facilitate discussions about how the ISSB Standards can serve as a global passport. A Jurisdictional Rationale Guide for the adoption or other use of ISSB Standards and an accompanying tool were also announced in the Symposium.
8The ISSB met on 6 November and discussed its Biodiversity, Ecosystems and Ecosystems Services (BEES) research project. In the first vote of three, the board agreed to build on the Taskforce on Nature-related Financial Disclosures' (TNFD) recommendations in future nature-related work. In the second vote, the board agreed to move forward with standard-setting activities in relation to nature-related risks and opportunities. What these activities will look like, and the formal decision to begin them, will be up for discussion at a future meeting. In the third vote, the board agreed that educational materials will be produced after standards have been produced.
9The ISSB published two Updates, one highlighting the preliminary decisions made at the 28 October ISSB meeting, as covered in the November TAC Update Paper, and the other summarising the 6 November ISSB meeting.
10Following the 6 November ISSB meeting, the TNFD announced that it will complete its technical work by the third quarter of 2026. It will not begin any further work until after the ISSB completes its standard-setting process on nature-related issues.
11TNFD has also published guidance this month, on incorporating nature-related information into transition plans. It has also published eight recommendations for improving the availability of nature-related information, and a guide for asset owners' Chief Investment Officers on questions to ask about nature.
12GRI has published a checklist resource to help companies align their climate disclosures with the latest UN guidance on science-based net zero pathways.
13A coalition of environmentally-focused organisations, including the World Business Council for Sustainable Development (WBCSD), Nature Positive Initiative (NPI), Global Reporting Initiative (GRI), TNFD, the Capitals Coalition, the International Union for Conservation of Nature (IUCN), and the World Resources Institute (WRI) have committed to establishing a Nature Measurement Protocol. The Protocol would provide standardised methodologies and tools for measuring nature-related information.
14Following the European Parliament vote on 13 November 2025 (further information below), GRI released a statement criticising the newly approved text simplifying the EU's Corporate Sustainability Reporting Directive (CSRD) and Corporate Sustainability Due Diligence Directive (CSDDD). The statement criticises the reduction in scope and states that stakeholder demands will not be met.
15The Partnership for Carbon Accounting Financials (PCAF) has integrated the Comprehensive Environmental Data Archive (CEDA) into its database, to help quantify the Greenhouse Gas (GHG) emissions linked to its signatories' financial activities.
Jurisdictional developments
16The following paragraphs provide a summary of updates from other jurisdictions in relation to sustainability-related reporting since the last update paper published for the November 2025 TAC meeting.
European Union
17On 13 November, the European Parliament finalised its position on the directive to simplify the CSRD and CSDDD. This follows the voting down of the legislative proposal put forward by the Legal Affairs Committee (JURI) in October. The simplification amendments approved on 13 November were more drastic than expected. Under the revised text, the CSRD will only apply to companies with over 1,750 employees and with an annual net turnover of over €450m, which will reduce the scope of those that need to meet the requirements by 92%. As under the JURI position, large businesses will not be allowed to request sustainability information from smaller companies in their supply chain which go beyond the information required by voluntary reporting standards for Small and Mediums-sized Enterprises (SMEs). Failure to comply will result in fines determined by the relevant Member State, where the original CSDDD set blanket fines of 5% of net global turnover.
18CSDDD will only be mandatory for firms with over 5,000 employees and more than €1.5bn in annual turnover.
19Seven business associations have signed a joint statement calling on the European Union to provide legal certainty on the simplifications to the CSRD and CSDDD.
20The European Commission (EC) has proposed amendments to simplify the EU Sustainable Finance Disclosure Regulation (SFDR). The proposals include deleting the requirement to disclose entity-level principle adverse impacts indicators for financial markets, and limiting product-level disclosures only to data which is available, comparable and meaningful.
Southeast Asia
21The Association of Southeast Asian Nations (ASEAN) Capital Markets Forum has published a guide to ESG disclosures for SMEs who are part of larger companies' supply chains. ASEAN members who have endorsed, or are committed to endorsing, the ISSB Standards include Indonesia, Malaysia, Philippines, Singapore and Thailand.
Switzerland
22The Federal Court of Switzerland has adopted five proposals to provide targeted support to SMEs on sustainability-related requirements, including providing summative fact sheets, providing a digital reporting tool, and offering support in identifying geographical and product-specific sustainability risks.
Appendix 1 – Jurisdictional developments
G20 jurisdictions committed to adopting IFRS Sustainability Disclosure Standards
Table 1 summarises the status of G20 jurisdictions publicly committed to adoption or other use of the IFRS Sustainability Disclosure Standards.
Table 1: G20 jurisdictions (countries and regional bodies) summary as at 25 November 2025.
| Jurisdiction | Current status | Both IFRS S1 & IFRS S2? | Reporting commencing from | Companies in scope |
|---|---|---|---|---|
| African Union: Ghana | Endorsed | Both | 2027-2028 | Significant Public Interest Entities (Listed & unlisted) |
| African Union: Kenya | Endorsed and published roadmap | Both | 2025-2027 | Public Interest Entities; Non-Public Interest Entities (large entities); Small- to Medium-Sized Entities |
| African Union: Morocco | Publicly committed | - | - | - |
| African Union: Nigeria | Endorsed and published roadmap | Both | 2028-2030 | Public Interest Entities; Small- to Medium-Sized Entities |
| African Union: Rwanda | Endorsed and published roadmap | Both | 2025-2026 | Listed & unlisted |
| African Union: Tanzania | Endorsed | Both | 2025 | Listed & unlisted |
| African Union: Uganda | Endorsed | Both | 2026-2028 | Listed |
| African Union: Zambia | Endorsed | Both | 2025 | Listed |
| African Union: Zimbabwe | Publicly committed | - | - | - |
| Australia | Endorsed | Both: IFRS S1-voluntary IFRS S2-mandatory | 2025 | Listed & unlisted |
| Brazil | Endorsed | Both | 2026 | Listed |
| Canada | Endorsed | Both | 2025 | Currently voluntary |
| China | Consultation on Climate ED closed | Both (but uses a double materiality approach) | 2026-2030 | Listed & unlisted |
| India | Consultation closed | IFRS S2 only | 2025-2029 | Banking & finance |
| Indonesia | Endorsed | Both | 2027 | To be confirmed |
| Japan | Endorsed | Both | - | Listed |
| Mexico | Endorsed | Both | 2026 | Listed and private |
| South Korea | Consultation closed | Both | 2026-2030 | Listed |
| Turkey | Endorsed | Both | 2024 | Regulated financial institutions & large companies |
Other jurisdictions committed to adopting IFRS Sustainability Disclosure Standards
Table 2 summarises the status of non-G20 jurisdictions publicly committed to adoption or other use of the IFRS Sustainability Disclosure Standards.
Table 2: Other jurisdictions (countries and regional bodies) summary as at 25 November 2025.
| Jurisdiction | Current status | IFRS S1 & IFRS S2? | Reporting commencing from | Companies in scope |
|---|---|---|---|---|
| Bangladesh | Endorsed | Both | 2024-2027 | Banking & finance |
| Bolivia | Endorsed | Both | 2027 | Listed & unlisted |
| Chile | Endorsed | Both | 2026 | Listed |
| Costa Rica | Endorsed | Both | 2025-2026 | Listed & unlisted |
| Hong Kong | Endorsed | Both | 2025 | Listed |
| Jordan | Endorsed | Both: IFRS S1-voluntary FRS S2-Mandatory | 2027 | All entities listed in the ASE20 index |
| Malaysia | Endorsed | Both | 2025-2027 | Listed & large unlisted |
| Panama | Publicly committed | - | - | - |
| Pakistan | Endorsed | Both | 2025-2027 | Listed & unlisted public interest companies |
| Philippines | Consultation closed | Both | 2026 | Listed |
| Qatar | Consultation closed | Both | 2026 | Listed |
| Singapore | Endorsed | IFRS S2 only | 2025-2027 | Listed |
| Sri Lanka | Endorsed | Both | 2025 | To be confirmed |
| Switzerland | Consultation closed - amending the Ordinance on Climate Disclosures | Both | 2026 | Listed & unlisted |
| Taiwan | Endorsed | Both | 2026-2028 | Listed |
| Thailand | Endorsed | Both | 2026-2030 | Listed |
G20 jurisdictions not publicly committed to adopting IFRS Sustainability Disclosure Standards
Table 3 summarises the status of G20 jurisdictions not publicly committed to adoption or other use of the IFRS Sustainability Disclosure Standards.
Table 3: G20 jurisdictions (countries and regional bodies) not publicly committed to adopting ISSB Standards as at 25 November 2025.
| Jurisdiction | Current status | Topics | Reporting commencing from | Companies in scope |
|---|---|---|---|---|
| Argentina | Unconfirmed | - | - | - |
| European Union (EU)1 | European Sustainability Reporting Standards (ESRS) & Corporate Sustainability Reporting Directive (CSRD) | Ten topical standards including a general and climate change standard | 2024-2028 | Listed & unlisted |
| Russia | Unconfirmed | - | - | - |
| Saudi Arabia | Unconfirmed | - | - | - |
| South Africa | Unconfirmed | - | - | - |
| United States of America | California Corporate Climate Accountability Act (SB 253 and SB 261) - adopted | California: 2026 | California: Listed & unlisted | |
| New York | New York Climate Corporate Data Accountability Act (SB 3456) - bill | New York: 2027-2028 | New York: Listed & unlisted | |
| Colorado | Colorado Corporate Climate Accountability Act (House Bill 25-119) - bill | Colorado: 2028-2031 | Colorado: Listed & unlisted |
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Although ESRS are required to be used by EU member states, the IFRS Foundation and EFRAG issued interoperability guidance in 2024 illustrating the high level of alignment achieved between ISSB Standards and ESRS. Note that this is subject to change as EFRAG finalises amendments to its standards arising from the simplification project. ↩