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TAC Public Meeting December 2025 Paper 3: SASB Phase 1 Due Process Summary
Executive summary
| Date | 9 December 2025 |
| Paper reference | 2025-TAC-053 |
| Project | Proposed amendments to SASB Standards |
| Topic | Due process summary |
Objective of the paper
This paper presents a brief summary of the due process followed in the development of the TAC's comment letters on phase one of the proposed amendments to the SASB Standards issued by the International Sustainability Standards Board (ISSB).
Decisions for the TAC
The TAC is asked whether it approves the due process summary.
Appendices
Appendix – Due process summary
This paper has been prepared by the Secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC) to discuss in a public meeting. This paper does not represent the views of the TAC or any individual TAC member.
Due process summary
1The TAC's Due Process Policy (DPP) 1 states that the TAC would usually publish a due process summary for its work developing comment letters. The due process summary should include a conclusion on whether the development of the comment letter complied with the TAC's Due Process Policy, along with an explanation of any noncompliance.
2This due process summary concerns the TAC's project, ‘Proposed amendments to the SASB Standards', which thus far has included producing two comment letters, responding to the ISSB's Exposure Drafts Proposed Amendments to the SASB Standards and Proposed Amendments to the Industry-based Guidance on Implementing IFRS S2. As these comment letters have been developed concurrently as part of the same project, this Summary will cover both outputs.
3The appendix includes a copy of the due process summary.
Questions for the TAC
- Does the TAC have any comments on the due process summary in the appendix?
- Does the TAC approve the due process summary?
Appendix – Due process summary for 'Proposed amendments to the SASB Standards'
Project initiation
| Due process tasks | Status | Comments |
|---|---|---|
| A project management plan, including target timeline, is prepared and approved by the TAC. The project management plan is published on the FRC website. | Expected | The project management plan was published (Paper 2025-TAC-040) and approved at a public meeting on 16 September 2025. It is available on the FRC website via the above link. |
Project delivery, including performing technical analysis
| Due process tasks | Status | Comments |
|---|---|---|
| The TAC, and FRC as TAC Secretariat, undertake outreach with UK stakeholders. | Expected | The FRC as TAC Secretariat undertook outreach with UK stakeholders by identifying key stakeholders and engaging with them via interviews and a roundtable. A public survey was also open for responses for nine weeks. Stakeholders reached included investors, preparers from the nine priority industries, accountancy firms, professional bodies, academics, not-for-profits, and other consultancies. |
| Draft comment letters with an invitation to comment are prepared, approved by the TAC and published on the FRC website. | Optional | The TAC decided to undertake a proportionate approach to its consultation response based on time available and the non-mandatory nature of the SASB Standards. Therefore, it decided not to undertake a public consultation. The TAC undertook targeted outreach with UK stakeholders instead. |
| Research activities are reviewed and noted by the TAC. | Optional | The TAC Secretariat's research activities included:
|
| Final comment letters are prepared and approved by the TAC. | Mandatory | These activities informed the development of the TAC's technical papers, available on the FRC website. The TAC approved the comment letters in Paper 2025-TAC-048 and Paper 2025-TAC-049, subject to amendments discussed in the 11 November TAC meeting. |
| Final comment letters are submitted to the ISSB or other consultative body and published on the FRC website. | Mandatory | The final comment letters were submitted to the ISSB once approved. They have also been published on the FRC website. |
| A stakeholder feedback summary is prepared and approved by the TAC. The stakeholder feedback summary is published on the FRC website. | Expected if a draft comment letter has been published for consultation | Although the TAC decided not to undertake a public consultation on the draft comment letters, a summary of stakeholder feedback from the roundtable, survey and one-to-one interviews was published (Paper 2025-TAC-047) for the 11 November TAC meeting. |
Project closure
| Due process tasks | Status | Comments |
|---|---|---|
| A due process summary is prepared and approved by the TAC. The due process summary is published on the FRC website. | Expected | The TAC tentatively approved the draft due process summary in the 11 November meeting. [The final due process summary was tabled at the 9 December meeting.] |
| A lessons learnt exercise is performed by the TAC. | Optional | The TAC performed a lessons learnt exercise at the 11 November meeting private meeting. |
TAC meetings
| Due process tasks | Status | Comments |
|---|---|---|
There are a number of requirements in the TAC's ToR relating to meetings, including that:
|
Mandatory | The project was discussed in public meetings held on 8 July, 16 September, 14 October, and 11 November 2025. As of 27 November 2025 (the date of preparing this summary), the meetings have complied with due process. Meetings agendas, technical papers, summaries and recordings, are available on the FRC website. All agendas, papers and recordings were published within the timeframe specified by the TAC's Terms of Reference. An administrative delay meant the summary for the October meeting was published on the FRC website; and
|
| published online slightly past the ten working day deadline, at 10:45am on the eleventh working day. |
Conclusion
As of 27 November 2025, the development of the comment letter has complied with due process in all material respects.
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The TAC's DPP is available at: https://www.frc.org.uk/library/external-groups/uk-sustainability-disclosure-tac/uk-sustainability-disclosure-tac-terms-of-reference/ ↩