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TAC Public Meeting March 2026 Paper 7: SASB standards project management plan
Executive summary
| Date | 24 March 2026 |
| Paper reference | 2026-TAC-008 |
| Project | Proposed amendments to SASB Standards – Phase 1 Part 2 |
| Topic | Project management plan and assessment approach |
Objective of the paper
This paper presents the project management plan to guide the TAC's review and response to the ISSB's Exposure Drafts for Phase 1, Part 2 of the proposed enhancements to the SASB Standards.
Decisions for the TAC
The TAC is asked to approve the project management plan and assessment approach.
Appendices
Appendix 1: Summary of the proposed approach for each SASB Standard
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.
Context
SASB Standards enhancement project
1The SASB Standards were initially published in 2018. Following the consolidation of SASB into the IFRS Foundation, the International Sustainability Standards Board (ISSB) has been responsible for maintaining and enhancing the SASB Standards.
2In March 2024, the ISSB decided to enhance the SASB Standards as part of its 2024-2026 work plan, following feedback on its consultation regarding agenda priorities. Key decisions made include:
- retaining the Sustainability Industry Classification System (SICS), and
- consulting on proposed enhancements to the SASB Standards, beginning with twelve priority SASB Standards. The first nine were issued for consultation in July 2025, with the remaining three scheduled for publication at the end of March 2026.
3At its meeting on 26 February 2026, the ISSB approved publication of the Exposure Draft for the remaining three priority SASB Standards which include:
- Agricultural Products
- Meat, Poultry & Dairy; and
- Electric Utilities & Power Generators.
4The ISSB noted stakeholder concerns on the July 2025 Exposure Draft for the first nine priority SASB Standards. These included the need for greater clarity on the role of the SASB Standards relative to the ISSB Standards, as well as the future direction of ISSB standard-setting given ongoing SASB enhancement work and research into nature and human capital. The ISSB confirmed that these broader issues will be addressed in phase 2 of the SASB enhancement project.
5Noting the stakeholder concerns, the ISSB decided to proceed with the Exposure Draft for the remaining three priority SASB Standards on the basis that:
- the prospective consultation is a continuation of the July 2025 Exposure Draft;
- most stakeholders, including investors, are supportive of the ISSB pursuing the project on enhancing the SASB Standards and of its objective, which is to provide timely implementation support for IFRS S1 and IFRS S2;
- the prospective consultation is significantly narrower in scope and complexity than the July 2025 Exposure Draft;
- the metrics proposed in these three priority SASB Standards and in the July 2025 Exposure Draft overlap significantly; and
- postponing the publication would disrupt the project's momentum and impede the ISSB's ability to receive timely feedback on the proposals.
6Consistent with the July 2025 Exposure Draft, the prospective consultation has the same objectives of supporting the implementation of IFRS S1 and IFRS S2 which are:
- enhancing international applicability;
- improving interoperability with other sustainability-related standards and frameworks;
- amendments related to nature and human capital; and
- alignment with IFRS Sustainability Disclosure Standards.
7The consultation also proposes consequential amendments to IFRS S2 industry-based guidance to maintain alignment.
Role of the TAC in the SASB Standards enhancement project
8The TAC has been asked by the Department for Business and Trade (DBT) to understand the ISSB's enhancements to the SASB Standards and the implications of this for the UK Sustainability Reporting Standards (UK SRS), in a TAC priorities letter issued in March 2026. The DBT letter does not commission a full assessment of all enhancements to the SASB Standards. Accordingly, and given that the SASB Standards are currently applied on a voluntary basis in the UK, the TAC is expected to adopt a proportionate approach.
9In UK SRS S1 and UK SRS S2, the wording was amended so that entities 'may refer to and consider' the disclosure topics and related metrics in SASB Standards rather than ‘shall refer to and consider' them as required by IFRS S1 and IFRS S2 when identifying sustainability related risks and opportunities.
10Although this amendment means that UK companies applying UK SRS are not required to consider the SASB Standards, data from the SASB website indicates more than 200 UK companies currently use SASB Standards voluntarily. As a result, the ISSB's project to enhance the SASB Standards remains directly relevant to the UK reporting landscape. It has implications for entities that already reference the SASB Standards and is important in the context of the ISSB's longer-term integration plans, which may involve incorporating SASB content into future IFRS Sustainability Disclosure Standards. In addition, both UK SRS S1 and UK SRS S2 require industry-based disclosures, and the SASB Standards could provide useful information in meeting this requirement.
11Additionally, the TAC has responsibility to undertake outreach with, and provide a focal point for, UK stakeholders to influence the technical development of IFRS Sustainability Disclosure Standards as outlined in the TAC's Terms of Reference.
Project overview
12This paper presents a project management plan to guide the TAC's review and response to the proposed Exposure Draft on the remaining three priority SASB Standards and the related consequential amendments to IFRS S2 industry-based guidance.
13It is expected that the Exposure Draft will be published at the end of March 2026. The project management plan spans 16 weeks, structured into three phases: project initiation, project delivery and project closure. It includes estimated resource requirements, stakeholder engagement strategies, and risk mitigation approaches.
14In the context of the TAC's remit, the objective of this project is to provide a proportionate review and response to the ISSB's Exposure Draft on enhancements to the SASB Standards. The project will involve an analysis of the proposed Exposure Draft and the Basis for Conclusions, stakeholder engagement, desk research and preparation of comment letters. It is expected that all these activities are to be completed in accordance with appropriate due process.
15The TAC's process for preparing the comment letters will include the following stages:
| Task description | Due Process Policy ref. | Indicative timeline |
|---|---|---|
| Project initiation | ||
| Project management plan and assessment approach to be discussed and agreed at March 2026 TAC meeting (this meeting). | Paragraphs 29-30 | 24 March TAC meeting |
| Project delivery | ||
| The Secretariat will re-visit the broader themes regarding the role of the SASB Standards. This might include setting up a roundtable with users of SASB Standards. | Paragraph 31 | 21 April TAC meeting |
| The Secretariat will engage in stakeholder outreach, including conducting interviews and a roundtable. | Paragraph 31 | April-May |
| An initial analysis of the ISSB's proposed amendments to the three SASB Standards will be discussed. | Paragraph 31 | 19 May TAC public meeting |
| Findings from the initial stakeholder engagement will be discussed. | Paragraph 31 | 19 May TAC public meeting |
| A draft comment letter will be discussed. | Paragraph 31 | 16 June TAC public meeting |
| Final comment letter presented at July TAC meeting. | Paragraphs 37–40 | 14 July TAC public meeting |
| Following any amendments agreed at the July TAC meeting, the Secretariat will submit the final comment letter to the ISSB and will publish the comment letter on the FRC website. | By July (the exact date is currently not known) | |
| Project closure | ||
| A draft Due Process Summary will be discussed. | Paragraphs 37–40 | 14 July TAC public meeting |
| The TAC to approve Due Process Summary at the September 2026 TAC meeting, which will be subsequently published on the FRC website. | Paragraphs 37–40 | 15 September TAC public meeting |
Assessment approach
16The technical assessment will only consider the content of the proposed amendments to the three SASB Standards including proposed consequential amendments to IFRS S2 industry-based guidance.
17As described in its Terms of Reference, the purpose of the TAC's work is to provide rigorous technical analysis of the standards issued by the ISSB and provide clear, well-reasoned and evidence-based recommendations accordingly on the grounds of supporting long-term public good in the UK.
18The following paragraphs set out a proposed assessment approach for the Exposure Draft, to be applied in the drafting and finalisation of the comment letter in order to achieve the TAC's purpose.
19Given the scope and specialised nature of the industries covered in the proposed Exposure Draft, the Secretariat has developed an approach tailored to each industry, reflecting the anticipated level of stakeholder engagement and the extent of desk-based research required. Details of the proposed approach are set out in the appendix.
20The Secretariat also proposes revisiting the broad themes on which the TAC commented in the July 2025 Exposure Draft to ensure they capture any relevant information arising from responses to the prospective Exposure Draft on the three industries.
21While the nature and depth of the analysis will depend on the initial review of the Exposure Draft and input from stakeholders, the technical work is expected to include:
- a proportionate review of the standards with proposed amendments and related Basis for Conclusions;
- to the extent necessary, review any available ISSB materials, including staff papers from previous meetings and historical SASB material;
- assessment of relevant third-party commentary and publications;
- review of a selected sample of listed companies' annual or sustainability reports that currently use the SASB Standards or operate in industries covered by the three SASB Standards;
- to the extent necessary, evaluation of interoperability with other frameworks such as the EU ESRS, GRI, TNFD, and others as appropriate.
22The assessment criteria in the TAC's Terms of Reference are required to be applied when responding to commissions for endorsement advice from DBT. However, the TAC considered these criteria not to be directly applicable in this case, as the work relates to a consultation response rather than an endorsement process. Instead, a relevant set of criteria, developed and applied for the earlier part 1 of the SASB enhancement consultation and focused on facilitating a principles-based analysis has been used. The TAC will assess whether the proposed amendments are conducive to the long term public good in the UK by:
- identifying the objective behind the proposed amendments;
- assessing whether the objective would support improvement in the quality of corporate reporting within the UK in the long-term;
- assessing whether the amendments successfully support the identified objective; and
- to the extent necessary, identifying any gaps in the amendments against the stated objectives, primarily through stakeholder engagement and desk research.
23Whilst the ISSB has issued international standards to serve as the global baseline, the TAC's technical assessment will consider the requirements in the context of the UK and views obtained from UK stakeholders. There are likely to be some issues that have been raised by UK stakeholders that are also relevant to the international application of the requirements, and the TAC will consider these issues as they pertain to the UK.
24The criteria will be assessed individually and in combination to ensure a full assessment has been completed. Additionally, if the TAC expresses views on the proposed amendments for use in the UK, they will be made in the context of the TAC's assessment criteria.
Stakeholder engagement
25In light of available resources, the voluntary status of the SASB Standards in the UK and limited adoption of the Meat, Poultry & Dairy, and Agricultural Products SASB Standards, the project will not undertake a UK public consultation on a draft comment letter. This also ensures that the assessment remains proportionate, consistent with the DBT commissioning letter.
26Instead, the Secretariat will carry out other forms of stakeholder engagement, including bilateral discussions with current and prospective users to capture some of the key questions that would otherwise have been included in a public consultation.
Assumptions, constraints and risks
27When developing the project management plan, the Secretariat has taken into consideration the following assumptions and constraints:
- The capacity of the TAC, including agenda capacity and recognition that the TAC members are volunteers. Since the TAC members are volunteers, there is a limited amount of work that they can be expected to complete in the time allocated.
- The capacity of the TAC Secretariat. The Secretariat will be expected to write papers for public TAC meetings in addition to conducting research and stakeholder engagement to inform the final comment letters. The expected available resources are 1.5 FTE project directors and oversight from the Head of the Secretariat.
- Some of the proposed changes may be highly technical, and the TAC or Secretariat may lack the expertise needed for a detailed response.
- Stakeholders' capacity to participate in outreach activities may be constrained by factors such as time pressures, the technical nature of certain proposals, consultation fatigue, or the lower level of emphasis placed on the SASB Standards within the UK SRS.
Target timeline
28The ISSB has proposed a 120-day comment period, and subject to the publication of the exposure draft the deadline is likely to be end of July 2026. Therefore, the TAC will need to approve the final comment letter at its 14 July meeting, for submission at the end of July 2026.
29The timeline presented below takes into consideration known events that have potential to impact the delivery of the final comment letters. However, the timeline does not take into consideration the assumptions, constraints and risks that are uncertain. This means that the target timeline may need to be amended during the project, within the scope of the deadline once set by the ISSB.
Project Timeline Overview
This diagram illustrates the project timeline from March 2026 to September 2026, showing key public meetings and project phases including Technical analysis, Stakeholder engagement, Preparing comment letters, and Response submission & project closure. Key dates include public meetings on 24 March, 21 April, 19 May, 16 June, 14 July, and 16 September, with comment letter submission in July.
Next steps
30Once the project management plan and assessment approach have been approved by the TAC, the Secretariat will continue its work to enable the TAC's submission of the comment letters on the ISSB's Exposure Draft.
Questions for the TAC
- Does the TAC have any comments on the proposed assessment approach?
- Does the TAC approve the project management plan?
Appendix 1: Summary of the proposed approach for each SASB Standard
The following table sets out the consultation questions in the draft Exposure Draft of Proposed Amendments to the SASB Standards and IFRS S2 Industry-based Guidance that was discussed by the ISSB in February 2026. Please note that at the time of the TAC March meeting, the final Exposure Draft may be published and there may be some differences in the questions referenced below. The table also sets out the proposed approach for the TAC's analysis and response to the Exposure Draft.
| Consultation Questions | Agricultural Products (FB-AG) | Electric Utilities & Power Generators (IF-EU) | Meat, Poultry & Dairy (FB-MP) |
|---|---|---|---|
| Q1(a-f); 2(a-e) & 3(a-e) | Proposed approach: Undertake high level thematic analysis covering substantive changes to or gaps in: - climate-related content - nature-related content - human capital-related content Analyse and assess areas where the Agricultural Products SASB Standard overlaps with the Processed Foods SASB Standard (addressed in the July 2025 Exposure Draft), and, where appropriate, draw on relevant and informative aspects of that previous work to support the analysis of the Agricultural Products Standard. Rationale: - There are currently no identified UK users of this Standard, |
Proposed approach: Full coverage of the standard which includes the following areas: - industry description - disclosure topics and related metrics, as appropriate - thematic considerations, including climate, nature and human capital-related content Rationale: - There is strong UK relevance given the sector's exposure to the energy transition. - The Standard has notable level of UK preparer adoption. - Four preparer stakeholders and one investor have so far agreed to participate in the consultation following early outreach conducted by the TAC Secretariat. |
Proposed approach: Undertake high level thematic analysis covering substantive changes to or gaps in: - climate-related content - nature-related content - human capital-related content Analyse and assess areas of overlap with the Processed Foods SASB Standard (addressed in the July 2025 Exposure Draft), drawing only on those elements of the prior work that are relevant and informative for the Meat, Poultry & Dairy SASB Standard. Rationale: - Limited UK preparer use, with only one listed company currently identified as applying the Standard. - Limited stakeholder engagement interest, with one preparer stakeholder having agreed to participate. |
| Q4 | This question relates to consequential amendments to IFRS S2 industry-based guidance. Our proposed approach is to treat any consequential amendments to the IFRS S2 Industry-based Guidance arising from these three standards in a manner consistent with the TAC's response to the July 2025 Exposure Draft. |
- The Standard has more linkage to IFRS S2 industry-based disclosure requirements. | - Some UK relevance through themes such as food security, methane emissions, land use, and supply-chain considerations. - Strong intersections with biodiversity and water-related issues. |
| Q5 | This question relates to the effective date. We propose our approach and response to be consistent with the position set out in the TAC's response to the July 2025 Exposure Draft. |
||
| Q6-9 | These questions relate to broader themes covered in the July 2025 Exposure Draft, including objectives, interoperability; and climate nature and human capital-related content. We propose to enhance our analysis of the broader themes through our work on the three standards. In our response, we would also reference the TAC's response to the July 2025 Exposure Draft. |
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.