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TAC Public Meeting March 2026 Paper 4: Updated due process summary technical assessment of S1S2
Executive summary
| Date | 24 March 2026 |
| Paper reference | 2026-TAC-005 |
| Project | Technical assessment of IFRS S1 and IFRS S2 |
| Topic | Due process summary |
| Objective of the paper | This paper presents a summary of the due process followed in the development of the TAC's endorsement recommendations in relation to IFRS S1 and IFRS S2, which has been updated to include the provision of supplementary advice on 26 January 2026. |
| Decisions for the TAC | The TAC is asked to approve the updated due process summary. |
| Appendices | Appendix: Due process summary |
Context
1The TAC's Terms of Reference (ToR) and Due Process Policy (approved at a public meeting on 13 May 2025)1 require the TAC to follow due process in relation to the development of its endorsement recommendations.
2The TAC approved a summary of the due process followed in the development of its endorsement recommendations in relation to IFRS S1 and IFRS S2 at a public meeting on 14 January 2025.
3Following the UK Government's consultation on the draft UK SRS S1 and UK SRS S2 and the ISSB's publication of Amendments to Greenhouse Gas Emissions Disclosures (IFRS S2) in December 2025, DBT commissioned the TAC to provide supplementary advice in relation to IFRS S1 and IFRS S2. Specifically, the TAC was commissioned to provide further assessment of the requirements relating to revising comparatives and financed emissions, and a technical assessment of the IFRS S2 amendments. The commissions were conveyed in DBT's June 2025 priorities letter (items 1 and 3), as well as in correspondence with DBT. The TAC's supplementary advice was approved at a public meeting on 19 January 2026, submitted to DBT on 26 January 2026 and published on the FRC website.
4The TAC Secretariat has updated the summary of the due process followed in the development of its endorsement recommendations in relation to IFRS S1 and IFRS S2 to include the due process followed in the provision of its supplementary advice on 26 January 2026.
5The TAC Secretariat is tabling, for approval in this meeting, the updated due process summary, a copy of which is included in the appendix. Key changes to the due process summary have been highlighted in grey for ease of reviewing.
Questions for the TAC
Does the TAC approve the updated due process summary?
Appendix – Due process summary
The wording highlighted in grey represents new content.
| Due process steps | TAC’s ToR paragraph references | Comments |
|---|---|---|
| Initiate project | ||
| A ministerial letter from DBT is sent to the TAC to commission it to initiate work on the IFRS Sustainability Disclosure Standard. The letter is published on gov.uk and/or the FRC website. | 8, 41 | A commission letter from the Minister of State for Enterprise, Markets and Small Business stating that the TAC can commence its analysis of IFRS S1 and IFRS S2 dated 17/05/2024 was sent to the TAC Chair. It was published on the FRC website on 21/05/2024. |
| The TAC aims to provide an endorsement recommendation by any target date provided by DBT on a best-efforts basis. The target date is published on gov.uk and/or the FRC website. | The target date included in the letter is the end of 2024. | |
| A project plan, including target timeline, is prepared and approved by the TAC. The project plan summarises key steps and includes an analysis of assumptions, constraints and risks and the target date. | A project webpage is available on the FRC website. The project plan was approved at a public meeting on 31/05/2024 and is available on the FRC website. |
|
| Technical analysis | ||
| The TAC conducts a rigorous technical analysis of the IFRS Sustainability Disclosure Standard. | 2, 3, 4, 5 | The technical work plan was approved at a public meeting on 31/05/2024 and is available on the FRC website. |
| A technical work plan is prepared and approved by the TAC. The technical work plan includes the application of assessment approach to the project (identification of technical areas by conducting research and stakeholder outreach activities and initial assessment of those areas) and any contextual information. | Technical papers were discussed in public meetings on 31/05/2024, 18/06/2024, 15/07/2024, 03/09/2024, 08/10/2024, 05/11/2024, 15/11/2024, 05/12/2024, 09/12/2025 and 19/01/2026 and the TAC's decisions are recorded in summaries of those meetings available on the FRC website. | |
| Technical papers prepared and discussed by the TAC. Technical papers include detailed assessment of priority technical areas listed in technical work plan. | ||
| Contextual information | ||
| The TAC has regard to any contextual information provided by DBT. The contextual information is published on gov.uk and/or the FRC website. | 11, 41 | The context letter from DBT dated 20/05/2024 was sent to the TAC Chair. It was published on the FRC website on 21/05/2024. |
| Contextual information was considered during the technical analysis and summarised in the final recommendations. | ||
| Further commissions | ||
| The TAC may be commissioned by DBT to provide further advice on the IFRS Sustainability Disclosure Standards or to support implementation decisions being taken by DBT or the FCA against UK Sustainability Reporting Standards. Any further commissions are published on gov.uk and/or the FRC website. | 7, 12, 13, 41 | Following the UK Government consultation on the draft UK SRS S1 and UK SRS S2 and the ISSB's publication of the IFRS S2 amendments in December 2025, DBT commissioned the TAC to provide supplementary advice. The commissions were conveyed in DBT's June 2025 priorities letter (items 1 and 3), as well as in correspondence with DBT. |
| Stakeholder outreach and research activities | ||
| The TAC considers whether it is necessary to publish a call for evidence. | 9 | A call for evidence was issued for three months and comment letters were published on the FRC website. |
| The TAC conducts stakeholder outreach, including with companies and investors, as well as the ISSB, national standard setters and securities regulators. | Stakeholder feedback was included in technical papers and is summarised in TAC paper 2024-TAC-027. | |
| The TAC performs research activities. | Stakeholder feedback on the proposed amendments to IFRS S2 and on relevant aspects of the UK Government consultation on the draft UK SRS S1 and UK SRS S2 was summarised in technical papers and contributed to the development of the supplementary advice. Research activities are summarised in TAC papers 2024-TAC-004a and 2024-TAC-004b and in monthly monitoring updates. |
|
| Project closure | ||
| The TAC votes on whether to include an amendment to the IFRS Sustainability Disclosure Standard and on its endorsement | 25, 26, 27, 28, 29, 42 | Votes took place in the public meeting on 05/12/2024. The report on the technical assessment and endorsement recommendations in a TAC meeting. |
| The TAC provides its endorsement recommendations to DBT in a report. | The report on the technical assessment and endorsement recommendations was submitted to DBT on 18/12/2024 and published on the FRC website. | |
| The TAC's report containing its endorsement recommendations, as well as any further advice provided by the TAC, is published on gov.uk and/or the FRC website. | The supplementary advice was approved in the public meeting on 19/01/2026, submitted to DBT on 26/01/2026 and published on the FRC website. | |
| TAC meetings | ||
| There are a number of requirements in the TAC's ToR relating to meetings, including that: | 24, 30, 32, 33, 36, 38, 39, 40 | The project was discussed in public meetings on 31/05/2024, 18/06/2024, 15/07/2024, 03/09/2024, 08/10/2024, 05/11/2024, 15/11/2024, 05/12/2024, 09/12/2025 and 19/01/2026. |
| * Meetings are quorate. | Meetings agendas, technical papers, summaries and recordings, are available on the FRC website. | |
| * Recordings are available on the FRC website within 5 working days. | The meetings complied with due process, with one minor exception: the summary notes for the 05/11/2024 meeting were published within 11 working days. The recording for this meeting, however, was available within 5 working days in accordance with the ToR. The summary notes were published within 11 working days, due to priority being given to preparing for the additional 15/11/2024 meeting. Prioritising preparing for this extra meeting gave the TAC the best chance of meeting the target date to provide the initial endorsement recommendations by the end of 2024. | |
| * Agendas and technical papers are agreed by the TAC Chair, circulated to members at least 5 working days in advance and published on the FRC website. | ||
| * Summaries are approved by the TAC Chair and published on the FRC website within 10 working days. |
Conclusion
Overall, and notwithstanding the minor exception relating to the publication of the summary notes for the 05/11/2024 meeting, the technical assessment of IFRS S1 and IFRS S2, including the provision of supplementary advice, complied with due process.
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.
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UK Sustainability Disclosure TAC Terms of Reference ↩