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TAC Public Meeting March 2026 Paper 5: Report on due process compliance
AGENDA PAPER 5
Executive summary
| Date | 24 March 2026 |
|---|---|
| Paper reference | 2026-TAC-006 |
| Project | Annual reporting |
| Topic | Report on due process compliance |
Objective of the paper
This paper presents a draft report on due process compliance for the period ended 31 March 2026.
Decisions for the TAC
The TAC is asked whether it approves the draft report on due process compliance.
Appendices
Appendix 1: Draft report on due process compliance for the period ended 31 March 2026
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
1The TAC's Terms of Reference and Due Process Policy require the TAC to report on compliance with its Due Process Policy to the Department for Business and Trade (DBT) once in every calendar year.
2The Framework and Terms of Reference for the Development of UK Sustainability Reporting Standards (Framework), which includes the TAC's Terms of Reference, was published by DBT on 16 May 2024.
3The TAC approved its Due Process Policy in a public TAC meeting on 13 May 2025.
4The TAC Secretariat has drafted the TAC's report on due process compliance for the period from the TAC's formation, on 16 May 2024, to 31 March 2026. The TAC's due process compliance has been assessed against its Terms of Reference only in the period from 16 May 2024 to 13 May 2025 and its Terms of Reference and its Due Process Policy in the period from 14 May 2025 to 31 March 2026.
5The draft report on due process compliance is presented in Appendix 1. This draft report is for the period ended 31 March 2026 and is updated as at 17 March 2026. The TAC Secretariat is not expecting there to be any significant changes to the TAC's due process compliance between 18 March 2026 and 31 March 2026.
Next steps
6If the TAC approves the draft report on due process compliance for the period ended 31 March 2026, the TAC Secretariat will work with the TAC Chair to finalise the document. The draft report on due process compliance will be updated for any developments between 18 March 2026 and 31 March 2026 (including the public meeting held on 24 March 2026) and will undergo final proofreading and formatting. Once completed, the TAC's report on due process compliance will be submitted to DBT and published on the FRC website.
7The Framework, which includes the TAC's Terms of Reference, states that it will be reviewed by the Secretary of State for Business and Trade (Secretary of State) following endorsement decisions for IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures. Alongside drafting the TAC's report on due process compliance, the TAC Secretariat is currently reviewing the TAC's Terms of Reference and Due Process Policy and liaising with DBT about any amendments. Any significant proposed amendments will be discussed at a future TAC meeting.
Questions for the TAC
- Does the TAC have any comments on the draft report on due process compliance in the appendix?
- Does the TAC approve the draft report on due process compliance?
Appendix 1: Draft report on due process compliance for the period ended 31 March 2026
Context
8The UK Sustainability Disclosure Technical Advisory Committee (TAC) supports the Secretary of State for Business and Trade (Secretary of State) with making endorsement decisions about IFRS Sustainability Disclosure Standards issued by the International Sustainability Standards Board (ISSB). The TAC conducts rigorous technical analyses of IFRS Sustainability Disclosure Standards and provides well-reasoned, clear and evidence-based advice to the Secretary of State accordingly. In particular, the TAC's analysis is used to provide a recommendation to the Secretary of State on whether the endorsement of a IFRS Sustainability Disclosure Standard would be conducive to the long-term public good in the UK.
9The TAC also has responsibility to undertake outreach with, and provide a focal point for, UK stakeholders to influence the technical development of IFRS Sustainability Disclosure Standards.
10The Framework and Terms of Reference for the Development of UK Sustainability Reporting Standards (Framework), which includes the TAC's Terms of Reference, was published by the Department for Business and Trade (DBT) on 16 May 2024.
11The TAC's Terms of Reference require the TAC to determine its Due Process Policy within 12 months following the approval of the Terms of Reference. Once the TAC's Due Process Policy has been approved, the TAC's Terms of Reference require the TAC to report on compliance with its Due Process Policy to DBT once in every calendar year.
Report on due process compliance
12The TAC's first report on due process compliance covers the period from the TAC's formation, on 16 May 2024, to 31 March 2026.
13The TAC's due process has four underlying principles: transparency; providing a focal point for UK stakeholders; accountability; and assessing the long-term public good in the UK.
Due Process Policy
14The TAC approved its Due Process Policy in a public TAC meeting on 13 May 2025. The TAC's due process compliance has therefore been assessed against its Terms of Reference only in the period from 16 May 2024 to 13 May 2025 and its Terms of Reference and its Due Process Policy in the period from 14 May 2025 to 31 March 2026.
15The Framework, which includes the TAC's Terms of Reference, states that it will be reviewed by the Secretary of State following endorsement decisions for IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures. The TAC is currently reviewing its Terms of Reference and Due Process Policy for future years and liaising with DBT about any amendments.
Governance requirements
Membership
16As at 31 March 2026, the TAC has 14 Members, including its Chair. Members are experts in categories which ensure that the TAC's membership represents those with an interest in, and familiarity with, sustainability reporting. Two places on the TAC are reserved for Members appointed by the FRC and UK Endorsement Board (UKEB), to reflect the connectivity between UK-adopted international accounting standards, UK Generally Accepted Accounting Principles (GAAP) and UK Sustainability Reporting Standards. There are observers with speaking rights from the Bank of England (BoE), DBT and the Financial Conduct Authority (FCA).
17Members can be appointed for terms of between one and three years, and membership can be renewed for one further consecutive term. All members are currently on their first term.
| Name | Role | Category | Term length & end date |
|---|---|---|---|
| Sally Duckworth | Chair | 3 years April 2027 | |
| Craig Mackenzie | Member | Academic & investor | 2 years April 2026 |
| David Harris | Member | Investor | 3 years April 2027 |
| Dia Desai | Member | Preparer | 2 years (with 1 year maternity leave) April 2027 |
| Harriet Cullum | Member | Preparer | 2 years April 2026 |
| Hilary Eastman | Member | Accountant and/or audit provider | 3 years April 2027 |
| Jeremy Osborn | Member | Accountant and/or audit provider | 2 years April 2026 |
| Madeleine Evans | Member | Investor | 3 years April 2027 |
| Nick Rowbottom | Member | Academic | 3 years April 2027 |
| Peter Hogarth | Member | Accountant and/or audit provider | 2 years April 2026 |
| Scott Barlow | Member | Preparer | 3 years April 2027 |
| Supriya Sobti | Member | Preparer | 2 years April 2026 |
| Jenny Carter | FRC appointed member | ||
| Paul Lee | UKEB appointed member |
18The TAC Chair is appointed by the Secretary of State. Members, except for the FRC and UKEB Members, are appointed by the TAC Chair, following an open and transparent recruitment process and after consultation with DBT.
19A register of interests for the TAC Chair is published on the FRC website and TAC Members declare any interests in agenda items in TAC meetings.
20The only change of membership during the period ended 31 March 2026 was the resignation of one Member, Joseph Noss, on 19 March 2025.
21The TAC is currently renewing its membership for future years. The TAC Chair and the FRC as TAC Secretariat have been working closely with DBT to consider additional expertise that needs to be added to the TAC's membership in the light of its expected work plan for 2026-2027 and beyond.
Organisation and conduct of meetings
22There are various meeting requirements in the TAC's Terms of Reference and Due Process Policy, including that meetings are quorate and generally held on a monthly basis in public. Meetings should also be scheduled at least 10 working days in advance, available for live viewing online and recordings available within five working days. Confidential and administrative matters can be discussed in private. Papers should be circulated to members at least 5 working days in advance and summary notes must be published within 10 working days. The threshold for TAC decisions is a simple majority of TAC Members present in the TAC meeting.
23There were 18 public meetings in the period from the TAC's formation to 31 March 2026. These meetings complied with due process with two minor exceptions; the summary notes for the 5 November 2024 and 14 October 2025 meetings were published one working day late.
Business-as-usual activities
24The TAC, and the FRC as TAC Secretariat, also continued their business-as-usual monitoring and influencing activities.
25Developments relating to sustainability-related reporting were monitored, including by preparing, publishing and discussing General Reporting Updates on a monthly basis.
26The technical development of IFRS Sustainability Disclosure Standards was influenced by engaging with the ISSB and participating in key fora. The TAC met in private with the ISSB on 2 December 2024, 10 June 2025 and 16 September 2025. A summary of matters covered was presented in public for all meetings except for the one on 16 September 2025. However, a summary of matters covered has subsequently been included on the FRC website.
Due process steps and documents
27Summaries of key due process steps and documents for the TAC's projects for the period ended 31 March 2026 are as follows:
Development of endorsement recommendations and advice
| Project | Commission letter, contextual information and target date | Project management plan | Technical work plan | Call for evidence | Votes and final report | Stakeholder feedback summary | Due process summary |
|---|---|---|---|---|---|---|---|
| Endorsement recommendations and advice on IFRS S1 and IFRS S2 | ✅ | ✅ | ✅ | Closed on 11/10/2023 1 | Submitted on 18/12/2024. Related letter sent to ISSB Chair on 27/01/2025. Supplementary advice submitted on 26/01/2026 | ✅ 2 | ✅ |
Development of comment letters
| Project | Project management plan | Draft comment letter with invitation to comment | Final comment letter | Stakeholder feedback summary | Due process summary |
|---|---|---|---|---|---|
| Proposed amendments to IFRS S2: Exposure Draft ISSB/ED/2025/1 – Amendments to greenhouse gas emissions disclosures | ✅ | N/A | Submitted on 25/06/2025 | ✅ 3 | ✅ |
| Enhancing the SASB Standards: Exposure Drafts SASB/ED/2025/1 and ISSB/ED/2025/2 – Proposed amendments to the SASB Standards and consequential amendments to the IFRS S2 Industry-based Guidance | ✅ | N/A | Submitted on 27/11/2025 | ✅ 3 | ✅ |
| Greenhouse Gas Protocol Scope 2 Guidance | ✅ | N/A | Submitted on 28/01/2026. Related letter sent to ISSB Chair on 28/01/2026 | ✅ 3 | TBC |
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There was a call for evidence conducted by the FRC acting as TAC Secretariat, however, as the TAC had not been formed, the call for evidence was not tabled for approval in a public TAC meeting. ↩
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There was a summary of stakeholder feedback provided as part of the TAC meeting papers, however, as the TAC's Due Process Policy had not been determined, the summary was not tabled for approval in a public TAC meeting. ↩
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There was a summary of stakeholder feedback, however, as the TAC did not publish a draft comment letter with an invitation to comment, the summary did not include consequent changes made to the comment letter and was not tabled for approval in a public TAC meeting. ↩↩↩