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TAC Public Meeting April 2026 Paper 3: SASB Standards enhancements general themes
AGENDA PAPER 3
Executive summary
| Date | 21 April 2026 |
| Paper reference | 2026-TAC-009 |
| Project | Proposed amendments to SASB Standards – phase 1 part 2 |
| Topic | SASB Standards enhancement - general themes |
Objective of the paper
This paper summarises the key themes on the SASB Standards enhancement developed in the TAC's response to the July 2025 Exposure Draft. It outlines subsequent developments and proposed updates to these themes for the TAC's consideration. The TAC's feedback on the proposed updates will guide the next phase of the enhancement project and inform discussions at the SASB Standards enhancement roundtable being organised by the Secretariat.
Decisions for the TAC
The TAC is asked to review the considerations set out by the Secretariat and provide any comments.
Appendices
- Appendix 1: SASB Standards disclosure topics for industries by sector
- Appendix 2: SASB Standards enhancement phasing
Context
1In response to the July 2025 SASB Standards enhancement Exposure Draft (phase 1 part 1), the TAC identified a set of general themes considered important to the long-term direction of the ISSB Standards, including the enhancement of the SASB Standards.
2As the ISSB progresses to phase 1 part 2 of the enhancement project, consulting on the three remaining priority SASB Standards (Agricultural Products; Electric Utilities & Power Generators; and Meat, Poultry & Dairy), the TAC Secretariat has revisited these themes to assess whether recent ISSB discussions and market practices warrant updates to the TAC's position communicated in its previous response letter.
3These themes are presented in a table outlining a summary of the TAC's position as set out in its response letter to the July 2025 Exposure Draft, a summary of further developments to each theme since that response and proposed updates for the TAC's consideration and discussion.
4Across the general themes summarised in the table on the next page, the Secretariat recommends that:
- the TAC emphasises to the ISSB:
- the need for clarity on the future architecture of the ISSB Standards, including how enhanced SASB Standards will interact with IFRS S1/S2 and future topic-specific standards such as nature and human capital.
- the importance of a holistic, sector-wide approach to enhancing the remaining SASB Standards to improve alignment and consistency across sectors.
- the importance for climate-first focus, international applicability and harmonisation with other frameworks.
- improvements to the effectiveness of the consultation process where legacy SASB materials add complexity.
- other issues raised in the July 2025 response such as mechanisms for keeping pace with change and the Industry Classification System (SICS) could be de-prioritised from the response to the current Exposure Draft.
5As part of the SASB Standards enhancement stakeholder engagement, the Secretariat plans to gather further stakeholder views on these themes through a roundtable discussion.
Questions for the TAC
- Does the TAC have any comments on the summary of themes and proposed updates since the July 2025 response?
- Does the TAC agree with the proposed updates to each theme, or have additional points to raise for the planned roundtable?
- Does the TAC have any additional themes or points it wishes to raise as part of its response to the current Exposure Draft?
- Does the TAC require any prioritisation of these themes when engaging with stakeholders?
SASB Standards general themes summary
| No. | Summary of responses to the July 2025 Exposure Draft | Developments since response to the July 2025 Exposure Draft | Recommended updates for the TAC's consideration |
|---|---|---|---|
| 1 | Future architecture of IFRS Sustainability Disclosure Standards (ISSB Standards) | Emphasise the need for the ISSB to: | |
| * Need clarity on how SASB Standards fit within the future ISSB Standards architecture. | * At present, no further discussions have been held publicly by the ISSB about the status of the SASB Standards and how they are planned to fit into the future architecture. However, the ISSB meetings have alluded to architecture and the role of SASB during discussions about nature. | * make decisions about the architecture of their standards, especially as they explore other topical standards (like nature and possibly human capital). | |
| * Need clarity on whether SASB Standards are a foundation or substitute for future topic specific IFRS Standards. | * At the March 2026 Sustainability Standards Advisory Forum (SSAF) meeting a majority of members expressed preference for a standalone IFRS Sustainability Disclosure Standard on nature to ensure equal prominence to climate, reduce complexity and minimise disruption to IFRS S1/S2 implementation. | * provide clarity on how the final architecture will treat nature-related topics and metrics in Industry-based Guidance and how IFRS S1/S2 would interact with the enhanced SASB Standards. | |
| * Ensure architecture preserves the global baseline set by IFRS S1/S2. | * A minority of SSAF members caution that the architecture decision may be premature given the current immaturity of nature reporting. | ||
| 2 | Strategy for enhancing SASB Standards | Recommend that the ISSB considers: | |
| * TAC broadly supports enhancements objectives but concerned about current approach. | * The ISSB's February 2026 meeting discussed that: | * adopting a holistic, sector-wide approach (e.g. addressing the full Food & Beverage sector) to enhancing the remaining SASB Standards, rather than piecemeal updates across different sectors. | |
| * Enhancements must prioritise simplification and alignment with IFRS S1/S2. | * the current prioritisation and phasing approach of the SASB Standards enhancements is intended to allow broad coverage across priority industries within sectors. | * ensuring that cross-sector topics (e.g. water, human capital, supply chain) are handled consistently under a sector-wide enhancement approach. | |
| * The SASB Standards were developed before IFRS S1/S2 and require redesign to align with the ISSB Standards (link to risks and opportunities and financial effects). | * the ISSB is open to revisiting the prioritisation approach, including options such as enhancing all SASB Standards within the same sector. | * Renaming the SASB Standards to avoid stakeholder confusion. | |
| * Consequential amendments to IFRS S2 Industry-based Guidance require clearer methodology, complete coverage of climate-related metrics, and improved transparency to maintain consistency with SASB enhancements. | * Appendix 1 to this paper shows that sectors with high topic overlap (e.g. Food & Beverage) are potentially exposed to inconsistencies when industries are revised individually, whereas diverse sectors (e.g. Infrastructure) may have less risk. | ||
| * Appendix 2 to this paper illustrates that staggered phasing across related industries may lock in inconsistent topic definitions or metrics. | |||
| 3 | Keeping pace with changes | ||
| * SASB Standards need a manageable, sustainable mechanism for updates. | * The industries covered in the current Exposure Draft show that a prescriptive approach in industries with operational diversity and evolving technologies such as agricultural innovation and grid management in the energy transition (e.g. Agricultural Products; Meat, Poultry & Dairy; Electric Utilities & Power Generators) risks undermining the long-term decision-usefulness of the of SASB Standards if updates do not keep pace with changes. | * Subject to any significant findings from the work on the current three Standards under consultation, consider dropping this from the second response. | |
| * Encourage the ISSB to adopt a principle-based approach to enhancing SASB Standards to avoid over specification that would require frequent updates. | |||
| 4 | Climate-first thematic approach | ||
| * Prioritise climate content by moving 'core' and industry-agnostic climate disclosures into IFRS S2 first across all 77 industries. | * In context of current Exposure Draft market practices indicates that: | * Emphasise the need for a climate-first approach, reflecting the high climate sensitivity of the industries in the current Exposure Draft (e.g. methane emissions in Meat, Poultry & Dairy; GHG emissions from Electric Utilities & Power Generators). | |
| * Enhancement of other topics would go alongside the development of further topic specific ISSB Standards. | * Electric Utilities & Power Generators is one of the most GHG emissions intensive industries. | ||
| * Agricultural Products and Meat, Poultry & Dairy have climate impacts through methane and other GHG emissions and land-use impacts (e.g. deforestation, overgrazing). | |||
| * One ISSB member voted against the ratification of the current Exposure Draft due to concerns that the Meat, Poultry & Dairy SASB Standard has limitations with respect to GHG emissions (including methane), freshwater use, land use and comparability. | |||
| 5 | Due Process concerns | ||
| * Concerns about lack of clear due process to SASB Standards development and amendments. | * IFRS Foundation Due Process Oversight Committee (DPOC) clarified that if the status of the SASB Standards changes, the regular ISSB due process will apply. | * Consider dropping this from the second response in light of the ISSB's ongoing work and clarification from IFRS Foundation DPOC. | |
| * Recommend due process proportionate to SASB Standards' unique role in IFRS S1/S2. | * IFRS Foundation DPOC highlighted that there are similarities with the due process for ISSB Standards, including that the full ISSB retains responsibility for exposure drafts and final amendments. | ||
| * Need for public deliberations on technical content to ensure stakeholders are familiar with the approach from the outset. | * ISSB recognises transition issues from SASB legacy material and noted the importance of communication with stakeholders. | ||
| * The use of 'shall' refer to consider the applicability of the SASB Standards and IFRS S2 Industry-based Guidance highlights the importance of the SASB Standards to IFRS S1/S2. | |||
| 6 | Consultation process effectiveness | ||
| * Consultation materials are complex, difficult to navigate and lack supporting materials. | * The Basis for Conclusions for the current Exposure Draft for the three SASB Standards have some improvements with links and footnotes to research materials used. | * While the ISSB has taken steps to improve the consultation's effectiveness, challenges remain due to the legacy development of the SASB Standards prior to their consolidation into the IFRS Foundation. | |
| * Suggested that ISSB provide tables, logs of changes and clearer summaries explaining origin of metrics. | * The Basis for Conclusions for the current three industries have been made more comprehensive (82 pages) when compared to previous nine industries (55 pages). | * Subject to full review of the proposed changes in the Exposure Draft, the TAC can consider emphasising the points raised in the previous response letter. | |
| * Encourage consulting an entire sector at once rather than piecemeal SASB Standards within a sector. | * Through discussions at its February meeting the ISSB noted that, given the specialised nature of industry standards, the quality of stakeholder feedback matters more than the volume. | ||
| * The ISSB also noted that stakeholder consultation fatigue is largely outside its control. | |||
| 7 | Alignment with ISSB Standards | ||
| * Alignment with IFRS S1/S2 should be the primary driver of changes. | * At its February 2026 meeting the ISSB: | * Emphasise the need for the ISSB to clarify the architectural relationship and ensure consistent alignment between the SASB Standards and IFRS S1/S2, resolving duplications. | |
| * ISSB considers clarifying the architectural relationship between SASB Standards terms and ISSB Standards, or reframing the current SASB Standards, structured around topics, metrics and technical protocols to align with IFRS S1/S2's risks and opportunities structure. | * acknowledged the tension between using the SASB Standards as IFRS guidance versus as standalone standards. | ||
| * ISSB considers proving an analytical bridge connecting SASB Standards metrics (largely backward-looking) to financial statements and IFRS S1/S2 anticipated financial effects. | * noted the need for clearer alignment between SASB and IFRS S1/S2, addressing duplications and inconsistencies (e.g. inclusion of Scope 1 but exclusion of Scope 3 GHG emissions in some industries). | ||
| * ISSB considers eliminating duplication between SASB Standards and IFRS S1/S2. | * signalled its intention to reconsider IFRS S1/S2 references within the SASB Standards to balance standalone use with their role as supporting guidance to IFRS S1/S2. | ||
| * noted the importance of SASB Standards enhancement for future nature-related standard setting. | |||
| 8 | International applicability | ||
| * Certain SASB Standards metrics assume single jurisdictional context for operating entities. | * Specific to the industries covered in the current Exposure Draft: | * Emphasise the importance of international applicability, using the three standards as a case study, and highlight the need for the ISSB to consider practices in regions beyond the US and Europe (e.g. Brazil, New Zealand, Africa, Asia-Pacific where UK companies and UK investors have agricultural interests). | |
| * Clearer evidence of ISSB's global outreach beyond North America and Europe would be helpful. | * Agricultural Products and Meat, Poultry & Dairy have diverse regulatory market contexts across jurisdictions. | ||
| * International applicability important for the UK due to the global nature of its companies and investors. | * Electric Utilities & Power Generators industry has jurisdictional differences between liberalised and government-controlled markets. | ||
| 9 | Interoperability and harmonisation | ||
| * Support alignment with GRI, ESRS, TNFD. | * At its March meeting, the ISSB highlighted that 'interoperability' remains undefined, resulting in potential ambiguity around its objective. | * Consistent with Theme 1 emphasise harmonisation with ISSB Standards. | |
| * Prefer that ISSB focuses on harmonisation (gradually minimising differences) over interoperability (different standards and frameworks working together). | |||
| * ISSB to consider focusing on mandated frameworks first (e.g. ESRS) over voluntary ones. | |||
| * Acknowledge the challenge of continuing evolution of other sustainability-related standards and their differences to materiality approach. | |||
| * Mapping to other sustainability-related Standards and frameworks showing similarities and differences would be helpful. | |||
| 10 | Concerns about nature and human capital amendments | ||
| * ISSB's nature and human capital research projects not complete. | * Connected to the March 2026 SSAF meeting's discussion on standards architecture, as outlined in Theme 1 above. | * See Theme 1 above. | |
| * The TAC considers it premature to amend SASB Standards based on nature and human capital research projects before clarity on future architecture of ISSB Standards. | |||
| * Some metrics arising from the nature/human capital research projects may belong in IFRS S1/S2 if a differentiated approach between 'core', 'industry-agnostic and industry-specific' approach is adopted. | |||
| 11 | Industry Classification System (SICS) | ||
| * Mixed views on SICS relevance outside North America. | * No new developments identified in this area. | * Consider dropping this in the second response. | |
| * The TAC recognises that conglomerates face challenges in simultaneously applying multiple SASB Standards, and that differentiating between 'core', 'industry-agnostic' and 'industry-specific' disclosures could help minimise these challenges. | |||
| * The TAC recommends mapping SICS to other global classification systems to improve comparability. |
Appendix 1: SASB Standards disclosure topics for industries by sector
| DISCLOSURE TOPIC | A. FOOD AND BEVERAGE SECTOR SASB STANDARDS | |||||||
|---|---|---|---|---|---|---|---|---|
| Agricultural Products¹ | Alcoholic Beverages | Food Retailers & Distributors | Meat, Poultry & Dairy¹ | Non-Alcoholic Beverages | Processed Food¹ | Restaurants | Tobacco | |
| Greenhouse Gas Emissions | ||||||||
| Air Emissions from Refrigeration | ||||||||
| Fleet Fuel Management | ||||||||
| Energy Management | ||||||||
| Water Management | ||||||||
| Food Loss & Food Waste | Currently Food Waste Management |
|||||||
| Land Use & Ecological Impacts | ||||||||
| Food Safety | ||||||||
| Health & Nutrition | Currently Product Health & Nutrition |
Currently Nutritional Content |
||||||
| Product Labelling & Marketing | ||||||||
| Marketing Practices | ||||||||
| Packaging Management | Currently Packaging Lifecycle Management |
Currently Packaging Lifecycle Management |
||||||
| Food & Packaging Waste Management | ||||||||
| Labour Conditions | Currently Labour Practices |
Currently Labour Practices |
||||||
| Workforce Health & Safety | ||||||||
| Environmental Supply Chain Management | Currently combined as Environmental & Social Impacts of Ingredient Supply Chain |
Currently combined as Management of Environmental & Social Impacts of Ingredient Supply Chain |
Currently combined as Environmental & Social Impacts of Ingredient Supply Chain |
|||||
| Social Supply Chain Management | ||||||||
| Ingredient Sourcing | ||||||||
| Supply Chain Management & Food Sourcing | ||||||||
| Antibiotic Use in Animal Production | ||||||||
| Animal Health & Welfare | ||||||||
| Product Innovation | ||||||||
| Responsible Drinking & Marketing | ||||||||
| Data Security | ||||||||
| Public Health |
¹ Disclosure topics shown for these SASB Standards reflect ISSB's proposed enhancements. All others reflect pre-enhancement disclosure topics.
B. INFRASTRUCTURE SECTOR SASB STANDARDS
| DISCLOSURE TOPIC | Electric Utilities & Power Generators¹ | Engineering & Construction Services | Gas Utilities & Distributors | Home Builders | Real Estate | Real Estate Services | Waste Management | Water Utilities & Services |
|---|---|---|---|---|---|---|---|---|
| Greenhouse Gas Emissions | ||||||||
| Greenhouse Gas Emissions & Energy Resource Planning | ||||||||
| Fleet Fuel Management | ||||||||
| Air Quality | ||||||||
| Energy Management | ||||||||
| Water Management | ||||||||
| Hazardous Waste Management | Currently Management of Leachate & Hazardous Waste |
|||||||
| Labour Practices | ||||||||
| Ecological Impacts | ||||||||
| Land Use & Ecological Impacts | ||||||||
| Community Relations & Rights of Indigenous Peoples | ||||||||
| Energy Affordability | ||||||||
| End-Use Efficiency | ||||||||
| Workforce Health & Safety | ||||||||
| Employee Recruitment, Development & Retention | ||||||||
| Demand-side Management | ||||||||
| Supply Chain Management | ||||||||
| Critical Incident Risk Management | ||||||||
| Operational Resilience & System Reliability | ||||||||
| Integrity of Gas Delivery Infrastructure | ||||||||
| Environmental Impacts of Project Development | ||||||||
| Structural Integrity & Safety | ||||||||
| Lifecycle Impacts of Buildings & Infrastructure | ||||||||
| Climate Impacts of Business Mix | ||||||||
| Business Ethics | ||||||||
| Design for Resource Efficiency | ||||||||
| Community Impacts of New Developments | ||||||||
| Climate Change Adaptation | ||||||||
| Management of Tenant Sustainability Impacts | ||||||||
| Sustainability Services | ||||||||
| Transparent Information & Management of Conflict of Interest | ||||||||
| Recycling & Resource Recovery | ||||||||
| Distribution Network Efficiency | ||||||||
| Effluent Quality Management | ||||||||
| Water Affordability & Access | ||||||||
| Drinking Water Quality | ||||||||
| Water Supply Resilience | ||||||||
| Network Resiliency & Impacts of Climate Change |
Appendix 2: SASB Standards enhancement phasing
| Sector/Industry | Last updated | Enhancement project phase |
|---|---|---|
| Consumer Goods | ||
| Apparel, Accessories & Footwear | Dec 2023 | |
| Appliance Manufacturing | Dec 2023 | |
| Building Products & Furnishings | Dec 2023 | |
| E-Commerce | Dec 2023 | TBD |
| Household & Personal Products | Dec 2023 | |
| Multiline and Specialty Retailers & Distributors | Dec 2023 | |
| Toys & Sporting Goods | Dec 2023 | |
| Food & Beverage | ||
| Agricultural Products | Dec 2023 | Phase 1 part 2 |
| Alcoholic Beverages | Dec 2023 | TBD |
| Food Retailers & Distributors | Dec 2023 | TBD |
| Meat, Poultry & Dairy | Dec 2023 | Phase 1 part 2 |
| Non-Alcoholic Beverages | Dec 2023 | TBD |
| Processed Foods | Dec 2023 | Phase 1 part 1 |
| Restaurants | Dec 2023 | TBD |
| Tobacco | Dec 2023 | TBD |
| Resource Transportation | ||
| Aerospace & Defense | Dec 2023 | |
| Chemicals | Dec 2023 | |
| Containers & Packaging | Dec 2023 | TBD |
| Electrical & Electronic Equipment | Dec 2023 | |
| Industrial Machinery & Goods | Dec 2023 | |
| Extractives & Mineral Processing | ||
| Coal Operations | Dec 2023 | Phase 1 part 1 |
| Construction Materials | Dec 2023 | Phase 1 part 1 |
| Iron & Steel Producers | Dec 2023 | Phase 1 part 1 |
| Metals & Mining | Dec 2023 | Phase 1 part 1 |
| Oil & Gas - Exploration & Production | Dec 2023 | Phase 1 part 1 |
| Oil & Gas - Midstream | Dec 2023 | Phase 1 part 1 |
| Oil & Gas - Refining & Marketing | Dec 2023 | Phase 1 part 1 |
| Oil & Gas - Services | Dec 2023 | Phase 1 part 1 |
| Health Care | ||
| Biotechnology & Pharmaceuticals | Dec 2023 | |
| Drug Retailers | Dec 2023 | |
| Health Care Delivery | Dec 2023 | TBD |
| Health Care Distributors | Dec 2023 | |
| Managed Care | Dec 2023 | |
| Medical Equipment & Supplies | Dec 2023 | |
| Services | ||
| Advertising & Marketing | Dec 2023 | |
| Casinos & Gaming | Dec 2023 | TBD |
| Education | Dec 2023 | |
| Financials | ||
| Asset Management & Custody Activities | Dec 2025 | |
| Commercial Banks | Dec 2025 | |
| Consumer Finance | Dec 2023 | |
| Insurance | Dec 2025 | TBD |
| Investment Banking & Brokerage | Dec 2023 | |
| Mortgage Finance | Dec 2023 | |
| Security & Commodity Exchanges | Dec 2023 | |
| Infrastructure | ||
| Electric Utilities & Power Generators | Dec 2023 | Phase 1 part 2 |
| Engineering & Construction Services | Dec 2023 | TBD |
| Gas Utilities & Distributors | Dec 2023 | TBD |
| Home Builders | Dec 2023 | TBD |
| Real Estate | Dec 2023 | TBD |
| Real Estate Services | Dec 2023 | TBD |
| Waste Management | Dec 2023 | TBD |
| Water Utilities & Services | Dec 2023 | TBD |
| Technology & Communications | ||
| Electronic Manufacturing Services & Original Design Manufacturing | Dec 2023 | |
| Hardware | Dec 2023 | |
| Internet Media & Services | Dec 2023 | TBD |
| Semiconductors | Dec 2023 | |
| Software & IT Services | Dec 2023 | |
| Telecommunication Services | Dec 2023 | |
| Renewable Resources & Alternative Energy | ||
| Biofuels | Dec 2023 | |
| Forestry Management | Dec 2023 | |
| Fuel Cells & Industrial Batteries | Dec 2023 | TBD |
| Pulp & Paper Products | Dec 2023 | |
| Solar Technology & Project Developers | Dec 2023 | |
| Wind Technology & Project Developers | Dec 2023 | |
| Transportation | ||
| Air Freight & Logistics | Dec 2023 | |
| Airlines | Dec 2023 | |
| Auto Parts | Dec 2023 | |
| Automobiles | Dec 2023 | TBD |
| Car Rental & Leasing | Dec 2023 | |
| Cruise Lines | Dec 2023 | |
| Marine Transportation | Dec 2023 | |
| Rail Transportation | Dec 2023 | |
| Road Transportation | Dec 2023 |
[TBD – To be determined]
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.