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UK Sustainability TAC Report on Due Process Compliance (For the period ended 31 March 2026)

The Financial Reporting Council (FRC) provides the secretariat to the UK Sustainability Disclosure Technical Advisory Committee (TAC). For more information on the FRC's role as secretariat, please see this page.

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Context

1The 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 an IFRS Sustainability Disclosure Standard would be conducive to the long-term public good in the UK.

2The 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.

Terms of Reference and Due Process Policy

3The 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.

4The 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.

5The TAC approved its Due Process Policy in a public TAC meeting on 13 May 2025.

6Once 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.

7The 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.

Report on due process compliance

8The TAC's first report on due process compliance covers the period from DBT's publication of the Framework, which includes the TAC's Terms of Reference, on 16 May 2024 to 31 March 2026.

9The 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 Due Process Policy in the period from 14 May 2025 to 31 March 2026.

Guiding principles

10The 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.

Governance requirements

Membership

11As at 31 March 2026, the TAC has 13 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 Practice (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).

12Members 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	Current term length & end date	First or second term?
Sally Duckworth	Chair		3 years April 2027	First
Craig Mackenzie	Member	Academic & investor	2 years April 2026	First
David Harris	Member	Investor	3 years April 2027	First
Harriet Cullum	Member	Preparer	2 years April 2026	First
Hilary Eastman	Member	Accountant and/or audit provider	3 years April 2027	First
Jeremy Osborn	Member	Accountant and/or audit provider	2 years April 2026	First
Madeleine Evans	Member	Investor	3 years April 2027	First
Nick Rowbottom	Member	Academic	3 years April 2027	First
Peter Hogarth	Member	Accountant and/or audit provider	2 years April 2026	First
Scott Barlow	Member	Preparer	3 years April 2027	First
Supriya Sobti	Member	Preparer	2 years April 2026	First
Jenny Carter	FRC appointed member*
Paul Lee	UKEB appointed member*

* as these members are appointed to represent their respective organisations they are not appointed for fixed terms.

13The 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.

14A 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.

15The only changes of membership during the period ended 31 March 2026 were the resignation of two Members: Joseph Noss, on 19 March 2025, and Dia Desai, on 31 March 2026.

16The 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

17There 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 five 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.

18There were 18 public meetings in the period from 16 May 2024 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.

Technical activities

19The TAC, and the FRC as TAC Secretariat, completed technical activities, including the development of its comment letters for submission to the ISSB or other consultative bodies and the development of endorsement recommendations and advice. Key due process steps and documents for the TAC's projects for the period ended 31 March 2026 are summarised in the appendix.

20Further information on the TAC's projects for the period ended 31 March 2026 is in the TAC's report on technical activities.

21The TAC, and the FRC as TAC Secretariat, also continued their business-as-usual monitoring and influencing activities.

22Developments relating to sustainability-related reporting were monitored, including preparing, publishing and discussing General Reporting Updates on a monthly basis.

23The 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.

Appendix: Key due process steps and documents

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, including the provision of supplementary advice	✓	✓	✓	✓ ¹ Closed on 11/10/2023	Submitted to SoS on 18/12/2024. Related letter sent to ISSB Chair on 27/01/2025. Supplementary advice submitted to SoS 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	✓	N/A	Submitted to ISSB on 25/06/2025	✓ ³	✓
Enhancing the SASB Standards: Exposure Drafts SASB/ED/2025/1 and ISSB/ED/2025/2	✓	N/A	Submitted to ISSB on 27/11/2025	✓ ³	✓
Greenhouse Gas Protocol Scope 2 Guidance	✓	N/A	Submitted to GHG Protocol Independent Standards Board on 28/01/2026. Related letter sent to ISSB Chair on 28/01/2026	✓ ³	✓

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. ↩
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. ↩
There was a summary of stakeholder feedback provided as part of the TAC meeting papers, 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. ↩↩↩

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Name UK Sustainability TAC Report on Due Process Compliance (For the period ended 31 March 2026)

UK Sustainability TAC Report on Due Process Compliance (For the period ended 31 March 2026)

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