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UK Sustainability TAC Report on Technical Activities (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

1 The 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.

2 The 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.

3 A minister from the Department for Business and Trade (DBT) commissions the TAC to work on an IFRS Sustainability Disclosure Standard and DBT may commission the TAC to provide supplementary advice and analysis to support endorsement or implementation decisions. DBT may also share its views on the TAC's upcoming priorities.

4 The TAC's function and remit are further explained in its Terms of Reference, published by DBT, and accompanying Due Process Policy. The principles underlying the TAC's work are transparency, providing a focal point for UK stakeholders, accountability and assessing the long-term public good in the UK.

Report on technical activities

5 The TAC's first report on technical activities covers the period 16 May 2024 to 31 March 2026 commencing from DBT's publication of the Framework and Terms of Reference for the Development of UK Sustainability Reporting Standards (Framework), which includes the TAC's Terms of Reference.

Projects completed for the period ended 31 March 2026

Development of endorsement recommendations and advice

Endorsement recommendations and advice on IFRS S1 and IFRS S2

6 In June 2023, the ISSB published IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) and IFRS S2 Climate-related Disclosures (IFRS S2).

7 On 17 May 2024, the TAC was commissioned by the Minister of State for Enterprise, Markets and Small Business to conduct rigorous technical analyses of IFRS S1 and IFRS S2 and provide well-reasoned, clear and evidence-based advice to the Secretary of State accordingly. In particular, the TAC's analyses were to be used to provide a recommendation to the Secretary of State on whether the endorsement of IFRS S1 and IFRS S2 would be conducive to the long-term public good in the UK. The TAC's target date was the end of 2024.

8 In its role of providing a focal point for UK stakeholders, the FRC as TAC Secretariat published a call for evidence, which closed on 11 October 2023, alongside using roundtables to elicit stakeholder views. The FRC as TAC Secretariat also updated its stakeholder engagement in 2024 by conducting further interviews of UK stakeholders. A summary of stakeholder feedback is included in TAC paper 2024-TAC-027.

9 The TAC voted on its proposed amendments to IFRS S1 and IFRS S2 and on its endorsement recommendations and advice on IFRS S1 and IFRS S2 in a public meeting on 5 December 2024. The TAC also approved its report UK Endorsement of IFRS S1 and IFRS S2: Technical assessment and endorsement recommendations in the same public meeting and submitted it to the Secretary of State on 18 December 2024. The TAC also approved a related letter in a public meeting on 14 January 2025 and submitted it to the ISSB Chair on 27 January 2025.

10 The TAC's report recommended full endorsement of IFRS S1 and IFRS S2, with a few amendments, for example amendments to the requirement in IFRS S2 relating to the use of Global Industry Classification Standard (GICS) when disaggregating gross financed emissions and to the transition reliefs. The TAC's report also identified areas for further guidance, including on financed emissions to assist with consistent implementation.

11 Following the UK Government's consultation on the draft UK SRS S1 and UK SRS S2 in 2025 and the ISSB's publication of amendments to IFRS S2 Amendments to Greenhouse Gas Emissions Disclosures, in December 2025 the TAC was commissioned to provide supplementary advice to DBT.

12 Stakeholder feedback on relevant aspects of the UK Government's consultation contributed to the development of the TAC's supplementary advice.

13 The TAC approved its supplementary advice in a public meeting on 19 January 2026 and submitted it to the Secretary of State on 26 January 2026.

14 The TAC's advice recommended endorsement of the ISSB's amendments to IFRS S2, except for amendments to the effective date and transition in relation to adjusting comparatives. The TAC's advice was to replace its previous amendments to the requirement in IFRS S2 relating to the use of GICS with the ISSB's amendments to IFRS S2 and to provide further clarification on financed emissions disclosures.

15 Further information is available on the project page: Endorsement: Technical assessment of IFRS S1 and IFRS S2.

Development of comment letters

Proposed amendments to IFRS S2

16 In April 2025, the ISSB published an Exposure Draft proposing targeted amendments to IFRS S2: Exposure Draft ISSB/ED/2025/1 Amendments to Greenhouse Gas Emissions Disclosures. The Exposure Draft was open for comment for 60 days, with the comment period closing on 27 June 2025.

17 The TAC was commissioned to respond to the ISSB consultation on the proposed amendments to IFRS S2 in correspondence with DBT and in DBT's June 2025 letter.

18 In its role of providing a focal point for UK stakeholders, the FRC as TAC Secretariat used roundtables to elicit stakeholder views. The FRC as TAC Secretariat also made targeted approaches to stakeholders and held one-to-one meetings with them. A summary of stakeholder feedback is included in TAC paper 2025-TAC-036.

19 The TAC approved its response in a public meeting on 10 June 2025 and submitted it to the ISSB on 25 June 2025.

20 The TAC's response covered the following matters:

  • Scope 3 Category 15 greenhouse gas emissions.
  • Use of Global Industry Classification Standard (GICS).
  • Jurisdictional reliefs - use of the Greenhouse Gas Protocol Corporate Standard and applicability of global warming potential values.

21 Further information is available on the project page: Consultation response: IFRS S2 amendments.

Enhancing the SASB Standards

22 In July 2025, the ISSB published two Exposure Drafts proposing amendments to the SASB Standards and consequential amendments to the Industry-based Guidance on Implementing IFRS S2. These were Exposure Draft SASB/ED/2025/1 Proposed amendments to the SASB Standards and Exposure Draft ISSB/ED/2025/2 Proposed Amendments to the Industry-based Guidance on Implementing IFRS S2. The Exposure Drafts were open for comment for 150 days, with the comment period closing on 30 November 2025.

23 The TAC was commissioned to respond to ISSB consultations on the SASB Standards in correspondence with DBT and in DBT's June 2025 letter.

24 In its role of providing a focal point for UK stakeholders, the FRC as TAC Secretariat used a survey and roundtables to elicit stakeholder views. The FRC as TAC Secretariat also made targeted approaches to stakeholders and held one-to-one meetings with them. A summary of stakeholder feedback is included in TAC paper 2025-TAC-047.

25 The TAC approved its responses in a public meeting on 11 November 2025 and submitted them to the ISSB on 27 November 2025.

26 In addition to responding to the specific questions posed by the ISSB, the TAC's responses noted the value of industry-based sustainability disclosures and recommended that the ISSB:

  • communicates the future architecture of the IFRS Sustainability Disclosure Standards as a priority and applies the level of due process to the SASB Standards that is commensurate to the role they will play in the future architecture;
  • considers restructuring the SASB Standards to distinguish between core disclosures, industry-agnostic disclosures and industry-specific disclosures;
  • considers moving core and industry-agnostic disclosures out of the SASB Standards and into IFRS S1, IFRS S2 and any further topic-specific IFRS Sustainability Disclosure Standards;
  • reconsiders the name of the SASB Standards;
  • emphasises a principles-based approach so that the SASB Standards do not have to be adapted so much to keep pace with changes; and
  • considers adopting a climate-first thematic approach to its project to enhance the SASB Standards.

27 Further information is available on the project page: Consultation response: SASB enhancements.

Greenhouse Gas Protocol Scope 2 Guidance

28 DBT requested the TAC respond to the GHG Protocol consultation on Scope 2 Guidance.

29 In its role of providing a focal point for UK stakeholders, the FRC as TAC Secretariat made targeted approaches to stakeholders, holding interviews with some and receiving submissions from others. A summary of stakeholder feedback is included in TAC paper 2025-TAC-054.

30 The TAC approved its response in a public meeting on 19 January 2026 and submitted it to the GHG Protocol Independent Standards Board on 28 January 2026. The TAC also approved a related letter in a public meeting on 19 January 2026 and submitted it to the ISSB Chair on 28 January 2026.

31 The TAC's response welcomed the intention of the proposals to improve the quality of Scope 2 emissions data. However, it noted that there are significant concerns about the feasibility and cost of the proposals which might outweigh their benefits, and therefore recommended that the GHG Protocol reconsider whether all the proposed revisions are necessary to improve decision-making by investors and concentrate on the revisions that are likely to have the greatest impact on advancing the quality of disclosures.

32 Further information is available on the project page: Consultation response: GHG Protocol Scope 2 Guidance.

Other activities

Due Process Policy

33 The TAC's Terms of Reference require the TAC to determine its Due Process Policy within 12 months following approval of the Terms of Reference.

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

35 The TAC's Due Process Policy expands on the requirements in the TAC's Terms of Reference, with a particular focus on the TAC's technical activities, including its influencing activities, the development of its comment letters for submission to the ISSB or other consultative bodies and the development of its endorsement recommendations and advice.

Business-as-usual activities

36 The TAC, and the FRC as TAC Secretariat, performed business-as-usual monitoring and influencing activities.

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

38 The 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.

Work plan for 2026-2027

39 The TAC's work plan for 2026-2027 includes further information on the areas the TAC is expected to focus on for 2026-2027, which are:

  • nature-related disclosures;
  • proposed amendments to SASB Standards Phase 1 - Part 2;
  • GHG Protocol revisions; and
  • due process annual review.

40 The TAC, and the FRC as TAC Secretariat, will also continue their business-as-usual activities.

41 The TAC's work plan for 2026-2027 will be reassessed after six months and updated to address any changes.

File

Name UK Sustainability TAC Report on Technical Activities (For the period ended 31 March 2026)
Publication date 20 April 2026
Type Report
Format PDF, 212.8 KB