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TAC Public Meeting June 2026 Paper 3c: Proposed amendments to SASB Standards - Phase 1 Part 2 Draft comment letter points

AGENDA PAPER 3C

Executive summary

Date	16 June 2026
Paper reference	2026-TAC-017
Project	Proposed amendments to SASB Standards – Phase 1 Part 2
Topic	Draft comment letter points
Objective of the paper	This paper presents the key points to be included in the TAC's response to the ISSB's March 2026 Exposure Draft: Proposed Amendments to the SASB Standards and IFRS S2 Industry-based Guidance (SASB/ED/2026/1).

This is an internal working paper prepared for discussion purposes only and does not represent a formal TAC position.

Decisions for the TAC

No decisions are required from the TAC. However, members are invited to share their comments on the key points and draft responses to the questions in SASB/ED/2026/1 set out in the appendix.

Appendices

Appendix: Draft responses to the questions in SASB/ED/2026/1.

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.

This publication contains copyright material of the IFRS Foundation® (Foundation). All rights reserved. Reproduced and distributed by the Financial Reporting Council (FRC) in its role as the secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC) with the permission of the Foundation. No rights granted to third parties without permission of the Foundation and the TAC. For more information about the Foundation and the rights to use its materials please visit www.ifrs.org

Context

1The ISSB published the SASB Standards Exposure Draft: Proposed Amendments to the SASB Standards and IFRS S2 Industry-based Guidance (SASB/ED/2026/1) in March 2026. The deadline for comments is 24 July 2026.

2SASB/ED/2026/1 continues Phase 1 of the ISSB's project on Enhancing the SASB Standards and sets out proposed amendments to three SASB Standards: Agricultural Products (FB-AG), Meat, Poultry & Dairy (FB-MP), and Electric Utilities & Power Generators (IF-EU).

Draft comment letter points

Introductory text

3The UK Sustainability Disclosure Technical Advisory Committee (TAC) welcomes the opportunity to provide comments on the International Sustainability Standards Board (ISSB)'s Exposure Draft: Proposed amendments to the SASB Standards and IFRS S2 Industry-based Guidance (SASB/ED/2026/1). Our comments on the proposed amendments to the SASB Standards in this letter also apply to the Industry-based Guidance on Implementing IFRS S2 (IFRS S2 Industry-based Guidance) where relevant.

4This paper sets out key points for consideration and is accompanied by an appendix containing detailed responses to the specific questions in each of the three SASB Standards under consultation.

5The paper references, and should be read alongside, the TAC's November 2025 response to the ISSB's July 2025: Exposure Draft of Proposed Amendments to the SASB Standards (SASB/ED/2025/1) (the TAC's November 2025 response).

Key points

6The TAC is asked for its views on whether to include the following key points:

• The TAC continues to reiterate the importance of the points it made in its November 2025 response, and is expanding on them to incorporate further key developments as follows:
• The TAC believes that there is a tension between the role of the SASB Standards as complementing IFRS Sustainability Disclosure Standards, and the role of the SASB Standards as a standalone resource. It may not be possible for one set of materials to fulfil both roles effectively. The TAC therefore recommends that the ISSB, as well as communicating the future architecture of the IFRS Sustainability Disclosure Standards, addresses these challenges with the current architecture of the IFRS literature.
• The TAC previously recommended that the ISSB 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, so that the SASB Standards would focus only on industry specific disclosures. However, the TAC does not expect it will be necessary to move core and industry-agnostic disclosures into IFRS S1 and IFRS S2, as they will likely already be there, and cautions against making amendments to IFRS S1 and IFRS S2 as this would disrupt their implementation.
• The TAC emphasises that conclusions about nature-related disclosure requirements should not be made based on the consultations on the SASB Exposure Drafts.
• The ISSB considers consulting on matters most relevant to stakeholders who are not currently using the SASB Standards. Such a consultation could include questions around the historical reasoning for the inclusion or exclusion of disclosure topics and metrics. Consulting on proposed amendments to the SASB Standards, in contrast, seems most likely to elicit comments from stakeholders who are currently using the SASB Standards.

Appendix: Draft responses to the questions in the SASB/ED/2026/1

Questions 1 to 3

QUESTION 1— Agricultural Products SASB Standard (FB-AG)

(a) Do you agree with the proposed Agricultural Products industry description? Does it accurately describe the business activities of entities in this industry? Why or why not?

7The TAC agrees that the proposed Agricultural Products industry description is more internationally applicable than the existing version and better reflects the operating models of entities across global markets, including emerging economies and the broader agricultural value chain.

8In particular, the distinction between direct farming and third-party sourcing provides a helpful framework for decision-useful disclosures, supporting both investors and preparers in assessing sustainability-related risks and opportunities.

9However, as noted in the TAC's November 2025 response (paragraph 21) the TAC believes that updating only three of the eight SASB Standards within the Food & Beverage sector in isolation limits stakeholders' ability to assess overall coherence. A concurrent review of all eight SASB Standards in this sector would have enabled more informed and holistic feedback, particularly in relation to consistency across the sector and value chain effects.

(b) Do you agree with the proposed inclusion of direct farming operations in the scope of activities included in the industry classification? Why or why not?

10Subject to the improvements discussed in detail in response to Question 1(c) below, the TAC broadly agrees with the inclusion of direct farming operations within the scope of activities. As noted in response to Question 1(a) above, this inclusion reflects the global structure of agricultural entities across international markets, particularly in emerging economies, which are not fully included in the scope of the current version of the Agricultural Products SASB Standard.

(c) Do you agree that the proposed industry description makes it clear that the intended scope of entities in the industry classification includes entities with direct farming operations, entities that source products from farms (including, for example, outgrowers, contract farmers and co-operatives), and entities that do both? Why or why not?

11The TAC broadly agrees that the proposed revisions to the industry description clearly differentiate between entities with direct farming operations, entities that source products from farms, and entities that do both. In particular, the TAC supports the key terminology used in the industry description, such as 'direct crop production', 'intermediaries', and 'third-party growers' as these help make the intended distinction clearer. However, the TAC suggests some key improvements, as set out below, for the ISSB's consideration.

Guidance for integrated entities on boundaries between direct farming and third-party sourcing

12The ISSB has structured the revised FB-AG Standard to distinguish direct farming activities, reported under the Land Use & Ecological Impacts; and Labour Conditions disclosure topics from third-party sourcing activities, reported under the Supply Chain Management disclosure topic. However, for entities with integrated farming models the distinction between own operations and third-party sourcing (including contract farming and outgrower schemes) may not always be clear in practice, depending on the nature of the contractual arrangement.

13To illustrate: an entity may operate a nucleus estate model in which it provides contracted smallholder farmers ('outgrowers') with seed, fertiliser, pesticides and technical advice and purchases 100% of their output at a guaranteed price under an arrangement precluding sales to any other party. The entity specifies the crop variety to be planted, the planting schedule and the inputs to be used, but does not employ the farmers and does not own or lease the land they farm. It is not clear whether such an arrangement would constitute 'direct farming operations', triggering reporting under the Land Use & Ecological Impacts metrics (FB-AG-160a.1 to 160a.6) and Labour Conditions (FB-AG-310a.1) or a supply chain relationship covered by the Environmental and Social Supply Chain Management metrics (FB-AG-430c.1 to 430c.3 and FB-AG-430d.1 to 430d.3). Two companies with identical outgrower arrangements could reach opposite conclusions, resulting in disclosures that investors cannot readily compare.

14Additionally, how farming activities are classified as either direct operations or third-party sourcing determines whether the resulting GHG emissions are reported under Scope 1 or Scope 3, which has implications for disclosure comparability.

15The TAC suggests that the ISSB consider providing illustrative guidance or worked examples to support the consistent classification of different farming arrangements, for example by reference to the degree of operational control exercised by the entity. A clear definition of 'direct farming' within the technical protocols would also help avoid potential misinterpretation, particularly where complex or hybrid arrangements exist. The current absence of such definition is inconsistent with the approach taken elsewhere in the Standard, where key terms such as deforestation, human activity, food loss and forced labour are defined.

16The TAC also notes that the term 'direct farming' is used in a number of places in the proposed Meat, Poultry & Dairy SASB Standard in relation to livestock raising rather than crop production. This creates further ambiguity as to the intended meaning of the term across the two Standards and reinforces the need for a single, clear and consistent definition.

Applying materiality judgement to integrated and complex farming arrangements

17Considering the scope extension made to this Standard as an alternative to developing a new ‘Direct Farming SASB Standard', the TAC suggests that the ISSB consider improving the technical protocols by drawing more explicit attention to the application of judgement and materiality considerations. This would support entities with integrated operations or complex farming arrangements in determining when direct farming or third-party sourcing activities fall below the materiality threshold and therefore do not require disclosure under the Land Use & Ecological Impacts or Supply Chain Management topics, respectively.

18For example, where an entity determines that direct farming represents only a small proportion of its overall operations and is not significant, it may reasonably conclude that only third-party sourcing information should be reported under the Supply Chain Management metrics. While the ISSB expects entities to apply judgement and materiality considerations in all reporting decisions, the role of the SASB Standards is not interpreted consistently by all stakeholders. Based on engagement with stakeholders on the general use of SASB Standards, the TAC believes some preparers may view the inclusion of metrics within the Standard as implying that they are presumed material for all entities within the industry. More explicit guidance would mitigate this risk.

Scope clarity regarding commodity trading activities

19Agricultural commodities trading is included in both the existing and proposed revised industry descriptions. However, neither the Basis for Conclusions nor the technical protocols clarifies whether this scope overlaps with agricultural commodity derivatives trading undertaken by financial services entities. Consistent with the approach taken in the Electric Utilities & Power Generators SASB Standard, where an explicit note directs companies with gas-related activities to apply the Gas Utilities SASB Standard for those activities, the ISSB could provide a similar note. This would help clarify the intended scope of agricultural commodities trading and distinguish physical commodity trading from derivatives trading.

(d) Do you agree that the proposed disclosure topics in the Agricultural Products SASB Standard would accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry? If not, what revisions would you suggest and why?

20The TAC broadly agrees that the proposed disclosure topics would help identify sustainability-related risks and opportunities that could reasonably be expected to affect an entity's prospects. However, the TAC has some suggested improvements and observations for the ISSB's consideration, as set out below.

Clarity on the term ‘Ecological Impacts’

21The disclosure topic Land Use & Ecological Impacts uses the term 'impacts'. However, the perspective from which the term is intended to be applied is not clearly articulated in either the technical protocols or the Basis for Conclusions. This may create confusion, as the concept of impact is commonly understood differently in other contexts, such as double materiality assessments under ESRS and impact reporting under GRI.

22The TAC suggests that the ISSB consider explicitly clarifying the intended lens in the Basis for Conclusions or technical protocols, as this would improve the consistency of application and the comparability of disclosures across entities. Alternatively, a neutral term like ‘Ecological Effects' could be considered a replacement.

(e) Do you agree that the proposed metrics and technical protocols in the Agricultural Products SASB Standard would help an entity provide primary users with decision-useful information about sustainability-related risks and opportunities? If not, what revisions would you suggest and why?

23The TAC neither agrees nor disagrees with the proposals but has some observations that may warrant further consideration by the ISSB.

Inconsistent referencing of 'direct farming' across Land Use & Ecological Impacts metrics

24The Basis for Conclusions (paragraph BC57(a)) explains that the new disclosure topics on Land Use & Ecological Impacts and Labour Conditions are intended to focus on direct farming activities. Within the Land Use & Ecological Impacts disclosure topic, only the final three of the six metrics (FB-AG-160a.4 to FB-AG-160a.6) explicitly refer to 'direct farming' in their description. A comparable explicit reference to direct farming is also appropriately included in the single metric under the Labour Conditions topic (FB-AG-310a.1) as it is specifically designated for direct farming activities.

25By contrast, the first three Land Use & Ecological Impacts metrics (FB-AG-160a.1 to FB-AG-160a.3) do not explicitly reference 'direct farming' in their descriptions. While the technical protocol includes an explicit note below the topic summary stating that all metrics relate only to direct farming, this note is relatively inconspicuous and may not be readily visible to all users who focus on the metric descriptions alone. This inconsistency in metric labelling may lead to differing interpretations and inconsistent application. For example, entities may include both direct farming and third-party sourcing within the first three metrics, which do not carry an explicit 'direct farming' reference.

26The TAC suggests that the ISSB consider explicitly incorporating a direct farming reference in the descriptions of FB-AG-160a.1 to FB-AG-160a.3, consistent with the approach taken for FB-AG-160a.4 to FB-AG-160a.6, to support consistent application.

Unit of measure for spatial footprint

27Through research, the TAC found that the majority of preparers reporting spatial footprint use hectares as the unit of measurement. However, the proposed metric requires this information in square kilometres, which appears inconsistent with current reporting practices. No explanation is provided as to whether the ISSB considers square kilometres to be a more appropriate or internationally comparable unit of measurement than hectares. The TAC also notes that the TNFD framework, from which the metric is derived, is principles-based and does not mandate a specific unit of measurement.

28The TAC suggests that the ISSB either align the required unit with hectares, which is the established international unit for reporting land area in many contexts (particularly agriculture), or provide a rationale in the Basis for Conclusions for requiring square kilometres.

'Sustainably managed land' credibility

29Land Use & Ecological Impacts metric FB-AG-160a.3 requires disclosure of the spatial footprint of 'sustainably managed land by product'. While the technical protocol defines 'sustainably managed', it does not address the credibility of the entity's claims of sustainable management, which is a key consideration for investors and other users of reports.

30The TAC suggests that the ISSB consider referencing commonly used, product-specific sustainability certification standards, for example RSPO, RTRS, ProTerra, Rainforest Alliance, Fairtrade or 4C, or compliance with jurisdiction-specific regulatory frameworks on sustainable land management, as an approach to enhancing credibility while minimising greenwashing risks.

Limited decision-usefulness of the qualitative Labour Conditions metric

31The Labour Conditions disclosure metric (FB-AG-310a.1) is currently framed as a qualitative, process-based disclosure. Given that this topic applies explicitly to direct farming operations where the reporting entity has greater visibility over its workforce, the TAC suggests that the ISSB consider introducing a quantitative sub-metric, for example, the percentage of employees covered by fair-wage provisions. Such quantitative information would likely be more decision-useful to investors than a purely process-based disclosure.

Omission of supply chain food loss disclosure and absence of measurement methodology

32The proposed metrics require the reporting of food loss only from direct farming operations. As a result, entities with third-party sourcing activities only would not report food loss, and integrated entities would report only the direct-operations component of their total food loss. This is a significant gap, as food loss represents a significant financial concern across all stages of the value chain, with substantial losses occurring during transport, storage and other downstream activities. The exclusion of supply chain food losses therefore appears inconsistent with the importance attributed to food loss in the Basis for Conclusions (BC73). This inconsistency has also been highlighted previously, including in the TAC's November 2025 response letter to the Processed Food SASB Standard.

33In addition, the Exposure Draft's technical protocols (FB-AG-150a.1) neither provide an indicative methodology for measuring food loss and food waste, nor require entities to disclose the methodologies they used to measure the food loss and food waste they report.

34The TAC suggests that the ISSB consider referencing established international frameworks for measuring food loss such as The Food Loss and Waste Accounting and Reporting Standard, which is also cited in GRI footnotes as illustrative guidance, without mandating its adoption. At a minimum, the technical protocols could be improved to require disclosure of the food loss and food waste measurement methodology preparers used. This would enable users to assess the robustness and credibility of reported food loss and waste information.

Absence of reference to GHG Protocol Land Sector and Removals Standard

35The TAC notes that the GHG Protocol Land Sector and Removals (LSR) Standard, published in January 2026, provides guidance on accounting specific to agricultural and land-based emissions and removals. While the TAC recognises that the LSR Standard was published shortly before this Exposure Draft and may not have been available for consideration during its drafting, the TAC considers it important that the ISSB acknowledges its relevance either in the Basis for Conclusions or the technical protocols. This is particularly pertinent for agricultural companies that have submitted or are working towards Science Based Targets initiative (SBTi) validated targets under the Forest, Land and Agriculture (FLAG) guidance, which incorporates land-based emissions and removals as an integral component of science-based target-setting for companies with significant land use footprints. For such entities, alignment between the GHG emissions metrics in the Agricultural Products SASB Standard and the LSR Standard's accounting methodology is a practical implementation consideration that the ISSB should address in any finalised materials accompanying the Standard.

Nutrient management planning: absence of arable crop equivalent in the Agricultural Products Standard

36The TAC notes that the proposed FB-MP-160a.9 requires disclosure of the percentage of livestock production from direct farming operations implementing a written nutrient management plan. No equivalent metric exists in the Agricultural Products Standard for direct arable crop farming operations, despite similar underlying soil health risks. Excess nitrogen application in arable farming is a principal driver of nitrate pollution and a significant source of nitrous oxide emissions.

37The TAC therefore recommends that the ISSB consider introducing an equivalent metric in the Agricultural Products SASB Standard. However, consistent with the TAC's observation on FB-MP-160a.9, the existence of a written plan alone does not provide decision-useful information. The TAC therefore recommends that the technical protocol be framed to require disclosure of the percentage of direct farming land area that either complies with applicable jurisdictional nutrient management practices or is covered by a recognised certification scheme that embeds nutrient management practices, such as Red Tractor in the UK. This would provide investors with a more meaningful and credible indicator of nutrient management practices than plan existence alone.

(f) Do you agree that the proposed metrics in the Environmental Supply Chain Management and Social Supply Chain Management disclosure topics would support cost-effective disclosure of information that primary users need about sustainability-related risks and opportunities in the supply chain (for example, on soil health and water scarcity)? If not, what revisions would you suggest and why?

38The TAC does not have sufficient practical application evidence or observations to assess the cost-effectiveness of the proposed disclosure metrics in the Environmental Supply Chain Management and Social Supply Chain Management disclosure topics. However, an observation on supply chain disclosure is set out below for the ISSB's consideration.

Clarity on alignment with the EU Deforestation Regulation

39The TAC suggests that the ISSB should consider clarifying in the Basis for Conclusions or some guidance material whether FB-AG-430c.3 (requiring percentages of sourced agricultural products determined to be deforestation or conversion-free) is intended to complement EUDR due diligence disclosure requirements. The current split between environmental and social due diligence elements in the Agricultural Products SASB Standard may not align with the EUDR's integrated approach, potentially creating duplicative reporting obligations yet the intended disclosure objective could be the same.

(g) Do you agree that the proposals would improve the international applicability of the Agricultural Products SASB Standard and would lead to the disclosure of decision-useful information from entities in the industry regardless of their jurisdiction? Why or why not?

40The TAC agrees that the revised industry description represents a meaningful step towards greater international applicability. The prior description was implicitly oriented towards US and European, vertically integrated agricultural commodity processors and did not fully reflect the diversity of entities operating across the agricultural value chain internationally, particularly in emerging markets. The revised description more clearly recognises that entities may engage in direct crop production, act as intermediaries, or operate across multiple stages of the food value chain.

(h) Do you agree that the proposed amendments would enhance the Agricultural Products SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? Why or why not? (Note that the ISSB is focused on providing material information for investors about the effects of sustainability-related risks and opportunities on an entity's prospects.)

41The TAC agrees that the proposed amendments incorporating TNFD and GRI considerations, as summarised in the Exposure Draft interoperability table and reflected in the Exposure Draft, have the potential to enhance interoperability. However, the TAC suggests that the ISSB continue its collaboration with EFRAG (and GRI as necessary) on interoperability matters, including, where helpful, joint work to clarify how specific metrics within the Agricultural Products SASB Standard align with ESRS to support dual reporters.

42The TAC's broader comments on interoperability and alignment with other sustainability-related standards and frameworks, as set out in the TAC's November 2025 response (paragraph 40-46), are also relevant to the ISSB's consideration in relation to this industry.

(i) Are there any proposed metrics in the Agricultural Products SASB Standard that would benefit from the inclusion of specific proportionality mechanisms described in paragraphs BC47–BC48 of the Basis for Conclusions? If so, identify which metrics you believe would benefit from the introduction of such mechanisms and explain why.

43The TAC neither agrees nor disagrees with the proposals but has some observations that may warrant further consideration by the ISSB.

Proportionality provisions

44The TAC acknowledges the explanation in the Basis for Conclusions (BC47–BC48) that proportionality mechanisms in IFRS S1 are available to entities using the SASB Standards as guidance, particularly in relation to value chain determinations. However, the TAC considers that this does not fully reflect the broader role of proportionality within the IFRS Sustainability Disclosure Standards.

45Proportionality mechanisms in IFRS S1, including the use of reasonable and supportable information without undue cost or effort and the materiality-based approach to the value chain, are central to ensuring the Standards can be applied across entities of different sizes and levels of reporting maturity. Limiting their application in the context of SASB Standards, primarily to value chain considerations, creates an unintended inconsistency as entities applying IFRS S1 and IFRS S2 directly benefit from these mechanisms broadly. Given that the SASB Standards are integrated as a source of industry-specific guidance within the framework, the TAC considers it important that their application is aligned.

46The TAC also notes that locating this guidance solely in the Basis for Conclusions may limit its visibility to preparers. Reflecting proportionality considerations within the main body of the Standard, or through clear cross-referencing, would improve accessibility.

Use of 'shall' in the technical protocols

47The Exposure Draft acknowledges that the SASB Standards may be used as guidance under IFRS S1. Nevertheless, the technical protocols continue to use mandatory 'shall' language throughout, which may mislead preparers into treating all disclosures as unconditionally required, irrespective of materiality or business model applicability.

48The TAC recommends that the ISSB include a standard-level framing statement in the introductory provisions, or a dedicated application note, clarifying that 'shall' in the technical protocols denotes the appropriate disclosure or measurement methodology where a metric is determined to be applicable, but it does not itself determine whether that metric applies. This would reduce interpretive uncertainty without requiring wholesale redrafting of the technical protocols.

QUESTION 2— Meat, Poultry & Dairy SASB Standard (FB-MP)

QUESTION 2— Meat, Poultry & Dairy SASB Standard (FB-MP)

(a) Do you agree with the proposed Meat, Poultry & Dairy industry description? Does it accurately describe the business activities of entities in this industry? Do you agree with the scope of activities included in the industry classification? Why or why not?

49The TAC broadly supports the proposals, subject to the ISSB's consideration of the suggested improvements outlined below.

50As highlighted in the TAC's November 2025 response (paragraph 21), considering changes to only three of the eight SASB Standards in the Food & Beverage sector means there is potential for inconsistency when the remaining Standards are consulted on and finalised.

Aquaculture and fisheries exclusion

51Aquaculture and fisheries are not explicitly excluded in the proposed industry description, although their exclusion is explained in the Basis for Conclusions. The narrowing of the term 'meat' to specify beef, pork and poultry implicitly excludes aquaculture and fisheries, but does not provide sufficient clarity for entities with diversified operations involving aquatic species.

52The TAC recommends that ISSB consider either:

• framing the industry description to reflect the exclusion more explicitly. For example, replacing the broad term 'animal' with ‘terrestrial animal' would clearly limit the scope to land-based animals; or
• including an explicit exclusion for aquaculture and fisheries in the industry description.

53Either approach would improve clarity for diversified entities without altering the substantive scope of the Standard.

Limitations of illustrative livestock categories on industry scope

54The proposed industry description expands the term 'meat' by referencing beef, pork and poultry, without reference to sheep and goat. This issue is not confined to the industry description; it also runs through the technical protocols. For example, the antibiotic disaggregation requirement in FB-MP-260a.1 uses pork, beef, chicken and turkey as illustrative examples of livestock types. This creates uncertainty for entities with material sheep and goat operations, particularly in regions such as Europe, New Zealand, Australia and China, where sheep production is commercially significant. While the illustrative nature of these examples does not formally exclude other livestock, the absence of explicit reference to sheep and goat may give rise to confusion or inconsistent application.

55The TAC suggests that, rather than extending the list of meat types further, the ISSB consider replacing species-specific lists with a function-based formulation. In the industry description, ‘beef, pork and poultry meats' could be replaced with 'animal protein products from livestock raised for slaughter.' The technical protocols, including FB-MP-260a.1, could similarly be reframed around 'each material livestock species in the entity's production mix.' This approach would allow the Standard to then apply to any commercially significant livestock species and support consistent international application across markets where dominant species differ from those referenced in the current drafting.

Live animal transportation metrics

56The ISSB has expanded the industry scope to include live animal transportation, but has not introduced corresponding metrics. This limits the decision-usefulness of this scope expansion for investors and appears inconsistent with the approach taken elsewhere in the Exposure Draft. For example, the proposed inclusion of direct farming in the Agricultural Products SASB Standard is accompanied by supporting metrics under the Land Use & Ecological Impacts and Labour Conditions disclosure topics.

57The TAC suggests that the ISSB consider introducing metrics to capture animal welfare and related regulatory risks associated with live animal transportation, for example covering in-transit mortality rates, journey distances or durations.

Inconsistent terminology across the Standard

58The industry description in the Meat, Poultry & Dairy SASB Standard uses the term 'animal raising' to refer to the primary production of livestock. However, several metrics, for example Land Use & Ecological Impact metrics (FB-MP-160a.8 and FB-MP-160a.9) and their associated technical protocols use the term 'direct farming'. In the Agricultural Products SASB Standard, 'direct farming', though not defined, typically refers to direct crop production. Using the same term across both Standards to describe different concepts risks creating confusion in practice.

59The TAC suggests that the ISSB consider adopting consistent terminology across the Meat, Poultry & Dairy and Agricultural Products SASB Standards to improve clarity and support consistent application. For example, instead of using 'direct farming' in the Meat, Poultry & Dairy SASB Standard, the ISSB could retain terms such as 'primary livestock production' or 'animal raising' to avoid conflation with terminology used in the Agricultural Products Standard.

(b) Do you agree that the proposed disclosure topics in the Meat, Poultry & Dairy SASB Standard would accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry? If not, what revisions would you suggest and why?

60The TAC broadly agrees with the proposed disclosure topics subject to the ISSB's consideration of the suggested improvements outlined below.

Absence of Labour Conditions disclosure topic for own operations

61The TAC notes that metric FB-MP-430c.1 under the Social Supply Chain Management topic requires disclosure of processes, controls and procedures for managing labour conditions and community impacts within the supply chain. However, this is considered insufficient, as it does not address labour conditions and practice issues associated with own operations, including livestock raising and meat processing. The absence of a Labour Conditions topic creates an inconsistency between the Meat, Poultry & Dairy and Agricultural Products SASB Standards. It is also inconsistent with the inclusion of a Workforce Health and Safety disclosure topic and related workforce metrics within the Meat, Poultry & Dairy SASB Standard itself and limits the availability of decision-useful information for investors in the food businesses.

62The TAC suggests that the ISSB consider introducing a Labour Conditions disclosure topic for own operations within the Meat, Poultry & Dairy SASB Standard, aligned with the comparable topic in the Agricultural Products SASB Standard (FB-AG-310a.1). Meat and poultry processing activities are at least as labour-intensive as agricultural production and often present heightened labour-related risks. This is evidenced by UK regulatory and industry sources, which document the sector's heavy reliance on large workforces and its persistent exposure to labour shortages that can affect operational capacity and food safety.

Absence of Food Loss & Food Waste disclosure topic

63Meat, poultry and dairy products are highly perishable, making food loss a financially material and significant sustainability-relevant issue across the value chain. However, the proposed Standard does not include a Food Loss & Food Waste disclosure topic. As noted in the TAC's observations on the Agricultural Products SASB Standard, and in its response to the Processed Foods SASB Standards consultation in November 2025, food loss is a value-chain issue.

64The TAC suggests that the ISSB consider introducing a Food Loss & Food Waste disclosure topic in the Meat, Poultry & Dairy SASB Standard, consistent with the approach taken in the Agricultural Products SASB Standard and in recognition of the particular perishability and other related risks in this industry.

(c) Do you agree that the proposed metrics and technical protocols in the Meat, Poultry & Dairy SASB Standard would help an entity provide primary users with decision-useful information about sustainability-related risks and opportunities? If not, what revisions would you suggest and why?

65The TAC broadly agrees with the proposals, subject to the ISSB's consideration of the suggested improvements outlined below.

Exclusion of Scope 3 metrics

66In its January 2025 letter to the ISSB, following the technical assessment of IFRS S2, the TAC recommended that the ISSB collaborate with the GHG Protocol and other global standard setters to develop further industry-based guidance for Scope 3 emissions reporting, specifically to identify which Scope 3 categories may be material across different industries and sectors.

67In line with the alternative view expressed by Dr Barker, the TAC invites the ISSB to consider whether guidance on Scope 3 Category 1 emissions disclosure for Meat, Poultry & Dairy entities would better serve investor decision-usefulness, noting that entities reporting under the CSRD are already disclosing this information.

Methane disclosure: inconsistency with other SASB Standards

68The July 2025 SASB Exposure Draft for Oil & Gas Exploration & Production includes a standalone methane reduction target metric (EM-EP-110a.3). By contrast, the Meat, Poultry & Dairy Exposure Draft identifies methane as a climate-related risk but includes no equivalent reduction target metric and no explanation for this asymmetry is provided in the Basis for Conclusions.

69The TAC suggests that the ISSB consider introducing a comparable methane reduction target disclosure in the Meat, Poultry & Dairy SASB Standard to ensure consistency across industries where methane is identified as a climate-related risk.

Nutrient Management Plan disclosure: credibility and effectiveness

70Metrics FB-MP-160b.9 and FB-MP-430b.3 require entities to disclose the percentage of livestock from direct farming operations and supply chain sourcing, respectively, that maintain and implement a written Nutrient Management Plan (NMP). As noted in BC116, the objective of nutrient and manure management is to support soil health. However, the usefulness of this disclosure is limited by the absence of any mechanism to assess the credibility of the NMP, which is an important consideration for investors. A similar concern is reflected in Dr Richard Barker's Alternative Views on Land Use, where he notes that reporting the existence of a written NMP does not, in itself, provide decision-useful information regarding the plan's credibility, ambition, or effectiveness.

71In some jurisdictions, nutrient management is subject to regulatory requirements, providing a more objective basis for disclosure. For example, in the UK, The Department for Environment, Food and Rural Affairs (DEFRA) requires farms above ten hectares to comply with nutrient management regulations.

72In addition, references to recognised certifications that cover nutrient management, such as Red Tractor in the UK, can help support the credibility of disclosed nutrient management practices.

73The TAC suggests that the ISSB consider improving the technical protocols by referencing the percentage of livestock from direct farming operations (FB-MP-160a.9) or sourced from third parties (FB-MP-430b.3) that comply with applicable or jurisdictional nutrient management requirements. Alternatively, the ISSB could improve disclosures proposals to reference recognised certification schemes or other credible external validation mechanisms, rather than relying solely on the existence of a written NMP. This would enhance the decision usefulness of the metric by providing greater insight into the credibility and effectiveness of nutrient management practices. In its current form, the metric may encourage binary, compliance-focused responses of limited value to investors, rather than capturing more meaningful indicators of nutrient management quality, ambition, and outcomes.

Deforestation-free direct farming metric: limited applicability to some jurisdictions

74Metric FB-MP-160a.7, which requires disclosure of the percentage of livestock produced from direct farming operations determined to be deforestation- or conversion-free, is likely to have limited decision-usefulness for entities operating in jurisdictions where direct farming operations are by definition deforestation-free, for example UK-based pork and poultry producers. For such entities, the TAC notes through stakeholder engagement that deforestation risk sits primarily in the animal feed supply chain, for example in soy sourced from South America, and is more appropriately captured by the supply chain metrics under FB-MP-430b.1. A not applicable response or 100% result for direct farming operations in such contexts conveys no meaningful information to investors.

75The TAC suggests that the ISSB clarify in the technical protocol whether entities in such circumstances may explain inapplicability in lieu of reporting the metric.

Antibiotic use metric: unit of measurement and differentiation for strong stewards

76The antibiotic use metric (FB-MP-260a.1) requires disclosure of the percentage of animal production that received medically important antibiotics and, separately, antibiotics that are not medically important. The TAC notes, through stakeholder feedback, that this binary distinction is unlikely to produce decision-useful information for investors. An entity with strong antibiotic stewardship which only administers antibiotics when clinically indicated would report close to 100% in the medically important category and zero in the non-medically-important category. An entity with weaker stewardship practices could report an identical result if the antibiotics it administers happen to fall within the medically important classification. The metric therefore does not allow investors to distinguish responsible operators from less responsible ones.

77The TAC suggests the ISSB consider replacing or supplementing the current percentage-based metric with an intensity-based measure expressed in milligrams of antibiotic used per Population Correction Unit (mg/PCU). This is the established standard unit used in regulatory and industry reporting across the UK and EU including by the UK Veterinary Medicines Directorate in its annual UK-VARSS reports and by the RUMA Targets Task Force, which sets sector-specific mg/PCU targets for UK livestock producers across pigs, poultry and ruminants. Expressing antibiotic use as mg/PCU normalises for herd size and animal type, enabling meaningful comparison across entities and tracking of performance trends over time both of which the current percentage metric cannot support.

Absence of a comparable 'sustainably managed land' metric

78The Agricultural Products SASB Standard introduces metric FB-AG-160a.3, which requires entities to disclose the total area of land directly owned or controlled that is sustainably managed. No comparable metric has been introduced in the Meat, Poultry & Dairy SASB Standard, despite similarities in sustainability risks and opportunities, as reflected by the inclusion of comparable spatial footprint metrics across the two Standards. This represents a potential gap in the coverage of land use sustainability-related risks and opportunities within the Meat, Poultry & Dairy SASB Standard.

79The TAC suggests the ISSB consider addressing this gap by introducing a comparable metric, consistent with the approach taken in the Agricultural Products SASB Standard.

(d) Do you agree that the proposed metrics in the Environmental Supply Chain Management and Social Supply Chain Management disclosure topics would support cost-effective disclosure of information that primary users need about sustainability-related risks and opportunities in the supply chain (for example, on soil health and water scarcity)? If not, what revisions would you suggest and why?

80The TAC does not have sufficient practical application evidence or observations to assess the cost-effectiveness of the proposed disclosure metrics in the Environmental Supply Chain Management and Social Supply Chain Management disclosure topics. However, some observations on supply chain disclosure are set out below for the ISSB's consideration.

Antibiotic use: limited supply chain coverage

81The TAC notes that the proposed updates to the Animal Health & Welfare topic largely address concerns that some metrics assume companies directly manage livestock. This has been improved by replacing the own-operation metrics FB-MP-410a.1 (gestation crates) and FB-MP-410a.2 (cage-free eggs) with more flexible, narrative disclosures. The TAC also notes that FB-MP-410a.4 recognises the role of the value chain, acknowledging that companies may manage animal welfare through their suppliers rather than through their own farming activities. Similarly, FB-MP-410a.3 focuses on third-party certification, which also works for companies that only process products and do not farm animals themselves.

82However, the TAC believes that FB-MP-410a.5, which requires disclosure of biosecurity risks and disease management, does not clearly distinguish between companies that raise livestock themselves and those that source animals from independent farmers. Biosecurity is mainly a farm-level responsibility. It includes things like hygiene practices, vaccinations, controlling animal movements, and monitoring disease. Companies that only process animal products do not carry out these activities themselves. Instead, they can only influence them through supplier requirements and contracts. Without clearly stating that this metric applies only to companies with primary livestock production, or offering a different way for other companies to report, processor-only companies may provide information that is not decision useful.

83The TAC therefore recommends that the ISSB make it clear in the technical guidance for FB-MP-410a.5 that this disclosure is intended for companies with direct livestock operations. Companies without such operations should instead explain how they manage biosecurity risks through their supply chain, for example by setting supplier standards, requiring farm assurance schemes, or using veterinary audits rather than describing farm-level activities they do not perform. This would help ensure the information reported is useful and accurate across different types of businesses, while remaining consistent with the value chain approach already reflected in FB-MP-410a.4.

(e) Do you agree that the proposals would improve the international applicability of the Meat, Poultry & Dairy SASB Standard and would lead to the disclosure of decision-useful information from entities in the industry regardless of their jurisdiction? Why or why not?

84The TAC's previous comments on international applicability, as set out in the TAC's November 2025 response (paragraphs 35-39), are also relevant to the ISSB's consideration for this industry.

(f) Do you agree that the proposed amendments would enhance the Meat, Poultry & Dairy SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? Why or why not? (Note that the ISSB is focused on providing material information for investors about the effects of sustainability-related risks and opportunities on an entity's prospects.)

85Please refer to the TAC's previous broader comments on interoperability and alignment with other sustainability-related standards and frameworks, as set out in the TAC's November 2025 response (paragraphs 40-46), which are also relevant to the ISSB's consideration in relation to this industry.

(g) Are there any proposed metrics in the Meat, Poultry & Dairy SASB Standard that would benefit from the inclusion of specific proportionality mechanisms described in paragraphs BC47–BC48 of the Basis for Conclusions? If so, identify which metrics you believe would benefit from the introduction of such mechanisms and explain why.

86None identified.

QUESTION 3—Electric Utilities & Power Generators SASB Standard (IF-EU)

QUESTION 3—Electric Utilities & Power Generators SASB Standard (IF-EU)

(a) Do you agree with the proposed Electric Utilities & Power Generators industry description? Does it accurately describe the business activities of entities in this industry? Do you agree with the scope of activities included in the industry classification? Why or why not?

Industry description

87Broadly, the TAC agrees with the proposed industry description of the Electric Utilities & Power Generators SASB Standard (IF-EU), subject to the improvements suggested below. The revised description is more internationally applicable than the existing version, reducing its North American-centric framing and broadening the characterisation to encompass a wider range of electricity sector business models. However, the TAC suggests the following areas for further improvement for the ISSB's consideration.

Integrated structure of IF-EU compared to other sectors

88The TAC notes that the integrated structure of the IF-EU Standard contrasts with the approach taken in the Oil and Gas sector, where separate SASB Standards have been developed for each major segment of the value chain. While the TAC recognises that the ISSB has considered and decided against such disaggregation, drawing on stakeholder feedback, and acknowledges the inherent complexity of designing an international standard that accommodates diverse industry and market configurations, there appears to be scope to enhance the clarity of application.

89In particular, more explicit guidance within the technical protocols could be beneficial. This could follow an approach similar to that used in the Agricultural Products Standard, where specific topics are clearly signposted as applying only to entities engaged in direct farming activities. Introducing comparable guidance within IF-EU would support entities with pure-play or partially integrated operations in identifying the disclosures most relevant to them.

Biomass and geothermal omission from illustrative energy source list

90The proposed industry description lists illustrative energy sources, being coal, natural gas, nuclear, hydropower, solar and wind, without reference to biomass and geothermal. The TAC notes this list is not intended to be exhaustive, however, our engagement with preparers indicates that this creates applicability ambiguity for biomass-to-power entities. In the same way, geothermal generators in jurisdictions where geothermal is a significant energy source could also face the same ambiguity.

91The TAC recommends that the ISSB either (a) add biomass and geothermal explicitly to the illustrative list of energy sources, or (b) re-phrase the relevant sentence to make clear the list is non-exhaustive by adding the words '....and other energy sources' at the end of the list. Either approach would remove the applicability ambiguity without altering the scope of the Standard.

Greenhouse Gas Emissions & Energy Resource Planning

Applicability of capacity metrics to interconnector-based supply models

92The proposed installed and planned capacity metrics (IF-EU-110a.5 and IF-EU-110a.6) are designed for entities whose capacity profile reflects owned or controlled generation assets. However, for a subset of entities within the IF-EU scope, the operationally relevant measure of supply capacity is not installed generation capacity but contracted import capacity accessed via interconnectors and cross-border infrastructure. Applying IF-EU-110a.5 as currently drafted to such entities would result in installed capacity figures that systematically understate their actual supply capacity and omit the interconnector capacity that represents their primary operational and financial risk exposure. This structural anomaly is common among smaller island operators but also exists in other jurisdictions where interconnectors represent the principal source of supply capacity.

93The ISSB could consider amending the IF-EU-110a.5 technical protocol, to clarify that entities for which contracted interconnector capacity constitutes the principal proxy for installed generation capacity should disclose their maximum import or transfer capacity by source jurisdiction, in lieu of or alongside installed generation capacity. The technical protocol also could be improved to require such entities to describe the nature, term and counterparty of their primary supply contract, given that the sustainability-related risks and opportunities associated with interconnector infrastructure are the direct equivalent of those associated with an owned generation asset portfolio.

(b) Do you agree that the proposed disclosure topics in the Electric Utilities & Power Generators SASB Standard accurately identify the sustainability-related risks and opportunities that could reasonably be expected to affect the prospects of entities in this industry? If not, what revisions would you suggest and why?

94The TAC broadly agrees with the proposed disclosure topics. Related improvements are discussed alongside observations on metrics and technical protocols under Question 3(c) below, rather than as a separate analysis.

(c) Do you agree that the proposed metrics and technical protocols in the Electric Utilities & Power Generators SASB Standard would help an entity provide primary users with decision-useful information about sustainability related risks and opportunities? If not, what revisions would you suggest and why?

95Subject to specific improvements set out below, the TAC broadly agrees that the proposed metrics and technical protocols would help entities provide primary users with decision-useful information. The observations and recommendations presented below respond to both Questions 3(b) and 3(c), reflecting that disclosure topic metrics and technical protocols have been considered together in the TAC's analysis.

Biogenic CO2 emissions disclosure treatment

96The TAC notes an inconsistency in how biogenic CO2 emissions from biomass combustion are treated under IF-EU-110a.1, depending on the framework under which entities apply the standard. Entities applying IF-EU on a standalone basis would likely follow the GHG Protocol Corporate Standard for both measurement and disclosure, under which biogenic emissions are excluded from Scope 1 and disclosed separately as an appendix or memorandum item. This approach is aligned with ESRS Amended E1 (paragraph 44), which explicitly requires separate disclosure of biogenic CO2 emissions outside Scope 1. By contrast, entities applying IF-EU within the IFRS S2 framework are required to use the GHG Protocol for measurement only, with IFRS S2 governing disclosure, and in practice this results in biogenic emissions being included within Scope 1 totals following the March 2026 Transition Implementation Group (TIG) determination.

97This divergence could result in a material inconsistency in reported information for economically similar entities applying the same IF-EU Standard reducing the decision-usefulness of disclosures. Whether this appears inside or outside Scope 1 is not a presentation detail but a fundamental comparability question for entities applying the IF-EU Standard.

98The TAC suggests that the ISSB consider amending the technical protocol for IF-EU-110a.1 to explicitly require a consistent treatment of biogenic CO2 across all entities applying the IF-EU Standard, so that Scope 1, 2 and 3 disclosures are comparable irrespective of the overarching reporting framework applied.

Grid connections: absence of connections-related performance disclosures for T&D entities

99The TAC notes, based on stakeholder feedback and research, that connections activity, being the process of connecting new generation and demand to the network, represents a significant sustainability related risk and opportunity for T&D (Transition & Distribution) operators, but is not adequately addressed in the proposed disclosures.

100The connection of new renewable generation is a primary mechanism for delivering the energy transition, and in some jurisdictions is substantial in scale. In the UK, for example, a FTSE 100 T&D operator has committed, under its current regulatory business plan, to connecting 35 GW of new generation and storage and 19 GVA of demand, representing the most significant expansion of the transmission network in a generation. Separately, another UK FTSE 100 integrated electric utility has embedded renewables connections within the KPIs of its sustainability linked financing. Internationally, in the United States, developers identify grid interconnection delays as a leading cause of project cancellations, with connection timelines typically extending four to five years. These factors represent investor-relevant sustainability related risks and opportunities, with direct implications for decarbonisation pathways, regulatory returns and reputational standing.

101The TAC recognises that IF-EU-210a.2, which covers non-technical delays and days idle, partially captures delays arising in the context of connections projects. However, this metric records the symptom, namely the number of delay events and idle days, without requiring disclosure of the connections pipeline that gives those delays their investor significance. An entity connecting 35 GW of new capacity and experiencing a given number of delay events presents a materially different sustainability profile from an entity with a negligible connections programme, yet both would produce similar IF-EU-210a.2 disclosures.

102The TAC recommends that the ISSB consider expanding the IF-EU-110a.7 capital strategy narrative, or the IF-EU-550a.5 operational resilience narrative, to explicitly require T&D entities to describe their connections pipeline and delivery performance. This could include: (a) the scale of generation and demand connections committed or awaiting connection; (b) average connection timescales achieved relative to targets; and (c) the sustainability-related risks and opportunities associated with connections delivery. This information is already produced by UK T&D operators in their regulatory business plans and Ofgem submissions, and is directly relevant to investors assessing the entity's role in, and exposure to, the energy transition.

Transmission & Distribution losses classification: Scope 2 vs Scope 3

103The proposed technical protocol for IF-EU-110a.2 classifies T&D losses as Scope 2. The TAC notes, through stakeholder engagement and research, that this classification is consistent with the current practice of the majority of comparable pureplay T&D network operators in the UK and internationally, particularly in New Zealand, Australia and Canada and welcomes it as a constructive starting position.

104However, the GHG Protocol does not provide definitive guidance on the appropriate scope classification for T&D losses from the perspective of the T&D network operator as reporting entity. The Electric Power Research Institute (EPRI, a US-based independent non-profit electricity research organisation) confirms in its 2025 Technical Update on GHG Emissions Accounting for Electric Companies and Combined Utilities (EPRI Report 3002031993, March 2025, pages vii-viii) that guidance on this point ‘is ambiguous and not definitive', that the appropriate classification depends in part on the entity's corporate structure and business model, and that multiple approaches are currently permissible under the GHG Protocol. As a result, divergent practice exists even within the UK, where one pure-play transmission operator classifies losses as Scope 2 and another classifies them as Scope 3 while both applying the GHG Protocol.

105The TAC considers that the proposed technical protocol does not adequately address this ambiguity. In particular, the protocol does not explain the business model circumstances in which a Scope 3 classification might be appropriate, nor does it require entities departing from the Scope 2 default to disclose the business model judgment underlying their classification choice.

106The TAC recommends that the ISSB:

• retain the Scope 2 classification as the default in the IF-EU-110a.2 technical protocol, as this is consistent with the majority of current practice and with EPRI's guidance for wires-only T&D operators;
• include explicit guidance in the technical protocol acknowledging that the appropriate classification may depend on the entity's corporate structure and business model, consistent with EPRI's analysis;
• require any entity that classifies T&D losses other than as Scope 2 to disclose explicitly the business model judgment and accounting rationale underlying that classification, to enable investors to understand and compare disclosures across entities; and
• include an explanation in the Basis for Conclusions that the Scope 2 default reflects a considered resolution of existing ambiguity in the GHG Protocol.

Air Quality

Air quality metric applicability

107The technical protocol for IF-EU-120a.1 does not confirm that the metric is inapplicable to entities with no combustion-based generation. Pure-play renewable generators and T&D-only network operators produce zero or negligible quantities of the listed air pollutants.

108The TAC suggests that the ISSB consider adding a clarifying sentence to the technical protocol confirming that the metric applies only to entities with combustion-based generation. This would align with the approach taken in metric IF-EU-550a.3, which specifically applies to generation-related activities. A similar distinction can also be observed in the Agricultural Products Standard, which explicitly differentiates between direct farming activities and third-party sourcing.

Community Relations & Rights of Indigenous Peoples

Non-technical delay metric contradiction

109The technical protocol for metric IF-EU-210a.2 contains an internal contradiction that may make consistent application challenging. Paragraph 1.1 defines non-technical delays as including delays resulting from 'pending regulatory permits'. Paragraph 3 of the technical protocol then excludes 'technical situations unrelated to community-related risks (permitting delays)'.

110In practice, permitting delays and community-related risks in electricity infrastructure development are often inseparable. Planning applications are frequently delayed by community objections processed through the permitting system. For example, a delay arising from a judicial review initiated by a community group constitutes both a permitting delay and a community-related delay. Major UK electricity transmission infrastructure projects illustrate this dynamic clearly.

111The TAC suggests that the ISSB considers amending paragraph 3 of the IF-EU-210a.1 technical protocol to address this inconsistency. This could be achieved by clarifying that the exclusion applies only to purely administrative or procedural regulatory processes that are independent of community opposition. Providing an illustrative example would further enhance clarity and support consistent application.

Jurisdictional applicability of Indigenous Peoples metrics

112The technical protocols for IF-EU-210a.3 and IF-EU-210a.4 reference ILO Convention 169 and the UN Declaration on the Rights of Indigenous Peoples. The UK has not ratified ILO Convention 169, and the UK Government's stated position is that the Convention cannot be implemented, as the UK has no indigenous peoples to whom it applies. As a result, entities with purely domestic UK operations applying these metrics would be likely to report nil or not applicable results by operation of jurisdictional context rather than through substantive assessment, which may limit the usefulness of the disclosures for investors.

113For entities operating across multiple jurisdictions, including Australia, where the Native Title Act 1993 establishes formal obligations, group level disclosure may obscure these jurisdictional distinctions. This is because the technical protocol appears to assume reporting within a single jurisdiction.

114The TAC suggests that the ISSB consider adding a clarifying note to the IF-EU-210a.3 and IF-EU-210a.4 technical protocols. This could note that, for operations in jurisdictions without a domestic legal framework recognising indigenous peoples' rights, entities should state this explicitly and describe the community engagement and stakeholder rights mechanisms applied in such contexts, rather than reporting a nil figure or not applicable comment.

Reference to IFC Performance Standards

115Technical protocols for IF-EU-160a.3 and IF-EU-210a.1 reference the IFC Performance Standards on Environmental and Social Sustainability (2012). The IFC is currently undertaking a review of its Performance Standards, with revised standards expected between 2026 and 2028. The metrics as currently drafted lock entities into a reference document that may be superseded before the revised IF-EU Standard is fully implemented.

116The TAC suggests that the ISSB consider including an explanatory note clarifying that entities may apply the current IFC Standards or any successor document in force at the reporting date, to avoid the standards referencing a superseded document before implementation.

Energy Affordability

Energy affordability metrics

117The TAC notes, through stakeholder outreach, two implementation challenges for the new affordability metrics (IF-EU-240a.5 and IF-EU-240a.6) that merit guidance. First, where affordability support is routed through NGOs or charitable funds rather than directly to customer bills, accurate number of active and eligible participants under IF-EU-240a.6 may not be feasible, risking systematic under-reporting of programme reach. Second, affordability measurement methodologies vary across jurisdictions: UK T&D operators typically measure their contribution by reference to the network cost component of the consumer bill, while US retail entities measure the full customer bill, limiting comparability across a single group with multi-jurisdictional operations. The TAC recommends that the ISSB provide guidance in the technical protocol on how entities should approach indirect programme delivery and cross-jurisdictional measurement differences.

118The TAC also does not support the deletion of IF-EU-240a.3 (residential customer disconnections and reconnection rate). The disconnection metric is the only quantitative, directly comparable affordability stress indicator in the standard. Similarly, the deletion of IF-EU-240a.4 (discussion of external factors affecting customer affordability) removes the only mechanism for contextualising affordability disclosures in relation to commodity prices, geopolitical supply disruptions, and climate-related events. The TAC therefore recommends that the ISSB either reinstate these disclosures or incorporate their key elements into the proposed metric IF-EU-240a.5, which in its current form is entirely qualitative, addressing energy affordability risks, opportunities, and related management strategies without providing sufficient quantitative or contextual support.

Workforce Health & Safety

Injuries to members of the public: gap in workforce safety metrics

119The proposed workforce health and safety metrics (IF-EU-320a.1) cover Total Recordable Injury Rate (TRIR) and fatality rates for employees and non-employee workers. However, they do not capture fatalities or injuries to members of the public caused by company assets, for example incidents arising from contact with electricity infrastructure. For network operators, public safety incidents resulting from asset failure can represent material regulatory, financial, and reputational risks. The TAC notes, based on stakeholder engagement, that preparers identified this as an area receiving increased scrutiny from investors.

120The TAC suggests that the ISSB consider introducing a separate sub-disclosure within IF-EU-320a.1 requiring entities to report fatalities and serious injuries to members of the public attributable to the entity's assets or operations.

Employee Recruitment, Development & Retention

Employee skill shortage categorisation

121The technical protocol for IF-EU-330a.2 leaves the determination of which occupational categories constitute a skill shortage to entity judgement, with no external reference point. Through stakeholder engagement and research, the TAC notes that without an objective floor, entities may populate this metric on entirely different bases, limiting its comparability across reporters.

122The TAC suggests that the ISSB consider improving the technical protocols to have regard to, at a minimum, illustrative occupational categories identified as experiencing a shortage in an official government or recognised industry labour market assessment, applicable to their jurisdiction.

Demand-side management

Demand-side management: energy aggregators and supply-side flexibility

123The proposed metric IF-EU-420a.4 requires disclosure of electricity savings delivered through demand-side management programmes. As drafted, the metric reflects a traditional model in which a licensed electricity supplier (retailer) directly incentivises its own customers to reduce or shift consumption. The TAC notes, through research and stakeholder engagement, that this framing does not accommodate a structural feature of modern electricity markets that is already important in the UK and growing internationally.

124A distinct market structure has emerged in which demand response is managed not by the licensed supplier but by an independent energy aggregator - a technology platform that contracts directly with customers to control their assets, such as EV chargers and home batteries and bids the resulting flexibility into grid balancing markets. In the UK, one major energy group's technology platform now manages over 2 GW of customer-owned domestic devices as a virtual power plant, providing flexibility services equivalent in scale to several mid-sized power stations. None of this capacity would be captured under IF-EU-420a.4, because the assets are customer-owned and the flexibility is managed through a platform rather than a traditional supplier programme.

125The TAC recommends that the ISSB amend the IF-EU-420a.4 technical protocol to clarify that the metric encompasses flexibility delivered through aggregator-managed programmes, including where underlying assets are customer-owned but contractually controlled by the reporting entity.

Supply Chain Management

Supply chain disclosure for biomass fuel operators

126The proposed Supply Chain Management metrics cover Human Rights Due Diligence (HRDD) processes and the percentage of high-risk suppliers audited. Through stakeholder engagement and research, the TAC notes that, for biomass plant operators, neither metric addresses what may be the most financially material supply chain question, which is whether biomass fuel inputs were sourced from sustainably managed forests without deforestation. Instead, the proposed metrics appear calibrated for diversified procurement of manufactured components and may be structurally misaligned with the dominant supply chain risk profile of biomass generation.

127The TAC suggests that the ISSB consider adding applicability guidance within the existing technical protocols of IF-EU-430a.1 and IF-EU-430a.2, specifying that, for entities for which biomass fuel constitutes a significant proportion of fuel inputs, the description of supply chain management processes includes the certification frameworks applied to biomass sourcing and the entity's approach to verifying deforestation- and conversion-free status. This would improve disclosures for these entities through clarification in technical protocols without introducing new metrics.

Circular definition of ‘high-risk suppliers’

128IF-EU-430a.2 defines high-risk suppliers as those where the entity has 'determined a heightened level of risk.' This appears circular as an entity self-selects based on its internal determination which suppliers count as high-risk, audits those suppliers and reports the resulting percentage coverage. An entity facing severe supply chain risks but applying a narrow internal definition can report 100% audit coverage, while a similar but more transparent entity defining high-risk broadly may appear weaker on the same metric.

129The TAC suggests that the ISSB consider establishing a minimum threshold by reference to an objective external framework, such as the Responsible Minerals Initiative country risk assessments or other recognised global frameworks, to enhance the credibility of the assessment. It should also clarify that value chain scope includes, at a minimum, Tier 1 direct suppliers.

Operational Resilience & System Reliability

SAIDI/SAIFI/CAIDI calculation methodology

130The technical protocol for IF-EU-550a.2 requires that SAIDI, SAIFI and CAIDI be calculated according to IEEE Std 1366. IEEE Std 1366 is an American National Standard that is not used by UK, Australian or European regulators. UK Distribution Network Operators report to Ofgem using Customer Interruptions and Customer Minutes Lost metrics under RIIO-ED2 (the Ofgem's economic regulatory framework), with Ofgem-specific exceptional event definitions that differ substantially from the IEEE log-average methodology.

131The TAC suggests that the ISSB consider amending the technical protocol to permit entities to report using the calculation methodology required by their primary electricity sector regulator, with a requirement to disclose the specific standard or methodology applied

Generation asset availability: commercial sensitivity

132The new metric IF-EU-550a.3 requires disclosure of average availability factors disaggregated by major energy source. For dispatchable generators such as biomass, gas peaking and pumped hydro operating in competitive wholesale electricity markets, fuel-type disaggregation can reveal asset-specific maintenance patterns and unplanned outage frequency, informing bilateral trading and forward hedging strategies.

133This concern has precedent. In the United States, detailed generator availability and outage data collected by the North American Electric Reliability Corporation (NERC) are not publicly disclosed at plant level and are instead restricted or published in aggregated form, reflecting their commercial sensitivity and potential market impact. Similarly, the Federal Energy Regulatory Commission (FERC) limits disclosure of certain operational data where it may affect market behaviour or system security. In the UK, Ofgem has recognised that generator operational behaviour can influence wholesale prices and has introduced licence conditions to mitigate the risk of market manipulation. These precedents indicate that disaggregated availability data may have strategic value in competitive wholesale markets. The risk is greatest for entities with a small number of dispatchable assets, where fuel-source disaggregation may approximate asset-level disclosure, and is less significant for weather-dependent generation such as wind and solar.

134The TAC therefore suggests that the ISSB acknowledge this issue in the Basis for Conclusions and permits entities, where fuel-source disaggregation would reveal commercially sensitive information in a competitive wholesale market context, to disclose availability at the portfolio level, with an explanation of why disaggregation has not been provided.

Vulnerable assets metric: absence of valuation methodology and multi-hazard counting guidance

135The technical protocol for IF-EU-550a.4 requires disclosure of the 'amount and percentage of assets vulnerable to climate-related physical risks, disaggregated by industry asset type and specific climate-related physical risks.' However, it does not specify the valuation basis for the 'amount' to be disclosed. For example, a long-lived electricity network asset with a carrying amount close to zero due to full depreciation may have a replacement cost of tens of millions of pounds. The choice between carrying amount, fair value, and replacement cost can therefore produce materially different figures for identical underlying economic conditions.

136The TAC suggests that the ISSB consider specifying in the technical protocol that the 'amount' should be based on the carrying amount recognised in the financial statements. This would enhance consistency and connectivity with financial reporting, consistent with the principles in IFRS S2 Application Guidance (including paragraph B65), which emphasise that disclosures should be linked to information in the financial statements. Where assets are fully depreciated but remain operationally significant, entities should also be required to disclose this fact.

137The TAC also notes that the protocol requires the 'amount and percentage of assets vulnerable to climate-related physical risks' to be disaggregated by industry asset type and by specific climate-related hazards. However, it does not specify how assets exposed to multiple concurrent hazards should be treated in this disaggregated disclosure. Published UK electricity network climate adaptation reports indicate that coastal substations may be simultaneously exposed to flooding, sea level rise, coastal erosion and salt-induced corrosion. Consequently, a network operator with 50 coastal substations out of 5,000 total assets could report a vulnerable asset percentage ranging from 1% to 4% for the same underlying facts, depending solely on the counting methodology applied.

138The ISSB should clarify that an asset exposed to multiple hazards is counted once in the overall percentage but is disclosed under each relevant hazard category in the disaggregated breakdown. As a result, the disaggregated figures would not be expected to sum to the total.

(d) Do you agree that the proposals would improve the international applicability of the Electric Utilities & Power Generators SASB Standard and would lead to the disclosure of decision-useful information from entities in the industry regardless of their jurisdiction? Why or why not?

139Broadly, the TAC agrees that the proposed amendments improve the international applicability of the IF-EU Standard. However, further improvements are recommended to address areas where US-centric regulatory assumptions continue to constrain broader international applicability. Evidence from UK entities with operations spanning the UK, Australia, Hong Kong and the United States illustrates this challenge directly.

140A number of technical protocol issues discussed elsewhere in this response have direct international applicability dimensions. These are addressed in the context of their respective metrics under Questions 3(b) and 3(c) above and are cross-referenced below for completeness:

• The mandatory reference to IEEE Std 1366 in IF-EU-550a.2, which is an American National Standard not used by UK, Australian or European regulators. See comments on SAIDI/SAIFI calculation methodology under Question 3(b) (paragraphs 130-131).
• The inapplicability of IF-EU-210a.3 and IF-EU-210a.4 to entities operating in jurisdictions that have not ratified ILO Convention 169. See comments on jurisdictional applicability of Indigenous Peoples metrics under Question 3(b) (paragraphs 112-114).
• The omission of biomass and geothermal from the illustrative energy source list. See comments under Question 3(a) (paragraphs 90-91).

141The TAC also recommends that the ISSB consider including implementation guidance sections in IF-EU explaining how entities with operations across multiple electricity regulatory regimes should structure group-level IF-EU disclosures, particularly for quantitative metrics where jurisdictional aggregation methodology is currently unspecified.

(e) Do you agree that the proposed amendments would enhance the Electric Utilities & Power Generators SASB Standard's interoperability and alignment with other sustainability-related standards or frameworks? Why or why not? (Note that the ISSB is focused on providing material information for investors about the effects of sustainability-related risks and opportunities on an entity's prospects.)

142The TAC agrees that the proposed amendments enhance interoperability, with the following specific observations.

• Biogenic CO2 treatment - see comments under Question 3(b).
• Interoperability mapping table - see comments under Question 3(b).
• Climate-related disclosure fragmentation across four topics - see comments under Question 3(b).

143The TAC's previous broader comments on interoperability and alignment, as set out in the TAC's November 2025 response (paragraphs 40-46), are also relevant to the ISSB's consideration in relation to this industry.

(f) Are there any proposed metrics in the Electric Utilities & Power Generators SASB Standard that would benefit from the inclusion of specific proportionality mechanisms described in paragraphs BC47–BC48 of the Basis for Conclusions? If so, identify which metrics you believe would benefit from the introduction of such mechanisms and explain why.

144The TAC has identified certain metrics that would benefit from proportionality considerations, as outlined below. In particular, the TAC suggests that the ISSB consider including explicit activity gates in the technical protocols, to indicate the value chain segments to which the metrics relate within the integrated electricity value chain covered by this Standard:

• IF-EU-540a.1 (Nuclear Safety Review Results) - applies only to entities with nuclear plant operations.
• IF-EU-550a.2 (SAIDI/SAIFI/CAIDI) - applies only to entities operating electricity T&D networks.
• IF-EU-240a.5 and IF-EU-240a.6 (Energy Affordability) - apply primarily to entities with direct customer billing relationships.
• IF-EU-210a.3 and IF-EU-210a.4 (Indigenous Peoples) - apply where relevant domestic legal frameworks for indigenous peoples' rights exist, as discussed under Question 3(c) above.
• Entities for which a metric is inapplicable should be required to explain inapplicability rather than indicated them has having a nil outcome.

Questions 4 to 6

QUESTION 4— Consequential amendments to the IFRS S2 industry-based guidance

Do you agree that the ISSB should make consequential amendments to the IFRS S2 industry-based guidance when it makes amendments to the SASB Standards as set out in this Exposure Draft? Why or why not?

145In its November 2025 response to the ISSB's separate consultation on making consequential amendments to the IFRS S2 Industry-based Guidance, the TAC supported maintaining alignment between the IFRS S2 Industry-based Guidance and the climate-related content in the SASB Standards. The TAC continues to support maintaining alignment between the IFRS S2 Industry-based Guidance and the climate-related content in the SASB Standards.

146The TAC therefore agrees that the ISSB should make consequential amendments to the IFRS S2 Industry-based Guidance when it makes amendments to the SASB Standards, subject to the TAC's comments on the ISSB's proposed amendments to the SASB Standards.

QUESTION 5— Relationship with IFRS Sustainability Disclosure Standards

(a) Do you agree with the ISSB's proposed approach to amending the SASB Standards in relation to the content in IFRS Sustainability Disclosure Standards? Why or why not?

147The TAC does not agree with the ISSB's proposed approach to amending the SASB Standards in relation to the content in IFRS Sustainability Disclosure Standards.

148In Appendix 1 of its November 2025 response, the TAC made a number of general points, which did not answer the specific questions posed by the ISSB in the ISSB's July 2025 Exposure Draft of Proposed Amendments to the SASB Standards, but which did comment on the ISSB's proposed approach to amending the SASB Standards in relation to the content in IFRS Sustainability Disclosure Standards. This included the recommendations below:

• Future architecture of the IFRS Sustainability Disclosure Standards, including the incorporation of the SASB Standards: the TAC recommended that, as a priority, the ISSB communicates the future architecture of the IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture. The future architecture should prioritise the continuance of the global baseline of sustainability disclosures for capital markets established by IFRS S1 and IFRS S2. In particular, the TAC would value greater clarity about whether the SASB Standards are intended to be a foundation or substitute for future topic-specific IFRS Sustainability Disclosure Standards.
• Strategy for enhancing the SASB Standards: the TAC recommended that the ISSB:
• 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. The SASB Standards would then focus only on industry-specific disclosures; and
• reconsiders the name of the SASB Standards and suggests that they are renamed the ‘ISSB Guidance on the Industry-based Sustainability Disclosures'.
• Keeping pace with changes: the TAC recommended that the ISSB emphasises a principles-based approach so that the SASB Standards do not have to be adapted so much to keep pace with changes. In particular, entities should be encouraged not to disclose information otherwise suggested by a SASB Standard if the information is not material.
• Climate-first thematic approach: the TAC recommended that the ISSB considers adopting a climate-first thematic approach by incorporating core and industry-agnostic climate-related disclosures from the SASB Standards into IFRS S2 first, making any enhancements to industry-specific climate-related disclosures in the SASB Standards at the same time; and then enhancing the content related to other topics in the SASB Standards, alongside developing further topic-specific IFRS Sustainability Disclosure Standards.
• A robust due process: the TAC recommended that the IFRS Foundation applies the level of due process to the SASB Standards that is commensurate to the role they will play in the future architecture of the IFRS Sustainability Disclosure Standards.
• The industry classification system: the TAC recommended that there are mappings from SICS to other industry classification systems to support reconciliations between industry classification systems.

149The TAC continues to reiterate the importance of these points and notes that further information on each of these points is in Appendix 1 of the TAC's November 2025 response.

Further developments

Future architecture of the IFRS Sustainability Disclosure Standards, including the incorporation of the SASB Standards

150The TAC's November 2025 response focused on the role of the SASB Standards as industry-based sustainability disclosures that support the application of IFRS S1 and IFRS S2. However, the TAC believes that there is a tension between the role of the SASB Standards as complementing IFRS Sustainability Disclosure Standards and the role of the SASB Standards as a standalone resource. It may not be possible for one set of materials to fulfil both roles effectively.

151The historic inconsistency between the way the SASB Standards approach Scope 1 and Scope 3 greenhouse gas emissions illustrates these problems with the current architecture of the IFRS literature and fit of the SASB Standards within it, including their dual role. For example:

• paragraph BC40 of the Basis for Conclusions states that the proposed amendments 'have been drafted under the assumption that an entity would apply the SASB Standards with the IFRS Sustainability Disclosure Standards', which ‘avoids unnecessary duplication of requirements already included in IFRS S1 and IFRS S2'. However, the proposed amendments to the SASB Standards for a number of industries duplicate the requirements in IFRS S2 in relation to Scope 1 greenhouse gas emissions.
• paragraph BC10 of the Basis for Conclusions states that the SASB Standards 'assist an entity in disclosing industry-specific information that is relevant to primary users because it sets out disclosure topics and metrics that will typically be applicable for an entity with the business model and associated activities of specific industries'. However, the Alternative View of Dr Richard Barker suggests that the proposed amendments to the SASB Standard for the Meat, Poultry & Dairy (FB-MP) industry do not include important disclosures in relation to Scope 3 greenhouse gas emissions.

152There is also, as the ISSB suggests in paragraph BC45 of the Basis for Conclusions, potential duplication of governance, strategy and risk management disclosures and it does not seem compatible for the SASB Standards to both avoid unnecessary duplication of requirements already included in IFRS S1 and IFRS S2, and to set out disclosure topics and metrics that will typically be applicable for an entity with the business model and associated activities of specific industries.

153It also may not be clear whether the proportionality mechanisms and the materiality provisions in IFRS S1 and IFRS S2 apply to the SASB Standards, particularly where the SASB Standards are used as a standalone resource.

154The TAC therefore recommends that the ISSB addresses these challenges with the current architecture of the IFRS literature, as well as communicating the future architecture of the IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture.

Strategy for enhancing the SASB Standards

155In its November 2025 response, the TAC recommended that the ISSB strategy for enhancing the SASB Standards links to the future architecture of the IFRS Sustainability Disclosure Standards and prioritises simplification, so that the SASB Standards are straightforward to apply and it is easy to understand their output. The TAC's November 2025 response states:

[W]ithout simplification and alignment with IFRS S1 and IFRS S2, stakeholders could disengage from the SASB Standards because they may not have a clear relevance to the overarching principles and disclosures in IFRS S1 and IFRS S2. The industry-based sustainability disclosures should naturally flow from, and be a deeper dive into, the general disclosures in the IFRS Sustainability Disclosure Standards and should focus on how those general disclosures specifically relate to an entity's industry and related activities.

156The TAC has further comments in relation to its recommendation that the ISSB considers restructuring the SASB Standards to distinguish between 'core' disclosures, 'industry-agnostic' disclosures and industry-specific disclosures, and its recommendation that the ISSB 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, so that the SASB Standards would focus only on industry specific disclosures.

157The TAC reiterates that these recommendations could help simplify the SASB Standards by reducing the volume and making the content more accessible. However, the TAC does not expect it will be necessary to move core and industry-agnostic disclosures into IFRS S1 and IFRS S2, as they will likely already be there, and cautions against making amendments to IFRS S1 and IFRS S2 as this would disrupt their implementation.

158An example of how the ISSB could achieve this restructuring is demonstrated in the table below.

Topic	Metric
Topic: Water management
Core disclosures (in IFRS S1)	Governance, Strategy, Risk Management
Industry-agnostic disclosures	(1) Total water withdrawn, (2) total water consumed; percentage of each in regions with High or Extremely High Baseline Water Stress
Industry-specific
Oil & Gas – Exploration & Production (EM-EP)	Percentage of hydraulically fractured wells for which there is public disclosure of all fracturing fluid chemicals used
Marine Transportation (TR-MT)	(1) Total amount of ship waste discharged to the environment, (2) percentage treated prior to discharge Percentage of fleet implementing ballast water (1) exchange and (2) treatment

Climate-first thematic approach

159In its November 2025 response, the TAC cautioned that the ISSB's proposed piecemeal approach to enhancing the climate-related content in the SASB Standards meant that the IFRS S2 Industry-based Guidance would be continuously revised, which could be extremely resource intensive and disruptive.

160Following the submission of the TAC's November 2025 response, the TAC's stakeholder outreach and research activities found that numerous preparers used several, rather than only one, SASB Standards. If the ISSB continues updating the SASB Standards for priority industries, then preparers may be using a mixture of older and newer versions of the SASB Standards, which could also be resource intensive. This further supports the TAC's suggestion that the ISSB considers adopting a climate-first thematic approach.

(b) Do you agree that, for preparers applying the SASB Standards as well as IFRS Sustainability Disclosure Standards, the relationship between their contents is sufficiently clear? Why or why not?

161The TAC does not agree that, for preparers applying the SASB Standards as well as IFRS Sustainability Disclosure Standards, the relationship between their contents is sufficiently clear.

162In the TAC's November 2025 response, the TAC noted that its stakeholder outreach and research activities suggest that there was confusion about the status of the SASB Standards in the IFRS literature. The TAC's November 2025 response states: Some preparers considered the word 'shall' to be prescriptive and having the potential to cause reporting burdens and assurance challenges. Such preparers note that the UK Government's proposed change enables entities to apply judgement in determining the extent of use of the SASB Standards for their reporting.

163Following the submission of the TAC's November 2025 response, a stakeholder noted that there was still confusion about the status of the SASB Standards in the IFRS literature and welcomed the amendment in UK SRS as clarifying the position of the SASB Standards in the UK as being guidance.

QUESTION 6—EFFECTIVE DATE

Do you agree with the proposed approach for setting the effective date of the amendments and permitting early application? Why or why not?

164The TAC made the following points in its November 2025 response:

• The TAC agreed that the ISSB should decide the effective date of the amendments after considering feedback on the proposed amendments.
• The TAC's initial view on the effective date for the amendments was that it should occur at least 18 months after their issuance and permit early application. The ISSB should also be clear about whether comparatives are required for newly revised metrics.
• The TAC believed that the timeline should be aligned with annual reporting cycles and provide preparers with sufficient lead time to update internal systems and processes. It should also support jurisdictions that rely on translated versions of the SASB Standards, allowing for consistent implementation across regulatory frameworks.

165The TAC continues to reiterate the importance of these points.

Further developments

166In its response to question 5, the TAC commented on the dual role of the SASB Standards as complementing IFRS Sustainability Disclosure Standards and as a standalone resource. In their role as complementing IFRS Sustainability Disclosure Standards, the TAC queries whether an effective date is necessary. However, the TAC also recognises that, in their role as a standalone resource, an effective date could be of value.

Questions 7 to 10 for respondents who did not respond to the July 2025 Exposure Draft

167The TAC made the following points in its November 2025 response:

• Clarity, conciseness and cost-effectiveness for preparers: The TAC agreed with the ISSB's stated intention of enhancing the clarity, conciseness and cost-effectiveness for preparers and recommended that the ISSB considers making further improvements to the consistency of the terminology used in the SASB Standards.
• Alignment with IFRS Sustainability Disclosure Standards: The TAC strongly supported the ISSB's aim of aligning the language and concepts with the IFRS Sustainability Disclosure Standards, and believed that alignment with the IFRS Sustainability Disclosure Standards should be the primary driver of the changes. For example, the TAC recommended that the ISSB considers:
• clarifying the architectural relationship between SASB Standards terms and the ISSB Standards or reframing the current SASB Standards, structured around disclosure topics, metrics and technical protocols to align with the ISSB Standards focus on risks and opportunities;
• providing an analytical bridge connecting the SASB metrics to the financial statements; and
• the duplication between the SASB Standards and the IFRS Sustainability Disclosure Standards.
• Enhancing international applicability: The TAC supported the ISSB's aim of enhancing the international applicability of industry groupings, disclosure topics, metrics and supporting technical protocols. The TAC also had concerns that certain metrics assume a single jurisdictional context. The TAC recommended that the ISSB considers ways of improving engagement with the SASB Exposure Draft and conducting further outreach in markets beyond North America and Europe.
• Improving interoperability with other sustainability-related standards and frameworks: The TAC generally supported the ISSB's aim of improving interoperability with the GRI Standards, ESRS and Task Force on Nature-related Financial Disclosures (TNFD). The TAC further believed that the ISSB's focus should be harmonisation (gradually minimising the differences between standards and frameworks) rather than interoperability (standards and frameworks working together).
• Amendments related to BEES (nature) and human capital: The TAC did not support the ISSB's aim of aligning the enhancements with the ISSB's research projects on BEES (nature) and human capital as the research projects had not been completed and a number of the BEES (nature) and human capital metrics may be industry-agnostic disclosures.

168The TAC continues to reiterate the importance of these points and notes that further information on each of these points is in Appendix 2 of the TAC's November 2025 response.

Further developments

Clarity, conciseness and cost-effectiveness for preparers

169Following the submission of the TAC's November 2025 response, the TAC has noted a number of differences in the the nature-related disclosure topics and metrics in the 77 SASB Standards, and that the reasons for the variations have not always been apparent. For example, the table below highlights four disclosure topics that are essentially the same, with the same metrics and technical protocols, with the only difference being the variation in the disclosure topic name.

Disclosure topic	Metric
Energy Management	(1) Total energy consumed, (2) percentage grid electricity and (3) percentage renewable
Energy Management in Manufacturing	(1) Total energy consumed, (2) percentage grid electricity and (3) percentage renewable
Energy Management in Retail & Distribution	(1) Total energy consumed, (2) percentage grid electricity and (3) percentage renewable
Energy Management in Retail	(1) Total energy consumed, (2) percentage grid electricity and (3) percentage renewable

170The ISSB could consider making further improvements to the consistency of the disclosure topics and metrics in the 77 SASB Standards to enhance the clarity, conciseness and cost-effectiveness for preparers.

Amendments related to nature

171In the TAC's November 2025 response, the TAC noted that 'the ISSB recently agreed to build on TNFD the [Taskforce on Nature-related Financial Disclosures] recommendations in future nature-related work and agreed to move forward with standard-setting activities in relation to nature-related risks and opportunities. The form of those activities and the formal decision to begin them, however, will only be discussed at a future meeting'.

172Following the submission of the TAC's November 2025 response and in light of the ISSB's further discussions and decisions on nature-related disclosures, the TAC has further considered its position in relation to the nature-related disclosures in the SASB Standards.

173In relation to the following question in SASB/ED/2026/1 (and an equivalent question in SASB/ED/2025/1):

Do the SASB Standards, including the proposed amendments, enable entities to provide decision-useful information about their nature-related risks and opportunities to users of general purpose financial reports? Why or why not?

the TAC reiterates its concerns about whether:

• the consultations on the SASB Exposure Drafts are engaging the appropriate stakeholders to provide informed responses to this question; and
• it is premature to pose this question ahead of the ISSB finalising its decisions on the nature-related standard setting project.

174The TAC further comments that the wording of the question is not likely to provide the ISSB with sufficient and appropriate information as to whether the SASB Standards provide primary users with sufficient decision useful information about nature-related risks and opportunities.

175The TAC emphasises that conclusions about nature-related disclosure requirements should not be made based on the consultations on the SASB Exposure Drafts.

176The TAC also believes that while the SASB Standards include a wide coverage of nature-related matters and metrics (even within a disclosure topic) across the 77 standards, it is not possible to conclude that the SASB Standards adequately include decision useful nature-related requirements. The disclosure topics and metrics will likely provide primary users with decision-useful information, but it is not possible to conclude that these disclosure topics and metrics provide primary users with a complete picture of an entity's exposure to nature-related risks and opportunities.

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Name TAC Public Meeting June 2026 Paper 3c: Proposed amendments to SASB Standards - Phase 1 Part 2 Draft comment letter points

Publication date 09 June 2026

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