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TAC Public Meeting June 2026 Paper 3a: Proposed amendments to SASB Standards - Phase 1 Part 2 - Preliminary analysis of the Electric Utilities & Power Generators SASB Standard (IF-EU)

Executive summary

Date: 16 June 2026 Paper reference: 2026-TAC-015 Project: Proposed amendments to SASB Standards – Phase 1 Part 2 Topic: Preliminary analysis of the Electric Utilities & Power Generators SASB Standard (IF-EU)

Objective of the paper

This paper sets out the TAC Secretariat's preliminary technical analysis of the proposed amendments to the Electric Utilities & Power Generators SASB Standard, as published in the ISSB's Exposure Draft on 26 March 2026. The paper:

presents proposed responses to the ISSB consultation questions Q3(a)-Q3(f) with rationale; and
explains the supporting evidence and technical analysis, grounded in the UK context and the international markets in which UK companies operate.

This is an internal working paper and does not represent a formal TAC position.

Decisions for the TAC

The TAC is asked to review the considerations set out by the TAC Secretariat and provide any comments.

Appendices

Appendix 1: Supplementary explanatory information on technical matters.

Context

1The International Sustainability Standards Board (ISSB) published an Exposure Draft (ED): Proposed Amendments to SASB Standards and IFRS S2 Industry-based Guidance (SASB/ED/2026/1) on 26 March 2026. The ED covers three industries: Agricultural Products (FB-AG), Meat, Poultry and Dairy (FB-MP), and Electric Utilities and Power Generators (IF-EU). This paper focuses on the IF-EU Standard, which is the only Infrastructure sector standard included in this consultation. Analysis for the Agricultural Products and Meat, Poultry & Dairy was covered in Paper 2026-TAC-012 presented at the May 2026 TAC meeting.

2In making amendments to the SASB Standards, the ISSB's overarching objectives as set out in BC21 of the Basis for Conclusions are to:

improve the international applicability of the standards, which were originally developed primarily for United States market conditions;
enhance interoperability with IFRS S1, IFRS S2, GRI, and TNFD; and
incorporate and field test topics relevant to nature, human capital and supply chain sustainability that have grown in investor relevance since the original SASB Standards were published.

Key proposed changes to the Electric Utilities & Power Generators SASB Standard

3The following summarises the most significant proposed changes consulted on in SASB/ED/2026/1.

GHG Emissions & Energy Resource Planning (retained topic)

4Three new metrics proposed include installed capacity by energy source and storage, planned capacity and capital strategy narrative. IF-EU-110a.2 which previously required power deliveries is revised to include Scope 3 Category 3 disclosure on net purchased electricity (mainly for retailers) and GHG emissions on transmission and distribution losses.

Energy Affordability (retained topic)

5Three metrics have been removed which are 'Average retail electric rate for residential, commercial and industrial customers', 'Number of residential customers electric disconnections for non-payment and percentage reconnected within 30 days' and 'Discussions of impact of external factors on customers affordability of electricity, including the economic conditions of the service territory'.

6Two new metrics have been proposed: (i) a requirement to describe energy affordability-related risks and opportunities, and (ii) disclosure of the number of active and eligible participants in energy affordability-related actions or programmes, disaggregated across residential, commercial, and industrial segments.

Ecological Impacts (new topic)

7This proposed new disclosure topic is accompanied by three metrics on spatial footprint, proximity to sensitive locations and environmental management policies, aligned with the TNFD LEAP ‘Locate' step.

Community Relations & Rights of Indigenous Peoples (new topic)

8This proposed new disclosure topic introduces four metrics on community risk processes, non-technical project delays, operations near Indigenous Peoples' land and the Free, Prior and Informed Consent (FPIC) engagement.

Employee Recruitment, Development & Retention (new topic)

9This proposed new disclosure topic is accompanied by two metrics on skills shortage strategy and voluntary/involuntary turnover by occupational category, directly relevant to the UK's projected 277,000 energy sector vacancies by 2030.

Supply Chain Management (new topic)

10The proposed new disclosure topic includes two metrics on supply chain sustainability-related risks narrative and ‘high-risk supplier' audit coverage, reflecting clean energy technology supply chain risks.

Hazardous Waste Management (renamed from Coal Ash Management)

11Broadened scope to all hazardous waste streams including nuclear waste, polychlorinated biphenyls in transformer oil, battery materials and others.

Operational Resilience & System Reliability (renamed from Grid Resiliency)

12Three proposed new metrics added include generation assets availability factor, climate physical risk asset vulnerability and operational resilience strategy narrative. Cybersecurity metric also improved from compliance-based to incident-based formulation.

Analysis

13The following pages present a tabular analysis of the proposed amendments, structured in themed blocks. Within the table, the analysis is organised under thematic headings. These themes cover: the scope of the standard or industry description; the disclosure topics and associated metrics; and considerations relating to international applicability, interoperability and proportionality mechanisms.

14Seven UK-relevant electric utility entities were reviewed covering the full scope of proposed activities, from a small island integrated electricity operator to the UK's large electricity generators, retailers and transmission & distribution companies.

15An AI-assisted tool was used, where appropriate, to support research and analysis, with outputs reviewed and validated by the Secretariat team.

16An appendix has been provided to include further explanatory information on technical matters discussed in the paper.

Preliminary response considerations and technical assessment

Q1 (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? Why or why not?

Preliminary response position:

Broadly agree with the proposed industry description, subject to some suggested improvements.

Rationale:

The revised industry description is more internationally applicable compared to the existing version, reducing North American-centric jurisdictional framing and broadening the characterisation to encompass the full spectrum of electricity sector business models. This includes vertically integrated utilities, independent power producers (IPPs), pure-play transmission and distribution (T&D) operators, electricity retailers, entities involved in energy storage and distributed energy resources (DERs). However, further enhancements would be beneficial, as outlined in Table 1.1 for the ISSB's consideration. These include:

Either the explicit inclusion of biomass and geothermal as illustrative energy sources within the description, or a rephrasing to make clear that the list of energy sources is non-exhaustive.
Provision of activity-based applicability guidance for single-segment entities.
Clarification of boundary considerations for conglomerates.

1.1 Detailed analysis of change in industry scope/description

Nature of proposed amendment

The revised description moves beyond the original binary regulated/unregulated framing to enumerate: vertically integrated utilities, independent power producers (IPPs), pure-play transmission & distribution (T&D) entities, electricity retailers and traders and entities with energy storage assets and distributed energy resources (DERs).

Energy sources listed explicitly in the revised industry description are coal, natural gas, nuclear, hydropower, solar and wind.

ISSB's rationale for changes (per Basis for Conclusions)

BC138-BC145 explains that the ISSB evaluated three structural options: (a) separate standards for discrete business activities in the value chain e.g. generation and T&D (b) single standard with additional guidance regarding the likely applicability of disclosure topics to specific activities within the value chain or (c) maintaining a single standard while relying on existing requirements, guidance and educational materials. The ISSB selected option (c) on the basis that users favour an integrated structure. It also observed that vertically integrated preparers tend to oppose disaggregation, as it would require them to navigate multiple standards containing overlapping or duplicated topics. Although preparers expressed mixed views on the proposed structure, the ISSB concluded that the current integrated approach represents the optimal solution (BC142).

BC143 explains that ISSB decided not to provide additional applicability guidance for specific activities because 'the responsibility for making materiality judgements ultimately rests with the reporting entity'.

Findings from UK company review

Suitability of proposed description to UK companies

Seven UK-relevant electric utility entities were reviewed across the full proposed Electric Utilities & Power Generators (IF-EU) industry scope, spanning vertically integrated conglomerates, pure generation businesses, T&D-dominant operators, retail-only suppliers and a small island integrated utility. The following bullet points summarise the entities:

A FTSE 100 electricity transmission, distribution and generation group is the most experienced SASB reporter in the review, disclosing voluntarily against two Infrastructure (IF) SASB Standards - Gas Utilities & Distributors (IF-GU) and IF-EU for six consecutive years. Its UK operations comprise high-voltage electricity transmission and distribution networks, rendering generation-related topics and metrics such as GHG emissions, air quality and water management largely non-relevant in that context. In contrast, its US operations encompass electricity transmission, gas distribution and fossil fuel peaking generation, including direct retail billing to customers. As a result, the group operates as a fully integrated energy business, particularly across the electricity value chain spanning generation, transmission, distribution, retail and storage across both UK and US state regulatory regimes. This makes it a relatively strong fit for the proposed integrated industry description.
A FTSE 100 integrated electricity utility applying the IF-EU SASB Standard. Its business spans renewable generation (offshore and onshore wind, hydro, solar and battery storage), electricity transmission and distribution and thermal generation. It spans nearly the full electricity value chain, from generation through transmission to distribution across two regulatory regimes (the UK and Ireland), making it another relatively strong fit for the integrated industry structure.
A global infrastructure conglomerate with primary listing in Hong Kong and secondary listing on the LSE, applying two Infrastructure SASB Standards – IF-EU and IF-GU. Its electricity businesses currently cover distribution across the UK, Australia, New Zealand and generation in Hong Kong. Its gas businesses cover transmission and distribution across the UK, Australia and Northern Ireland. The business operates across up to four distinct electricity regulatory regimes: Australian AER, Hong Kong EMSD, New Zealand Commerce Commission and UK Ofgem creating unique multi-jurisdiction application challenges given the regulatory focus of the IF-EU SASB Standard. Unlike a single operating group structure spanning the full electricity value chain, this is an investment holding company whose subsidiary businesses each occupy a specific segment of the industry. Biomass generation also forms a small part of the conglomerate's renewable energy sources.
A FTSE 100 diversified energy company applying the IF-EU SASB Standard. Its business comprises residential and business electricity & gas supply, distributed energy solutions (EV charging, solar, microgrids), upstream gas production, gas-peaking generation via Open Cycle Gas Turbines (OCGT) and a stake in the UK nuclear fleet. The business spans generation, retail supply and energy services but is retail-weighted, with its upstream gas production activities reported under Oil & Gas - Exploration & Production (EM-EP) SASB Standard. The company's last year of reporting under IF-EU and EM-EP was 2022.
A FTSE 250 biomass and renewable electricity generator, currently not applying SASB Standards. Its business spans biomass power generation, pumped storage hydro, Open Cycle Gas Turbines, pellet production and a small retail energy supply arm to business customers. Therefore, the generation-related segment and associated topics are a better fit for this entity. Although it has a small retail business serving business customers, this appears to be insignificant relative to the overall business.
An LSE-listed small island integrated electricity company that imports approximately 94% of its electricity supply via three subsea cables from France, transmitting, distributing and retailing that supply to island customers. On-island generation (a small solar farm, diesel backup and an energy-from-waste plant) exists solely as contingency. The three subsea cables are in substance the functional equivalent of the entity's generation asset portfolio: they determine available capacity, carry the primary supply security risk and are the assets whose physical vulnerability dominates its climate risk exposure. The entity operates within a Crown Dependency self-regulatory framework, outside both the UK ETS and EU ETS, and does not currently apply any Infrastructure SASB Standard. While its transmission, distribution and retailing activities align clearly with the IF-EU industry scope, the generation-focused metrics, particularly IF-EU-110a.5 (installed capacity) and IF-EU-550a.4 (physical risk asset exposure) do not map naturally onto a business model where import contract capacity substitutes for owned generation assets portfolio and where no independent national regulator applies.
A UK major retail energy supply group with minimal own generation and no T&D network, making approximately 40-50% of IF-EU metrics inapplicable. The most relevant IF-EU metrics are Energy Affordability, Scope 3 Category 3 GHG (purchased electricity for retailing), Employee Recruitment Development & Retention and Cybersecurity. The entity does not apply SASB Standards.

Suggested response letter comments for the TAC's consideration

Biomass and geothermal energy sources missing on illustrative energy sources

The proposed description lists illustrative energy sources (coal, natural gas, nuclear, hydropower, solar and wind) but does not mention biomass and geothermal. The UK's largest biomass generator produces approximately 99.8% renewable electricity from biomass, pumped storage hydro and hydro, contributing approximately 5% of UK electricity demand. Under the proposed description, this entity could reasonably question whether it is clearly within IF-EU scope given the limitation of cited illustrative examples of energy sources. The ISSB should consider including biomass (bioenergy) and geothermal among the sources of illustrative energy sources.

Integrated business activities structure of the Standard

The IF-EU SASB Standard is designed to apply across the full electricity value chain, encompassing generation, transmission, distribution, storage and retail activities. In practice, however, only a limited number of entities operate as fully vertically integrated businesses spanning this entire value chain.

Our sample of UK entities illustrates this point. Only two entities demonstrate vertically integrated operations consistent with the structure envisaged by the Standard and therefore would likely find most topics relevant, subject to their own assessments of risks and opportunities. In addition, one dual-listed conglomerate largely aligns with the value chain except for retail and nuclear related metrics, albeit through a portfolio of distinct businesses operating across multiple jurisdictions rather than through a single integrated structure. The remaining entities are predominantly either pure-play operators focused on specific segments, such as generation or retail or partially integrated entities, as is the case with certain island operators.

This integrated approach contrasts with the structure adopted by the ISSB in the Oil & Gas sector standards, where discrete SASB Standards have been developed for each major segment of the value chain. For example, separate standards exist for Oil & Gas Exploration & Production, Midstream, Refining & Marketing, and Services.

The TAC recognise that the ISSB has indicated that stakeholder feedback informed the development of the current structure, and acknowledges the inherent complexity of designing an international standard that accommodates diverse industries and market configurations. However, there appears to be scope to enhance the clarity of application through more explicit guidance within the technical protocols. For example, the Agricultural Products SASB Standard provides clearer delineation by specifying certain topics, such as Land Use & Ecological Impacts and Labour Conditions, apply specifically to entities engaged in direct farming activities. This approach provides clarity and enhances consistency in application. Introducing similar guidance within IF-EU would support entities with pure-play or partially integrated operations in identifying relevant disclosures, while also enhancing comparability and decision-usefulness for investors.

Biomass and geothermal omission from illustrative energy source list

The proposed industry description lists illustrative energy sources (coal, natural gas, nuclear, hydropower, solar and wind) without reference to biomass, bioenergy or geothermal. This creates ambiguity as to whether IF-EU is relevant for biomass-to-power entities and for geothermal generators in jurisdictions where geothermal is significant. Therefore, the TAC recommends that the ISSB:

either add biomass, bioenergy and geothermal to the illustrative list of energy sources, or
re-phrase the sentence listing energy sources in the industry description to read '...coal, natural gas, nuclear, hydropower, solar, wind and other energy sources' to make clear the list is non-exhaustive. Either approach would remove the ambiguity without altering the scope of the standard.

Applicability of capacity metrics to interconnector-based supply model

The proposed installed capacity metrics (IF-EU-110a.5 and IF-EU-110a.6) require entities to disclose total installed and planned capacity, respectively, disaggregated by energy source and storage type. These metrics are designed for entities whose capacity profile reflects owned or controlled generation assets such as coal, gas, nuclear, wind, solar and are directly linked to the capital strategy and transition risk disclosures under IF-EU-110a.7. 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 or purchase capacity accessed via interconnectors and other cross-border infrastructure. Applying IF-EU-110a.5 as currently drafted would result in such entities reporting installed capacity figures (typically comprising contingency or backup generation) that systematically understate their actual supply capacity. This approach omits the interconnector infrastructure capacity, which represents their primary operational and financial risk exposure equivalent. This is not an isolated structural anomaly limited to UK island operators, but also arises in certain other jurisdictions where interconnectors represent the primary source of supply capacity or proxy to generation assets portfolio.

The ISSB could consider amending the IF-EU-110a.5 technical protocol to clarify that entities for which contracted capacity via interconnectors constitutes the principal proxy for installed generation capacity should disclose their maximum import or transfer capacity (in MW/GW) by source jurisdiction in lieu of, or alongside, installed owned generation capacity. The technical protocols can also be improved to require such entities to cross-reference the nature, term and counterparty disclosures of their primary supply contract, given that the sustainability-related risks and opportunities associated with the supply contract and interconnector infrastructure are the direct equivalent of those associated with owned or controlled generation assets portfolio.

Q3 (b) – Do you agree that the proposed disclosure topics in the Electric Utilities & Power Generators SASB Standard would accurately identify the sustainability-related risks and opportunities that are reasonably likely to affect the financial condition or operating performance of a typical entity within this industry? Why or why not?

Q3 (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 to assess and price the identified sustainability-related risks and opportunities? Why or why not?

Preliminary response position:

Broadly agree with the proposed disclosure topics and metrics overall, with suggested improvements.

Rationale:

The proposed new disclosure topics (Ecological Impacts, Community Relations, & Rights of Indigenous Peoples, Employee Recruitment Development & Retention, and Supply Chain Management) address sustainability-related risks for entities in the electricity sector. The revised GHG topic introduces decision-useful capacity and capital strategy metrics directly relevant to the UK's Clean Power 2030 programme and RIIO-T3 (Ofgem's regulatory framework) investment pipeline. The revised Operational Resilience topic reasonably captures cybersecurity and physical climate risk. However, there remain opportunities for the ISSB to further improve certain topics, metrics and technical protocols to enhance clarity, comparability and decision-usefulness of the disclosures. Specific recommendations are set out in the table below.

1.2 GHG Emissions & Energy Resource Planning (retained disclosure topic)

Nature of proposed amendment

Disclosure topic description is unchanged in the Exposure Draft.

New metrics added: IF-EU-110a.5: Installed capacity (MW) by energy source and storage type, aligned to GHG boundary. IF-EU-110a.6: Planned capacity (MW) including investments, disposals, uncommitted plans and retirements; short/medium/long-term (IFRS S2 10(d)). IF-EU-110a.7: Narrative on how transition risks/opportunities affect capital strategy, covering 'regulation, trade-offs (reliability/affordability/resilience), policymaker engagement, transition plans (IFRS S2 14(a)(vi)), and GHG targets.

ISSB's rationale for changes (per Basis for Conclusions)

BC146-BC147 explain that amendments to the GHG topic are intended to respond to user demand for more decision-useful information on climate transition risks and opportunities, particularly in relation to current and planned generation capacity.

BC152-BC154 set out the rationale for introducing IF-EU-110a.7 (which requires discussion of how transition risks and opportunities influence capital deployment) as an industry-specific application of IFRS S2, designed to provide narrative context to quantitative capacity metrics (IF-EU-110a.5 and 110a.6). The metric is framed as transition-focused, covering capacity plans, low-carbon procurement, GHG targets, and transition plans.

BC154 further explains the deletion of IF-EU-110a.3 on the basis of duplication with IF-EU-110a.7, although this creates inconsistency with other SASB Standards that retain standalone GHG targets metrics.

BC150 clarifies the revision of IF-EU-110a.2 to include Scope 2 and Scope 3 Category 3 emissions, highlighting their significance for both T&D (line losses) and retail entities (purchased electricity) respectively. This also reflects their usefulness in assessing regulatory exposure and responsiveness to demand for low-carbon energy.

Deleted metrics include:

IF-EU-110a.3: discussion and analysis of long and short term GHG emissions strategy/targets/performance removed and incorporated into 110a.7 (which is qualitative metric discussing how climate risks influence capital decisions).

Revised metrics include:

IF-EU-110a.2: Revised to cover GHG emissions associated with (1) T&D losses and (2) net electricity purchased. Per the technical protocol, T&D losses are classified as Scope 2 and net electricity purchased is classified as Scope 2 (for retail entities purchasing electricity). IF-EU-110a.1: Aligned to IFRS S2 29(a) and removed US-specific reference and introduces 'percentage subject to emissions reporting regulations'.

Findings from UK company review

All companies reviewed, whether applying SASB Standards or not, disclose GHG emissions, driven primarily by existing UK climate reporting requirements.

The FTSE 100 T&D company reports sulphur hexafluoride (SF₆) emissions arising from its use as an insulating and arc-quenching gas in high-voltage electrical equipment. SF₆ is a highly potent greenhouse gas, with a global warming potential approximately 23,500 times that of CO₂ and an atmospheric lifetime of around 3,200 years. The specific disclosure is required by the UK regulator Ofgem.

Biogenic CO2 gap – significant issue for biomass generators

The GHG Protocol Corporate Standard (Chapter 9, Reporting GHG Emissions) requires biogenic CO2 emissions to be reported separately from Scope 1, 2 and 3 totals, typically as a distinct disclosure outside the main inventory (e.g. a memo item or appendix-style presentation). UK biomass generators follow this approach and do not include biogenic emissions within their Scope 1 emissions, but as an appendix in line with the GHG Protocol Corporate Standard principles. This satisfies TCFD and SECR disclosure requirements.

As an example, a major UK biomass operator combusting approximately 7.7 million tonnes of compressed wood pellets annually results in approximately 14,085 ktCO2e of direct biogenic CO2 emissions. Under the GHG Protocol Corporate Standard, only approximately 301 ktCO2e (non-biogenic emissions i.e emissions from other combustion outside biomass) would be reported in Scope 1 (approximately 1/47th of the total CO2 released to the atmosphere). In the same manner, an LSE/Hong Kong dual-listed conglomerate has a diversified energy mix that also includes biomass (though an insignificant component of its energy mix) and currently apply SASB IF-EU, reporting biogenic emissions outside of its Scope 1 emissions.

In March 2026, the ISSB's Transition Implementation Group (TIG) considered whether biogenic emissions from biomass plant operators should be included in Scope 1, 2 and 3 under IFRS S2, despite the GHG Protocol zero-rating disclosure approach. The TIG determined that IFRS S2 requires the GHG Protocol for measurement purposes only, rather than for disclosure. As a result, the TIG decided that biogenic emissions would be disclosed in accordance with IFRS S2 requirements, effectively leading to their inclusion within Scope 1 for biomass operators applying IFRS S2. It noted that an entity may consider applying disaggregation, as needed, to provide the details of its Scope 1 emissions to facilitate comparability.

The TIG's interpretation of biogenic emissions reporting under IFRS S2 implies that a comparable biomass operator applying SASB Standards on a standalone basis (i.e. not as supporting material to IFRS S2), or reporting under TCFD or UK SECR, would instead follow GHG Protocol disclosure principles and exclude these emissions from Scope 1. This gives rise to potentially material information asymmetry between otherwise comparable entities reporting under IF-EU.

Furthermore, ESRS E1 (Disclosure Requirement E1-6 and related Application Requirements)) explicitly requires biogenic CO2 emissions from biomass combustion to be disclosed separately from Scope 1 – a disclosure and presentation approach that aligns with the GHG Protocol principles but diverges from IFRS S2. Thus, an additional interoperability gap arises for biomass-intensive generators reporting across IFRS S2, SASB and CSRD/ESRS standards.

Other research findings

DESNZ's Clean Power 2030 Action Plan of December 2024 sets out ambitious deployment targets of 43 to 50 GW of offshore wind, 27 to 29 GW of onshore wind, and 45 to 47 GW of solar capacity by 2030. Delivering this pathway will require a significant expansion of the overall electricity system, based on modelling undertaken by the National Energy System Operator. Ofgem's Regulatory Framework (RIIO T3 Final Determination), published in December 2025 as part of its Revenue = Incentives + Innovation + Outputs (RIIO) regulatory framework for setting price controls for monopoly energy network companies, provides approximately £28 billion of upfront investment within a wider pipeline of around £90 billion over the period 2026 to 2031.

This scale of capital investment, alongside the rapid build out of generation capacity required under the Clean Power 2030 pathway, further reinforces the investor relevance of the proposed and planned capacity related metrics: IF EU 110a.5 and IF EU 110a.6 respectively, as well as capital strategy disclosures under IF EU 110a.7. [Appendix A1.4]

Suggested response letter comments for the TAC's consideration

Biogenic CO2 emissions disclosure treatment

As highlighted in the company review findings summarised above, biogenic emissions may be reported inconsistently under IF-EU depending on whether entities apply IF-EU on a standalone basis or as supporting guidance to IFRS S2. Entities applying IF-EU on a standalone basis are likely to follow the GHG Protocol principles for both measurement and disclosure. Under this approach, biogenic emissions are excluded from Scope 1 emissions and instead disclosed separately, for example, as a memorandum item or an appendix. This treatment is broadly aligned with the approach adopted under ESRS. By contrast, entities applying IF-EU as guidance material to IFRS S2 would use the GHG Protocol Corporate Standard for measurement purposes only, while IFRS S2 governs disclosure. In practice, this results in biogenic emissions being included within Scope 1 emission totals. This divergence notably creates a material information inconsistency between economically similar entities applying the same IF-EU Standard.

To address this issue, the ISSB could consider revisiting the relevant requirements. In particular, the technical protocol for IF-EU-110a.1 could be amended to explicitly require the inclusion of biogenic emissions within Scope 1 emissions for disclosure purposes. This would ensure all entities apply the standard follow the same disclosure approach.

1.3 Air Quality (retained disclosure topic)

Nature of proposed amendment

The existing Air Quality topic is retained with targeted metric revisions. The proposed amendment to IF-EU-120a.1 aligns it with GRI 305-7 by: (a) removing the existing separate lead (Pb) and mercury (Hg) sub-disclosures in favour of the simpler combined pollutant categories used in GRI 305-7; (b) adding particulate matter; and (c) retaining the requirement to report the percentage of each pollutant emitted in or near areas of dense population.

ISSB's rationale for changes (per Basis for Conclusions)

BC156: The ISSB explains that the air quality metric amendments respond to initial user feedback that disclosing lead and mercury separately provides too much detail to be useful at the pollutant category level. The change also aligns pollutant categories with the broader, simpler set provided in GRI 305-7.

Findings from UK company review

Among the seven entities reviewed, air quality disclosure varies significantly with generation mix. A UK biomass and renewable electricity generator reports stack emissions under environmental permits, but not in IF-EU-120a.1 format. A small island utility entity relying on approximately 94% imported electricity and solar generation does not report air quality. An infrastructure conglomerate with global renewable generation assets reports zero combustion air pollutant emissions. Thus, three of the seven entities would disclose zero or near-zero figures, indicating limited applicability of air quality to their business models.

Interoperability findings

The revised IF-EU-120a.1 metric categories (NOx, SOx, PM10/PM2.5, hazardous air pollutants) align with GRI 305-7. UK entities reporting under GRI 305-7 will be able to cross-reference, reducing dual preparation burden.

Suggested response letter comments for the TAC's consideration

Air quality metric applicability for non-combustion generators

The technical protocol for IF-EU-120a.1 does not confirm that the air quality topic is inapplicable to entities with no combustion-based generation. Pure-play wind, solar, run-of-river hydro generators and T&D-only network operators produce zero or negligible quantities of the listed air pollutants. The ISSB could consider adding a single sentence to the technical protocol confirming that the metric applies to entities with combustion-based generation activities, and that entities without combustion generation should state inapplicability. This would be consistent with the approach taken in the Agricultural Products Standard where entities with direct farming activities have distinctly identifiable topic and metrics.

1.4 Ecological Impacts (new disclosure topic)

Nature of proposed amendment

This new disclosure topic introduces three metrics:

IF-EU-160a.1: Total spatial footprint (km²), disaggregated by (1) area occupied, (2) disturbed and (3) restored. Aligned with TNFD LEAP Locate step core metric C1.0
IF-EU-160a.2: Percentage of total spatial footprint in or near environmentally sensitive locations. Aligned with TNFD Locate step sensitivity guidance referencing IUCN, RAMSAR and UNESCO databases.

IF-EU-160a.3: Description of environmental management policies and practices for operational facilities.

ISSB's rationale for changes (per Basis for Conclusions)

BC163-BC165: Ecological Impacts added because electricity sector activities can affect various aspects of the natural environment and the industry's physical footprint is expected to grow to meet increasing electricity demand and to facilitate the transition to more diverse energy sources' creating regulator and reputational risks.

Findings from UK company review

Among the entities reviewed, none currently reports total operational spatial footprint (km²) or the percentage of assets in or near environmentally sensitive locations in the structured format required by IF-EU-160a.1 and IF-EU-160a.2. However, some entities report related information in narrative or qualitative form including biodiversity net gain commitments, ISO 14001 environmental management certification and TNFD pilot participation but this falls short of the quantitative Geographic Information System (GIS)-based metric required by IF-EU-160a.1.

One entity discloses total land owned (26.3 km²) in its ESG report, which is the closest approximation to IF-EU-160a.1 found in the review.

Infrastructure and network operators show some partial readiness, with site-level tools (e.g., DEFRA biodiversity metric) and established processes, but lack group-level spatial data capabilities.

Overall readiness for the new Ecological Impacts topic is relatively low across the reviewed entities, with the TNFD pilot participation by the largest UK T&D group suggesting a development trajectory rather than current compliance readiness. Most companies will require significant development of GIS capabilities and methodological approaches to meet IF-EU spatial footprint requirements.

Interoperability findings

IF-EU-160a.1/2 directly implement TNFD core metric C1.0 (total spatial footprint) and TNFD Locate step sensitivity guidance. TNFD published Additional Sector Guidance for Electric Utilities and Power Generators in June 2024, providing sector-specific recommended metrics directly mapped to IF-EU-160a.1/2.

Suggested response letter comments for the TAC's consideration

The technical protocols for metric IF-EU-160a.3 (requiring disclosure of environmental management policies and practices for operational facilities) and technical protocol for metric IF-EU-210a.1 (requiring disclosure of processes to manage risks and opportunities related to community rights and interests) reference the International Finance Corporation's (IFC) Performance Standards on Environmental and Social Sustainability (2012). However, this version of the IFC Standards is likely to be out of date soon as the IFC is currently undertaking a review of its Performance Standards, with revised standards expected between 2026 and 2028. Metrics IF-EU-160a.3 and IF-EU-201a.1 as currently drafted lock entities into a reference a version of standards that may be superseded potentially before the revised IF-EU is fully implemented.

The 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.

1.5 Community Relations & Rights of Indigenous Peoples (new disclosure topic)

Nature of proposed amendment

Disclosure topic description is newly introduced in the Exposure Draft. New metrics added:

IF-EU-210a.1: Processes used to manage risks and opportunities related to community rights and interests (aligned with GRI 413).
IF-EU-210a.2: Number of non-technical delays and total days idle due to community or permitting issues (excluding labour and technical delays).
IF-EU-210a.3: Percentage of operations in or near Indigenous Peoples' land (within 5 km), aligned with GRI 411 and international definitions (UNDRIP, ILO 169).
IF-EU-210a.4: Description of engagement and due diligence processes relating to Indigenous Peoples' rights, including FPIC (aligned with IFC Performance Standard 7).

ISSB's rationale for changes (per Basis for Conclusions)

BC166-BC168: Community Relations disclosure topic has been proposed because sector activities affect communities near operations and entities proactively engaging with Indigenous Peoples may be better positioned to mitigate legal, operational and reputational risks.

Findings from UK company review

None of the entities reviewed currently report non-technical delays or days idle in line with IF-EU-210a.2, indicating that this is a new metric and that overall readiness for quantitative reporting is low. However, a FTSE 100 T&D and integrated utilities entity demonstrates more advanced community engagement practices, including extensive consultation processes, project redesign based on stakeholder input and community investment programmes. While not currently quantified, these provide a strong foundation for IF-EU-210a.1 qualitative disclosures.

Infrastructure-heavy projects, particularly large electricity transmission developments and Nationally Significant Infrastructure Projects (NSIPs) requiring Development Consent Orders in England and Wales clearly experience permitting and community-related delays, suggesting material underlying exposure that entities understand qualitatively but do not currently track in a format suited to quantitative IF-EU-210a.2 disclosure. A FTSE 100 T&D entity's published NSIP project timelines and community consultation records illustrate the type of delay currently reported voluntarily but would need to be adapted for the proposed disclosure metric IF-EU-210a.2.

Retail-focused and non-infrastructure entities have low exposure and limited relevance, particularly for project delay-related metrics.

On community relations more broadly, UK domestic operations engage actively with local communities even in the absence of any indigenous peoples framework. A UK biomass generator maintains a formal community liaison programme covering its large power station site and surrounding areas, and discloses community investment spend and a dedicated nature reserve on its site both consistent with IF-EU-210a.1 qualitative disclosure expectations. A FTSE 100 T&D entity publishes detailed stakeholder engagement records for each major infrastructure project, including responses to objections and project modifications made as a result of community input.

Entities with international operations show higher readiness for Indigenous Peoples-related metrics (IF-EU-210a.3/.4), where consent processes and land rights are already embedded in applicable regulatory frameworks. The biomass plant operator, which sources wood pellets from North America, publishes supplier engagement policies explicitly referencing Free, Prior and Informed Consent (FPIC) processes with First Nations communities in regions of procurement, being the most substantive IF-EU-210a.3 adjacent disclosure found in the review. An infrastructure conglomerate with electricity distribution operations in Australia is subject to the Native Title Act 1993, requiring formal engagement with Traditional Owners for network infrastructure on or near native land. By contrast, Community Relations metrics IF-EU-210a.3 and IF-EU-210a.4 are not applicable to purely UK domestic operations given the absence of a domestic indigenous peoples legal framework.

ILO Convention No. 169 on Indigenous Peoples and UK applicability

The UK has not ratified ILO Convention No. 169 (1989). The UK government's stated position is that the Convention cannot be implemented as the UK has no indigenous peoples to whom it applies. This means IF-EU-210a.3 and IF-EU-210a.4 are inapplicable to UK domestic electricity operations. For entities with international operations, the position differs, for example, a UK FTSE 100 T&D company operates in the New England and New York where Native American nations hold treaty rights. An LSE/Hong Kong dual listed conglomerate with Australian and New Zealand electricity distribution businesses operates under Australia's Native Title Act 1993 and New Zealand laws for Indigenous peoples respectively.

The technical protocol defines Indigenous Peoples' land by reference to Article 33 of the 2007 UN Declaration on the Rights of Indigenous Peoples and ILO Convention 169. Several UK-listed entities and their UK domestic operations specifically operate in jurisdictions where ILO Convention 169 has not been ratified and where there is no domestic legal framework equivalent to indigenous peoples' rights as defined in international law. For these entities, applying IF-EU-210a.3 (percentage of operations in or near Indigenous Peoples' land)) to their UK domestic operations produces a result of zero by definition, not because of any genuine assessment, but simply because the legal framework on which the metric rests does not exist in the jurisdiction. This matters in the opposite direction too. The company review identified that the global infrastructure conglomerate's electricity distribution businesses in Australia operate in areas with formal Aboriginal and Torres Strait Islander native title rights under the Native Title Act 1993, making IF-EU-210a.3 and 210a.4 directly applicable to those operations, but the same group's UK operations produce zero under the same metric for entirely different reasons. Group-level disclosure will obscure this distinction entirely.

[See Appendix A1.2 for ILO Convention 169 ratification status]

Suggested response letter comments for the TAC's consideration

Non-technical delay metric contradiction

The technical protocol for metric IF-EU-210a.2 which requires (1) the number of non-technical delays and (2) the total days idle, contains an internal contradiction that will make consistent application challenging. Paragraph 1.1 defines non-technical delays as 'shutdowns and project delays resulting from pending regulatory permits or other delays resulting from community-related risks such as protests.' This definition therefore explicitly includes regulatory permitting delays within scope. Paragraph 3 then excludes 'technical situations unrelated to community-related risks (permitting delays)' from the disclosure. These two paragraphs directly conflict. Paragraph 1.1 brings permitting delays in, and paragraph 3 takes them out, but only where they are unrelated to community-related risks. In practice, permitting delays and community-related risks may be inseparable. In the UK, planning applications for electricity infrastructure are routinely delayed by community objections, legal challenges and judicial review proceedings that are processed through the permitting system. A planning inspector's delay caused by a judicial review brought by a community group is simultaneously a permitting delay and a community-related delay. An entity cannot determine from the current protocol text whether to include or exclude such a delay.

A review of UK company reports indicates that this is not hypothetical. Major UK transmission infrastructure projects (including new overhead line routes) have experienced extended consent timelines directly attributable to community opposition channeled through the planning and permitting system.

The ISSB could consider amending paragraph 3 to resolve the contradiction by clarifying that the exclusion applies only to delays caused by purely administrative or procedural regulatory processes that are independent of community opposition. For example, a regulator's standard statutory determination period running its course with no challenge. Delays arising from planning objections, judicial review, legal challenge or community opposition that are processed through a permitting or regulatory system remain in scope. A worked example in the technical protocol would significantly improve consistent application.

Jurisdictional applicability of Indigenous Peoples metrics

Consistent with the jurisdictional variations on Indigenous Peoples described under ILO Convention No. 169 on Indigenous Peoples and UK applicability above, the ISSB could consider adding a note to the IF-EU-210a.3 and 210a.4 technical protocols clarifying that for operations in jurisdictions without a domestic legal framework recognising indigenous peoples' rights as defined by ILO Convention 169, 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.

For entities with operations across multiple jurisdictions, disaggregation by jurisdiction may be necessary to prevent group-level results masking significant exposures in relevant jurisdictions.

1.6 Energy Affordability (retained disclosure topic)

Nature of proposed amendment

Three existing metrics are deleted:

IF-EU-240a.1 (average retail electric rate by customer type deleted as not internationally applicable);
IF-EU-240a.3 (residential customer disconnections and reconnection rate); and
IF-EU-240a.4 (discussion of external factors affecting customer affordability).

Two new metrics are introduced: IF-EU-240a.5 qualitative description of affordability-related risks, opportunities and management strategies, with the technical protocol listing limiting factors including median household income and poverty rates; and IF-EU-240a.6 number of active and eligible participants in affordability programmes, disaggregated by residential, commercial and industrial customers.

ISSB's rationale for changes (per Basis for Conclusions)

BC170: All three metrics were deleted on the basis that they do not capture a sufficiently broad variety of related risks and opportunities, and the strategies used to manage them. For IF-EU-240a.3, the main justification given is that customer electric disconnections are seasonally prohibited in some jurisdictions. No substantive rationale other than stakeholder feedback is provided for the deletion of IF-EU-240a.4.

BC172-BC174: In amending the Energy Affordability topic, the ISSB considered the forthcoming IFRS Accounting Standard on Regulatory Assets and Regulatory Liabilities, intending IF-EU-240a.5 to complement those disclosures.

Findings from UK company review

The entities reviewed reveal strong qualitative readiness for IF-EU-240a.5 but varied quantitative readiness for IF-EU-240a.6, reflecting the structural divide between entities with direct customer billing relationships and those without. The retail-focused integrated energy supplier demonstrates the strongest overall affordability disclosure in the review: a £90 million Winter Affordability Scheme, an Energy Fund, a Winter Debt Commitment, and 7.99 million customer accounts with an 83% customer happiness score. Its existing programme participation data provides a near-complete foundation for IF-EU-240a.6.

A FTSE 100 T&D and integrated utility has strong affordability performance in its US retail operations (new low-income customers enrolled in tiered discount programmes) and strong UK narrative (2.6 million Priority Services Register customers, £13.8 million Energy Affordability Fund committed 2025-28; 288,101 households supported cumulatively since 2022). However, its UK transmission and distribution businesses have no direct retail billing relationship. Disconnection and programme participation data apply only to the US retail segment, illustrating the structural inapplicability of affordability metrics to T&D-only operators in jurisdictions like the UK.

An infrastructure conglomerate reports Priority Services Register data at scale across its UK electricity distribution subsidiary (3.1 million customers) and gas distribution subsidiary (11,700 PSR referrals), directly supporting IF-EU-240a.6 participant counts.

A FTSE 100 integrated utility reports 1 million customers on its Priority Services Register, showing a key foundation for IF-EU-240a.6, alongside strong affordability narrative, including price protection measures for its Irish electricity customers.

A small island utility operates its own Think Customer programme, but operates outside the UK regulatory regime and without the price-capped affordability framework that drives most UK mainland disclosure.

UK energy debt and affordability crisis:

UK domestic energy debt reached £4.43 billion in June 2025, up 71% since 2023, rising further to £4.55 billion by Q4 2025. With zero forced disconnections recorded since Q1 2023 due to Ofgem regulatory restrictions, smart prepayment meter self-disconnection has become the primary quantitative proxy for affordability stress which is a good indicator that the deleted IF-EU-240a.3 was designed to capture. This supports the need for the ISSB to consider reinstating IF-EU-240a.3.

Ofgem's Debt Relief Scheme (launched early 2026) expected to write off between £312 million and £473 million for between 280,000 and 400,000 eligible accounts illustrates the type of programme-level data reportable under IF-EU-240a.6 and IF-EU-240a.5. Hence the relevance of these new proposed metrics. [Source: Ofgem, Debt and Arrears Indicators (Q4 2025); Ofgem, Debt Relief Scheme Impact Assessment (November 2025).]

DESNZ Annual Fuel Poverty Statistics 2026:

DESNZ Annual Fuel Poverty Statistics in England 2026 (2025 data, published 26 March 2026) report 2.36 million households (9.4%) in fuel poverty under the LILEE metric in 2025, with an aggregate fuel poverty gap of £896 million and an average gap of £379 per household. In 2025, 30.4% of households (7.63 million) spent more than 10% of income on energy. This confirms the materiality of IF-EU-240a.6 participant count disclosures and reinforces the case for reinstating IF-EU-240a.4, given that these figures reflect the direct consequences of the commodity price movements and external supply disruptions that IF-EU-240a.4 required entities to address. [Source: DESNZ, Annual Fuel Poverty Statistics in England, 2026 (26 March 2026)].

Suggested response letter comments for the TAC's consideration

Energy affordability metrics

The TAC recommends that the ISSB consider the following:

Reinstating the deleted metric IF-EU-240a.3 (disconnection metric) as it is the only quantitative, directly comparable affordability stress indicator for affordability. Its deletion removes an investor-useful signal at a time when the UK energy arrears have reached £4.43 billion and 564,588 customers are self-disconnecting quarterly.
Reinstating metric IF-EU-240a.4 (impact of external factors on customer affordability) is an indicator of external factors addressing commodity price movements, geopolitical supply disruptions and climate events, all of which have dominated UK energy affordability since 2021.

1.7 Workforce Health & Safety (retained disclosure topic)

Nature of proposed amendment

The disclosure topic is maintained. However, metrics are revised as follows. IF-EU-320a.1 now capture (1) number of fatalities and (2) total recordable incident rate for (a) employees and (b) non-employee workers; (3) average hours of health, safety and emergency response training. This replaces the single Total recordable Incident Rate (TRIR), the fatality rate and the near miss frequency rate (NMFR)

A new narrative metric IF-EU-320a.2 is added, requiring description of management systems used to foster a safe working environment.

ISSB's rationale for changes (per Basis for Conclusions)

BC175: Notes that the amendments reflect the high-hazard nature of electricity network construction and maintenance, including working at heights, heavy machinery operation and electrocution risk combined with heightened public and regulatory scrutiny due to the sector's monopoly characteristics.

BC177: States that IF-EU-320a.2 (narrative) was added following research and feedback indicating that disclosures on leading indicators and safety training provide decision-useful context alongside fatality and incident metrics.

Findings from UK company review

The review reveals wide variation in current readiness, with one entity closely aligned to the proposed format. A FTSE 100 T&D and integrated utility has the most complete Workforce Health & Safety disclosure in the review (considering its 6 years of consecutive reporting under current IF-EU): TRIR (the current metric proposed for deletion), fatality rate and NMFR (also proposed for deletion) separately reported for employees and contractors precisely the proposed IF-EU-320a.1 structure. The entity has also recently changed its reporting basis from 200,000 to 100,000 hours (the ILO/UK HSE basis) showing the relevance of the current deletion of the US focussed 200 000hours from the Exposure Draft. Considering closeness of the deleted TRIR and NMFR metric to be replaced with number of fatalities and total recordable incident rate, it should be fairly easy to adapt the new metrics from the existing ones.

A UK biomass generator reports TRIR, NMFR and fatality rate, using 'NMHIR' (Near Miss and Hazard Identification Rate). As NMFR has now been proposed for removal the company would need to adapt this to the new metric which is number of total fatalities.

A FTSE 100 integrated utility reported two fatalities during the review period in a manner consistent with the revised IF-EU-320a.1 metric. This apparent alignment, independent of the proposed changes, indicates that market expectations may already be converging around such disclosures, supporting the relevance of the proposed metric. An infrastructure conglomerate reports LTIR on a 100,000-hour ILO/Australasian basis, ISO 45001 coverage at 50.9% of employees.

A small island utility reports a single lost time injury in its annual report but not TRIR, NMFR or fatality rate in IF-EU-compatible format

Suggested response letter comments for the TAC's consideration

The Secretariat suggest that the TAC support the proposed amendments.

1.8 Employee Recruitment, Development & Retention (new disclosure topic)

Nature of proposed amendment

This new disclosure topic introduces two metrics: IF-EU-330a.1: Description of recruitment, development and retention risks and opportunities and strategies to manage them. Aligned with GRI Employment Exposure Draft (EMPL 3, EMPL 7) and GRI Training and Education Exposure Draft (TRED 1, TRED 2). IF-EU-330a.2: (1) Voluntary and (2) involuntary employee turnover rate for (a) all employees and (b) occupational categories with a skill shortage. Entity self-defines relevant skill shortage categories and discloses the assessment method and any occupational classification standard used (technical protocol paras.2.1-2.2).

ISSB's rationale for changes (per Basis for Conclusions)

BC178-BC182: Employee Recruitment Development & Retention has been proposed because 'labour and skills shortages in this industry can pose operational risks to entities, such as infrastructure failure, cybersecurity risks, supply chain disruption, project delays and increasing recruitment costs.' The ISSB considered specifying occupational categories but concluded entity self-definition 'would better meet users' information needs' given the diversity of entities in the industry.

Findings from UK company review

The entity review reveals a consistent partial readiness pattern across all seven entities. No entity currently discloses voluntary and involuntary turnover rates disaggregated by skill shortage occupational category as required by IF-EU-330a.2. However, the quality of underlying people data varies significantly.

An infrastructure conglomerate with international electricity distribution operations is closest to IF-EU-330a.2 compliance, disclosing voluntary and involuntary turnover rates disaggregated by gender, age group and region, requiring only the addition of an occupational category dimension.

A UK biomass generator discloses both voluntary and involuntary turnover rates separately. The only entity in the review to disaggregate the two, providing some close alignment tor IF-EU-330a.2 format.

A FTSE 100 T&D and integrated utility demonstrates strong qualitative foundations for IF-EU-330a.1, with a workforce of over 30,000, 80% employee engagement and an explicit workforce expansion programme.

For IF-EU-330a.1 qualitative disclosures, readiness is generally higher across the review, with most entities publishing people strategies, apprenticeship programmes and skills investment narratives sufficient to form the basis of the required disclosure.

The common skill shortage categories identified across the review are high-voltage power and transmission engineers, smart meter and digital infrastructure technicians, offshore wind installation engineers and Bioenergy with Carbon Capture and Storage specialists, confirming that the skill shortage categorisation question is relevant for UK electricity sector entities.

Other UK research findings

Energy & Utility Skills (EU Skills) Workforce Demand Estimates 2024–2030 (September 2024) project the UK energy and utilities sector requires 277,000 vacancies to be filled by 2030, equivalent to approximately 50% of the current sector workforce. The power sub-sector alone is forecast to grow from 158,600 to 290,300 employees (83% increase), requiring 156,900 new entrants. Key shortage categories include: offshore wind installation and maintenance technicians (requiring 39,000 additional workers, up 223%); high-voltage cable jointers and overhead line workers for Ofgem economic framework delivery; power engineers for new build transmission infrastructure; battery storage engineers; and digital infrastructure and cybersecurity specialists.

Suggested response letter comments for the TAC's consideration

Employee skill shortage categorisation

The technical protocol for metric IF-EU-330a.2 (requiring disclosure of voluntary and involuntary employee turnover rates, for both the total workforce and roles experiencing skill shortages) defines an occupational category as having a skill shortage 'if the entity's prospects could reasonably be expected to be affected by having fewer employees in that category than necessary.' The entire determination of which categories qualify is left to the entity's judgement with no objective external reference point and no minimum list of categories to consider. This creates two distinct problems. First, an entity facing genuine and documented skill shortages, such as in high-voltage cable jointing, confirmed independently by EU Skills industry workforce data could exclude that category from IF-EU-330a.2 disclosure if its management determines the shortage does not affect 'prospects' by its own internal definition. Second, two entities facing identical workforce dynamics could disclose entirely different categories, making the metric challenging for investor comparison. The purpose of giving investors visibility of skill shortage risk is undermined if entities can define their own shortage categories without reference to any external standard or benchmark.

The ISSB could consider improving the technical protocols by requiring, at a minimum, the inclusion of any occupational categories identified as being in shortage within an official government or recognised industry labour market assessment relevant to the entity's jurisdiction. For UK-based entities, this would include, for example, assessments such as HM Government's Clean Energy Jobs Plan and relevant EU sectoral workforce data where applicable. Entities may include additional occupational categories beyond this baseline requirement; however, they should not exclude categories that are objectively identified as being in shortage in any relevant, recognised assessment.

1.9 Supply Chain Management (new disclosure topic)

Nature of proposed amendment

A new Supply Chain Management disclosure topic is introduced with two metrics. IF-EU-430a.1: requires a qualitative description of processes to manage sustainability risks in the supply chain, including supplier codes of conduct, Human Rights Due Diligence (HRDD) processes, and audit practices. IF-EU-430a.2: requires the proportion of high-risk suppliers independently audited or verified in the past three years, with disclosure of identified non-conformances and corrective actions. High-risk suppliers are defined as those exposed to elevated risks of human rights violations (e.g. forced or child labour), adverse impacts on local communities (including Indigenous Peoples), or serious breaches of law or supplier codes of conduct.

ISSB's rationale for changes (per Basis for Conclusions)

BC186-BC188: Supply Chain Management has been proposed because entities are competing for scarce critical materials and equipment. They might face supply chain risks arising from sustainability-related issues through the concentration of critical materials, some of which are in regions that have limited governance and regulatory structures or are subject to geopolitical tensions.

Findings from UK company review

Review of company reports reveal partial readiness for this topic and metrics as a consistent pattern across all entities. All entities report the Modern Slavery Act 2015 annual transparency and compliance statements. This provides a partial qualitative foundation for IF-EU-430a.1. However, the structured HRDD process description and quantitative supplier audit coverage required by IF-EU-430a.2 are absent across all entities and no indicative information showing proximity.

A FTSE 100 T&D and integrated utility operates the most developed supply chain governance across the review: 36,285 global suppliers, a Supplier Code of Conduct, ESG screening embedded in procurement and a measurable target of 29.4% reduction in supplier-specific Scope 3 carbon intensity. Supplier audit coverage as a percentage is not currently reported hence this is entirely a new data point with limited foundation.

A retail-focused integrated energy supplier operates a supplier code of conduct, Modern Slavery statement, and has begun requiring carbon reduction commitments from key suppliers, but percentage of high-risk suppliers audited is not quantified.

For a UK FTSE 250 biomass generator, the most material supply chain sustainability issue is not conventional human rights due diligence (HRDD), but the certification of biomass sourcing. The company currently provides voluntary disclosures on certification coverage, including the Sustainable Biomass Program (SBP), Forest Stewardship Council (FSC), and Programme for the Endorsement of Forest Certification (PEFC), as well as deforestation-free verification and fibre origin. These disclosures are relevant and decision-useful for investors assessing biomass operators. However, none of these metrics are reflected in the proposed IF-EU supply chain requirements, highlighting a significant gap in the standard for biomass power generators.

Other UK specific electricity supplier chain research findings

The Great British Energy Act 2025 includes an amendment (announced April 2025) requiring Great British Energy to exclude solar panels linked to forced labour in China's Xinjiang region from its supply chain. China produces approximately 50% of global polysilicon, with approximately 40% from Xinjiang specifically. UK customs data indicates the UK imports more than 40% of its solar photovoltaics from China. Walk Free's 2023 Global Slavery Index found only 7% of UK and Australian renewable energy companies have due diligence policies for sourcing minerals from conflict-affected areas. The UK Parliament's Joint Committee on Human Rights (report published 24 July 2025, HC 633/HL Paper 159) estimated the UK imports approximately US$26 billion of goods at annual risk of forced labour, including approximately US$14.8 billion of solar panels.

Suggested response letter comments for the TAC's consideration

Supply chain disclosure for biomass fuel operators

The proposed IF-EU Supply Chain Management metrics (IF-EU-430a.1 and IF-EU-430a.2) cover HRDD processes and percentage of high-risk suppliers audited. For biomass plant operators, neither metric address what is financially material third-party sourced input. Biomass pellets typically constitute the majority of purchased fuel inputs for such entities. The sustainability characteristic that matters to investors is not how many suppliers have been audited against general labour standards, but whether the biomass material is sourced from sustainably managed forests without deforestation. The proposed metrics are calibrated for diversified procurement of manufactured components and are structurally misaligned with the dominant supply chain risk of biomass generation.

The ISSB could address the biomass sourcing gap not by adding a new metric but by adding applicability guidance within the technical protocols of the existing IF-EU-430a.1 and IF-EU-430a.2, along the following lines: 'For entities for which biomass fuel constitutes a material proportion of fuel inputs, the description of supply chain management processes under IF-EU-430a.1 should include: the certification frameworks applied to biomass sourcing (including scheme name and coverage percentage); the entity's approach to verifying deforestation- and conversion-free status of biomass inputs.'

Circular definition of 'high-risk suppliers'

IF-EU-430a.2 defines high-risk suppliers as those 'where the entity has determined a heightened level of risk.' This is circular as the entity self-selects using its judgement which suppliers count as high-risk, audits those self-selected suppliers and reports the audit coverage percentage. A narrowly defining entity can report 100% coverage while facing severe supply chain risks. A more transparent entity defining high-risk broadly reports 60% and appears weaker on the same metric despite stronger oversight.

The ISSB could consider establishing a minimum threshold definition of high-risk by reference to an objective external framework, for example, suppliers operating in countries flagged by the Responsible Minerals Initiative, the US Department of Labor List of Goods Produced by Child Labor or Forced Labor, or equivalent unless. The technical protocol could also clarify that 'value chain' means at minimum Tier 1 suppliers.

1.10 Critical Incident Risk Management (renamed disclosure topic from Nuclear Safety & Emergency disclosure topic)

Nature of proposed amendment

The Nuclear Safety & Emergency Management topic is renamed Critical Incident Risk Management with scope broadened from nuclear-specific incidents to all critical incidents with potential for catastrophic consequences explicitly including hydroelectric dam failures, gas-fired power plant explosions, earthquakes and wildfires.

IF-EU-540a.2 (discussion of efforts to manage nuclear safety and emergencies) is replaced by new IF-EU-540a.3 (description of management systems to identify and mitigate serious accidents) covering all critical incident types. IF-EU-540a.1 (nuclear power unit safety review results by national regulatory authority) is retained with clarification that the review must be conducted by a competent national regulatory authority.

ISSB's rationale for changes (per Basis for Conclusions)

BC190 explains that the original Nuclear Safety topic focused on severe nuclear accident risk and the associated financial consequences. BC191 outlines the rationale for expanding the scope, noting stakeholder feedback that entities without nuclear operations are exposed to other critical incidents, such as hydropower dam failures, gas plant explosions, earthquakes and wildfires, which can result in similarly severe operational disruptions and financial impacts.

Findings from UK company review

None of the seven entities reviewed operates nuclear generation. The broadened scope to all critical incidents is therefore the operationally relevant dimension for this entity review and for the majority of the global IF-EU reporter population.

A UK biomass generator faces two critical incident risk categories within the broadened scope: wood pellet dust explosion risk (classified as an explosive substance under UK DSEAR regulations); and large-scale operational disruption from an incident at the UK's largest single power station by capacity. The entity's fire and emergency management framework is described in its ESG report, demonstrating foundation for IF-EU-540a.3 reporting format.

A FTSE 100 T&D and integrated utility has material gas infrastructure in UK and US operations, creating pipeline explosion and fire risk directly within the broadened scope. Its TCFD operational resilience disclosures address this qualitatively in a manner that is adaptable for IF-EU-540a.3 format.

A small island utility has a distinctive critical incident profile: the loss of its three subsea interconnector cables would eliminate approximately 94% of electricity supply to the island a single-point-of-failure concentration not found in any other entity reviewed. Its Resilience Programme and Security of Supply Standard review address this qualitatively.

An infrastructure conglomerate with hydroelectric assets in its international portfolio is exposed to dam failure risk, one of the four incident types explicitly identified within the expanded scope. Although the entity does not currently report in the proposed format, its existing disclosures appear adaptable to meet these requirements.

Suggested response letter comments for the TAC's consideration

Support scope broadening

Renaming the disclosure topic from 'Nuclear Safety Emergency' to 'Critical Incident Risk Management', and explicitly including dam failures, gas plant explosions, earthquakes and wildfires, makes the topic substantially more relevant at an international level. The majority of entities in the IF-EU universe, particularly those in emerging markets, do not operate nuclear generation. The revised IF-EU-540a.3 therefore more directly captures the most operationally significant catastrophic risks for most entities within the scope of IF-EU.

1.11 Operational Resilience & System Reliability (renamed from Grid Resiliency disclosure topic)

Nature of proposed amendment

Grid Resiliency renamed to Operational Resilience & System Reliability. Revised metrics: IF-EU-550a.1: Now counts cybersecurity incidents disrupting power systems, replacing prior non-compliance focus; includes incidents without regulatory breach (IFRS S1 para.73 relief applies). IF-EU-550a.2: SAIDI, SAIFI, and CAIDI required both including and excluding major event days, defined per IEEE Std 1366 New metrics: IF-EU-550a.3: Average generation asset availability (%), adding generation reliability insight. IF-EU-550a.4: Amount and % of assets exposed to climate physical risks, split by asset type (generation, T&D etc) and risk type (acute vs chronic), aligning with IFRS S2 para.29(c). IF-EU-550a.5: Narrative on resilience strategy, covering grid hardening, DER/storage integration, interconnection, and cybersecurity risk management.

ISSB's rationale for changes

BC194-BC195 explain that the ISSB refined the metrics to enhance decision-usefulness and relevance by shifting from compliance-based measures to actual operational outcomes, such as cybersecurity incidents, while maintaining compatibility with jurisdictional disclosure requirements (BC194). The ISSB also aligned climate-related disclosures with IFRS S2 by translating cross-industry requirements into practical, industry-specific metrics for utilities (BC195(f))). In addition, new narrative disclosures were introduced in response to investor feedback that emphasised the importance of understanding how entities manage and invest in resilience across climate, cybersecurity and broader systemic risks (BC195(g)))

Findings from UK company review:

The entity review reveals varied readiness across the five metrics in this disclosure topic. A FTSE 100 T&D and integrated utility entity demonstrates the most advanced operational resilience disclosure of all entities reviewed. It reports zero cybersecurity non-compliance incidents (IF-EU-550a.1), network reliability for all its jurisdictions - UK electricity transmission at 99.99983%, UK electricity distribution at 99.98294%, and US operations at 99.84-99.98% alongside availability rates for all its interconnectors. SAIDI and SAIFI are reported for US operations in IEEE Std 1366 format (NMPC SAIDI 123.87 minutes, SAIFI 1.04; MECO SAIDI 124.44 minutes, SAIFI 0.84) but not for UK operations, where Ofgem CI/CML equivalents are used instead. This directly illustrates the IEEE Std 1366 international applicability gap discussed below and Appendix A1.6.

A small island integrated utility reports customer minutes lost as a headline KPI, the direct operational equivalent of SAIDI, but does not report SAIFI or CAIDI separately (US measures). No cybersecurity related disclosure found in the reporting.

IF-EU-550a.3 (generation availability factor) is not disclosed by any entity in the review in a format aligned with, or comparable to, the proposed metric. A UK biomass generator, for example, does not currently disclose an availability factor for its power station on a voluntary basis. This represents a notable gap in investor-relevant disclosure, given that plant availability is the primary operational risk for a single-site, large-scale generation entity and a key input to investor assessments of operational performance and risk.

IF-EU-550a.4 (physical risk asset vulnerability quantification) could be a potentially demanding new metric and is not currently reported quantitatively by any entity reviewed. All infrastructure-owning entities publish TCFD-aligned physical risk narratives, identifying coastal substations, overhead transmission lines, subsea interconnectors and flood-exposed sites as priority risk locations. However, none have translated these disclosures into the financial quantification format required by the metric (i.e. carrying value of vulnerable assets disaggregated by asset type and hazard type). This represents a potential implementation readiness gap across the entities reviewed.

IF-EU-550a.5 (operational resilience strategy narrative) has the strongest foundation across the review. Multiple entities publish grid hardening strategies, climate resilience investment programmes and cybersecurity risk management frameworks within their TCFD and Annual Reports content directly relevant to the narrative requirements of this metric. A FTSE 100 T&D and integrated utility's climate resilience strategy and a small island utility's Resilience Programme and Security of Supply Standard review both represent substantive narrative disclosures that would satisfy the intent of IF-EU-550a.5 with modest reformatting.

Suggested response letter comments for the TAC's consideration

SAIDI/SAIFI/CAIDI calculation methodology

The technical protocol mandates that SAIDI, SAIFI and CAIDI be calculated, including the Major Event Day exclusion, 'according to IEEE Std 1366.' IEEE Std 1366 is an American National Standard developed by the Institute of Electrical and Electronics Engineers, used primarily in US and Canadian electricity distribution regulation. It is not used by UK's Ofgem (which requires Customer Interruptions and Customer Minutes Lost per 100 customers under RIIO-ED2), the Australian Energy Regulator (which uses SAIDI and SAIFI but under AER-specific major event exclusion criteria), or any European regulator. The Major Event Day threshold calculation in the protocol requiring five years of historical daily SAIDI data, logarithm calculations and computing a specific threshold requires data infrastructure calibrated to IEEE Std 1366 that UK, Australian and Hong Kong entities do not maintain. A conglomerate with T&D operations across the UK, Australia, New Zealand and Hong Kong cannot produce a single comparably calculated SAIDI/SAIFI figure without first converting each regulator's data to IEEE Std 1366 format, a process the protocol does not describe.

The ISSB should consider amending the technical protocol to permit entities to report SAIDI, SAIFI and CAIDI equivalents using the calculation methodology relevant for their primary electricity sector regulator, with a requirement to disclose the specific standard or methodology applied. For Major Event Day exclusion, the protocol should permit use of equivalent jurisdictional exceptional event definitions where IEEE Std 1366 is not applicable.

Absence of valuation methodology for 'amount' of vulnerable assets

The technical protocol for metric IF-EU-550a.5 requires disclosure of the 'amount and percentage of assets vulnerable to climate-related physical risks' in the entity's presentation currency, disaggregated by industry asset and climate-related physical hazard. Table 5 in the technical protocol illustrates this as a 'monetary value'. However, the protocol does not specify the valuation basis for this amount specifically, whether it should be the carrying amount (book value) recognised in the financial statements or fair value. For long-lived electricity network assets, the choice of valuation basis can produce materially different outcomes. For example, a substation constructed decades ago may have a carrying amount close to zero due to full depreciation, but a fair value of millions of pounds. In such cases, the reported value of 'vulnerable assets' would vary significantly depending on the basis applied. While the technical protocol cross-refers to IFRS S2 paragraph 29(c), that paragraph does not specify a valuation methodology. The company review found that none of the seven entities assessed currently discloses this metric, or a comparable equivalent, suggesting a lack of established market practice.

The ISSB could therefore consider amending the technical protocol to specify that the 'amount' of vulnerable assets should be measured using the carrying amount (net book value) recognised in the entity's financial statements. Where assets are fully depreciated but remain operationally material, the protocol should clearly require disclosure of this fact to ensure the metric is not misleading.

Multi-hazard counting guidance

The technical protocol for metric IF-EU-550a.5 requires assets vulnerable to climate-related physical risks to be disaggregated by climate-related physical risk. However, the technical protocol does not specify how an asset exposed to multiple simultaneous hazard types should be treated in the disaggregated disclosure. Published ARP4 climate adaptation reports from UK electricity network operators reveal that specific asset classes face concurrent multi-hazard exposure: coastal substations are simultaneously exposed to flooding, sea level rise, coastal erosion and salt-accelerated corrosion; overhead transmission lines face concurrent exposure to high winds, ice and freeze-thaw, extreme heat conductor sagging, and lightning; and distribution transformers face simultaneous thermal overload, wind damage, and flood inundation risk. A network operator with 50 coastal substations out of 5,000 total assets could report a vulnerable asset percentage of anywhere between 1% and 4% for identical underlying facts, depending solely on whether each asset is counted once for all hazards or once per applicable hazard.

The ISSB could consider improving the technical protocols to clarify that: (i) an asset exposed to multiple hazards is counted once in the overall percentage of vulnerable assets but disclosed under each applicable hazard category in the disaggregated breakdown, such that the disaggregated figures may not sum to the total; and (ii) the denominator is the entity's total T&D asset base, measured by carrying amount, consistent with the financial statements. Without such clarification, the metric may be difficult to interpret.

Q3 (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 adoption of the Standard by entities in jurisdictions other than the United States? Why or why not?

Preliminary response position: Subject to further improvements on areas that are still US-centric, broadly agree that the proposed amendments would enhance international applicability.

Rationale: The revised description broadly reduces the US-centric regulatory framing. However, a detailed review of the technical protocols indicates the presence of remaining implicit single-jurisdiction regulatory assumptions. These assumptions create practical challenges for entities operating across multiple electricity regulatory regimes. Evidence from reviewed UK-listed entities, with operations spanning the UK, Australia, New Zealand, Hong Kong, Northern Ireland and the United States illustrates this challenge directly.

1.12 International applicability

Findings from UK company review

Three of the seven entities reviewed operate across multiple distinct electricity regulatory regimes, providing direct evidence of the international applicability challenge at group level.

A FTSE 100 T&D and integrated utilities entity operates simultaneously under Ofgem's regulatory framework in the UK, and under state Public Service Commission regulations in the US - two structurally different regulatory billing frameworks. It reports SAIDI and SAIFI for its US operations in IEEE Std 1366 format, but uses Ofgem's Customer Interruptions and Customer Minutes Lost framework for its UK networks, directly illustrating why the mandatory IEEE Std 1366 reference in IF-EU-550a.2 creates a non-comparable group-level disclosure.

A global infrastructure conglomerate with primary listing in Hong Kong and secondary listing on the LSE operates electricity distribution under up to four distinct regulatory regimes - the Australian Energy Regulator, Hong Kong Electrical and Mechanical Services Department, the New Zealand Commerce Commission and Ofgem in the UK. No single set of IF-EU technical protocol regulatory references accommodates this portfolio.

A small island integrated utility operates entirely outside both the UK ETS and EU ETS under a Crown Dependency self-regulatory framework.

These three entities collectively demonstrate that the international applicability challenge arises directly within the UK-listed entity population expected to apply the standard.

Suggested response letter comments for the TAC's consideration

The TAC recommends the following further improvements to make IF-EU internationally applicable:

The ISSB could consider replacing the use of IEEE Std 1366 with jurisdictional equivalents. The IF-EU-550a.2 technical protocol should acknowledge that entities operating outside the US and Canada may calculate Major Event Days using alternative methodologies recognised by their relevant national electricity regulator, provided the methodology is disclosed and applied consistently. See Appendix A1.6 for further detail on IEEE Std 1366 and international equivalents.
Guidance on how entities with operations across multiple electricity regulatory regimes/jurisdictions should structure group-level IF-EU disclosures, particularly for quantitative metrics where jurisdictional aggregation methodology is unspecified.
Either amend industry description to include biomass and geothermal energy source list, or amend or modify the description to include the phrase 'other energy sources'.
Replace US-specific institutional terminology. For instance, paragraph 4.3 of the IF-EU-110a.7 technical protocol should replace 'utility commissions' with the internationally applicable term 'electricity sector regulatory authorities'.

Q3 (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 disclosure standards or frameworks? Why or why not?

Preliminary response position: Broadly agree that the proposed amendments enhance interoperability subject to consideration of suggested improvements.

Rationale: The GRI, TNFD and IFRS S2 alignments embedded in the new metrics seem reasonably targeted. The IFRS Foundation-TNFD MoU (April 2025) and GRI-ISSB MoU (May 2024) provide a positive structural foundation. The most significant interoperability gap identified relates to biogenic CO2 treatment: ESRS Amended E1 (adopted November 2025) requires disclosure of biogenic CO2 from biomass combustion outside Scope 1, while IF-EU-110a.1 provides no equivalent requirement.

1.13 Interoperability with IFRS S1/S2, ESRS, GRI and TNFD

Nature of proposed amendment

GRI alignments (BC Appendix A):

IF-EU-120a.1 (Air Quality): Aligned with GRI 305-7.
IF-EU-210a.1 (Community Rights): Aligned with GRI 413-1 and GRI 413-2.
IF-EU-330a.1 (Employee R&D&R): Aligned with GRI Employment Exposure Draft (EMPL 3, EMPL 7) and GRI Training and Education Exposure Draft (TRED 1, TRED 2).

TNFD alignments (BC Appendix A):

IF-EU-160a.1/2 (Ecological Impacts): Directly implement TNFD core metric C1.0 (total spatial footprint) and TNFD Locate step sensitivity guidance. TNFD published Additional Sector Guidance for Electric Utilities and Power Generators in June 2024.
IF-EU-150a.4/5/6 (Hazardous Waste): Aligned with TNFD C2.2 (waste generation and disposal) and EP.C2.2 (nuclear waste storage).

IFRS S2 alignment:

IF-EU-110a.5/6 (Capacity): Operationalise IFRS S2 paras.10–17 (transition strategy and capital allocation).
IF-EU-110a.7 (Capital strategy): Directly implements IFRS S2 para.12(b).
IF-EU-550a.4 (Physical risk assets): Industry-specific operationalisation of IFRS S2 para.29(c).

Suggested response letter comments for the TAC's consideration

Biogenic CO2 emissions IFRS S2/SASB/ESRS alignment

The TAC recommends that ISSB consider addressing the biogenic CO2 interoperability gap by extending the standard's industry description to include biomass generation, and then require biomass generators to separately disclose biogenic CO2 outside Scope 1 in the IF-EU-110a.1 technical protocol, consistent with ESRS Amended E1, para.44, and the GHG Protocol Corporate Standard, Chapter 9. This single change would close a significant interoperability gap for UK electricity sector entities reporting under both frameworks.

Interoperability

The TAC suggests that the ISSB continues its collaboration with EFRAG, GRI and TNFD on interoperability matters, including, where helpful, joint work to clarify how specific metrics are interoperable.

Q3 (f) - Are there any proposed metrics in the Electric Utilities & Power Generators SASB Standard that would benefit from the inclusion of specific proportionality mechanisms, such as the use of a transition period or the inclusion of narrative disclosures as a starting point? If so, which proposed metrics, and why?

1.14 Proportionality mechanism

Metrics requiring proportionality considerations

Applicability criteria

The ISSB should include explicit activity gates (explicit applicability criteria) in the technical protocols confirming:

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. Generation-only entities, retail-only suppliers and entities such as the small island utility (importing approximately 94% of supply through an import contract) should explain inapplicability rather than producing empty disclosures;
energy affordability metrics IF-EU-240a.3/.5/.6 apply primarily to entities with direct customer billing relationships. Wholesale-only generators should explain inapplicability; and
under IF-EU-210a.3/.4 (Indigenous Peoples) entities operating exclusively in jurisdictions without domestic indigenous peoples legal frameworks should describe their local community engagement framework as an alternative disclosure rather than producing empty metric outputs.

Appendix 1: Supplementary explanatory information on technical matters

This appendix provides explanatory information on technical terms and contextual matters referenced in the main analysis paper, with full source citations and clickable links to primary sources.

A1.1 - Biogenic CO2 Accounting: GHG Protocol Treatment for Biomass Generators

Under the GHG Protocol Corporate Standard (2004), CO2 from biomass combustion is zero-rated within Scope 1 because the carbon was previously sequestered during tree growth. However, the GHG Protocol itself requires entities to disclose biogenic CO2 from biomass combustion outside the GHG inventory as a memo or appendix item (Chapter 9 of the standard).

ESRS Amended E1 (adopted November 2025) explicitly requires separate disclosure of direct biogenic CO2 from biomass combustion or biodegradation as a distinct data point outside Scope 1 (ESRS E1, para.44). IFRS S2 and the proposed IF-EU-110a.1 technical protocol do not address biogenic CO2 treatment directly.

Sources:

GHG Protocol Corporate Standard (Revised Edition, 2004) – Chapter 9 covers biogenic emissions treatment. Available at: https://ghgprotocol.org/corporate-standard ESRS Amended E1 (European Sustainability Reporting Standards on Climate Change) – para.44 on biogenic CO2 disclosure. Available via the European Financial Reporting Advisory Group (EFRAG) at: https://www.efrag.org/en/projects/esrs-mandatory-2024-omnibus-amendment

A1.2-ILO Convention No. 169 and UK Ratification Status

ILO Convention No. 169 on Indigenous and Tribal Peoples (1989) is the primary binding international instrument protecting indigenous peoples' rights. As of 2025, approximately 23 countries have ratified the Convention, primarily in Latin America (including Peru, Bolivia, Chile, Mexico, Brazil), with a small number in Europe (Norway, Luxembourg, the Netherlands, Spain, Germany) and Africa. The UK has not ratified ILO Convention 169. The UK Government's stated position is that the Convention cannot be implemented as 'the UK has no indigenous peoples to whom it applies'.

Sources:

ILO NORMLEX Database – C169 ratification status and full list of ratifying countries: https://normlex.ilo.org/dyn/nrmlx_en/f?p=NORMLEXPUB:12100:0::NO::P12100_ILO_CODE:C169 ILO C169 – Full text of Indigenous and Tribal Peoples Convention, 1989: https://www.ilo.org/media/324306/download

A1.3 - UK Cybersecurity Regulatory Framework and IF-EU-550a.1

The Network and Information Systems (NIS) Regulations 2018 require energy-sector operators of essential services (OES) to implement appropriate cyber risk management measures and report significant incidents to Ofgem. The UK Cyber Security and Resilience (CS&R) Bill (introduced House of Commons, 12 November 2025) expands and strengthens NIS Regulations in alignment with EU NIS2 (Directive 2022/2555). DESNZ and Ofgem's "Reshaping Cyber" consultation (published 27 March 2026, closing 22 May 2026) proposes enhanced baseline cyber resilience requirements for all Ofgem licensees. The consultation's foreword confirms NCSC now handles four nationally significant cyber-attacks per week, with 204 nationally significant cyber incidents handled in 2025 (more than double the 89 in 2024). Average annual costs of cyber incidents range from £93,665 (micro-entities) to £436,443 (larger entities) based on KPMG economic modelling for DESNZ (2025), referenced in footnote 8 of the consultation document.

Sources:

DESNZ/Ofgem "Reshaping Cyber" consultation – GOV.UK consultation landing page (27 March 2026): https://www.gov.uk/government/consultations/whole-energy-cyber-resilience-requirements-reshaping-cyber-regulation-in-downstream-gas-and-electricity DESNZ/Ofgem "Reshaping Cyber" consultation – full accessible consultation document (includes NCSC statistics and KPMG cost figures referenced in the paper): https://www.gov.uk/government/consultations/whole-energy-cyber-resilience-requirements-reshaping-cyber-regulation-in-downstream-gas-and-electricity/reshaping-cyber-regulation-in-downstream-gas-and-electricity-consultation-document-accessible-webpage DESNZ/Ofgem "Reshaping Cyber" consultation – PDF version of the consultation document: https://assets.publishing.service.gov.uk/media/69c51142471d520038d0f68d/whole-energy-resilience-consultation-document.pdf

A1.4-UK Clean Power 2030 and Grid Investment Context

DESNZ's Clean Power 2030 Action Plan (December 2024) requires at least 95% of electricity generation from low-carbon sources by 2030, with carbon intensity falling from 171 gCO2e/kWh in 2023 to below 50 gCO2e/kWh by 2030.

Required 2030 capacity targets: 43-50 GW offshore wind, 27-29 GW onshore wind, 45-47 GW solar. NESO estimates total required system capacity of 204-231 GW by 2030.

Ofgem's RIIO-T3 Final Determination (4 December 2025) approves £28.1 billion of upfront investment within a wider investment pipeline of approximately £90 billion over 2026-2031 for electricity and gas transmission. National Grid has indicated group-wide capital expenditure intentions of approximately £60 billion between 2024 and March 2029. These investment levels make IF-EU-110a.5/6 (installed and planned capacity) and IF-EU-110a.7 (capital strategy) among the most material new IF-EU metrics for UK electricity sector investors.

Sources:

DESNZ, Clean Power 2030 Action Plan – main report (GOV.UK, December 2024): https://www.gov.uk/government/publications/clean-power-2030-action-plan/clean-power-2030-action-plan-a-new-era-of-clean-electricity-main-report Ofgem, RIIO-T3 Final Determinations – overview document and NGET company annex (4 December 2025): https://www.ofgem.gov.uk/sites/default/files/2025-12/RIIO-3-Final-Determinations-NGET.pdf NESO, Grid connections reform announcement (includes 204-231 GW capacity range): https://www.neso.energy/neso-implements-electricity-grid-connection-reforms-unlock-investment-great-britain

A1.5 - UK Energy Sector Workforce Shortages and IF-EU-330a.2

Energy & Utility Skills (EU Skills) Workforce Demand Estimates 2024-2030 (September 2024) project the UK energy and utilities sector will need to fill 277,000 vacancies by 2030, equivalent to approximately 50% of the current sector workforce. The power sub-sector alone is forecast to grow from 158,600 to 290,300 employees an 83% increase requiring 156,900 new entrants.

Key shortage categories relevant to IF-EU-330a.2 include: offshore wind installation and maintenance technicians (requiring 39,000 additional workers, up 223%); high-voltage cable jointers and overhead line workers for RIIO-T3 delivery; power engineers for new build transmission infrastructure; battery storage system engineers; digital infrastructure and cybersecurity specialists; and project managers for large capital programmes. The UK government's Clean Energy Jobs Plan (2025, co-developed with EU Skills) identifies 42 actions across six delivery chapters to address this gap.

Sources:

EU Skills, The Energy and Utilities Sector Workforce Demand Estimates 2024-2030 – landing page and report access (September 2024): https://euskills.co.uk/report/the-energy-and-utilities-sector-workforce-demand-estimates-2024-to-2030/ EU Skills, Workforce Demand Estimates 2024-2030 – summary report PDF (direct download): https://www.euskills.co.uk/wp-content/uploads/2024/09/Energy-Utilities-Workforce-Demand-Estimates-2024-30-Summary-v5_Cover-added.pdf

A1.6 - IEEE Standard 1366 and International SAIDI/SAIFI Calculation Methodologies

IEEE Standard 1366 (“IEEE Guide for Electric Power Distribution Reliability Indices") is a standard published by the Institute of Electrical and Electronics Engineers' (IEEE) Power and Energy Society. IEEE is a US-based professional association, and the standard was developed primarily for and is adopted predominantly within US and Canadian electricity distribution regulation. It specifies how to calculate SAIDI (average minutes of power outage per customer per year), SAIFI (average number of outages per customer per year) and CAIDI, including which severe weather days ('major event days') can be excluded.

UK Distribution Network Operators (DNOs) do not use IEEE Std 1366. Under Ofgem's RIIO-ED2 regulatory framework, UK DNOs report interruption performance using Customer Interruptions (CI) and Customer Minutes Lost (CML) metrics, with Ofgem-specific definitions of 'exceptional events' (the UK equivalent of major event days) that differ substantially from the IEEE log-average methodology.

Australian electricity distribution network service providers (DNSPs) use SAIDI and SAIFI metrics but under the Australian Energy Regulator's Distribution Annual Planning Report (DAPR) procedures, which include AER-specific major event exclusion criteria defined in the Service Standards applicable to each network. Hong Kong utilities use the EMSD Scheme of Control framework.

The exclusive reference to IEEE Std 1366 in the IF-EU-550a.2 technical protocol without acknowledgement of these established international equivalents means that conglomerates with T&D operations across the UK, Australia and Hong Kong face significant practical complexity in producing a single comparable group-level SAIDI/SAIFI figure.

Sources:

Ofgem, RIIO-ED2 Information and Incentives Guidance (2022); Australian Energy Regulator, Distribution Annual Planning Report Requirements; IEEE Std 1366-2012 (IEEE Guide for Electric Power Distribution Reliability Indices); https://standards.ieee.org/ieee/1366/3549/

A1.7 - Biomass Supply Chain Certification Frameworks (relevant to IF-EU-430a)

UK biomass generator source wood pellets from North America and elsewhere and certify their supply chains using three complementary frameworks. Sustainable Biomass Program (SBP) is specific to the biomass energy sector it certifies pellet mills and trading chains and is the primary standard cited in leading UK biomass generator disclosures (98.6% SBP-compliant in 2024). Forest Stewardship Council (FSC) certifies responsible forest management at source and is regarded by environmental organisations as the most rigorous standard, particularly for sensitive forest types. Programme for the Endorsement of Forest Certification (PEFC) is broader in geographic coverage, endorsing national forest certification systems globally. Neither FSC nor PEFC maps to any standardised SASB IF-EU metric under the proposed amendments, which is the core of the biomass supply chain gap identified in section 1.6 of this paper.

Sources:

SBP-https://sbp-cert.org/ |FSC-https://fsc.org/en| PEFC-https://www.pefc.org

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