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TAC Public Meeting July 2026 Paper 3: SASB enhancements - Final comment letter

Executive summary


Date	14 July 2026
Paper reference	2026-TAC-018
Project	Proposed amendments to SASB Standards – Phase 1 Part 2
Topic	Final comment letter

Objective of the paper

This paper presents the TAC's final draft response to the ISSB's March 2026 Exposure Draft: Proposed Amendments to the SASB Standards and IFRS S2 Industry-based Guidance (SASB/ED/2026/1).

Decisions for the TAC

The TAC is asked to approve the final draft response to SASB/ED/2026/1, in paragraphs 6 to 30 and in the appendix.

Appendices

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

Context

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

2SASB/ED/2026/1 continues Phase 1 of the ISSB's project on Enhancing the SASB Standards and sets out proposed amendments to the SASB Standards for the Agricultural Products, Meat, Poultry & Dairy, and Electric Utilities & Power Generators industries.

3This paper presents the TAC's final draft response to SASB/ED/2026/1. The main body of the comment letter is in paragraphs 6 to 30 and the responses to the questions are in the appendix.

Next steps

4If the TAC approves the final draft response to SASB/ED/2026/1, the TAC Secretariat will work with the TAC Chair to finalise the document. The TAC'S response to SASB/ED/2026/1 will undergo final proofreading and formatting and, once completed, will be submitted to the ISSB and published on the FRC website.

5The final Due Process Summary will then be presented for approval at the TAC's September 2026 meeting.

Comment letter

6The UK Sustainability Disclosure Technical Advisory Committee (TAC) welcomes the opportunity to provide comments on the International Sustainability Standards Board (ISSB)'s Exposure Draft: Proposed amendments to the SASB Standards and IFRS S2 Industry-based Guidance (SASB/ED/2026/1). The TAC's comments on the proposed amendments to the SASB Standards in this letter also apply to the Industry-based Guidance on Implementing IFRS S2 (IFRS S2 Industry-based Guidance) when relevant.

7This letter sets out key points for consideration and is accompanied by an appendix containing detailed responses to the specific questions posed by the ISSB.

8The TAC is an independent expert advisory body, established by the UK Government, whose purpose is to assess IFRS Sustainability Disclosure Standards on a technical basis and provide independent recommendations on endorsement to the Secretary of State for Business and Trade. The TAC also has a responsibility to undertake outreach with, and provide a focal point for, UK stakeholders to influence the technical development of IFRS Sustainability Disclosure Standards. This includes the way the ISSB develops its future standards and the ISSB's choices to amend or produce guidance on existing standards.

9The TAC is formed of a chair and members from a range of relevant professional backgrounds. The TAC's response to SASB/ED/2026/1 has been developed following discussions of TAC members in public meetings. It takes into account the views of UK stakeholders when relevant.

10The TAC's response to SASB/ED/2026/1 references, and should be read alongside, the TAC's November 2025 response to the ISSB's July 2025: Exposure Draft of Proposed Amendments to the SASB Standards (SASB/ED/2025/1) (the TAC's November 2025 response).

11The TAC continues to reiterate the importance of the points it made in its November 2025 response and expands on a number of them to incorporate further key developments.

12Following the submission of the TAC's November 2025 response, additional stakeholder outreach and research activities found that UK preparers had a number of concerns about the SASB Standards, including:

confusion about the status of the SASB Standards in the IFRS materials;
the SASB Standards not necessarily connecting to sustainability-related risks and opportunities that could have current and anticipated financial effects on an entity's prospects;
duplication between the SASB Standards and IFRS Sustainability Disclosure Standards;
the differences in interpretation between entities using the SASB Standards and that further definitions and guidance are required to support comparability;
the difficulties with benchmarking disclosures due to the lack of widespread use of the SASB Standards;
the difficulties caused by certain disclosures in the SASB Standards still being US-centric despite the ISSB's previous work to enhance their international applicability; and
the difficulties caused by having similar, but not identical, disclosures across different standards and frameworks.

13The real practical challenges faced by UK preparers in applying the SASB Standards are reflected in the detailed responses to the specific questions posed by the ISSB in SASB/ED/2026/1.

14Taken together, the TAC broadly supports the proposed amendments to the three SASB Standards in SASB/ED/2026/1. The amendments represent a positive step towards improved international applicability and interoperability and better reflect the diverse business models of entities in the Agricultural Products, Meat, Poultry & Dairy, and Electric Utilities & Power Generators industries. However, the TAC recommends that further improvements are made before these Standards are finalised to ensure that they provide primary users with decision-useful information.

15The TAC has also made a number of general points on the relationship between the SASB Standards and IFRS Sustainability Disclosure Standards. A number of the specific issues identified by the TAC in relation to the proposed amendments to the three SASB Standards reinforce these general points and illustrate the problems with the current architecture of the IFRS materials and how the SASB Standards fit into that architecture.

Current architecture of the IFRS materials and how the SASB Standards fit into that architecture

16The TAC believes that there is a tension between the role of the SASB Standards in complementing IFRS Sustainability Disclosure Standards and their role as a standalone resource. It may be challenging for one set of materials to fulfil both roles effectively.

17The TAC believes that the challenges for preparers applying the SASB Standards as well as IFRS Sustainability Disclosure Standards include the:

unclear status of the SASB Standards in the IFRS materials;
prescriptive nature of the SASB Standards, including unclear materiality principles;
duplication between the SASB Standards and IFRS Sustainability Disclosure Standards; and
inconsistency in and between the SASB Standards.

Further information on these challenges is in paragraphs 179 to 194 of the appendix.

18The TAC suggests that the ISSB considers including in each SASB Standard a clarifying statement, either in the introductory provisions or an application note. The statement would clarify that the conceptual foundations and principles in IFRS Sustainability Disclosure Standards, including the materiality principles and proportionality mechanisms (such as the concept of 'all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort'), apply in the same way to the SASB Standards as they do to IFRS Sustainability Disclosure Standards.

19The TAC also suggests that the ISSB considers a strategy for enhancing the SASB Standards, which could provide a number of possible solutions to the problems with the current architecture of the IFRS materials and how the SASB Standards fit into that architecture.

Strategy for enhancing the SASB Standards

20Following the completion of Phase 1 of the ISSB's project on Enhancing the SASB Standards, the TAC suggests that the ISSB pauses its review of specific industries and reconsiders its approach to amending the SASB Standards in light of stakeholder feedback and other developments.

21A strategy for enhancing the SASB Standards could include:

restructuring the SASB Standards;
emphasising principles, not rules; and
renaming the SASB Standards.

Further information on this strategy is in paragraphs 195 to 209 of the appendix.

22The TAC suggests that the ISSB considers restructuring the SASB Standards to distinguish between 'core' disclosures, ‘industry-agnostic' disclosures and 'industry-specific' disclosures.

23The TAC recommends that the ISSB emphasises principles, not rules, so that the SASB Standards do not have to be adapted so much to keep pace with changes. There is a case for allowing practices in relation to industry-specific disclosures to emerge naturally first, driven by the market, and then for standardisation to follow once practices are better developed and have begun to converge.

24The TAC suggests that the SASB Standards are renamed the ‘ISSB Guidance on the Industry-based Sustainability Disclosures'.

Approach to the ISSB's project to enhance the SASB Standards

25The TAC recommends that the ISSB considers adopting a climate-first thematic approach to its project to enhance the SASB Standards.

26If the ISSB continues to prioritise industries for enhancement, rather than adopting a climate-first thematic approach, the TAC continues to encourage the ISSB to issue proposed amendments to all SASB Standards in a sector together.

27Therefore, as the ISSB has not so far considered all industries in the Food & Beverage sector, the TAC recommends that the ISSB issues the three updated SASB Standards within that sector on a provisional basis. Entities can then choose whether to use the updated SASB Standards or the existing SASB Standards for those industries. The SASB Standards can then be finalised when all eight of the SASB Standards within the Food & Beverage sector have been updated.

28The TAC believes that the ISSB should not conclude on nature-related disclosure requirements based on its consultations on the SASB Standards because:

the consultation questions are industry-specific and do not focus on the ISSB's overall strategy in relation to nature-related disclosures;
the respondents to these consultations will most likely be stakeholders who are currently using the SASB Standards, and such stakeholders will not necessarily be experts on nature-related disclosures; and
while disclosure topics and metrics are likely to provide users with some decision-useful information about an entity's nature-related risks and opportunities, there is no evidence that the SASB Standards provide a global baseline of nature-related disclosures for capital markets.

Other points

29The TAC has noted that this consultation seems most likely to elicit feedback from stakeholders who are already familiar with the SASB Standards. The TAC might have expected the ISSB to seek views from all the market, including stakeholders who are not familiar with the SASB Standards, which the ISSB could have done by including materials about the historical reasoning for the inclusion or exclusion of the disclosure topics and metrics. The TAC recommends that the ISSB reconsiders its approach and the stakeholders it is targeting for any future phases of this project.

30If you have any queries or would like to discuss our comments in more detail, please do not hesitate to contact me or the TAC Secretariat at [email protected].

[Chair signature]

Questions for the TAC

Do you have any comments on the final draft response to SASB/ED/2026/1, in paragraphs 6 to 30 and in the appendix, and, in particular, paragraphs 198 to 202 on ways of restructuring the SASB Standards?
Does the TAC approve the final draft response to SASB/ED/2026/1?

Appendix: Responses to the questions in SASB/ED/2026/1

Questions 1 to 3

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

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

31The TAC broadly agrees that the proposed Agricultural Products industry description appropriately describes the business activities of entities in this industry. The revised description is more internationally applicable than the existing version and better reflects the diversity of operating models across international markets, including emerging markets, as well as the broader agricultural products value chain.

32In particular, the categorisation of activities into direct farming and third-party sourcing provides a useful structure for decision-useful disclosures, supporting primary users in assessing sustainability-related risks and opportunities. However, as noted in the TAC's response to Question 1(c), the ISSB should explicitly define 'direct farming' within the technical protocols to improve clarity and support consistent application of the Standard.

33Further, as noted in the TAC's November 2025 response the TAC continues to consider that updating only three of the eight SASB Standards within the Food & Beverage sector in isolation limits stakeholders' ability to assess overall coherence, particularly in relation to consistency across the sector and value chain effects. The TAC's recommendation on how the ISSB should address this, including issuing the three updated Food & Beverage Standards on a provisional basis until all eight have been updated, is set out in full in paragraphs 213-214.

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

34Subject to the improvements discussed in response to Question 1(c), the TAC broadly agrees with the inclusion of direct farming operations within the scope of activities included in the industry classification. This inclusion reflects the global structure of agricultural entities across international markets, particularly in emerging markets, which are not fully reflected in the scope of the current version of the Agricultural Products SASB Standard.

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

35The TAC broadly agrees that the proposed revisions to the industry description capture entities with direct farming operations, entities that source products from farms and entities that undertake both activities. In particular, the TAC supports the key terminology used in the industry description, such as 'direct crop production', 'intermediaries', and 'third-party growers' as these help to clarify the categories. However, the TAC suggests some key improvements, as set out below.

Definition and boundary between direct farming and third-party sourcing

36The revised Agricultural Products SASB Standard distinguishes between direct farming and third-party sourcing activities. However, the technical protocols do not include an explicit definition of 'direct farming' operations, notwithstanding that this is a key scope change in the Standard. While the industry description includes some references associated with direct farming, such as 'direct crop production' and entities that 'own and operate farms', these references are not sufficiently clear or comprehensive to support effective and consistent application in reporting. This issue is also relevant to the Meat, Poultry & Dairy SASB Standard, where the term 'direct farming' is used in FB-MP-160a.7 to FB-MP-160a.9 in the context of livestock production, again without an explicit definition in the technical protocols.

37In practice, the distinction may be particularly challenging to apply for entities with integrated farming models or complex farming arrangements, where the boundary between own operations and third-party sourcing is not always evident. For example, an entity may operate a nucleus estate model under which it provides contracted smallholder farmers with inputs and technical support, specifies the crop variety, planting schedule and production methods, and purchases 100% of the output at a guaranteed price under arrangements that preclude sales to other parties. It neither employs the farmers nor owns or leases the land on which production takes place. In such circumstances, without an explicit definition of 'direct farming' and some illustrative examples, it is not clear whether such an arrangement constitutes 'direct farming' operations, triggering reporting under the Land Use & Ecological Impacts metrics, FB-AG-160a.1 to FB-AG-160a.6, and the Labour Conditions metric, FB-AG-310a.1, or a supply chain relationship falling under the Environmental and Social Supply Chain Management metrics, FB-AG-430c.1 to FB-AG-430c.3 and FB-AG-430d.1 to FB-AG-430d.3.

38The classification of farming activities as either direct farming or third-party sourcing is consequential, as it determines the applicable metrics and also affects the classification of related greenhouse gas emissions as either Scope 1 or Scope 3.

39The TAC recommends that the ISSB explicitly defines 'direct farming' in the technical protocols for each of the two Standards, FB-AG and FB-MP, for example, by reference to operational control, financial control or other specified criteria. In addition, the ISSB should provide illustrative guidance or worked examples for common arrangements such as nucleus estate models, outgrower schemes, contract farming, co-operatives and leased farms. Such an approach would be consistent with the treatment of other key terms such as 'deforestation', 'human activity', 'food loss' and 'forced labour', which are explicitly defined in the technical protocols of these Standards.

Scope clarity regarding commodity trading activities

40Agricultural commodities trading is included in the industry description. However, neither the Basis for Conclusions nor the technical protocols clarifies whether this scope overlaps with agricultural commodity derivatives trading undertaken by financial services entities. Consistent with the approach taken in the Electric Utilities & Power Generators SASB Standard, where an explicit note directs companies with gas-related activities to apply the Gas Utilities SASB Standard for those activities, the ISSB could provide a similar note. This would help clarify the intended scope of agricultural commodities trading and distinguish physical commodity trading from derivatives trading.

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

41The TAC broadly agrees that the proposed disclosure topics would help identify sustainability-related risks and opportunities that could reasonably be expected to affect an entity's prospects. However, the TAC has a suggested improvement set out below.

Clarity on the term ‘Ecological Impacts'

42The disclosure topic Land Use & Ecological Impacts uses the term 'impacts'. However, the perspective from which the term is intended to be applied is not articulated in either the technical protocols or the Basis for Conclusions. This may create confusion, as the concept of impact is commonly understood differently in other contexts, such as double materiality assessments under the European Sustainability Reporting Standards (ESRS) and impact reporting under the Global Reporting Initiative (GRI) Standards.

43The TAC suggests that the ISSB considers explicitly clarifying the intended lens in the Basis for Conclusions or technical protocols, as this would improve the consistency of application and the comparability of disclosures across entities.

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

44The TAC does not agree that the proposed metrics and technical protocols in the Agricultural Products SASB Standard would enable an entity to provide primary users with decision-useful information about sustainability-related risks and opportunities, as key gaps have been identified, including the lack of an explicit definition for direct farming as explained in the response to Question 1(c). Further key areas identified are set out below, together with recommended improvements.

GHG Protocol Land Sector and Removals Standard

45The TAC notes that the GHG Protocol Land Sector and Removals Standard (LSR), published in January 2026, provides the first detailed corporate accounting requirements for land-based emissions, CO2 removals and related metrics. The TAC acknowledges that the LSR was issued shortly before this ISSB Exposure Draft and may not have been available for consideration during its drafting. However, the LSR is now directly relevant to the Agricultural Products SASB Standard. This is particularly pertinent for entities with significant land use activities and for entities applying Science Based Targets initiative's (SBTi's) Forest, Land and Agriculture (FLAG) guidance, which incorporates land-based emissions and removals into target setting.

46The TAC recommends that the ISSB acknowledges the relevance of the LSR in the final Agricultural Products SASB Standard, preferably in the technical protocols. This would clarify the relationship between the proposed greenhouse gas emissions metrics and current accounting practice for agricultural and land-based emissions and removals, and support more consistent and comparable application across reporting entities.

'Sustainably managed land' credibility

47Land Use & Ecological Impacts metric, FB-AG-160a.3, requires disclosure of the spatial footprint of 'sustainably managed land', by product. While the technical protocol explicitly defines ‘sustainably managed' and provides examples of farming practices consistent with that concept, it does not address how entities should substantiate claims of sustainable management. This is a key consideration for investors and other primary users of sustainability-related financial disclosures.

48The TAC suggests that the ISSB considers improving the technical protocol to reference either: (a) recognised product-specific sustainability certification schemes; or (b) jurisdiction-specific regulatory frameworks governing sustainable land management with which the entity is required to comply. The TAC considers that such references would enhance the credibility of an entity's claims regarding its sustainably managed land footprint and reduce the risk of greenwashing.

Limited decision-usefulness of the qualitative Labour Conditions metric

49The Labour Conditions disclosure metric, FB-AG-310a.1, is currently framed as a qualitative, process-based disclosure. Given that this topic applies explicitly to direct farming operations where the reporting entity has greater visibility over its workforce, the TAC recommends that the ISSB considers including a quantitative metric, for example, the percentage of employees covered by fair-wage provisions. Such quantitative information would be more decision-useful to investors than a purely process-based disclosure.

Scope of food loss disclosure and absence of measurement methodology

50The proposed quantitative metric, FB-AG-150a.1, requires disclosure of food loss only for activities owned or controlled by the entity. This means that entities with exclusive third-party sourcing would report no food loss, while integrated entities would report only a partial picture of total food loss because losses arising from stages outside their control would be excluded. This approach appears inconsistent with the significance attributed to food loss set out in paragraph BC73 of the Basis for Conclusions.

51In addition, the technical protocol for metric, FB-AG-150a.1, does not specify a measurement methodology for food loss and food waste, nor does it require disclosure of the methodology used. Without this, primary users cannot assess the robustness or comparability of the reported figures.

52The TAC recommends that the ISSB considers:

extending the scope of food loss disclosure to cover the principal supply chain stages where food loss is most likely to occur, or requiring entities to disclose which supply chain stages are included in the reported figures and which principal stages have been excluded; and
requiring disclosure of the measurement methodology used, or referencing, as illustrative examples and without mandating their use, established international frameworks for measuring food loss, such as the Food Loss and Waste Accounting and Reporting Standard, which is also cited as an illustrative example in GRI footnotes.

53In its November 2025 response on the Processed Foods SASB Standard, the TAC made a similar recommendation on the inclusion of food loss disclosure.

Nutrient management gap in the Agricultural Products SASB Standard

54The TAC notes that the Meat, Poultry & Dairy metric, FB-MP-160a.9, requires disclosure of the percentage of livestock production from direct farming operations that implement and maintain a written nutrient management plan (NMP). No equivalent metric is proposed in the Agricultural Products SASB Standard for direct arable crop farming operations, despite similar underlying soil health risks.

55Excess nitrogen application in arable farming can contribute to nitrate pollution through leaching into groundwater and surface waters and can increase nitrous oxide emissions from agricultural soils. These risks support the case for an equivalent nutrient management metric for direct arable crop farming operations.

56The TAC recommends that the ISSB considers including an equivalent metric in the Agricultural Products SASB Standard. However, consistent with the TAC's observation on FB-MP-160a.9, the existence of a written plan alone does not provide decision-useful information. The TAC therefore recommends that the technical protocol be framed to require disclosure of the percentage of direct farming land area that either complies with applicable jurisdictional nutrient management requirements or is covered by a recognised certification scheme that embeds nutrient management practices. This would provide investors with a more meaningful and credible indicator of nutrient management practices than the existence of a written NMP alone.

57The Basis for Conclusions, at paragraph BC57(a), explains that the new Land Use & Ecological Impacts and Labour Conditions disclosure topics are intended specifically for direct farming activities. Within the Land Use & Ecological Impacts topic, however, only the final three metrics, FB-AG-160a.4 to FB-AG-160a.6, explicitly refer to 'direct farming' in their descriptions. A comparable reference is included in the Labour Conditions metric, FB-AG-310a.1, which is expressly directed to direct farming activities.

58By contrast, the first three Land Use & Ecological Impacts metrics, FB-AG-160a.1 to FB-AG-160a.3, do not explicitly refer to 'direct farming' in their descriptions. Although the technical protocol includes a note below the topic summary stating that all metrics in this topic relate to direct farming, that note is relatively inconspicuous and may not be readily apparent to primary users who focus primarily on the metric descriptions. This inconsistency in labelling could lead to differing interpretations and inconsistent application. For example, entities might include both direct farming and third-party sourcing within the first three metrics, which do not carry an explicit reference to direct farming.

59The TAC suggests that the ISSB considers explicitly incorporating a reference to direct farming in the descriptions of FB-AG-160a.1 to FB-AG-160a.3, consistent with the approach taken in FB-AG-160a.4 to FB-AG-160a.6, in order to support consistent application.

Unit of measurement for spatial footprint

60Through research, the TAC found that the majority of preparers reporting spatial footprint use hectares as the unit of measurement. However, the proposed metric requires this information in square kilometres, which appears inconsistent with current reporting practices. No explanation is provided as to whether the ISSB considers square kilometres to be a more appropriate or internationally applicable unit of measurement than hectares. The TAC also notes the GHG Protocol LSR refers to hectares for land use measurement. In addition, the Taskforce on Nature-related Financial Disclosures (TNFD) framework, from which the metric is derived, is principles-based and does not mandate a specific unit of measurement.

61The TAC recommends that the ISSB either aligns the required unit of measurement with hectares, which is widely used internationally for reporting land area, particularly in agriculture, or explains in the Basis for Conclusions why square kilometres has been required instead.

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

62The TAC has not obtained practical evidence or other related observations to sufficiently assess the cost-effectiveness of the proposed metrics in the Environmental Supply Chain Management and Social Supply Chain Management disclosure topics. Accordingly, the TAC neither agrees nor disagrees with whether those metrics would achieve an appropriate balance between cost-effectiveness for preparers and decision-usefulness for primary users. However, a recommendation for improvement of supply chain disclosure is set out below.

Clarity on alignment with the EU Deforestation Regulation

63The TAC notes that proposed metric, FB-AG-430c.1, requires disclosure of the percentages of sourced agricultural products determined to be deforestation- or conversion-free, including any targets set to monitor progress. This metric may draw on similar information to that required under the EU Deforestation Regulation (EUDR), which applies to in-scope commodities and products imported into, traded within or exported from the EU to be deforestation-free, legally produced and supported by due diligence. There is therefore potential overlap between the information needed for FB-AG-430c.1 and information required for EUDR compliance. However, the Agricultural Products SASB Standard separates environmental and social supply chain disclosures, while the EUDR takes a more integrated approach covering deforestation-free status, legal compliance and due diligence.

64The TAC recommends that the ISSB provides clarification in the Basis for Conclusions or technical protocols, how the proposed SASB disclosures are intended to interact with EUDR obligations. This would help preparers and primary users understand the extent to which common underlying information could support both FB-AG-430c.1 disclosures and EUDR compliance. This would reduce duplicative or overlapping reporting, while recognising that SASB and the EUDR have different reporting objectives.

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

65The TAC agrees that the revised industry description represents a meaningful step towards improved international applicability. The prior description was implicitly oriented towards North American agricultural commodity processors and did not fully reflect the diversity of entities operating across the agricultural value chain internationally, particularly in emerging markets. The revised description recognises that entities may engage in direct crop production, act as intermediaries, or operate across multiple stages of the food value chain in international markets.

66However, the TAC considers that further clarification is needed for the proposed amendments to result in consistently decision-useful information across jurisdictions. In particular, explicit definitions, boundaries and measurement guidance are needed to support comparable application by entities with different operating models and regulatory contexts. Accordingly, the TAC's responses to Questions 1(c) and 1(e), together with its broader comments on international applicability in response to Question 5, are relevant to the ISSB's consideration of whether the proposed amendments would support internationally applicable and decision-useful disclosures for entities in this industry.

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

67The TAC's broader comments on interoperability and alignment with other sustainability-related standards, frameworks and regulatory regimes, set out in response to Question 5, are also relevant to this industry.

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

68The TAC has not undertaken an exercise to identify specific metrics in the Agricultural Products SASB Standard that would most benefit from the proportionality mechanisms discussed in paragraphs BC47 to BC48. However, the TAC's broader comments on proportionality in response to Question 5 are also relevant to this industry.

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

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

70Subject to the ISSB's consideration of the suggested improvements set out below, the TAC broadly agrees that the proposed Meat, Poultry & Dairy industry description appropriately reflects the business activities of entities in this industry.

71However, as noted in the TAC's November 2025 response, the TAC continues to consider that updating only three of the eight SASB Standards within the Food & Beverage sector in isolation limits stakeholders' ability to assess overall coherence, particularly in relation to consistency across the sector and value chain effects. The TAC's recommendation on how the ISSB should address this, including issuing the three updated Food & Beverage Standards on a provisional basis until all eight have been updated, is set out in full in paragraphs 213-214 of this letter.

Aquaculture and fisheries exclusion

72The ISSB explains in the Basis for Conclusions that aquaculture and fisheries have sustainability-related risks and opportunities that differ from those associated with terrestrial animal products and therefore decided to exclude them from the scope of the Meat, Poultry & Dairy SASB Standard. However, this exclusion is not made explicit in the Standard itself. The TAC observes that this could create scope uncertainty for entities with broader protein portfolios, including aquaculture or fisheries products, when determining the applicability of the Meat, Poultry & Dairy SASB Standard.

73The TAC recommends that ISSB considers either:

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

74Although the Exposure Draft and Basis for Conclusions explain the ISSB's decision to exclude aquaculture and fisheries from the scope of the Meat, Poultry & Dairy SASB Standard, which the TAC supports, the TAC considers that entities with significant aquaculture or fisheries activities would benefit from clearer direction on how to identify relevant industry-based disclosures. The TAC recommends that the ISSB identifies existing disclosure topics and metrics within related SASB Standards that may be relevant to those activities. These could include, where appropriate, metrics in the Meat, Poultry & Dairy, Processed Foods or other related SASB Standards. This would support decision-useful reporting for the aquaculture industry and provide a practical interim approach while the ISSB considers how best to address aquaculture within the Sustainability Industry Classification System (SICS).

75The TAC considers that this issue is not limited to aquaculture and fisheries. Through stakeholder engagement, the TAC has identified entities with business models that do not fit clearly within a single existing SASB industry classification. For example, the TAC identified an entity whose primary activities include smart metering rental and services and energy storage, that is currently using disclosure topics and metrics from several SASB Standards to report relevant sustainability-related risks and opportunities. The TAC therefore recommends that, as part of its broader consideration of the SASB Standards architecture, the ISSB considers how such entities should identify the most relevant industry-based disclosures.

Live animal transportation metrics

76The ISSB has expanded the industry scope to include live animal transportation but has not introduced corresponding metrics. This limits the decision-usefulness of this scope expansion for investors and appears inconsistent with the approach taken elsewhere in the Exposure Draft. For example, the proposed inclusion of direct farming in the Agricultural Products SASB Standard is accompanied by supporting metrics under the Land Use & Ecological Impacts and Labour Conditions disclosure topics.

77The TAC recommends that the ISSB considers including metrics that capture animal welfare and related regulatory risks associated with live animal transportation, for example in-transit mortality rates and journey distances or durations.

Inconsistent terminology for direct livestock and crop production

78The industry description in the Meat, Poultry & Dairy SASB Standard uses the term 'animal raising' to refer to the primary production of livestock. However, several metrics, for example Land Use & Ecological Impact metrics, FB-MP-160a.8 and FB-MP-160a.9, and their associated technical protocols use the term 'direct farming'. In the Agricultural Products SASB Standard, 'direct farming', although not defined, typically refers to direct crop production. In the absence of an explicit definition, the use of the term ‘direct farming' across both Standards to describe different concepts could create confusion in practice.

79The TAC recommends that the ISSB considers adopting consistent terminology across the Meat, Poultry & Dairy and Agricultural Products SASB Standards to improve clarity and support consistent application. For example, instead of using 'direct farming' in the Meat, Poultry & Dairy SASB Standard, the ISSB could use terms such as 'primary livestock production' or 'animal raising' to avoid conflation with terminology used in the Agricultural Products SASB Standard. Alternatively, if the term 'direct farming' is intended to be used across both Standards, it should be explicitly defined to ensure that it can be applied consistently.

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

80The TAC broadly agrees that the proposed disclosure topics would help identify sustainability-related risks and opportunities that could reasonably be expected to affect an entity's prospects. However, the TAC has set out below suggested improvements.

Absence of Labour Conditions disclosure topic for own operations

81The TAC notes that metric FB-MP-430c.1, under the Social Supply Chain Management topic, requires disclosure of processes, controls and procedures for managing labour conditions and community-related matters in the supply chain. However, this disclosure is insufficient because it does not address labour conditions and labour practices in the entity's own operations, including livestock raising and meat processing. This creates an inconsistency between the Meat, Poultry & Dairy and Agricultural Products SASB Standards, given that the Agricultural Products SASB Standard includes a Labour Conditions metric for direct operations (FB-AG-310a.1). It is also inconsistent with the inclusion of a Workforce Health & Safety disclosure topic and related workforce metrics within the Meat, Poultry & Dairy SASB Standard itself. The absence of such a topic limits the availability of decision-useful information for investors about labour-related risks in entities' own operations.

82The TAC recommends that the ISSB considers including a Labour Conditions disclosure topic for own operations within the Meat, Poultry & Dairy SASB Standard, aligned with the comparable topic in the Agricultural Products SASB Standard. Meat and poultry processing activities are at least as labour-intensive as agricultural production and often present heightened labour-related risks. This is evidenced by UK regulatory and industry sources, which document the sector's heavy reliance on large workforces and its persistent exposure to labour shortages that can affect operational capacity and food safety.

Absence of Food Loss & Food Waste disclosure topic

83Meat, poultry and dairy products are highly perishable, making food loss a significant sustainability-related issue across the value chain. However, the proposed amendments do not include a Food Loss & Food Waste disclosure topic. As noted in the TAC's observations on the Agricultural Products SASB Standard, and in its response to the Processed Foods SASB Standards consultation in November 2025, food loss is a significant value-chain issue for food operators.

84The TAC recommends that the ISSB considers including a Food Loss & Food Waste disclosure topic in the Meat, Poultry & Dairy SASB Standard, to align it with the Agricultural Products SASB Standard, subject to the recommendation set out in paragraph 52. This would recognise the significant food loss and waste risks associated with the perishable nature of products in this industry, as well as other sustainability-related risks and opportunities.

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

85The TAC broadly agrees with the proposals, subject to the suggested improvements set out below.

Exclusion of Scope 3 metrics

86The TAC notes, consistent with the alternative view expressed by Dr Richard Barker, that for entities in the Meat, Poultry & Dairy industry, investor-relevant climate exposure is likely to arise significantly from purchased livestock and feed, land-use change, enteric methane, manure management and supplier farming practices. For entities with extensive third-party livestock or feed sourcing, climate exposure sits substantially within Scope 3, particularly Category 1 purchased goods and services.

87Consistent with its January 2025 letter to the ISSB, following the technical assessment of IFRS S2, the TAC emphasises the importance of industry-based guidance for Scope 3 emissions reporting, developed in collaboration with the GHG Protocol and other global standard setters. Such guidance should help identify which Scope 3 categories are likely to be material across different industries and sectors. This is particularly relevant to the Meat, Poultry & Dairy industry, where significant investor-relevant climate exposure may arise from Scope 3 emissions in purchased goods and services. This would improve decision-usefulness and comparability, particularly as entities reporting under ESRS are already required to consider significant value chain emissions.

Methane disclosure inconsistency with other SASB Standards

88The July 2025 SASB Exposure Draft for Oil & Gas Exploration & Production includes a standalone methane reduction target metric, EM-EP-110a.3. By contrast, the Meat, Poultry & Dairy Exposure Draft identifies methane as a climate-related risk but includes no equivalent reduction target metric and no explanation for this asymmetry is provided in the Basis for Conclusions.

89The TAC recommends that the ISSB considers including a comparable methane reduction target disclosure in the Meat, Poultry & Dairy SASB Standard to ensure consistency across industries where methane is identified as a climate-related risk.

Credibility and effectiveness of Nutrient Management Plan disclosure

90Metrics FB-MP-160a.9 and FB-MP-430b.3, require entities to disclose the percentage of livestock from direct farming operations and supply chain sourcing respectively, that maintain and implement a written Nutrient Management Plan (NMP). As noted in paragraph BC116 of the Basis for Conclusions, the objective of nutrient and manure management is to support soil health. However, the usefulness of this disclosure is limited by the absence of any mechanism to assess the credibility of the NMP, which is an important consideration for investors. A similar concern is reflected in Dr Richard Barker's Alternative Views on Land Use, where he notes that reporting the existence of a written NMP does not, in itself, provide decision-useful information regarding the plan's credibility, ambition, or effectiveness.

91In some jurisdictions, nutrient management is subject to regulatory requirements, providing a more objective basis for disclosure. For example, in the UK, The Department for Environment, Food and Rural Affairs (Defra) requires farms in England to comply with the Farming Rules for Water, with additional nutrient management requirements applying to farms located within Nitrate Vulnerable Zones.

92In addition, references to recognised certifications that incorporate nutrient management practices can provide greater confidence in the reported information.

93The TAC recommends that the ISSB considers improving the technical protocols by referencing the percentage of livestock from direct farming operations (FB-MP-160a.9) or sourced from third parties (FB-MP-430b.3) that comply with applicable or jurisdictional nutrient management requirements. Alternatively, the ISSB could improve the disclosure proposals to reference recognised certification schemes or other credible external validation mechanisms, rather than relying solely on the existence of a written NMP. This would enhance the decision-usefulness of the metric by providing greater insight into the credibility and effectiveness of nutrient management practices. In its current form, the metric may encourage binary, compliance-focused responses of limited value to investors.

Antibiotic use metric unit of measurement and differentiation of stewardship

94The antibiotic use metric, FB-MP-260a.1, requires disclosure of the percentage of animal production that received medically important antibiotics (that is, antibiotics that are also relied upon to treat infections in humans, the use of which for animals contributes to antimicrobial resistance and reduced effectiveness in human medicine) and, separately, antibiotics that are not medically important. The TAC notes, through stakeholder feedback, that this binary distinction is unlikely to produce decision-useful information for investors. An entity with strong antibiotic stewardship which only administers antibiotics when clinically indicated would report close to 100% in the medically important category and zero in the non-medically-important category. An entity with weaker stewardship practices could report an identical result if the antibiotics it administers happen to fall within the medically important classification. The metric therefore does not allow investors to distinguish responsible operators from less responsible ones.

95The TAC recommends that the ISSB considers replacing or supplementing the current percentage-based metric with an intensity-based measure expressed in milligrams of antibiotic used per Population Correction Unit (mg/PCU). This is the established standard unit used in regulatory and industry reporting across the UK and EU, including by the UK Veterinary Medicines Directorate in its annual UK Veterinary Antibiotic Resistance and Sales Surveillance (UK-VARSS) reports and by the Responsible Use of Medicines in Agriculture Alliance (RUMA) Targets Task Force. RUMA sets sector-specific mg/PCU targets for UK livestock producers across pigs, poultry and ruminants. Expressing antibiotic use as mg/PCU would normalise for herd size and animal type. This would enable meaningful comparison across entities and allow users to track performance trends over time, which the current percentage metric does not support.

Absence of a comparable 'sustainably managed land' metric

96The Agricultural Products SASB Standard introduces metric FB-AG-160a.3, which requires disclosure of the total area of land directly owned or controlled that is 'sustainably managed'. No comparable metric is included in the Meat, Poultry & Dairy SASB Standard despite similarities in sustainability-related risks and opportunities, as reflected by the inclusion of comparable spatial footprint metrics across the two Standards. This represents a potential gap in the coverage of land use sustainability-related risks and opportunities within the Meat, Poultry & Dairy SASB Standard.

97The TAC recommends that the ISSB considers addressing this gap by including a comparable metric, consistent with the approach taken in the Agricultural Products SASB Standard.

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

98The TAC has not obtained practical application evidence or other related observations to sufficiently assess the cost-effectiveness of the proposed disclosure metrics in the Environmental Supply Chain Management and Social Supply Chain Management disclosure topics. However, a recommendation for improvement in supply chain disclosure is set out below.

Animal health risks across business models

99The TAC supports the proposed updates to the Animal Health & Welfare topic, which address concerns that some metrics assumed entities directly manage livestock. The replacement of the own-operation metrics FB-MP-410a.1 (gestation crates) and FB-MP-410a.2 (cage-free eggs) with more flexible narrative disclosures, the recognition of value chain management in FB-MP-410a.4, and the focus on third-party certification in FB-MP-410a.3 each work for entities that only process products and do not raise animals themselves.

100By contrast, FB-MP-410a.5 (biosecurity risks and disease management) does not distinguish between entities that raise livestock and those that source animals from independent farmers. Biosecurity is primarily a farm-level activity, and processor-only entities can influence it only indirectly through supplier requirements. Without a clear scope, or an alternative basis of reporting for entities without primary livestock production, the metric risks producing information that is not decision-useful for those entities.

101The TAC recommends that the ISSB clarifies in the technical protocol for FB-MP-410a.5 that the metric is for entities with direct livestock operations, and that entities without such operations should instead describe how they manage biosecurity risks through their supply chain, for example through supplier standards, farm assurance schemes or veterinary audits. This would keep the disclosure decision-useful across different business models and consistent with the value chain approach already reflected in FB-MP-410a.4.

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

102The TAC's broader comments on international applicability, set out in response to Question 5, are also relevant to the ISSB's consideration of this industry.

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

103The TAC's broader comments on interoperability and alignment with other sustainability-related standards, frameworks and regulatory regimes, set out in response to Question 5, are also relevant to this industry.

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

104The TAC has not undertaken an exercise to identify metrics in the Meat, Poultry & Dairy SASB Standard that would most benefit from the proportionality mechanisms discussed in paragraphs BC47 to BC48. However, the TAC's broader comments on proportionality in response to Question 5 are also relevant to this industry.

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

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

105The TAC broadly agrees with the proposed industry description of the Electric Utilities & Power Generators SASB Standard, subject to the suggested improvements set out below. The revised description is more internationally applicable than the existing version, reducing its North American-centric framing and encompassing a wider range of electricity sector business models.

Integrated structure of IF-EU compared to other sectors

106The TAC notes that the integrated structure of the IF-EU contrasts with the approach taken in the Oil and Gas sector, where separate SASB Standards have been developed for each major segment of the value chain. While the TAC recognises that the ISSB has considered and decided against such disaggregation, drawing on stakeholder feedback, and acknowledges the inherent complexity of designing an international standard that accommodates diverse industry and market configurations, there appears to be scope to enhance the clarity of application.

107In particular, more explicit guidance within the technical protocols could be beneficial. This could follow an approach similar to that used in the Agricultural Products Standard, where specific topics are clearly signposted as applying only to entities engaged in direct farming activities. Including a similar structure within IF-EU would support entities with pure-play or partially integrated operations in identifying the disclosures most relevant to them.

Illustrative energy sources list

108The proposed industry description lists coal, natural gas, nuclear, hydropower, solar and wind as illustrative energy sources. The TAC acknowledges that this is framed as an illustrative list only and not exhaustive. However, the list omits key energy sources like bioenergy (which includes biomass and biofuels) and geothermal, both of which provide increasingly important renewable dispatchable baseload generation that complements variable renewable sources such as wind and solar. The TAC's engagement with preparers indicates that the exclusion of these energy sources from the illustrative list creates applicability ambiguity for generation entities operating these energy sources.

109The TAC recommends that the ISSB explicitly adds bioenergy and geothermal to the illustrative list of energy sources. Both are important technologies in the energy transition because they can provide firm, dispatchable or baseload renewable generation.

110Separately, the TAC notes that pumped hydro storage is becoming an increasingly important technology in the energy transition, providing large-scale, long-duration storage that supports the integration of variable renewables. In the UK, the expansion of these projects is supported by the UK Government's 'cap-and-floor' scheme, a regulatory mechanism that guarantees operators a minimum revenue (the floor) while limiting their maximum revenue (the cap), thereby reducing investment risk for these long-lived, capital-intensive assets. While the TAC notes that pumped hydro is referenced in the technical protocols under the installed and planned capacity metrics, the TAC recommends that the ISSB ensures that pumped hydro storage is sufficiently captured in its standard-setting activities relating to the energy transition.

Greenhouse Gas Emissions & Energy Resource Planning

Capacity metrics applicability and energy transition disclosure

111The proposed installed and planned capacity metrics, IF-EU-110a.5 and IF-EU-110a.6, are designed for entities whose capacity profile reflects owned or controlled generation assets. However, for a subset of entities within the IF-EU scope, the operationally relevant measure of supply capacity is not installed generation capacity, but contracted import capacity accessed via interconnectors and cross-border infrastructure. Applying IF-EU-110a.5 as currently drafted to such entities would result in installed capacity figures that systematically understate their actual supply capacity as this would omit the interconnector capacity that represents their primary operational and financial risk exposure. This structural anomaly is common among island electric operators that import nearly all their electricity supply via undersea cables, but also exists in other jurisdictions where interconnectors represent the principal source of supply capacity.

112The TAC further observes that capacity metric disclosures are more decision-useful when accompanied by information on the readiness and status of an entity's energy transition.

113The TAC recommends that the ISSB considers improving the IF-EU-110a.5 technical protocol, to clarify that entities for which contracted interconnector capacity constitutes the principal proxy for installed generation capacity should disclose their maximum import or transfer capacity (in MW or GW), in lieu of or alongside installed generation capacity. The technical protocol could also be improved further for entities to describe the nature, term and counterparty of their primary supply contract, given that the sustainability-related risks and opportunities associated with interconnector infrastructure are the direct equivalent of those associated with an owned generation asset portfolio.

114The TAC also recommends that the ISSB clarifies, either in the technical protocols for IF-EU-110a.5 and IF-EU-110a.6 or in narrative metric IF-EU-110a.7, that capacity disclosures reflect information on the status of the entity's generation mix transition.

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

115The TAC broadly agrees that the proposed disclosure topics would help entities in identifying sustainability-related risks and opportunities that could reasonably be expected to affect their prospects. However, related improvements are discussed alongside observations on metrics and technical protocols under Question 3(c) below, rather than as a separate analysis.

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

116Subject to the improvements set out below, the TAC broadly agrees that the proposed metrics and technical protocols would help entities provide primary users with decision-useful information. The observations and recommendations presented below respond to both Questions 3(b) and 3(c), reflecting that disclosure topics, metrics and technical protocols have been considered together in the TAC's analysis.

Biogenic CO2 emissions disclosure treatment

117The TAC notes an inconsistency in how biogenic CO2 emissions are treated under IF-EU-110a.1, depending on the framework under which entities apply the standard. Entities applying IF-EU on a standalone basis would likely follow the GHG Protocol Corporate Accounting and Reporting Standard (GHG Protocol Corporate Standard) for both measurement and disclosure, under which biogenic emissions are excluded from Scope 1, Scope 2 or Scope 3 and disclosed separately as an appendix or memorandum item. This approach is aligned with ESRS E1, which requires separate disclosure of biogenic emissions outside Scope 1, Scope 2 and Scope 3.

118By contrast, entities applying IF-EU within the scope of IFRS S2 are required to use the GHG Protocol Corporate Standard for measurement only, with IFRS S2 governing disclosure, and in practice this results in biogenic emissions being included within Scope 1, Scope 2 or Scope 3 totals, as appropriate, following the March 2026 Transition Implementation Group (TIG) determination. This undermines the interoperability objective set out in paragraph BC21 of the Basis for Conclusions and could lead to inconsistent reporting by economically similar entities applying the same IF-EU Standard.

119The TAC recommends that the ISSB considers improving the technical protocol for metric IF-EU-110a.1 to explicitly have consistent treatment of biogenic CO2 across all entities applying the IF-EU Standard, so that Scope 1, Scope 2 and Scope 3 disclosures are comparable irrespective of the overarching reporting framework applied. This would support interoperability for entities applying the IF-EU Standard under different reporting frameworks.

120The TAC notes, based on stakeholder feedback and research, that connections activity, being the process of connecting new generation and demand to the grid network, represents a significant sustainability-related risk and opportunity for Transmission and Distribution (T&D) operators, but is not adequately addressed in the proposed disclosures.

121The connection of new renewable generation is a primary mechanism for delivering the energy transition, and in some jurisdictions is substantial in scale. In the UK, for example, a FTSE 100 T&D operator has committed, under its current regulatory business plan (RIIO-T3), to connecting 35 GW of new generation and storage and 19 GVA (gigavolt-amperes - a measure of electrical network capacity) of demand, representing the most significant expansion of the transmission network in a generation. Separately, another UK FTSE 100 integrated electric utility has embedded renewables connections within the key performance indicators of its sustainability linked financing. Internationally, in the United States, developers identify grid interconnection delays as a leading cause of project cancellations, with connection timelines typically extending four to five years. These factors represent investor-relevant sustainability related risks and opportunities, with direct implications for decarbonisation pathways, regulatory returns and reputational standing.

122The TAC recognises that IF-EU-210a.2, which covers non-technical delays and days idle, may partially capture delays arising in the context of connections projects. However, this metric records the symptom, which is delay events and idle days, without disclosing the scale of the connections pipeline that gives those delays their investor significance. An entity connecting a large volume of new capacity and experiencing a given number of delay events presents a different sustainability profile from an entity with a negligible connections programme, even if both report the same number of non-technical delays.

123The TAC recommends that the ISSB consider clarifying, either in the IF-EU-110a.7 capital strategy narrative or the IF-EU-550a.5 operational resilience narrative, that entities should describe their connections pipeline and delivery performance when this is material. This could include: (a) the scale of generation, storage and demand connections committed or awaiting connection; (b) average connection timescales achieved relative to targets; and (c) the sustainability-related risks and opportunities associated with connections delivery. This information is already produced by some UK T&D operators in regulatory business plans and the Office of Gas and Electricity Markets (Ofgem) submissions, and is directly relevant to investors assessing the entity's role in, and exposure to, the energy transition.

Transmission & Distribution losses classification: Scope 2 vs Scope 3

124The proposed technical protocol for IF-EU-110a.2 classifies T&D losses as Scope 2 emissions. The TAC notes, through stakeholder engagement and research, that this classification is consistent with the current practice of the majority of comparable pure-play T&D network operators in the UK and internationally, particularly in New Zealand, Australia and Canada.

125However, the GHG Protocol Corporate Standard does not provide definitive guidance on the appropriate scope emissions classification for T&D losses from the perspective of the T&D network operator as the reporting entity. The Electric Power Research Institute (EPRI, a US-based independent non-profit electricity research organisation) confirms in its 2025 Technical Update on GHG Emissions Accounting for Electric Companies and Combined Utilities (EPRI Report 3002031993, March 2025, pages vii-viii), that guidance on this point 'is ambiguous and not definitive', that the appropriate classification depends in part on the entity's corporate structure and business model, and that multiple approaches are currently permissible under the existing GHG Protocol Corporate Standard (though potentially being considered further in the revision of the GHG Protocol Corporate Standard). As a result, divergent practice exists even within the UK, where one pure-play transmission operator classifies T&D losses as Scope 2 and another classifies them as Scope 3 while both apply the GHG Protocol Corporate Standard.

126The TAC considers that the proposed technical protocol does not adequately address this ambiguity. In particular, the protocol does not provide guidance or examples of the type of business models in which a Scope 3 classification might be appropriate.

127The TAC recommends that the ISSB:

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

Community Relations & Rights of Indigenous Peoples

Non-technical delay metric contradiction

128The technical protocol for metric IF-EU-210a.2 contains an internal contradiction that may make consistent application challenging. Paragraph 1.1 defines non-technical delays as including delays resulting from 'pending regulatory permits'. Paragraph 3 of the technical protocol then excludes 'technical situations unrelated to community-related risks (permitting delays)'.

129In practice, permitting delays and community-related risks in electricity infrastructure development are often inseparable. Planning applications are frequently delayed by community objections processed through the permitting system. For example, a delay arising from a judicial review initiated by a community group constitutes both a permitting delay and a community-related delay. Major UK electricity transmission infrastructure projects illustrate this dynamic clearly.

130The TAC recommends that the ISSB considers improving paragraph 3 of the IF-EU-210a.1 technical protocol to address this inconsistency. This could be achieved by clarifying that the exclusion applies only to purely administrative or procedural regulatory processes that are independent of community opposition. Providing an illustrative example would further enhance clarity and support consistent application.

Jurisdictional applicability of Indigenous Peoples metrics

131The technical protocols for IF-EU-210a.3 and IF-EU-210a.4 reference International Labour Organization (ILO) Convention 169 and the United Nations (UN) Declaration on the Rights of Indigenous Peoples. The UK has not ratified ILO Convention 169, and the UK Government's stated position is that the Convention cannot be implemented, as the UK has no indigenous peoples to whom it applies. As a result, entities with purely domestic UK operations applying these metrics would be likely to report nil or not applicable results by operation of jurisdictional context rather than through substantive assessment, which may limit the usefulness of the disclosures for investors.

132A related issue arises for entities operating across multiple jurisdictions where some jurisdictions establish formal obligations in relation to Indigenous Peoples' rights, such as Australia under the Native Title Act 1993, and others, including the UK, do not. In such cases, group-level disclosures that are not appropriately structured may obscure important jurisdictional distinctions. This is because the technical protocols appear to provide limited guidance on how the metrics should be applied when an entity operates across jurisdictions with different legal frameworks for Indigenous Peoples' rights.

133The TAC suggests that the ISSB considers adding a clarifying note to the IF-EU-210a.3 and IF-EU-210a.4 technical protocols. This could note that, for operations in jurisdictions without a domestic legal framework recognising indigenous peoples' rights, entities should state this explicitly and describe the community engagement and stakeholder rights mechanisms applied in such contexts, rather than reporting a nil figure or not applicable comment.

134The TAC also recommends that the technical protocols be improved to guide entities to provide disclosures by jurisdiction, or by groups of jurisdictions with comparable legal frameworks. This would help primary users understand where an entity's substantive exposure to Indigenous Peoples' rights arises.

Energy Affordability

Energy affordability metrics

135The TAC notes that the Exposure Draft proposes deleting IF-EU-240a.3, a quantitative metric on residential customer disconnections and reconnection rates, and IF-EU-240a.4, a narrative metric on external factors affecting customer affordability. The proposed replacement metrics include qualitative disclosure on affordability risks, opportunities and management strategies, and a quantitative metric on participation in affordability programmes. However, these proposed metrics do not provide an equivalent replacement for IF-EU-240a.3 as a direct affordability stress indicator, nor do they preserve the dedicated contextual affordability disclosure provided by IF-EU-240a.4. The TAC considers that affordability disclosures would be less decision-useful without both a quantitative indicator of customer affordability stress and contextual information on the external drivers of affordability pressure.

136The TAC recommends that the ISSB reinstates metrics IF-EU-240a.3 and IF-EU-240a.4. IF-EU-240a.3 is the only quantitative, directly comparable affordability stress indicator in the Standard, and IF-EU-240a.4 is the only mechanism for contextualising affordability disclosures against external drivers such as commodity price movements, geopolitical supply disruptions and climate-related events. Their deletion removes investor-useful information at a time when UK domestic energy debt and arrears have been rising, and affordability pressures remain elevated.

Workforce Health & Safety

Gap in safety metrics for injuries to members of the public

137The proposed Workforce Health & Safety metric IF-EU-320a.1 covers Total Recordable Injury Rate (TRIR) and fatality rates for employees and non-employee workers. However, it does not capture fatalities or serious injuries to members of the public arising from the entity's assets or operations where the entity is liable, such as incidents involving electricity infrastructure. For transmission and distribution operators, such public safety incidents can give rise to significant regulatory, financial and reputational risks. The TAC recognises that the Exposure Draft includes a separate Critical Incident Risk Management disclosure topic. However, that topic does not provide a clear or systematic basis for reporting public safety incidents that do not meet the threshold of a 'critical incident', but may nevertheless give rise to significant regulatory, financial and reputational risks, for example for T&D entities.

138The TAC notes, based on stakeholder engagement and research, that public safety incidents are receiving increased investor and regulatory scrutiny. Public safety reporting is already established among major transmission and distribution operators in some jurisdictions. In Australia, for example, network operators publish regulatory safety reports that include quantitative incident metrics for public safety, including incidents relating to safety of members of the public, unintended contact, unauthorised access and electric shocks involving network assets. In the UK, some network operators also report publicly on public safety management and education activities. This demonstrates that public safety is already recognised.

139The TAC recommends that the ISSB incorporates public safety within the existing narrative metric IF-EU-320a.2, which requires disclosure of management systems used to foster a safe working environment. The technical protocol should clarify that entities should describe how they manage and, where relevant, report fatalities and serious injuries to members of the public attributable to the entity's assets or operations, where the entity is liable.

Employee Recruitment, Development & Retention

Employee skill shortage categorisation

140The technical protocol for IF-EU-330a.2 leaves the determination of which occupational categories constitute a skill shortage to the reporting entity's judgement, with no external reference point. Through stakeholder engagement and research, the TAC notes that without an objective reference point, entities may populate this metric on entirely different bases, limiting its comparability across reporters.

141The TAC recommends that the ISSB considers improving the technical protocols to have regard to, at a minimum, illustrative occupational categories identified as experiencing a shortage in an official government or recognised industry labour market assessment applicable to their jurisdiction(s).

142The TAC further notes that skill shortages are likely to be a common issue across other industries with specialised skills needs, and recommends that the ISSB applies a consistent approach to this topic across those industries as relevant.

Demand-side management

Aggregator-managed flexibility in demand-side management metrics

143Proposed metrics IF-EU-420a.4, IF-EU-420a.5 and IF-EU-420a.6, require disclosure of demand-side management-related risks, opportunities and strategies; participation in demand-side management-related actions or programmes; and peak demand savings from those strategies respectively. As drafted, the metrics reflect a traditional model in which a licensed electricity supplier (retailer) directly incentivises its own customers to reduce or shift consumption. The TAC notes, through research and stakeholder engagement, that this framing does not accommodate a structural feature of modern electricity markets that is already important in the UK and growing internationally.

144A distinct market structure has emerged in which demand response may be managed by an energy aggregator or technology platform, including independent aggregators and supplier-operated platforms. These platforms contract directly with customers to control customer-owned assets, such as EV chargers and home batteries, aggregate the resulting flexibility capacity, and offer that capacity into grid balancing markets through bidding processes.

145A major UK-based energy group's technology platform has reported managing over 2 GW of customer-owned energy devices, including EVs, home batteries, heat pumps, solar panels and smart thermostats, as a residential virtual power plant. This is equivalent in scale to several mid-sized power stations and demonstrates the scale at which aggregator-managed flexibility is now emerging. None of this capacity would be captured under the current metrics if the assets are customer-owned and the flexibility is managed through a platform rather than a traditional supplier programme.

146The TAC recommends that the ISSB amend the technical protocols for IF-EU-420a.4, IF-EU-420a.5 and IF-EU-420a.6 to clarify that the Demand-side Management disclosure topic includes flexibility delivered through aggregator-managed programmes.

Supply Chain Management

Supply chain disclosure for bioenergy operators

147The proposed Supply Chain Management metrics cover Human Rights Due Diligence (HRDD) processes, and the percentage of high-risk suppliers audited. Through stakeholder engagement and research the TAC notes that, for bioenergy plant operators, particularly those using biomass, neither metric addresses what may be the most financially and operationally significant supply chain question: the environmental sustainability of sourcing inputs. This includes, for example, whether bioenergy is sourced from sustainably managed forests, including in relation to deforestation and conversion, soil and water quality, and biodiversity. Instead, the proposed metrics appear calibrated for diversified procurement of manufactured components and may be structurally misaligned with the dominant supply chain risk profile of bioenergy generation.

148The TAC recommends that the ISSB considers improving the technical protocols for IF-EU-430a.1 and IF-EU-430a.2 to guide entities for which bioenergy constitutes a significant proportion of fuel inputs. For such entities, the description of supply chain management processes could include the certification frameworks applied to bioenergy sourcing and the entity's approach to verifying the environmental sustainability of that sourcing, including, for example, verification of deforestation- and conversion-free status. This would improve the relevance of disclosures for these entities through clarification in the technical protocols, without introducing new metrics.

Circular definition of ‘high-risk suppliers'

149IF-EU-430a.2 defines high-risk suppliers as those where the entity has 'determined a heightened level of risk.' This appears circular as an entity self-selects based on its internal determination of which suppliers count as high-risk, audits those suppliers and reports the resulting percentage coverage. An entity facing severe supply chain risks but applying a narrow internal definition of high-risk can report 100% audit coverage, while a similar but more transparent entity defining high-risk more broadly may appear to be performing relatively poorly.

150The TAC recommends that the ISSB considers establishing a minimum threshold by reference to an objective external framework, such as the Responsible Minerals Initiative country risk assessments or other recognised global frameworks, to enhance the credibility of the assessment. It should also clarify that value chain scope includes, at a minimum, Tier 1 direct suppliers.

Operational Resilience & System Reliability

SAIDI/SAIFI/CAIDI calculation methodology

151The technical protocol for IF-EU-550a.2 requires SAIDI, SAIFI and CAIDI to be calculated in accordance with IEEE Std 1366. While these reliability indices are widely used internationally, IEEE Std 1366 is a North American-origin Standard and its prescribed methodology may not align with the methodologies required by electricity regulators in other jurisdictions. For example, UK Distribution Network Operators report to Ofgem using Customer Interruptions and Customer Minutes Lost metrics under RIIO-ED2, with Ofgem-specific definitions and exclusions for interruptions. Similarly, Australian regulators use jurisdiction-specific reliability measures and definitions, and European regulators apply national methodologies that can affect the comparability of SAIDI, SAIFI and CAIDI reporting.

152The TAC recommends that the ISSB considers amending the technical protocol to permit entities to report reliability metrics using the calculation methodology required by their primary electricity regulator, provided that the entity discloses the standard or methodology applied. This would improve international applicability while preserving transparency for primary users.

Commercial sensitivity of generation asset availability disclosure

153The new metric IF-EU-550a.3 requires disclosure of average availability factors disaggregated by major energy source. For dispatchable generators such as biomass, gas peaking and pumped hydro operating in competitive wholesale electricity markets, fuel-type disaggregation can reveal asset-specific maintenance patterns and unplanned outage frequency, informing bilateral trading and forward hedging strategies.

154This concern has precedent. In the United States, detailed generator availability and outage data collected by the North American Electric Reliability Corporation (NERC) are not publicly disclosed at plant level and are instead restricted or published in aggregated form, reflecting their commercial sensitivity and potential market impact. Similarly, the Federal Energy Regulatory Commission (FERC) limits disclosure of certain operational data where it may affect market behaviour or system security. In the UK, Ofgem has recognised that generator operational behaviour can influence wholesale prices and has introduced licence conditions to mitigate the risk of market manipulation. These precedents indicate that disaggregated availability data may have strategic value in competitive wholesale markets. The risk is greatest for entities with a small number of dispatchable assets, where fuel-source disaggregation may approximate asset-level disclosure, and is less significant for weather-dependent generation such as wind and solar.

155The TAC recommends that the ISSB acknowledges this issue in the technical protocols and permits entities, when fuel-source disaggregation would reveal commercially sensitive information in a competitive wholesale market context, to disclose availability at the portfolio level, with an explanation of why disaggregation has not been provided.

Multi-hazard counting in vulnerable asset disclosures

156The technical protocol for IF-EU-550a.4 requires disclosure of the amount and percentage of assets vulnerable to climate-related physical risks, disaggregated by industry asset type and by specific climate-related physical risk. However, the protocol does not clarify how assets exposed to multiple concurrent climate-related hazards should be treated in this disaggregated disclosure. This could create inconsistent reporting because the same asset could be counted once in the overall vulnerable asset percentage, but multiple times across the hazard-level disaggregation.

157This issue is particularly relevant for electricity networks, where a single asset may be exposed to several concurrent hazards. For example, coastal substations may be exposed to flooding, sea level rise, coastal erosion and salt-induced corrosion. Without clear guidance, entities with similar risk profiles could report different vulnerable asset percentages depending on whether they count each asset once or count it separately for each hazard. This would reduce comparability and make it harder for primary users to understand the scale and nature of climate-related physical risk exposure.

158The TAC recommends that the ISSB clarifies in the technical protocol for IF-EU-550a.4 that an asset exposed to multiple hazards is counted once in the overall percentage of vulnerable assets, but disclosed under each relevant hazard category in the disaggregated breakdown. The protocol should further clarify that, as a result, the disaggregated hazard-level figures would not necessarily sum to the overall total. This would support more consistent and comparable reporting while preserving useful information about the specific hazards to which assets are exposed.

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

159Broadly, the TAC agrees that the proposed amendments improve the international applicability of the IF-EU Standard. However, further improvements are recommended to address areas where US-centric regulatory assumptions continue to constrain broader international applicability and decision usefulness of reported information. Evidence from UK entities with operations spanning the UK, Australia, Hong Kong and the United States illustrates this challenge directly.

160A number of technical protocol issues discussed elsewhere in this response have direct international applicability dimensions. These are addressed in the context of their respective metrics under Questions 3(b) and 3(c) above and are cross-referenced below for completeness:

The reference to IEEE Std 1366 in IF-EU-550a.2, which may not align with reliability reporting methodologies used by regulators in jurisdictions such as the UK, Australia and Europe.
The inapplicability of IF-EU-210a.3 and IF-EU-210a.4 to entities operating in jurisdictions that have not ratified ILO Convention 169; and
The omission of bioenergy and geothermal from the illustrative energy source list.

161The TAC also recommends that the ISSB considers including implementation guidance sections in IF-EU explaining how entities with operations across multiple electricity regulatory regimes should structure group-level IF-EU disclosures, particularly for quantitative metrics where jurisdictional aggregation methodology is currently unspecified.

162The TAC's broader comments on international applicability, set out in response to Question 5, are also relevant to the ISSB's consideration of this industry.

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

163The TAC agrees that the proposed amendments have the potential to enhance interoperability. However, the different treatment of biogenic CO2 emissions under IFRS S2 and the GHG Protocol, discussed in response to Question 3(b), could result in inconsistent reporting by entities applying IF-EU. The TAC therefore recommends that the technical protocol is amended to address this issue.

164The TAC's broader comments on interoperability and alignment with other sustainability-related standards, frameworks and regulatory regimes, set out in response to Question 5, are also relevant to this industry.

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

165The TAC has not undertaken an exercise to identify metrics in the Electric Utilities & Power Generators SASB Standard that would most benefit from the proportionality mechanisms discussed in paragraphs BC47 to BC48. However, the TAC's broader comments on proportionality in response to Question 5 are also relevant to this industry.

Questions 4 to 6

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

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

166In its November 2025 response to the ISSB's separate consultation on making consequential amendments to the IFRS S2 Industry-based Guidance, the TAC supported maintaining alignment between the IFRS S2 Industry-based Guidance and the climate-related content in the SASB Standards. The TAC continues to support maintaining alignment between the IFRS S2 Industry-based Guidance and the climate-related content in the SASB Standards.

167The TAC therefore agrees that the ISSB should make consequential amendments to the IFRS S2 Industry-based Guidance when it makes amendments to the SASB Standards, subject to the TAC's comments on the ISSB's proposed amendments to the SASB Standards.

QUESTION 5 – Relationship with IFRS Sustainability Disclosure Standards

Do you agree with the ISSB's proposed approach to amending the SASB Standards in relation to the content in IFRS Sustainability Disclosure Standards? Why or why not?
Do you agree that, for preparers applying the SASB Standards as well as IFRS Sustainability Disclosure Standards, the relationship between their contents is sufficiently clear? Why or why not?

168The TAC does not agree:

with the ISSB's proposed approach to amending the SASB Standards in relation to the content in IFRS Sustainability Disclosure Standards; and
that, for preparers applying the SASB Standards as well as IFRS Sustainability Disclosure Standards, the relationship between their contents is sufficiently clear.

169In Appendix 1 of its November 2025 response, the TAC made a number of general points. The TAC's general points did not answer the specific questions posed by the ISSB in the ISSB's July 2025 Exposure Draft of Proposed Amendments to the SASB Standards, but did comment on:

the ISSB's proposed approach to amending the SASB Standards in relation to the content in IFRS Sustainability Disclosure Standards; and
the relationship between the content in the SASB Standards and IFRS Sustainability Disclosure Standards.

170The TAC's general points included recommendations in relation to the ISSB:

communicating the future architecture of IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture;
considering restructuring the SASB Standards so that the SASB Standards would focus only on industry-specific disclosures;
emphasising a principles-based approach so that the SASB Standards keep pace with changes;
reconsidering the name of the SASB Standards;
considering adopting a climate-first thematic approach; and
applying the level of due process to the SASB Standards that is commensurate to the role they will play in the future architecture of IFRS Sustainability Disclosure Standards.

171In Appendix 2 of its November 2025 response, the TAC also made a number of general points, including in relation to the ISSB's aims of:

aligning the language and concepts with IFRS Sustainability Disclosure Standards;
enhancing the international applicability of industry groupings, disclosure topics, metrics and supporting technical protocols; and
improving interoperability with the GRI Standards, ESRS and TNFD.

172The TAC continues to reiterate the importance of the points it made in its November 2025 response, but further develops its points in relation to the:

current architecture of IFRS Sustainability Disclosure Standards, including the incorporation of the SASB Standards;
strategy for enhancing the SASB Standards; and
approach to the ISSB's project to enhance the SASB Standards.

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

173In its November 2025 response, the TAC recommended that, as a priority, the ISSB communicates the future architecture of IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture.

174The TAC's November 2025 response focused on the role of the SASB Standards as industry-based sustainability disclosures that support the application of IFRS S1 and IFRS S2 and the TAC strongly supported the ISSB's aim of aligning the language and concepts with IFRS Sustainability Disclosure Standards.

175However, the TAC believes that there is a tension between the role of the SASB Standards in complementing IFRS Sustainability Disclosure Standards and as a standalone resource. It may be challenging for one set of materials to fulfil both roles effectively.

176The historical inconsistency between the way the SASB Standards approach Scope 1 and Scope 3 greenhouse gas emissions illustrates these problems with the current architecture of the IFRS materials and how the SASB Standards fit into that architecture, including their dual role. For example:

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

177It therefore does not seem compatible for the SASB Standards to both avoid unnecessary duplication of requirements already included in IFRS S1 and IFRS S2, and to set out disclosure topics and metrics that will typically be applicable for an entity with the business model and associated activities of specific industries.

178The TAC believes that the challenges for preparers applying the SASB Standards as well as IFRS Sustainability Disclosure Standards include the issues mentioned in its responses to questions 1 to 3, as well as in relation to the:

unclear status of the SASB Standards in the IFRS materials;
prescriptive nature of the SASB Standards, including unclear materiality principles;
duplication between the SASB Standards and IFRS Sustainability Disclosure Standards; and
inconsistency in and between the SASB Standards.

Unclear status of the SASB Standards in the IFRS materials

179IFRS Sustainability Disclosure Standards state that entities ‘shall' refer to and consider the applicability of the SASB Standards when identifying sustainability-related risks and opportunities and when preparing related disclosures.

180In its November 2025 response, the TAC noted that its stakeholder outreach and research activities suggest that there is confusion about the status of the SASB Standards in the IFRS materials because of these requirements. The TAC's November 2025 response states:

Some preparers considered the word 'shall' to be prescriptive and having the potential to cause reporting burdens and assurance challenges. Such preparers note that the [proposed amendment in the UK Government consultation on UK Sustainability Reporting Standards that ‘shall' should be amended to ‘may'] enables entities to apply judgement in determining the extent of use of the SASB Standards for their reporting.

181Following the submission of the TAC's November 2025 response, the UK Government's response to its consultation on UK Sustainability Reporting Standards concluded that:

Following stakeholder responses, and noting the majority support received, the government has decided to maintain the proposed amendment...

182A stakeholder also noted that there was still confusion about the status of the SASB Standards in the IFRS materials and welcomed the amendment in UK Sustainability Reporting Standards as clarifying that the status of the SASB Standards in the UK is that of guidance.

183The TAC suggests that the ISSB considers ways to clarify the status of the SASB Standards in the IFRS materials and has made various suggestions which may help diminish confusion, including renaming the SASB Standards, in the section on Strategy for enhancing the SASB Standards.

Prescriptive nature of the SASB Standards, including unclear materiality principles

184In its November 2025 response, the TAC noted that stakeholders expressed concerns about the prescriptive nature of the SASB Standards, viewing them as a potentially onerous reporting burden and believing they lack the materiality principles in IFRS Sustainability Disclosure Standards.

Most stakeholders recommended a shift towards a principles-based and proportionate approach consistent with IFRS S1 and IFRS S2. Preparers cautioned that an overly prescriptive approach may discourage disclosure, particularly in cases where entities do not possess the necessary data or rely on alternative measurement methodologies. They emphasised the need for industry standards that accommodate varying levels of data availability and reporting maturity.

185Examples of the content of the SASB Standards being prescriptive include in relation to the:

Application of materiality: The inclusion of disclosure topics and metrics that will typically be applicable for entities in specific industries may lead preparers to believe that the related disclosures are likely to be material for all entities in specific industries. The TAC's November 2025 response therefore states that entities should be encouraged not to disclose information otherwise suggested by a SASB Standard if the information is not material.
Use of 'shall' in the technical protocols: The technical protocols repeatedly use 'shall' language, which may mislead preparers into believing the related disclosures are mandatory, irrespective of materiality or business model applicability.
Proportionality mechanisms: Paragraphs BC47–BC48 of the Basis for Conclusions state that the concept of 'all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort' applies to disclosures with reference to the SASB Standards when relevant. However, the paragraphs further state that the concept would apply to value chain determinations, but not ‘in other circumstances' in relation to the SASB Standards. The statement appears to be a clarification, however, its wording is ambiguous and may suggest a greater use of proportionality mechanisms is possible in IFRS Sustainability Disclosure Standards than in the SASB Standards.

186The TAC suggests that the ISSB considers including in each SASB Standard a clarifying statement, either in the introductory provisions or an application note. The statement would clarify that the conceptual foundations and principles in IFRS Sustainability Disclosure Standards, including the materiality principles and proportionality mechanisms (such as the concept of 'all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort'), apply in the same way to the SASB Standards as they do to IFRS Sustainability Disclosure Standards. Such a statement would reduce interpretive uncertainty without requiring wholesale redrafting.

Duplication between the SASB Standards and IFRS Sustainability Disclosure Standards

187In its November 2025 response, the TAC suggested that the ISSB considers the duplication between the SASB Standards and IFRS Sustainability Disclosure Standards.

188As well as the potential duplication of the requirements in IFRS S2 in relation to Scope 1 greenhouse gas emissions, there is also, as the ISSB suggests in paragraph BC45 of the Basis for Conclusions, potential duplication of governance, strategy and risk management disclosures.

189The TAC therefore reiterates its suggestion that the ISSB considers the duplication between the SASB Standards and IFRS Sustainability Disclosure Standards and has made various suggestions which may help avoid duplication, including restructuring the SASB Standards, in the below section on Strategy for enhancing the SASB Standards.

Inconsistency in and between the SASB Standards

190In its November 2025 response, the TAC agreed with the ISSB's stated intention of enhancing the clarity, conciseness and cost-effectiveness for preparers and recommended that the ISSB considers making further improvements to the consistency of the terminology used in the SASB Standards.

191Following the submission of the TAC's November 2025 response, the TAC has noted a number of differences in the nature-related disclosure topics and metrics in the 77 SASB Standards. The reasons for the variations are not always clear. For example, the table below highlights four disclosure topics with different names, but that are essentially the same, as they have the same metrics and technical protocols. Having different names suggests they are different.

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

192The TAC has also noted the number of different qualifying terms to scope disclosures, including 'priority products', 'priority sourced' products, 'high-risk suppliers', and 'medically important' antibiotics.

193The inconsistency in these terms could compromise the clarity, conciseness and cost-effectiveness for preparers (and other stakeholders). Preparers (and other stakeholders) could dedicate resources to considering the implications of the differences between similar, but not identical, terms and the judgement involved in doing so means there could be differences in interpretation. Preparers (and other stakeholders) could experience further challenges because of the lack of alignment with the terminology used in IFRS Sustainability Disclosure Standards.

194The TAC therefore reiterates its suggestion that the ISSB considers making further improvements to the consistency of the terminology used in the SASB Standards and has made various suggestions which may help improve consistency, including restructuring the SASB Standards, in the below section on Strategy for enhancing the SASB Standards.

Strategy for enhancing the SASB Standards

195Following the completion of Phase 1 of the ISSB's project on Enhancing the SASB Standards and the amendments to the twelve priority industries, the TAC suggests that the ISSB pauses its review of specific industries and reconsiders its approach to amending the SASB Standards in light of stakeholder feedback so far, as well as other developments. This includes the ISSB's tentative decision to issue further guidance materials in the form of a Practice Statement for nature-related disclosures. In its November 2025 response, the TAC recommended that the ISSB seeks stakeholder views on the architecture of IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture. The TAC notes that the next agenda consultation is one such opportunity for the ISSB to seek further stakeholder views.

196In its November 2025 response, the TAC recommended that the ISSB strategy for enhancing the SASB Standards links to the architecture of IFRS Sustainability Disclosure Standards and prioritises simplification, so that the SASB Standards are straightforward to apply and it is easy to understand their output. The response states:

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

197In its November 2025 response, the TAC suggests a strategy for enhancing the SASB Standards, which could provide a number of possible solutions to the problems with the current architecture of the IFRS materials and how the SASB Standards fit into that architecture. The suggested strategy includes:

restructuring the SASB Standards;
emphasising principles, not rules; and
renaming the SASB Standards.

Restructuring the SASB Standards

198In its November 2025 response, the TAC recommended that the ISSB consider restructuring the SASB Standards to distinguish between 'core' disclosures, 'industry-agnostic' disclosures and ‘industry-specific' disclosures. The terms 'core' disclosures, ‘industry-agnostic' disclosures and 'industry-specific' disclosures have the following meanings:

'core' disclosures are relevant to all entities applying IFRS Sustainability Disclosure Standards and could relate to general disclosures about governance, strategy and risk management;
'industry-agnostic' disclosures are metrics that could be relevant to entities in different industries (i.e. cross-industry metrics). They do not have to be tailored to specific industries and can be used in an identical way for any industry that has identified risks or opportunities related to the topic; and
'industry-specific' disclosures are metrics that are only relevant to entities in specific industries (i.e. industry-specific metrics).

199An example of how the ISSB could accomplish such a restructuring is demonstrated as follows for the topic of ‘Water management'.

Topic: Water management

Core disclosures

E.g. relating to governance, strategy and risk management

Industry-agnostic disclosures

(1) Total water withdrawn, (2) total water consumed; percentage of each in regions with High or Extremely High Baseline Water Stress

Industry-specific disclosures

Oil & Gas – Exploration & Production (EM-EP)	Marine Transportation (TR-MT)
Percentage of hydraulically fractured wells for which there is public disclosure of all fracturing fluid chemicals used	(1) Total amount of ship waste discharged to the environment, (2) percentage treated prior to discharge
	Percentage of fleet implementing ballast water (1) exchange and (2) treatment

200In its November 2025 response, the TAC also recommended that the ISSB consider moving core and industry-agnostic disclosures out of the SASB Standards and into IFRS S1, IFRS S2 and any further topic-specific materials, so that the SASB Standards would focus only on industry-specific disclosures.

201The TAC reiterates that these recommendations could help simplify the SASB Standards by reducing the volume and making the content more accessible. However, the TAC cautions against making amendments to IFRS S1 and IFRS S2 which would disrupt their ongoing implementation.

202The TAC suggests that the ISSB considers possible interim solutions which would not involve amending IFRS S1 and IFRS S2 or issuing any further topic-specific materials. Such solutions could include:

restructuring the SASB Standards as shown in paragraph 199 without moving any disclosures out of the SASB Standards and into IFRS S1, IFRS S2 and any further topic-specific materials;
moving the non-climate-related industry-agnostic disclosures into a new technical guidance document to support IFRS S1. As IFRS S1, IFRS S2 and the IFRS S2 Industry-based Guidance include core disclosures and climate-related industry-agnostic and industry-specific disclosures, the SASB Standards could then focus only on the non-climate-related industry-specific disclosures; or
greying out the core disclosures and climate-related industry-agnostic and industry-specific disclosures in the SASB Standards which are already included in IFRS S1, IFRS S2 and the IFRS S2 Industry-based Guidance.

Emphasising principles, not rules

203In its November 2025 response, the TAC noted that the SASB Standards will have to be updated for rapidly evolving sustainability-related issues and recommended that the ISSB emphasises principles, not rules, so that the SASB Standards do not have to be adapted so much to keep pace with changes.

204An example of a rapidly evolving sustainability-related issue is in relation to energy. The TAC's stakeholder outreach and research activities found that there are already rapid changes in the energy landscape, including energy aggregators. However, significant further changes are expected in the global energy landscape due to, for example, energy transition, the importance of resilience and agility, and innovations due to Al. The SASB Standards would ideally be developed in such a way that they can continue to be applied notwithstanding these changes.

205The TAC's recommendation that the ISSB emphasises principles, not rules, in line with the TAC's recommendation that the architecture of IFRS Sustainability Disclosure Standards, including how the SASB Standards fit into that architecture, prioritises the continuance of the global baseline of sustainability disclosures for capital markets established by IFRS S1 and IFRS S2.

206Emphasising principles, not rules, would also support the ISSB's aims of:

aligning the language and concepts with IFRS Sustainability Disclosure Standards;
enhancing the international applicability of industry groupings, disclosure topics, metrics and technical protocols; and
improving interoperability with the GRI Standards, ESRS and TNFD.

207A number of preparers commented that their disclosures would evolve considerably over the next few years. There is a risk that the number of industry-specific disclosures in the SASB Standards exceed the global baseline, diluting focus on the implementation of IFRS S1 and IFRS S2 and on the provision of decision-useful information. There may also be tradeoffs between the quality and quantity of disclosures and between the resources devoted to managing risks and the resources devoted to reporting risks. There is a case for allowing practices in relation to industry-specific disclosures to emerge naturally first, driven by the market, and then for standardisation to follow once practices are better developed and have begun to converge.

Renaming the SASB Standards

208In its November 2025 response, the TAC recommended that the ISSB reconsiders the name of the SASB Standards and suggested that they are renamed the 'ISSB Guidance on the Industry-based Sustainability Disclosures'. The TAC's November 2025 response states that the current project presents the opportunity to rename the SASB Standards:

...to clearly demonstrate the link to the IFRS Sustainability Disclosure Standards and also to reaffirm the status of these materials as 'guidance'.

209The TAC reiterates that this recommendation could help clarify the status of the SASB Standards in the IFRS materials. The industry-specific disclosures could also be presented as illustrative examples.

Approach to the ISSB's project to enhance the SASB Standards

210In its November 2025 response, the TAC recommended that the ISSB considers adopting a climate-first thematic approach to its project to enhance the SASB Standards, by:

incorporating core and industry-agnostic climate-related disclosures from the SASB Standards into IFRS S2 first;
making any enhancements to industry-specific climate-related disclosures in the SASB Standards at the same time; and
enhancing the content related to other topics in the SASB Standards alongside developing further topic-specific materials.

211The TAC cautioned that the ISSB's proposed piecemeal approach to enhancing the climate-related content in the SASB Standards meant that the IFRS S2 Industry-based Guidance would be continuously revised, which could be extremely resource intensive and disruptive.

212Following the submission of the TAC's November 2025 response, the TAC's stakeholder outreach and research activities found that numerous preparers used several, rather than only one, SASB Standards. If the ISSB continues updating the SASB Standards for priority industries, then preparers may be using a mixture of older and newer versions of the SASB Standards, which could also be resource intensive and disruptive. This further supports the TAC's suggestion that the ISSB considers adopting a climate-first thematic approach.

213In its November 2025 response (paragraph 21), the TAC stated that if the ISSB continues to prioritise industries for enhancement, rather than adopting a climate-first thematic approach, the TAC encourages the ISSB to issue proposed amendments to all SASB Standards in a sector together as was the case for the SASB Standards in the Extractives & Minerals Processing sector. The TAC believes that updating only three of the eight SASB Standards within the Food & Beverage sector in isolation stops stakeholders from fully assessing overall coherence. A concurrent review of all eight SASB Standards in this sector would have enabled more informed and holistic feedback, particularly in relation to consistency across the sector and value chain effects.

214The TAC therefore recommends that the ISSB issues the three updated SASB Standards within the Food & Beverage sector on a provisional basis. Entities can then choose whether to use the updated SASB Standards or the existing SASB Standards for those industries. The SASB Standards can then be finalised when all eight of the SASB Standards within the Food & Beverage sector have been updated.

QUESTION 6 – EFFECTIVE DATE

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

215In its November 2025 response, the TAC made the following points.

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

216The TAC continues to reiterate the importance of these points. The TAC also notes that the issue of the effective date is another example of the tension between the role of the SASB Standards in complementing IFRS Sustainability Disclosure Standards and as a standalone resource. An effective date may be essential for SASB Standards used as a standalone resource but perhaps not as critical for SASB Standards used as guidance material to accompany IFRS Sustainability Disclosure Standards.

217Finally, if the ISSB agrees with the TAC's suggestion to issue the three updated SASB Standards within the Food & Beverage sector on a provisional basis, then further consideration will need to be given as to effective date.

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

218The TAC responded to the July 2025 Exposure Draft and continues to reiterate the importance of the points it made in its November 2025 response, but further develops its points in its response to question 5 and in relation to the proposed amendments related to nature.

219In its November 2025 response, the TAC did not support the ISSB's aim of aligning the enhancements with the ISSB's research projects on nature as the research project had not been completed and a number of the nature metrics may be industry-agnostic disclosures.

220Following the submission of the TAC's November 2025 response and in light of the ISSB's further discussions and decisions on nature-related disclosures, the TAC continues to reiterate its concerns that the ISSB's consultations on the proposed amendments to the SASB Standards for specific industries will not enable the ISSB to conclude on whether the SASB Standards enable entities to provide decision-useful information about their nature-related risks and opportunities to users of general purpose financial reports. This is because:

the consultation questions are industry-specific and do not focus on the ISSB's overall strategy in relation to nature-related disclosures;
the respondents to these consultations will most likely be stakeholders who are currently using the SASB Standards, and such stakeholders will not necessarily be experts on nature-related disclosures; and
while disclosure topics and metrics are likely to provide users with some decision-useful information about an entity's nature-related risks and opportunities, there is no evidence that the SASB Standards provide a global baseline of nature-related disclosures for capital markets.

221The TAC therefore believes that the ISSB should not conclude on nature-related disclosure requirements based on its consultations on the SASB Standards.

This paper has been prepared by the Secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC) to discuss in a public meeting. This paper does not represent the views of the TAC or any individual TAC member.

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

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