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Nature-related Disclosures Exposure Draft: Project management plan and timeline
NATURE-RELATED DISCLOSURES EXPOSURE DRAFT Project management plan and timeline
Context
1Following the conclusion of its research project on nature-related disclosures in December 2025, the ISSB has been deliberating on a proposed Practice Statement for nature-related disclosures. An Exposure Draft is anticipated to be published for consultation in October 2026 for a 120-day period.
2The TAC will prepare and submit a response to this consultation. This document sets out the project management plan and proposed timeline for this influencing project.
3The project management plan and proposed timeline are being presented ahead of the publication of the Exposure Draft to provide the TAC with the maximum opportunity to engage stakeholders and discuss the draft's content in scheduled public meetings. It is anticipated that the Exposure Draft will be published on the 22 October 2026, during the 2026 UN Biodiversity COP (COP17). As a result, the TAC's first opportunity to consider the Exposure Draft will be at its November meeting. Given that the holiday period is likely to reduce opportunities for stakeholder engagement during December, the TAC Secretariat is keen to begin planning engagement activities as early as possible following publication. Presenting the project management plan and proposed timeline now will enable advance planning of stakeholder engagement activities.
Role of the TAC
4In the priorities letter sent to the TAC in March 2026, the Department for Business and Trade (now the Department for Business, Innovation, Science and Trade) asked the TAC to influence the development of the ISSB's standard-setting project on nature-related disclosures, including assessing and responding to the anticipated Exposure Draft.
5In accordance with the TAC's Terms of Reference, it is the TAC's remit to undertake outreach with, and provide a focal point for, UK stakeholders to influence the technical development of IFRS Sustainability Disclosure Standards, including the way the ISSB develops its future standards and the ISSB's choices to amend or produce guidance on existing standards. While the Practice Statement is not currently a formal standard, the TAC has a responsibility to ensure that the document is subject to appropriate technical scrutiny and rigour. This is particularly important given the ISSB's indication that the Practice Statement may, in time, be developed into a formal standard.
Project overview
Approach
6The TAC Secretariat proposes undertaking both desk-based analysis and stakeholder engagement to best capture current UK views.
7Drawing on the findings of the TAC's research project on nature-related disclosures, the desk-based analysis will assess the Exposure Draft's technical content using the criteria described below. The analysis will also identify areas where further research, evidence gathering, and stakeholder engagement may be required to support the development of a comprehensive TAC response.
8The assessment criteria in the TAC's Terms of Reference are required to be applied when responding to commissions for endorsement advice from the Department for Business, Innovation, Science and Trade. However, the TAC considered these criteria not to be fully applicable in this case, as the work relates to a consultation response rather than an endorsement process. The TAC Secretariat proposes amending the assessment criteria for the purpose of this project. The TAC will assess whether the proposed Practice Statement is conducive to the long term public good in the UK by considering whether:
- the objectives set out by the ISSB in its consultation are appropriate in the context of the UK;
- the requirements and guidance in the Practice Statement successfully address the objectives set out by the ISSB in its consultation;
- there are any gaps in the requirements and guidance provided by the Practice Statement;
- the use of the Practice Statement is likely to result in an improvement in the international comparability of sustainability-related reporting in the UK;
- the requirements and guidance in the Practice Statement are likely to support entities in making disclosures that are understandable, relevant, reliable and comparable;
- the use of the Practice Statement is likely to improve the quality of corporate reporting within the UK in the long term; and
- entities are able to provide the disclosures required by the Practice Statement within the timeframes that an entity normally reports without undue cost or effort.
9The criteria will be assessed individually and in combination to ensure a full assessment has been completed.
Stakeholder engagement
10It is anticipated that this consultation will attract significant interest from UK stakeholders. To facilitate effective stakeholder engagement, the TAC Secretariat proposes conducting a programme of roundtables and one-to-one interviews with stakeholders representing preparers, primary users (including investors and creditors), academics, data providers, and other interested parties. Adopting both approaches will enable the collection of a broad range of views while also generating more detailed insights on key technical issues.
11As part of the TAC's research project on nature-related disclosures, an expert stakeholder group was convened through a series of roundtables. This group was made up of sixteen participants who were selected based on their expertise and experience in nature-related disclosure. The group represents a broad range of stakeholder perspectives, including:
- four preparers;
- six primary users (the majority of whom were also preparers);
- three academics;
- two data providers; and
- one non-governmental organisation.
Additional sessions are planned with this group during the consultation period to discuss the content of the Exposure Draft.
12In addition, the TAC Secretariat has identified a number of industry bodies representing different stakeholder groups and proposes partnering with these organisations to host targeted roundtables for their members. This approach is considered more effective than organising general TAC-led roundtables, as it enables engagement with specific stakeholder groups and allows discussions to be tailored to their particular perspectives and areas of expertise. Working through existing industry networks will also help maximise participation while enabling the TAC Secretariat resources to be focused on conducting one-to-one interviews.
13Previous stakeholder engagement activities have demonstrated that one-to-one interviews often provide more detailed and nuanced insights than roundtable discussions. However, identifying and engaging suitable participants can be challenging. The TAC Secretariat therefore proposes working with industry bodies and other organisations to identify stakeholders who are both willing to participate in interviews and possess relevant knowledge and experience of nature-related reporting. The TAC Secretariat will also leverage findings from the FTSE 100 review, conducted as part of the nature-related research, to identify reporting entities that may have interesting insights into the preparation of nature-related disclosures. This will help ensure that feedback obtained through the engagement programme is informed, relevant, and technically robust.
Key tasks and proposed timeline
14In accordance with the TAC's Due Process Policy, the TAC's process for preparing the comment letter will include the following stages:
| Task description | Due Process Policy ref. | Indicative timeline |
|---|---|---|
| Project initiation | ||
| Project management plan and proposed timeline to be discussed and agreed at September 2026 TAC meeting (this meeting). | Paragraphs 29-30 | 15 September 2026 TAC meeting |
| Project delivery | ||
| The TAC Secretariat undertakes desk-based analysis activities. | N/A | October – November 2026 |
| The TAC Secretariat will engage in stakeholder outreach, including conducting interviews and roundtables. | Paragraph 31 | November – December 2026 |
| A draft comment letter will be discussed by the TAC. | Paragraph 31 | 15 December 2026 TAC meeting |
| The final response is prepared. The TAC reviews and approves it. | Paragraph 31 | 26 January 2027 TAC meeting |
| The TAC Secretariat will submit the final comment letter to the ISSB and will publish the comment letter on the FRC website. | N/A | By 19 February 2027 |
| Project closure | ||
| A draft Due Process Summary will be discussed. | Paragraphs 37 – 40 | 16 February 2027 TAC meeting |
| The TAC approves the final Due Process Summary, which will be subsequently published on the FRC website. | Paragraphs 37 – 40 | 23 March 2027 |
15It is expected that the Exposure Draft will be published on the 22 October 2026 with a deadline on the 19 February 2027. The TAC's February meeting is scheduled for 16 February. As the TAC meeting is close to the deadline, It is unlikely that the TAC will discuss its response at the February meeting. Therefore, it is assumed that the final opportunity for the TAC to discuss and agree its response would be at the January public meeting. The February meeting could be utilised if any last minute changes are necessary and need to be discussed in public.
Timeline of Project Initiation to Project Closure A timeline illustrating the project stages from September 2026 to March 2027. * Sep 26: Project initiation * Oct 26: Publication of ED (22 October) * Nov 26 - Dec 26: Desk-based analysis * Dec 26 - Jan 27: Stakeholder engagement * Jan 27: Preparing comment letter * Feb 27: Final response submitted by 19 February * Mar 27: Project closure
Assumptions, constraints and risks
16When developing the project management plan, the TAC Secretariat has taken into consideration the following assumptions and constraints.
- The TAC's capacity and meeting cadence: The TAC's meetings are scheduled once a month, which provides up to three (possibly four) opportunities for the TAC to discuss the content of the Exposure Draft and its response.
- The capacity of the TAC Secretariat: The TAC Secretariat will be expected to write papers for public TAC meetings in addition to conducting research and stakeholder engagement to inform the final comment letters. The expected available resources are 2 FTE Project Directors/Managers and oversight from the Head of the Secretariat.
- Obtaining representative stakeholder input: Although we anticipate a high level of interest, there might be some challenges in identifying and securing engagement with appropriate stakeholders. The challenges might include time pressures, the technical nature of certain proposals, consultation fatigue, or the uncertainty of whether this Practice Statement is likely to be adopted in the UK.