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Appendix A: Technical Advisory Committee Update

Executive Summary

| Category | Description |---|---| | Project Type | Monitoring | Description | Description | |---|---| | Project Type | Monitoring | | Project Scope | Limited | | Purpose of the paper | This paper provides a summary of the agenda and discussion at the 14 October 2025 meeting of the UK Sustainability Disclosure Technical Advisory Committee (TAC). | | Summary of the Issue | The Committee considered the application of SASB Standards by a sample of UK companies and the initial themes to include in comment letters to the International Sustainability Standards Board (ISSB) on their current Exposure Drafts (EDs) regarding initial amendments to SASB Standards1 and the consequential amendments to the industry-based guidance on implementing IFRS S2 Climate-related Disclosures2 (IFRS S2). | | Questions for the Board | None | | Recommendation | N/A - noting only | | Appendices | | | Annex A: | UK Sustainability Disclosure TAC - Background | | Annex B: | UK Sustainability Disclosure TAC - 2025 meeting schedule |

TAC meeting - October 2025

A1 The 14 October 2025 TAC meeting focused on research into the application of SASB Standards by a sample of UK companies and initial themes for consideration in the comment letters to the ISSB on their two Exposure Drafts (ED).

A2 The TAC Secretariat will publish an official record of the meeting and any decisions in due course. A summary of the topics relevant to the UKEB remit of connectivity with IFRS financial statements, is noted in this paper for information.

General Reporting Update

A3 The TAC noted a summary of local and international sustainability news and jurisdictional developments.

Current SASB Standards reporting by UK Companies

A4 The TAC considered an analysis of the application of SASB Standards for a limited sample of UK companies. The research is intended to be used as input for responding to the ISSB EDs (see sections below). No decisions were required of the Committee.

A5 The Committee observed that in the absence of mandatory standards entities appeared to use a variety of sustainability disclosure frameworks, in varying degrees, to identify material sustainability-related risks and opportunities.

A6 The TAC paper noted that in relation to the integration of SASB topics and associated metrics into risks and opportunities that some asset-intensive companies using the Metals & Mining and Oil & Gas - Exploration & Production SASB Standards had discussed asset impairments related to climate change within the notes to the financial statements.

A7 The TAC Secretariat will supplement this analysis with stakeholder outreach before preparing a draft response to the ISSB for the Committee to consider.

SASB Exposure Draft – Draft Comment Letter Points

A8 The TAC considered a summary of points discussed in previous TAC meetings to include in its response to the Exposure Draft Proposed Amendments to the SASB Standards.

A9 While the TAC welcomed the SASB Standards as a source of guidance that supported entities to identify material sustainability-related information, several concerns were also noted. This included the need to communicate a clear strategy for the SASB Standards and to prioritise connectivity with IFRS Accounting Standards.

IFRS S2 Industry-based Guidance Consultation Exposure Draft - Draft Comment Letter points

A10 The TAC considered key points to include in the Committee's response to the ISSB's consultation on its Exposure Draft Proposed Amendments to the Industry-based Guidance on Implementing IFRS S2.

A11 In principle, the TAC supported the amendments on the basis that they maintain alignment with the climate-related content in the SASB Standards and IFRS S2.

Annex A: UK Sustainability Disclosure TAC - Background

A1 In addition to the TAC's initial brief (see below) the Committee has been requested by the Department for Business and Trade (DBT)7 to understand the ISSB's enhancements to the SASB Standards and the implications of this for UK Sustainability Reporting Standards (UK SRS).

A2 The TAC will continue to meet monthly during 2025 (refer Annex B). The UKEB is represented on the TAC by a Board Member, who is appointed as a full Committee member to reflect the need to maintain connectivity between UK-adopted international accounting standards and UK SRS.

A3 The TAC was initially tasked by the DBT8 to assess the IFRS Sustainability Disclosure Standards, from a technical perspective, and provide advice9 to the Secretary of State on whether their endorsement would be conducive to the long-term public good in the UK.

A4 On 18 December 2024, the TAC concluded10 that the endorsement of both IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) and IFRS S2 Climate-related Disclosures (IFRS S2), was likely to be conducive to the long-term public good in the UK.

A5 In addition to the TAC, a separate Committee, the Policy Implementation Committee11 (PIC) is responsible for ensuring that any endorsed standards are implemented in a way that aligns with the mandates of UK government departments and regulator representatives.

Annex B: UK Sustainability Disclosure TAC - 2025 meeting schedule

B1 UK Sustainability Disclosure TAC meetings, in 2025, are scheduled as follows:

  1. 14 January - link to meeting summary.
  2. 11 February - The TAC met in private on 11 February to hold confidential information sessions on upcoming workstreams and to discuss related administrative matters. No minutes issued.
  3. 25 March - The private TAC meeting scheduled for 25 March was cancelled due to illness and rescheduled to 15 April.
  4. 15 April - The TAC met in private on 15 April, to hold confidential informational sessions on upcoming workstreams and to discuss related administrative matters. No minutes issued.
  5. 13 May - link to meeting summary.
  6. 10 June - link to meeting summary.
  7. 8 July - link to meeting summary.
  8. 16 September - link to meeting summary.
  9. 14 October - meeting summary pending.
  10. 11 November
  11. 9 December

B2 The public meeting agenda, technical papers and summary minutes from the TAC meetings can be found on the UK Sustainability Disclosure Technical Advisory Committee website12.

Appendix B: Sustainability Update

ISSB meeting

September 2025

B1 The ISSB met in Frankfurt on 24–26 September 2025 to discuss initial stakeholder feedback on Exposure Drafts (ED) relating to enhancements to the SASB Standards and Amendments to IFRS S2 Climate-related Disclosures (IFRS S2) and research on investor information needs in relation to Biodiversity, ecosystems and ecosystem services (BEES).

Amendments to Greenhouse Gas Emissions Disclosures (Amendments to IFRS S2)

B2 The ISSB discussed a summary of initial stakeholder feedback on the Exposure Draft (ED) for the proposed targeted amendments to IFRS S2. The amendments will have an effective date of 1 January 2027 and the ISSB anticipate publishing them before the end of 2025. The ISSB made several decisions regarding retaining or adjusting the proposed amendments.

Enhancing the SASB Standards

B3 The ISSB was provided with an update on the project to enhance the SASB Standards. The Board considered initial stakeholder feedback in relation to the proposed amendments to the following three SASB standards which have been prioritised by the ISSB:

  1. Electric Utilities & Power Generators.
  2. Agricultural Products.
  3. Meat, Poultry & Dairy.

B4 The ISSB anticipates publication of an ED by the end of 2025 or early in 2026. The ISSB was not asked to make any decisions.

Biodiversity, ecosystems and ecosystem services

B5 The ISSB discussed a summary of investor information needs from general-purpose financial reports related to nature-related risks and opportunities. The ISSB also considered how entities may be able to meet those needs and any residual gaps from applying IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1), IFRS S2, the SASB Standards and the Climate Disclosure Standards Board (CDSB) Framework Application Guidance.

B6 The ISSB staff will conduct further analysis and bring recommendations to the ISSB October 2025 meeting at which point the ISSB anticipates setting the project direction.

IFRS Foundation

B7 The Key Issues and Update paper15 for the October meeting of the Due Process Oversight Committee notes that ‘Disclosures about Uncertainties in the Financial Statements using Climate-related Examples’ project will need additional time to draft the Basis for Conclusions. The illustrative examples were due to be finalised in October 2025 but will now be published at a later date.

B8 The IFRS Foundation Trustees announced16 updates to the membership of the International Sustainability Standards Board (ISSB) including the reappointment of Sue Lloyd as Vice-Chair, Elizabeth Seeger and Hiroshi Komori for second terms. Michael Jantzi and Tae-Young Paik are both stepping down from the ISSB on 30 September 2025, with Mr Paik becoming a Senior Advisor to the ISSB Chair for one year. The Trustees announced17 their intention to transition from 14 to 10 members of both the ISSB and IASB by the end of 2028.

European updates

B9 The Legal Affairs Committee18 of the European Parliament (JURI) approved its position on the proposals of the European Commission's (EC) Omnibus package regarding reducing the sustainability and due diligence reporting burden for entities under the Corporate Sustainability Reporting Directive (CSRD). JURI proposed a CSRD scope for only those entities with over 1,000 employees on average and a net annual turnover above EUR 450 million.

B10 On 22 October 2025, the European Parliament19 rejected the mandate adopted by JURI to simplify sustainability reporting under the CSRD and due diligence obligations under the CSDDD. As a result, the EU Parliament will vote on amendments to the JURI position on 13 November 2025.

B11 EFRAG20 will hold a conference in early December 2025 to discuss with stakeholders its draft simplified European Sustainability Reporting Standards (ESRSs). The conference follows the planned delivery of technical advice on the revised ESRS to the European Commission at the end of November 2025.

International updates

B12 The Malaysian Advisory Committee on Sustainability Reporting21 (ACSR) has published illustrative sustainability reports for the plantation and construction sectors which includes connectivity with financial statements.

B13 The reports provide examples that are aligned with ISSB standards that are intended to guide Malaysian entities in preparing disclosures under Malaysia's National Sustainability Reporting Framework.

B14 The New Zealand government announced22 an increase in the thresholds for mandatory climate reporting for listed companies due to the cost burden of compliance. The threshold for companies was a market capitalization of NZD 60m which has now been increased to NZD 1 billion or more. In addition, directors will no longer be deemed liable if companies break the reporting rules and managed investment schemes will be descoped.

Appendix C: Post-implementation Review of IFRS 16 Leases- Due Process Compliance Statement

The International Accounting Standards Board (IASB) published its Request for Information (RFI) for the Post-implementation Review (PIR) of IFRS 16 Leases23 on 17 June 2025. The IASB comment period ends on 15 October 2025.

Influencing process

Project preparation

| Step | Mandatory / optional24 | Metrics or evidence |---|---| | Project Type | Monitoring | | Project Scope | Limited | | Purpose of the paper | This paper provides a summary of the agenda and discussion at the 14 October 2025 meeting of the UK Sustainability Disclosure Technical Advisory Committee (TAC). | | Summary of the Issue | The Committee considered the application of SASB Standards by a sample of UK companies and the initial themes to include in comment letters to the International Sustainability Standards Board (ISSB) on their current Exposure Drafts (EDs) regarding initial amendments to SASB Standards1 and the consequential amendments to the industry-based guidance on implementing IFRS S2 Climate-related Disclosures2 (IFRS S2). | | Questions for the Board | None | | Recommendation | N/A - noting only | | Appendices | | | Annex A: | UK Sustainability Disclosure TAC - Background | | Annex B: | UK Sustainability Disclosure TAC - 2025 meeting schedule |

Desk-based research

| Step | Mandatory / optional24 | Metrics or evidence | UKEB Secretariat comments | | Added to UKEB technical work plan [Due Process Handbook (Handbook) 4.30] | Mandatory | Project included in the UKEB published technical work plan | Complete: The PIR of IFRS 16 Leases was included in the UKEB technical work plan published in October 2024 as active monitoring and as an active influencing project from June 2025. | | Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, A1 to A2 and A12 to A14] | Mandatory | Project initiation plan (PIP) draft with project outline (background, scope, project objective) and approach for influencing (key milestones and timing) | Complete: The Secretariat included mandatory milestones for the project and considered, as appropriate, other milestones and activities. The PIP was approved at the 26 June 2025 Board meeting. | | | Mandatory | Outreach plan for stakeholders and communication approach outlined | Complete: The PIP (referred to above) included the outreach plan and approach. | | | Mandatory | Resources allocated | Complete: One project director supported and overseen by one senior project director, with communications and economics team support. | | Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, | Mandatory | Assessment of whether to set up an ad-hoc advisory group | Complete: Taking a proportionate approach, an ad-hoc advisory group was not considered necessary due to the limited scope nature of the project. | | A1 to A2 and A12 to A14] (continued) | Mandatory | Assessment of whether PIP required updating | Complete: We monitored this throughout the project, the nature and scope of which remained as proposed in the original PIP. | | | Mandatory | UKEB Board public meeting held to approve PIP | Complete: The PIP was approved at the 26 June 2025 Board meeting. | | Education sessions [Handbook 4.10] | Optional | Board provided with education sessions | Complete: The Board was provided with an education session on 24 June 2025. |

Desk-based research

| Step | Mandatory / optional24 | Metrics or evidence | UKEB Secretariat comments | | UKEB Secretariat comments | Complete: The PIR of IFRS 16 Leases was included in the UKEB technical work plan published in October 2024 as active monitoring and as an active influencing project from June 2025. | | | Complete: The Secretariat included mandatory milestones for the project and considered, as appropriate, other milestones and activities. The PIP was approved at the 26 June 2025 Board meeting. | | | Complete: The PIP (referred to above) included the outreach plan and approach. | | | Complete: One project director supported and overseen by one senior project director, with communications and economics team support. | | | Complete: Taking a proportionate approach, an ad-hoc advisory group was not considered necessary due to the limited scope nature of the project. | | | Complete: We monitored this throughout the project, the nature and scope of which remained as proposed in the original PIP. | | | Complete: The PIP was approved at the 26 June 2025 Board meeting. | | | Complete: The Board was provided with an education session on 24 June 2025. | | | Complete: The Secretariat has reviewed:

  • the IASB's work on the PIR;
  • other standard-setters' views; and
  • accounting manuals and press releases for guidance and illustrative examples.
| | Outreach | Complete: Due to the limited scope nature of the project, consultation activities were focused consultation with advisory groups and on obtaining responses to the Draft Comment Letter (DCL). The UKEB received two comment letters. One comment letter received was published on the UKEB website while the other one was not published as the stakeholder requested that the letter was not made publicly available. However, it was made available to UKEB members. | | Draft Comment Letter (DCL) | Complete: The DCL was published for consultation for 45 days on 25 July 2025 (comment period deadline: 8 September 2025). | | | Complete: The DCL was reviewed and approved at the Board meeting on 26 June 2025 subject to revision after the meeting. The revision was approved by the Chair. | | | Complete: The DCL was published for consultation for 45 days on 25 July 2025 (comment period deadline: 8 September 2025). | | Project finalisation and project closure | Complete: The UKEB received two comment letters one of which was published on the UKEB website while one letter was not published as the stakeholder requested that the letter was not made publicly available. However, the letter was made available to UKEB members. All responses were assessed, reflected as appropriate in the FCL and summarised in the Feedback Statement. | | | Complete: The FCL was presented to the Board for approval on 25 September 2025. The Board approved the FCL subject to suggested amendments. The revision was approved by the Chair. | | | Complete: The FCL was submitted to the IASB and posted on the UKEB website on 15 October 2025. | | Feedback Statement [Handbook 5.19 to 5.22 and A9 to A11] | Complete: A draft of the Feedback Statement was presented for approval to the Board at its 25 September 2025 public meeting. The Board approved the draft Feedback Statement, subject to editorial changes. | | | Complete: The final Feedback Statement was published on the UKEB website on 15 October 2025. | | Due Process Compliance Statement (DPCS) [Handbook 5.23 to 5.26 and A12 to A14] | Complete: A draft DPCS was presented for approval to the Board at its 25 September 2025 public meeting. | | | [Complete: The final DPCS was presented for noting at the Board's 30 October 2025 meeting.] | | | [Completed: The final DPCS was published on the UKEB website after the 30 October 2025 Board meeting.] | | Ongoing communications | Complete: The Board received an overview of the project in June 2025. The Board approved the PIP at its meeting on 26 June 2025, DCL at its meeting on 15 July 2025 and FCL at its meeting on 25 September 2025. | | | The UKEB's meeting papers were published on the UKEB website 5 working days before the public meetings. Meeting minutes and recordings were made publicly available via the UKEB website. | | | Complete: The project webpage has been updated regularly on a timely basis. | | | Complete: Subscribers were alerted via email 5 days before each Board meeting, with links to the agenda, papers and the option to dial in to observe the discussion. | | | Complete: News Alerts and LinkedIn posts calling for comments were published on the following dates:
  • 25 July 2025 (both)
  • 25 July 2025 (both)
  • 3 September 2025 (News Alert)
  • 4 September 2025 (LinkedIn post)
A News Alert announcing publication of the Feedback Statement was published on 16 October 2025. |

Conclusion

This project complies with the applicable due process steps, as set out in the December 2022 Handbook.

Appendix D: IFRS Interpretations Committee Tentative Agenda Decision: Updates to Committee's agenda decisions for IFRS 18 - Due Process Compliance Statement

The IFRS Interpretations Committee (the Committee) published the Tentative Agenda Decision (TAD): Updates to Committee's agenda decisions for IFRS 18 on 8 July 2025. The TAD proposes updates to ten agenda decisions following the issuance of IFRS 18 Presentation and Disclosure in Financial Statements.

The Committee's comment period ended on 6 October 2025.

The UKEB submitted its response25 to the Committee on 6 October 2025.

Influencing process

Project preparation

| Step | Mandatory / optional26 | Metrics or evidence | If | added to UKEB technical work plan [due process handbook (handbook) 4.30] | Mandatory | project included in the UKEB published technical work plan | Complete: The PIR of IFRS 16 Leases was included in the UKEB technical work plan published in October 2024 as active monitoring and as an active influencing project from June 2025. | | Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, A1 to A2 and A12 to A14] | Mandatory | Project initiation plan (PIP) draft with project outline (background, scope, project objective) and approach for influencing (key milestones and timing) | Complete: The Secretariat included mandatory milestones for the project and considered, as appropriate, other milestones and activities. The PIP was approved at the 26 June 2025 Board meeting. | | | Mandatory | Outreach plan for stakeholders and communication approach outlined | Complete: The PIP (referred to above) included the outreach plan and approach. | | | Mandatory | Resources allocated | Complete: One project director supported and overseen by one senior project director, with communications and economics team support. | | Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, | Mandatory | Assessment of whether to set up an ad-hoc advisory group | Complete: Taking a proportionate approach, an ad-hoc advisory group was not considered necessary due to the limited scope nature of the project. | | A1 to A2 and A12 to A14] (continued) | Mandatory | Assessment of whether PIP required updating | Complete: We monitored this throughout the project, the nature and scope of which remained as proposed in the original PIP. | | | Mandatory | UKEB Board public meeting held to approve PIP | Complete: The PIP was approved at the 26 June 2025 Board meeting. | | Education sessions [Handbook 4.10] | Optional | Board provided with education sessions | Complete: The Board was provided with an education session on 24 June 2025. | | Desk-based research [Handbook 5.9 and A3] | Optional | Review of relevant documentation | Complete: The Secretariat has reviewed:

  • the IASB's work on the PIR;
  • other standard-setters' views; and
  • accounting manuals and press releases for guidance and illustrative examples.
|

Outreach

Step Mandatory / optional24 Metrics or evidence UKEB Secretariat comments
Added to UKEB technical work plan [Due Process Handbook (Handbook) 4.30] Mandatory Project included in the UKEB published technical work plan Complete: The PIR of IFRS 16 Leases was included in the UKEB technical work plan published in October 2024 as active monitoring and as an active influencing project from June 2025.
Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, A1 to A2 and A12 to A14] Mandatory Project initiation plan (PIP) draft with project outline (background, scope, project objective) and approach for influencing (key milestones and timing) Complete: The Secretariat included mandatory milestones for the project and considered, as appropriate, other milestones and activities. The PIP was approved at the 26 June 2025 Board meeting.
Mandatory Outreach plan for stakeholders and communication approach outlined Complete: The PIP (referred to above) included the outreach plan and approach.
Mandatory Resources allocated Complete: One project director supported and overseen by one senior project director, with communications and economics team support.
Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, Mandatory Assessment of whether to set up an ad-hoc advisory group Complete: Taking a proportionate approach, an ad-hoc advisory group was not considered necessary due to the limited scope nature of the project.
A1 to A2 and A12 to A14] (continued) Mandatory Assessment of whether PIP required updating Complete: We monitored this throughout the project, the nature and scope of which remained as proposed in the original PIP.
Mandatory UKEB Board public meeting held to approve PIP Complete: The PIP was approved at the 26 June 2025 Board meeting.
Education sessions [Handbook 4.10] Optional Board provided with education sessions Complete: The Board was provided with an education session on 24 June 2025.
Desk-based research [Handbook 5.9 and A3] Optional Review of relevant documentation Complete: The Secretariat has reviewed:
  • the IASB's work on the PIR;
  • other standard-setters' views; and
  • accounting manuals and press releases for guidance and illustrative examples.

Outreach

| Step | Mandatory / optional24 | Metrics or evidence | UKEB Secretariat comments | Step | Optional27 | Metrics or evidence | UKEB Secretariat Comments | | --- | --- | --- | --- | | Added to UKEB technical work plan [Due Process Handbook (Handbook) 4.30] | Mandatory | Project included in the UKEB published technical work plan | Complete: The Committee's Tentative Agenda Decision: Updates to Committee's agenda decisions for IFRS 18 was included in the UKEB technical work plan published in September 2025. Link to document: UKEB Work Plan September 2025. | | Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, A1 to A2 and A12 to A14] | Mandatory | PIP draft with project outline (background, scope, project objective) and approach for influencing (key milestones and timing) | Complete: The PIP was prepared in line with the UKEB's Due Process, setting out the key milestones and stakeholder outreach envisaged for influencing IFRS Interpretation Committee's tentative agenda decision29: Updates to Committee's agenda decisions for IFRS 18 – Project Initiation Plan was approved at the 25 September 2025 Board meeting (link to UKEB's Summary of Decisions – September 2025 Board meeting). | | | Mandatory | Outreach plan for stakeholders and communication approach outlined | Complete: The PIP (referred to above) included the outreach plan and approach. | | | Mandatory | Resources allocated | Complete: The Secretariat involved in this project consists of one Project Director, on a part-time basis, with oversight provided by one Senior Project Director. Sufficient resources are allowed for in the UKEB plan for 2025-26. | | Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, | Mandatory | Assessment of whether to set up an ad-hoc advisory group | Complete: Given that the tentative agenda decision does not introduce substantial or contentious issues, an ad-hoc advisory group was not considered necessary for this project. | | A1 to A2 and A12 to A14] (continued) | Mandatory | Assessment of whether PIP required updating | Complete: No updates to the PIP were required. | | | Mandatory | UKEB Board public meeting held to approve PIP | Complete: The PIP was approved at the 25 September 2025 Board meeting. | | Education sessions [Handbook 4.10] | Optional | Board provided with education sessions | Complete: No education session was provided to the Board, however, a brief summary of the IFRS Interpretations Committee's discussions held in September 2024, November 2024 and June 2025, and a brief summary of the IASB's discussions held in April 2025 meeting was reported to the Board at its meetings in 19 September 2024, 28 November 2024, 22 May 2025, 26 June 2025 and 15 July 2025. | | Desk-based research [Handbook 5.9 and A3] | Optional | Review of relevant documentation | Complete: The Secretariat reviewed relevant documentation, including:

|

Outreach

| Step | Mandatory / optional26 | Metrics or evidence | UKEB Secretariat comments | Step | Optional28 | Metrics or evidence | UKEB Secretariat comments | Step | Optional29 | Metrics or evidence | UKEB Secretariat Comments | Step | Mandatory / optional28 | Metrics or evidence | UKEB Secretariat Comments | | --- | --- | --- | --- | | Added to UKEB technical work plan [Due Process Handbook (Handbook)] | Mandatory | Project included in the UKEB published technical work plan | Complete: The Committee's Tentative Agenda Decision: Updates to Committee's agenda decisions for IFRS 18 was included in the UKEB technical work plan published in September 2025. Link to document: UKEB Work Plan September 2025. | | Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, A1 to A2 and A12 to A14] | Mandatory | PIP draft with project outline (background, scope, project objective) and approach for influencing (key milestones and timing) | Complete: The PIP was prepared in line with the UKEB's Due Process, setting out the key milestones and stakeholder outreach envisaged for influencing IFRS Interpretation Committee's tentative agenda decision29: Updates to Committee's agenda decisions for IFRS 18 – Project Initiation Plan was approved at the 25 September 2025 Board meeting (link to UKEB's Summary of Decisions – September 2025 Board meeting). | | | Mandatory | Outreach plan for stakeholders and communication approach outlined | Complete: The PIP (referred to above) included the outreach plan and approach. | | | Mandatory | Resources allocated | Complete: The Secretariat involved in this project consists of one Project Director, on a part-time basis, with oversight provided by one Senior Project Director. Sufficient resources are allowed for in the UKEB plan for 2025-26. | | Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, | Mandatory | Assessment of whether to set up an ad-hoc advisory group | Complete: Given that the tentative agenda decision does not introduce substantial or contentious issues, an ad-hoc advisory group was not considered necessary for this project. | | A1 to A2 and A12 to A14] (continued) | Mandatory | Assessment of whether PIP required updating | Complete: No updates to the PIP were required. | | | Mandatory | UKEB Board public meeting held to approve PIP | Complete: The PIP was approved at the 25 September 2025 Board meeting. | | Education sessions [Handbook 4.10] | Optional | Board provided with education sessions | Complete: No education session was provided to the Board, however, a brief summary of the IFRS Interpretations Committee's discussions held in September 2024, November 2024 and June 2025, and a brief summary of the IASB's discussions held in April 2025 meeting was reported to the Board at its meetings in 19 September 2024, 28 November 2024, 22 May 2025, 26 June 2025 and 15 July 2025. | | Desk-based research [Handbook 5.9 and A3] | Optional | Review of relevant documentation | Complete: The Secretariat reviewed relevant documentation, including:

| | Outreach activities [Handbook 5.10 to 5.12 and A4 to A8] | Mandatory | Evidence of consultation | Complete: As explained in the PIP, the Secretariat followed a proportionate approach in responding to the TAD. During June 2025 the Secretariat engaged with members of the UKEB's Accounting Firms and Institutes Advisory Group, Investor Advisory Group and the Preparer Advisory Group. The UKEB received general support before the text of the TAD came out. After the TAD was published further input was received via email with some recommendations to enhance the clarity on the proposed updates. All input was considered when drafting the Final Comment Letter discussed by the Board at its September 2025 meeting. | | Draft Comment Letter (DCL) | Mandatory | Comment period set for responses to DCL and review and approval at a UKEB public meeting | At its June 2025 meeting the UKEB made a decision to submit a response to the Committee's Tentative Agenda Decision: Updates to Committee's agenda decisions for IFRS 18. The Committee's comment deadline was October 6 2025. As explained in the PIP, following a review of the proposed timeline at its June 2025 meeting, the Board concluded that issuing a Draft Comment Letter in response to the TAD was not practicable due to the timing of the date of the TAD's publication for comment and the UKEB meeting timeline. | | | Mandatory | DCL published on website for public consultation | Not Applicable. See above comment. | | Project finalisation and project closure | Mandatory | Public responses to DCL considered and published on website | As noted above, issuing a draft comment letter was not practicable. All stakeholder feedback received was considered in the preparation of the draft FCL, presented for Board approval at its 25 September 2025 meeting. | | Final Comment Letter (FCL) [Handbook paragraph 5.18 and A4(d)] | Mandatory | FCL approved by the UKEB in public meeting | Complete: A draft of the FCL was presented for approval to the Board at its 25 September 2025 public meeting. The Board approved the FCL, subject to minor editorial changes. | | | Mandatory | FCL submitted to the IASB and posted on UKEB website | Complete: The FCL was submitted to the IFRS Interpretations Committee on 6 October 2025 and posted on the UKEB website on 8 October 2025. | | Feedback Statement [Handbook 5.19 to 5.22 and A9 to A11] | Mandatory | Feedback Statement approved for publication by the UKEB in a public meeting and published on the UKEB website | A Feedback Statement is generally prepared summarising feedback received from UK stakeholders on UKEB consultation documents. As noted above, no UKEB consultation document (i.e. draft comment letter) was published and all stakeholder feedback received was considered and reflected accordingly in the Final Comment Letter (approved at the 25 September 2025 Board meeting). As a result, no Feedback Statement was prepared for this project. | | Due Process Compliance Statement (DPCS) [Handbook 5.23 to 5.26 and A12 to A14] | Mandatory | DPCS approved by the UKEB in public meeting | Complete: A draft DPCS was presented for approval to the Board at its 25 September 2025 public meeting. | | | Mandatory | DPCS published on the UKEB website | [Complete: The final DPCS will be published on the UKEB website after the October 2025 Board meeting.] | | Ongoing communications | Mandatory | UKEB public meetings held to discuss technical project | Complete: A summary of the IFRS Interpretations Committee's discussions held in September 202433, November 202434 and June 202535 was reported to the Board at its meetings on 19 September 202436, 28 November 202437 and 26 June 202538, respectively. A summary of the IASB's discussions held in April 202539 was reported to the Board at its meeting on 22 May 2025[^40]. A further update on these activities was presented to the Board at its 15 July 2025[^41] meeting. The Board approved the Project Initiation Plan and Final Comment Letter at its meeting on 25 September 2025 (link to UKEB's Summary of Decisions – September 2025 Board meeting). | | Secretariat papers [Handbook 4.20] | Mandatory | Board meeting papers posted and publicly available usually no later than 5 working days before a Board meeting. | Complete: The UKEB's meeting papers were published on the UKEB website 5 working days before the public meetings. Meeting minutes and recordings were made publicly available via the UKEB website. | | Project webpage [Handbook 4.25(b)] | Mandatory | Project webpage contains a project description with up-to-date information on the project. | Complete: The UKEB project webpage contains all relevant project information. | | Subscriber Alerts [Handbook 4.24] | Optional | Evidence that subscriber alerts have occurred | Complete: Subscribers were alerted via email 5 days before each Board meeting, with links to the agenda, papers and the option to dial in to observe the discussion. | | News Alerts [Handbook 4.24] | Optional | News Alert to announce publication of key documents | Complete: A News Alert and a LinkedIn post was published on 8 October 2025 announcing the publication of the UKEB Final Comment Letter in response to the Committee's Tentative Agenda Decision: Updates to Committee's agenda decisions for IFRS 18. |

Conclusion

This project complies with the applicable due process steps envisaged for influencing IFRS Interpretation Committee's tentative agenda decisions, as set out in the December 2022 UKEB Due Process Handbook.

Footnotes

Footnotes

  1. ISSB Proposed amendments to the SASB Standards (July 2025) ↩↩

  2. ISSB Proposed amendments to the Industry-based Guidance on Implementing IFRS S2 (July 2025) ↩↩

  3. TAC-Update - TAC Update 2025. ↩

  4. TAC Paper 3: Current SASB Standards reporting by UK Companies. ↩

  5. TAC Paper 4: SASB Exposure Draft Comment Letter Points. ↩

  6. TAC Paper 5: IFRS S2 Industry-based Guidance Consultation - Comment Letter Key Points. ↩

  7. DBT TAC priorities (June 2025). ↩

  8. Section B: UK Sustainability Disclosure TAC Terms of Reference. ↩

  9. Context letter from the Department for Business and Trade (May 2024) suggests that the TAC may wish to consider whether definitions in IFRS S1 and IFRS S2 are sufficiently clear, and whether any significant incompatibilities are identified with those currently used UK adopted international accounting standards. ↩

  10. TAC endorsement recommendation - UK Endorsement of IFRS S1 and IFRS S2. ↩

  11. Section C: UK Sustainability Disclosure PIC Terms of Reference (updated September 2025). ↩

  12. UK Sustainability Disclosure Technical Advisory Committee. ↩

  13. ISSB Amendments to Greenhouse Gas Emissions Disclosures (Amendments to IFRS S2) (September 2025). ↩

  14. ISSB Summary of common investor information needs and comparison to ISSB materials (September 2025). ↩

  15. DPOC IASB Technical Activities: Key Issues and Update Agenda reference: DP2 (October 2025). ↩

  16. IFRS Foundation announces updates to inaugural ISSB membership (September 2025). ↩

  17. IFRS Foundation Trustees meet in Milan (June 2025). ↩

  18. Legal Affairs Committee Sustainability reporting and due diligence: simpler rules for fewer companies (October 2025). ↩

  19. DRSC No agreement in the European Parliament on a position on simplifying sustainability reporting (October 2025). ↩

  20. EFRAG unveils Draft Simplified ESRS: A European Milestone for Sustainability Reporting (October 2025). ↩

  21. ACSR National Sustainability Reporting Framework (October 2025). ↩

  22. New Zealand Government Commonsense changes to boost capital markets (October 2025). ↩

  23. IASB Request for Information on the Post-implementation Review of IFRS 16 Leases. ↩

  24. In accordance with the Due Process Handbook. ↩↩↩↩↩

  25. This response to the TAD is separate from the UKEB's ongoing assessment of whether to adopt IFRS 18 for use in the UK. ↩

  26. In accordance with the Handbook. ↩↩

  27. The tentative agenda decision had not been issued when the July 2025 UKEB workplan was drafted. This was noted in paragraph E3 of Agenda Paper 9E presented at the July 2025 Board meeting. The project was therefore not added to the work plan in July 2025. ↩

  28. UKEB Due Process Handbook - 'Influencing tentative agenda decisions', paragraphs 5.27-5.33. ↩↩

  29. This includes the IASB staff papers presented to the IFRS Interpretations Committee in September 2024, November 2024 and June 2025, and the IASB staff paper presented to the IASB at its April 2025 meeting. ↩↩↩

  30. The Secretariat discussed the proposed updates with PAG at its meeting on 16 June 2025. The Secretariat provided a general update on IFRS 18's activities to IAG at its meeting on 2 June 2025 and to AFIAG at its meeting on 10 June 2025. ↩

  31. This included the discussion of IFRIC staff paper 6. ↩↩

  32. This included the discussion of IFRIC staff paper 8. ↩

  33. This included the discussion of IFRIC staff papers 5, 5A and 5B. ↩

  34. This was reported in Appendix E of UKEB Agenda Paper 7. ↩

  35. This was reported in Appendix E of UKEB Agenda Paper 8. ↩

  36. This was reported in UKEB Agenda Paper 9E. ↩

  37. This included the discussion of IASB staff paper 12D. ↩

  38. This was reported in UKEB Agenda Paper 4. ↩

  39. This was reported in Appendix E of UKEB Agenda Paper 9. ↩