10 Items for Noting

Executive Summary

The November considered stakeholder feedback and the content of draft comment letters to the ISSB exposure drafts Proposed Amendments to the SASB Standards¹ (SASB ED) and Proposed Amendments to the Industry-based Guidance on Implementing IFRS S2² (Industry Guidance ED).

In addition, the TAC also considered a plan and approach to the GHG Protocol³ consultations for Scope 2 Standard⁴ and Electricity-Sector Consequential Methods⁵ for estimating avoided emissions.

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

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TAC meeting – November 2025

A1. The 11 November 2025 TAC considered stakeholder feedback and the content of draft comment letters to the ISSB for the SASB ED and Industry Guidance ED. In addition, the TAC also considered a plan and approach to the GHG Protocol consultations for Scope 2 Standard and Electricity-Sector Consequential Methods.

General reporting update

A2. The TAC noted a summary of local and international sustainability news and jurisdictional developments.

Summary of stakeholder feedback

A3. The TAC considered a consolidated summary of stakeholders' feedback gathered through outreach activities on the SASB ED and Industry Guidance ED.

A4. The Secretariat noted that the overall UK stakeholder engagement had been notably low and that the quality of feedback suggested that stakeholders had limited engagement with the ISSB's SASB Exposure Draft. However, stakeholder feedback generally supported the ISSB's initiative to enhance the SASB Standards to improve interoperability and alignment with the ISSB Standards.

A5. Stakeholders had expressed concerns regarding the prescriptive nature of the current SASB Standards and recommended a shift towards a more principles-based and proportionate approach, consistent with the principles in IFRS S1 and IFRS S2.

SASB Exposure Draft, Draft Comment Letter6

A6. The TAC discussed a draft response to the SASB ED and noted that UK stakeholders generally welcomed sources of guidance, including the SASB Standards, as they assisted entities identify and disclose material information about sustainability-related risks and opportunities. The TAC also encouraged the ISSB to align its industry-based guidance aligned with IFRS Sustainability Disclosure Standards.

A7. The TAC recommended that the ISSB develop a clear strategy for enhancing the SASB Standards and that this should prioritise international applicability and connectivity with IFRS Accounting Standards. The members also raised concerns regarding the ISSB due process, noting that other similar projects had been subject to a greater stakeholder scrutiny at the IFRS Foundation, such as the Disclosures about Uncertainties in the Financial Statements Illustrated using Climate-related Examples⁷.

IFRS S2 Industry-based Guidance Consultation Exposure Draft - Draft Comment Letter8

A8. The TAC discussed a draft response to the Industry Guidance ED. In principle, the TAC supported making climate-linked consequential amendments to the IFRS S2 Industry-based Guidance concurrently with updates to the SASB Standards as it would maintain alignment.

GHG Protocol Revisions: Scope 2 Guidance consultation – project management plan9 and initial analysis¹⁰

A9. On 30 October the GHG Protocol issued two consultations on the revisions to the Scope 2 Guidance (2015) and requested feedback by 19 December 2025.

A10. The TAC has been requested by the Department for Business and Trade (DBT) to consider providing feedback to the Greenhouse Gas (GHG) Protocol on its consultations and proposed revisions to its materials.

A11. The TAC noted that IFRS S2 and draft UK SRS S2 required the use of the GHG Protocol Corporate Standard (2004) but did not reference or require the use of the Scope 2 Guidance. The TAC discussed an approach and plan to consider the consultations.

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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)¹¹ 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 DBT¹² to assess the IFRS Sustainability Disclosure Standards, from a technical perspective, and provide advice¹³ 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 concluded¹⁴ 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 Committee¹⁵ (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.

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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 – link to meeting summary.
10. 11 November – summary pending.
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 website¹⁶.

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Appendix B: Sustainability Update

ISSB

B1. The ISSB announced an initiative to facilitate the role of ISSB Standards as a global passport¹⁷. The Board's intention is to introduce 'passporting provisions' to allow jurisdictions to accept sustainability reports prepared under ISSB Standards. The ISSB's Jurisdictional Working Group will be expanded to facilitate multilateral discussions with regulators on how ISSB Standards could serve as a global passport.

ISSB meetings October and November 2025

B2. The ISSB met on 28 October 2025 and 6 November to discuss Biodiversity, Ecosystems and Ecosystem Services (BEES)¹⁸.

B3. In relation to BEES, the ISSB discussed the Taskforce on Nature-related Financial Disclosures (TNFD) recommendations, metrics and additional guidance in the context of using it to develop materials or requirements that complement requirements in ISSB Standards.

B4. At its 6 November 2025 meeting, the ISSB continued its discussion on BEES. It discussed information primary users of general-purpose financial reports commonly require regarding nature-related risks and opportunities¹⁹. It also tentatively decided to draw on the TNFD framework to build on the requirements in IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1). It will undertake standard-setting where nature-related requirements were not reflected in IFRS S1 and IFRS S2.

B5. The ISSB is targeting having an Exposure Draft of incremental nature-related disclosure requirements ready by the Convention on Biological Diversity COP17 in October 2026.

B6. At its October meeting, the ISSB also discussed Human Capital²⁰ and Amendments to Greenhouse Gas Emissions Disclosures²¹.

B7. For Human Capital, the ISSB discussed an approach to the initial phase of research but was not asked to make any decisions. The ISSB will now consider the feasibility of standard-setting.

B8. Relating to the Amendments to Greenhouse Gas Emissions Disclosures, the ISSB discussed whether to align the SASB Standards with the prospective Amendments to Greenhouse Gas Emissions Disclosures in IFRS S2 Climate-related Disclosures (IFRS S2). The ISSB tentatively decided to amend the financed emissions metrics in the Asset Management & Custody Activities, Commercial Banking and Insurance SASB Standards to align the guidance with IFRS S2. The Board also tentatively agreed to set an effective date for the consequential amendments for annual reporting periods beginning on or after 1 January 2027, with early application permitted.

B9. The consequential amendments to the SASB Standards and the prospective amendments to IFRS S2 will be balloted concurrently and issued in December 2025.

Taskforce on Nature-related Financial Disclosures (TNFD)

B10. Following the ISSB's decision to advance work regarding the disclosure of nature-related risks and opportunities, TNFD announced²² that it will complete its technical work by the third quarter of 2026 and pause any further technical guidance.

UK update

B11. The UK Sustainability Disclosure Technical Advisory Committee (TAC) is seeking new members²³ to support its ongoing work to inform both UK and international sustainability disclosures.

European update

B12. The European securities regulator, ESMA issued its priorities²⁴ for 2025 annual reports. ESMA re-emphasised the need for connectivity and consistency between financial and sustainability reporting. It also highlighted the near final illustrative examples issued by the IASB relating to the Disclosures about Uncertainties in the Financial Statements Illustrated using Climate-related Examples project.

B13. On 22 October 2025, the European Parliament²⁵ rejected the mandate adopted by Legal Affairs Committee of the European Parliament (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.

International update

B14. On 30 October, the Organization for Economic Co-operation and Development (OECD) reported²⁶ insights on how companies are implementing the sustainability-related recommendations of the G20/OECD Principles of Corporate Governance providing a comprehensive analysis of sustainability practices among listed companies worldwide.

B15. The Australian Accounting Standards Board (AASB) issued educational guidance for disclosing information about anticipated financial effects when applying AASB S2 Climate-related Disclosures²⁷. The guidance provides a complementary perspective about how the financial statements are expected to be affected over the short, medium and long term.

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Footnotes