Where this comes from
Primary sources unless labelled secondary.
IFRS S1 and S2 are the closest thing to a global sustainability reporting standard. They carry legal force only where a jurisdiction adopts them, and over 45 are adopting or moving towards adoption.[5]
IFRS S1 sets the general requirements: disclose sustainability-related risks and opportunities that could reasonably be expected to affect the company’s prospects, for the same reporting entity and period as the financial statements, published at the same time.[2]
IFRS S2 applies that to climate. It requires Scope 1, 2 and 3 greenhouse gas emissions, climate-related targets, climate resilience analysis, and industry-based metrics.[3]
Both follow TCFD’s four pillars: governance, strategy, risk management, and metrics and targets. A company already reporting under TCFD has most of the structure.
The major markets, with the status that matters to a reporting team: is it mandatory, and from when?
Adoption is not one-way. Brazil made ISSB reporting mandatory for listed companies and then, in May 2026, made it voluntary again.[11] Canada’s regulators paused their rule.[10]
Smaller adopters in 2026 include Nigeria, Peru and Uzbekistan.[13]
AASB S2 is mandatory under the Corporations Act: Group 1 from financial years starting on or after 1 January 2025, Group 2 from 1 July 2026, Group 3 from 1 July 2027.[6]
SSBJ standards (March 2025) apply to Prime Market companies by market capitalisation: ¥3tn+ from fiscal years ending March 2027, ¥1tn+ from March 2028, ¥500bn+ from March 2029. Limited assurance follows a year later.[7]
All listed companies report Scope 1 and 2 from FY2025. Straits Times Index companies report full IFRS S2 from FY2025 and Scope 3 from FY2026. Large non-listed companies are deferred to FY2030.[8]
HKEX climate rules based on IFRS S2 apply on a comply-or-explain basis from 1 January 2025 and are mandatory for large-cap issuers from 1 January 2026. HKFRS S1 and S2 took effect on 1 August 2025.[9]
UK SRS S1 and S2, closely based on ISSB, published February 2026 for voluntary use.[14] The FCA has proposed requiring them of listed companies.[15] UK SRS →
CSDS 1 and 2 were issued in December 2024 for voluntary use. The securities regulators paused their mandatory rule in April 2025.[10]
CVM Resolution 193 had made ISSB-based reporting mandatory for listed companies from 2026. Resolution 244 of 29 May 2026 revoked that; reporting is voluntary, with comply-or-explain from 2027.[11]
The Ministry of Finance issued its Basic Standard (trial) in 2024 and a climate standard (trial) on 19 December 2025. Both are voluntary until a mandatory scope is set, with a national system targeted by 2030.[12]
No federal adoption. California’s SB 261 accepts a report under IFRS S2.[16] US rules →
Targeted amendments to IFRS S2, issued on 11 December 2025 and effective from 1 January 2027, with early application allowed:[4]
Issued 26 June 2023, effective for annual periods beginning on or after 1 January 2024.[1] They bind a company only where a jurisdiction adopts them, on that jurisdiction’s timetable.
Issued 11 December 2025, effective from 1 January 2027 with early application allowed. Entities can limit Scope 3 category 15 to financed emissions (excluding derivatives), use classifications other than GICS, apply jurisdictional relief from the GHG Protocol to part of the entity, and use jurisdiction-required global warming potential values.[4]
The IFRS Foundation said in September 2026 that over 45 jurisdictions have adopted or are taking steps towards the standards.[5] “Adopted” ranges from mandatory reporting for listed companies to voluntary national standards, so the country detail matters more than the count.
Primary sources unless labelled secondary.