IFRS S2 — Climate-related Disclosures was issued by the International Sustainability Standards Board on 26 June 2023, alongside IFRS S1, and applies to annual reporting periods beginning on or after 1 January 2024.
It has been amended once. Getting both dates right matters more than it sounds, because the amendments are issued but not yet effective, and the two are routinely conflated.
| Date | |
|---|---|
| IFRS S2 issued | 26 June 2023 |
| Effective (§C1) | annual reporting periods beginning on or after 1 January 2024 |
| Amendments issued | 11 December 2025 |
| Amendments effective (§C1A) | annual reporting periods beginning on or after 1 January 2027, early application permitted |
The amending document is Amendments to Greenhouse Gas Emissions Disclosures (Amendments to IFRS S2). It was preceded by an exposure draft in April 2025 — which is the source of a common dating error, since the exposure draft and the final amendments are eight months apart. If a document tells you the GHG amendments were made in mid-2025, it is describing the consultation.
A second trap. The IFRS Foundation publishes annual bound compilations, so IFRS S2 can be surfaced under a 2026 label. That is the compilation year, not an issue date, and it does not mean the December 2025 amendments are effective. For a financial year beginning 1 January 2026, the operative text is the 2023 text unless the entity chooses early application.
Four reliefs, all narrowing the greenhouse gas disclosure burden rather than widening it.
Issued the same day: Consequential Amendments to Align with Amendments to Greenhouse Gas Emissions Disclosures, which updates the SASB Standards and the IFRS S2 industry-based guidance for asset management, commercial banking and insurance. Same effective date.
The architecture deliberately mirrors TCFD's four pillars.
Governance (§§5–6). Which body oversees climate-related risks and opportunities, how that is reflected in terms of reference, how it satisfies itself the right skills are available, how often it is informed, and how it oversees targets. Then management's role.
Strategy (§§9–23). The risks and opportunities themselves, classified as physical or transition; the time horizons used; effects on the business model and value chain; the effect on strategy and decision-making, including transition plans; current and anticipated financial effects; and climate resilience (§22).
Risk management (§§24–25). How climate risks are identified, assessed, prioritised and monitored — including the use of scenario analysis as an input — and how that is integrated into overall risk management.
Metrics and targets (§§27–37). Cross-industry metrics, industry-based metrics, and targets.
§22 requires disclosure enabling users to understand the resilience of the strategy and business model, and requires the entity to use climate-related scenario analysis using an approach commensurate with the entity's circumstances.
The guidance at §§B1–B18 makes the proportionality explicit: a qualitative, narrative approach is acceptable for an entity building capability, while an entity with high exposure and available resources is directed toward quantitative approaches.
Read that as an insurer and it is not a relief. Insurers and reinsurers are the archetype of high exposure with modelling capability already in place. The proportionality provision that protects a mid-size manufacturer offers a catastrophe underwriter very little.
Absolute gross emissions in tonnes of CO₂ equivalent, classified as Scope 1, 2 and 3, measured in accordance with the GHG Protocol Corporate Standard (2004) unless a jurisdictional authority or listing exchange requires otherwise. Scope 1 and 2 disaggregated between the consolidated accounting group and other investees. Scope 2 disclosed on a location-based basis, plus information on contractual instruments. For Scope 3, disclosure of which categories are included.
§C3 — no comparative information required in the first annual reporting period. §C4 — in the first year an entity may continue using a non-GHG-Protocol measurement method it used immediately before, and may omit Scope 3 entirely, including financed emissions. §C5 — the reliefs carry forward for presenting comparatives in the following period. IFRS S1 separately permits reporting only climate in the first year.
Financed emissions. §29(a)(vi)(2) requires additional information about Category 15 emissions where an entity's activities include asset management, commercial banking or insurance, with the detail set out at §§B58–B63. For an insurer that means absolute gross financed emissions split by Scope 1, 2 and 3; gross exposure by industry and by asset class; the percentage of gross exposure included in the calculation; and the methodology. In the 2023 text the industry breakdown was tied to GICS; §B63A relaxed that.
Industry-based metrics. §32 requires disclosure of industry-based metrics, referring to the IFRS S2 Industry-based Guidance, which includes a volume for insurance derived from the SASB Insurance Standard. Its topics run to environmental risk exposure and the incorporation of environmental risk into underwriting and capital adequacy.
A limit on what we will state here. The current Insurance volume of the industry-based guidance sits behind an IFRS Foundation login and we have not read the final text. We are therefore not reproducing metric codes, because the provisional codes in the 2022 exposure draft were superseded — the financed-emissions metrics were renumbered to the FN-IN-410c series in the December 2025 consequential amendments. Any source still citing the exposure draft's FN-IN-1 to FN-IN-5 codes is quoting a superseded document.
Insurance-associated emissions are not required. The ISSB has twice declined to require them, citing the absence of established methodologies. Its basis for conclusions distinguishes financed emissions from facilitated emissions and from insurance-associated emissions associated with underwriting. Financed emissions are defined by reference to loans and investments — loans, project finance, bonds, equity investments and undrawn loan commitments.
So an insurer's investment portfolio is in scope and its underwriting book is not. Underwriting-portfolio emissions are addressed by PCAF Part C, which is a separate, voluntary, non-ISSB methodology. Any claim that IFRS S2 requires underwriting emissions is wrong, and it appears in vendor material often enough to be worth checking.
IFRS S2 is not law anywhere until a jurisdiction adopts it. The IFRS Foundation's jurisdictional profiles, last updated 16 July 2026, record 25 finalised profiles — including Australia, Brazil, Hong Kong SAR, Japan, Malaysia, Nigeria, Singapore and Türkiye — plus 13 jurisdictions whose approach is still in development, among them Canada, China, South Korea, Switzerland and the United Kingdom. The ISSB has separately reported more than 40 jurisdictions adopting or taking steps. Those two figures count different things and should not be added together.
The UK did not adopt IFRS S2 directly. It ran an endorsement process producing UK SRS S1 and UK SRS S2, issued 25 February 2026 and voluntary, with the effective dates deliberately removed. Mandation rests on an FCA policy statement that has not been published. We set that out in full on the UK SRS page.
Carefully worded: the TCFD was disbanded, and its recommendations are fully incorporated into IFRS S2 — but TCFD-derived regulation persists.
The ISSB states that IFRS S1 and S2 fully incorporate the TCFD recommendations, and that a company applying IFRS S2 meets them. The TCFD itself disbanded in October 2023, when the Financial Stability Board declared its work complete and asked the IFRS Foundation to take over monitoring of companies' disclosure progress from 2024.
That is not the same as supersession by legal instrument. In the UK the FCA's TCFD-aligned listing rules remain in force today, and are only proposed to be replaced from January 2027. Our TCFD and ISSB page covers the transition between the two frameworks in more detail.
| Workstream | Status |
|---|---|
| Nature-related disclosures | The ISSB agreed in April 2026 to proceed via an IFRS Practice Statement rather than a new standard or amendments to S1/S2, drawing on TNFD. Exposure draft targeted October 2026 |
| Enhancing the SASB Standards | Exposure draft March 2026 covering agricultural products, meat/poultry/dairy and electric utilities. Comment period closed 24 July 2026. Insurance is not in this tranche |
| Human capital | Research stage. No date |
| Taxonomy update for the GHG amendments | Open for comment to 28 September 2026 |
IFRS S2 was issued on 26 June 2023 and applies to annual reporting periods beginning on or after 1 January 2024, under paragraph C1. It has been amended once: the Amendments to Greenhouse Gas Emissions Disclosures were issued on 11 December 2025 and apply to annual reporting periods beginning on or after 1 January 2027 under paragraph C1A, with early application permitted. For a financial year beginning 1 January 2026 the operative text is the 2023 text unless the entity early-applies.
Four reliefs. New paragraph 29A permits an entity to limit Scope 3 Category 15 to only its financed emissions and to exclude emissions attributable to derivatives. New paragraphs 29B and 29C attach explanation and subtotal conditions. New paragraphs B62A and B63A remove the hard requirement to use GICS, allowing an entity to select a suitable industry-classification system - B63A is the insurance provision. Amended paragraph 29(a)(ii) clarifies the jurisdictional relief from the GHG Protocol where an entity is required in whole or in part to use a different method. A related relief covers global warming potential values. The exposure draft preceding these amendments was published in April 2025, which is a common source of dating errors.
Not universally. Paragraph 22 requires an entity to use climate-related scenario analysis to assess climate resilience using an approach commensurate with its circumstances, and the guidance at paragraphs B1 to B18 is explicitly proportionate: qualitative or narrative approaches are acceptable for entities building capability, while entities with high exposure and available resources are directed toward quantitative approaches. For insurers and reinsurers, which combine high exposure with existing catastrophe modelling capability, the proportionality provision offers little relief in practice.
Paragraph 29(a)(vi)(2) requires additional information about Scope 3 Category 15 emissions where an entity's activities include asset management, commercial banking or insurance, with detail at paragraphs B58 to B63. For an insurer that means absolute gross financed emissions split by Scope 1, 2 and 3; gross exposure by industry and by asset class; the percentage of gross exposure included in the calculation; and the methodology used. The 2023 text tied the industry breakdown to GICS; paragraph B63A relaxed that from 2027.
No. The ISSB has declined to require insurance-associated emissions, citing the absence of established methodologies, and its basis for conclusions distinguishes them from financed emissions and from facilitated emissions. Financed emissions are defined by reference to loans and investments - loans, project finance, bonds, equity investments and undrawn loan commitments. An insurer's investment portfolio is therefore in scope and its underwriting book is not. Underwriting-portfolio emissions are addressed by PCAF Part C, a separate voluntary non-ISSB methodology.
Yes, with a jurisdictional carve-out. Paragraph 29(a) requires absolute gross emissions to be measured in accordance with the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard (2004), unless a jurisdictional authority or an exchange on which the entity is listed requires a different method. The December 2025 amendments clarified that this relief applies where an entity is required in whole or in part to use a different method. Scope 2 must be disclosed on a location-based basis, with information about contractual instruments provided separately.
Not of itself. An ISSB standard has no legal force in a jurisdiction until that jurisdiction adopts it. The IFRS Foundation's jurisdictional profiles, last updated 16 July 2026, record 25 finalised profiles and 13 jurisdictions whose approach is still in development, including the United Kingdom. The UK did not adopt IFRS S2 directly: it ran an endorsement process producing UK SRS S1 and UK SRS S2, issued 25 February 2026, which are voluntary and have no effective date.
The TCFD was disbanded in October 2023, when the Financial Stability Board declared its work complete and asked the IFRS Foundation to take over monitoring of companies' disclosure progress from 2024. IFRS S1 and S2 fully incorporate the TCFD recommendations, so an entity applying IFRS S2 meets them. That is not supersession by legal instrument, however: TCFD-derived regulation persists in some jurisdictions. In the UK the FCA's TCFD-aligned listing rules remain in force today and are only proposed to be replaced from January 2027.
Paragraph C3 removes the requirement to disclose comparative information in the first annual reporting period. Paragraph C4 permits an entity, in the first year, to continue using a non-GHG-Protocol measurement method it used immediately beforehand, and to omit Scope 3 disclosures entirely including financed emissions. Paragraph C5 allows the reliefs to be carried forward for the purpose of presenting comparatives in the following period. IFRS S1 separately permits an entity to report only climate-related information in its first year.
Developments on this and related instruments are tracked in regulatory updates.
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