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The ISSB baseline · two standards, one set of disclosures

IFRS S1 and S2: how the pair works, and when it applies

IFRS S1 and IFRS S2 are the ISSB’s first two standards: one sets the general requirements, the other applies them to climate.

They were issued on 26 June 2023, are effective for periods beginning on or after 1 January 2024, and are written to be applied together.

The UK endorsed them as UK SRS S1 and S2 on 25 February 2026, and took the effective date out.

The short answer

IFRS S1 and S2 in the UK today

IFRS S1 and IFRS S2 are not law in the UK.

The UK route is UK SRS S1 and UK SRS S2, which the government’s guidance says are “available for voluntary use, by any entity that chooses to do so”.

For listed companies, the FCA’s final rules of 30 September 2026 add comply-or-explain reporting against UK SRS from accounting periods beginning on or after 1 January 2027.

The regime as a whole is explained on what is UK SRS, and the dated sequence on the UK SRS S1 and S2 timeline.

2
ISSB standards in issue: IFRS S1 and IFRS S2
IFRS Foundation
0
UK entities required to report against IFRS S1 or S2 as such
DBT guidance; FCA PS26/19

Who wrote them

The ISSB, and what it consolidated

The IFRS Foundation Trustees announced the International Sustainability Standards Board on 3 November 2021 at COP26 in Glasgow.

It “operates alongside—but independently from—the IASB”, which is why “IFRS” on its own can mean either the accounting standards or the sustainability standards.

The ISSB built on the Climate Disclosure Standards Board, the TCFD, the Value Reporting Foundation’s Integrated Reporting Framework and the SASB Standards.

It issued IFRS S1 and S2 on 26 June 2023, and its only amendment since is to IFRS S2, in December 2025.

The body itself is covered on our ISSB guide.

IFRS Foundation, ISSB group page; IFRS S1 ¶¶55, 58.
Initiative the ISSB built onWhere it went
TCFD recommendationsThe four areas of IFRS S1 and S2; the TCFD disbanded in October 2023
SASB StandardsMaintained by the ISSB; the industry topics in S1 ¶55 and S2 ¶12
CDSB FrameworkIts water and biodiversity application guidance is a named source in S1 ¶55(b)
Integrated Reporting FrameworkStill a voluntary framework, now under the IASB and ISSB

How the pair interlocks

S1 is the frame; S2 is the first topic in it

Which standard answers which question.

S2 borrows everything general from S1 and adds only what is specific to climate.

IFRS S1 (June 2023) and IFRS S2 (December 2025 text), free HTML from the IFRS Foundation.
QuestionAnswered in IFRS S1Answered in IFRS S2
What is in scope?¶3: all sustainability-related risks and opportunities that could reasonably be expected to affect prospects¶3: climate-related physical risks, transition risks and opportunities
What makes information material?¶18: could reasonably be expected to influence primary users’ decisionsUses S1’s test
How is it organised?¶25: governance, strategy, risk management, metrics and targets¶¶5–37: the same four areas, for climate
What if no standard covers the topic?¶¶54–58: SASB (shall consider), then CDSB, other standard-setters, peers; Appendix C: GRI and ESRSNot needed for climate
Where and when is it reported?¶¶60–69: in general purpose financial reports, with the financial statements, same periodUses S1
Scenario analysis?Resilience disclosure under ¶41–42¶22: required, commensurate with circumstances
Emissions?—¶29(a): absolute gross Scope 1, 2 and 3
Compliance statement?¶72: explicit and unreserved, only if every requirement is metUses S1

IFRS S1 paragraph 3 reaches every sustainability-related risk and opportunity that could affect the entity’s cash flows, access to finance or cost of capital; climate is only the first topic with a standard of its own.

IFRS S2 paragraph 7 tells the entity to avoid duplicating what it already discloses under S1, for example by giving integrated governance disclosures.

Materiality is single and financial: information is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions of primary users of general purpose financial reports.

Each standard is read at the paragraph on IFRS S1 and IFRS S2.

The dates

Effective dates: IFRS has one, UK SRS has none

IFRS S1 paragraph E1 applies the standard to annual reporting periods beginning on or after 1 January 2024, and requires an early adopter to apply IFRS S2 at the same time.

IFRS S2 paragraph C1 says the same in reverse, and paragraph C1B applies the ISSB’s December 2025 amendments from 1 January 2027.

The IFRS dates are the standards’ own; a company is only bound by them where its jurisdiction or exchange says so.

In the first year, IFRS S1 lets a company report on climate only (¶E5), publish its sustainability disclosures after its financial statements (¶E4), and skip comparatives (¶E3).

The ISSB’s own educational material on the climate-first relief explains that it narrows the scope of S1 for that year and does not otherwise alter it.

The UK version has no effective date at all: the government removed it, and Annex A records that UK SRS can be applied when an entity chooses, unless UK law or regulation requires it.

IFRS S1 Appendix E; IFRS S2 Appendix C; DBT Annex A.
IFRS S1 and S2UK SRS S1 and S2
Effective dateAnnual periods from 1 January 2024None — removed
Early applicationPermitted, with both standards togetherAny time; no date to be early against
Climate-first reliefFirst annual period only (S1 ¶E5)No time limit in the standard (S1 ¶E3)
Scope 3 reliefFirst annual period only (S2 ¶C4(b))No time limit in the standard (S2 ¶C4)
Publishing after the accounts, year onePermitted (S1 ¶E4)Removed
December 2025 GHG amendmentsPeriods from 1 January 2027Built in from the start

The UK position

Are IFRS S1 and S2 mandatory in the UK?

No UK law requires IFRS S1 or IFRS S2 by name.

The FCA’s final rules, published on 30 September 2026, require listed companies in UKLR 6, 14, 15, 16 and 22 to report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027.

Comply or explain runs across both standards, S2 included.

The CP26/5 consultation had proposed making UK SRS S2 mandatory and giving UKLR 14 and 15 companies a signposting statement only; the final rules did neither.

The Policy Statement gives no total company count; the consultation estimated that around 600 listed companies would be affected (CP26/5 Annex 2 ¶43).

A company using either relief says that it is doing so, and need give no further explanation during the relief period.

Everyone else may use UK SRS voluntarily; no private-company threshold is proposed anywhere, as UK SRS scope sets out.

FCA final rules — PS26/19

Listed companies in UKLR 6, 14, 15, 16 and 22 report against UK SRS on a comply-or-explain basis.

Accounting periods beginning on or after 1 January 2027; first reports in 2028.

One year’s Scope 3 relief and two years’ relief for S1 non-climate matters.

What the UK changed

From IFRS to UK SRS: the differences, without a count

The government consulted on six proposed amendments in June 2025; the final standards differ from IFRS S1 and S2 as set out in Annex A of its consultation response, which carries no total.

Annex A’s own rule makes it exhaustive: where a requirement is not in the table, there is no difference.

The effective dates were removed, not replaced.

References to the SASB Standards and the Industry-based Guidance changed from “shall” to “may” at UK SRS S1 ¶¶55(a) and 58(a) and UK SRS S2 ¶¶12, 23 and 32.

The first-year option to publish after the accounts was removed from S1, and the climate-first and Scope 3 reliefs lost their time limits.

UK SRS S1 ¶73A says a company using the climate-first relief may not assert compliance with UK SRS S1, and UK SRS S2 ¶B59A adds a duty to explain when financed emissions cannot be disclosed.

The ISSB’s December 2025 amendments, including the removal of the fixed industry classification, are the ISSB’s; the UK did not make them.

Every row is set out on UK SRS against IFRS S1 and S2; the sister site covers UK SRS S1 and, for financial institutions, IFRS sustainability reporting in finance.

Who uses them

Global use: the standard has spread, the mandate has not settled

Adopting a standard, requiring its use and naming the regulator that requires it are three separate facts.

The IFRS Foundation’s own classifications keep them apart; so does this table.

Classifications are the IFRS Foundation’s own, as stated in each profile; a profile is not the owner of the jurisdiction’s law.
JurisdictionIFRS Foundation classification or owner’s positionSource
United KingdomSnapshot, not a profile: UK SRS voluntary; FCA comply-or-explain rules from 2027IFRS Foundation register
Japan“Adopting ISSB Standards with limited transition” — SSBJ Standards designed to be functionally alignedJapan profile
SingaporeThe IFRS S2 requirements and the climate-related parts of IFRS S1; beyond climate to be reviewedSingapore profile
Australia“Partially incorporating ISSB Standards” — AASB S2 climate reporting in cohorts from 1 January 2025Australia profile
Hong Kong SAR“Partially incorporating … and permitting the use of ISSB Standards”; target full adoptionHong Kong SAR profile
Brazil (CVM)Mandatory reporting for public companies revoked on 29 May 2026; comply-or-explain notice from 2027CVM press release

In the Foundation’s words of 18 June 2026, over 40 jurisdictions “have already decided to use or are taking steps to introduce ISSB Standards”.

A harder and more useful figure is the Foundation’s of 24 February 2026: “requirements in 19 jurisdictions have already come into effect”.

Taking steps is not the same as companies being required to report, and the two figures should never be read as one.

The Foundation’s register publishes a profile only once a jurisdiction’s approach is final and no longer under consultation; the UK sits among the snapshots.

The count and its history are on the ISSB guide.

Against the others

IFRS S1 and S2 against the ESRS and UK SRS

Omnibus I Directive (EU) 2026/470; Delegated Regulation (EU) 2026/1563 Art 3; IFRS Foundation.
SetIssued byWho it reachesMaterialityStatus on 30 September 2026
IFRS S1 and S2ISSB, IFRS FoundationWherever a jurisdiction adopts or permits themSingle, financialEffective from 1 January 2024 as standards
UK SRS S1 and S2Secretary of State for Business and TradeAny UK entity voluntarily; listed companies on comply or explain from 2027Single, financialPublished 25 February 2026; no effective date
ESRSEuropean CommissionEU undertakings above 1,000 employees and €450m net turnover, from financial years 2027Double: impact and financialRevised ESRS apply to financial years from 1 January 2027
TCFD recommendationsTCFD (FSB)VoluntaryFinancial, climate onlyDisbanded October 2023; carried by IFRS S2

The EU’s scope after Directive (EU) 2026/470 needs both limbs — more than 1,000 employees and more than €450 million net turnover — and the revised ESRS apply under Delegated Regulation (EU) 2026/1563 from 1 January 2027.

The IFRS Foundation says the TCFD disbanded in October 2023, and that IFRS S2 is consistent with its recommendations.

The European standards are read on the European Sustainability Reporting Standards.

Frequently asked

IFRS S1 and S2: frequently asked

What are IFRS S1 and S2?

IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures are the ISSB's first two standards, issued on 26 June 2023.

S1 sets the general requirements for all sustainability-related risks and opportunities: the materiality test, the four areas of disclosure, where and when to report, and what to do when no standard covers a topic.

S2 is the first topic standard, for climate, and adds scenario analysis, Scope 1, 2 and 3 emissions and seven cross-industry metrics.

When are IFRS S1 and S2 effective?

Both are effective for annual reporting periods beginning on or after 1 January 2024 (IFRS S1 paragraph E1, IFRS S2 paragraph C1).

Earlier application is permitted only if the other standard is applied at the same time.

The ISSB's December 2025 amendments to IFRS S2 apply for periods beginning on or after 1 January 2027.

The effective date is the standards' own; whether any company must use them depends on each jurisdiction.

Are IFRS S1 and S2 mandatory in the UK?

Not as IFRS S1 and S2.

The UK endorsed them as UK SRS S1 and S2, published by the Department for Business and Trade on 25 February 2026 for voluntary use and with no effective date.

Under the FCA's final rules (PS26/19, 30 September 2026), listed companies in UKLR 6, 14, 15, 16 and 22 must report against UK SRS on a comply-or-explain basis for accounting periods beginning on or after 1 January 2027, with first reporting in 2028.

Nothing in UK SRS is mandatory under those rules.

Do you have to apply IFRS S1 and S2 together?

Yes.

IFRS S1 paragraph E1 says an entity applying it early shall apply IFRS S2 at the same time, and IFRS S2 paragraph C1 says the reverse.

In the first year IFRS S1 paragraph E5 lets an entity report on climate only — the 'climate-first' relief — and apply S1 only so far as it relates to climate, disclosing that it has done so.

Who issues IFRS S1 and S2?

The International Sustainability Standards Board, formed by the IFRS Foundation Trustees on 3 November 2021 at COP26 in Glasgow.

The ISSB operates alongside, but independently from, the IASB, which writes the IFRS Accounting Standards.

It built on the work of the CDSB, the TCFD, the Value Reporting Foundation's Integrated Reporting Framework and the SASB Standards.

How many jurisdictions use IFRS S1 and S2?

In the IFRS Foundation's own words of 18 June 2026, over 40 jurisdictions 'have already decided to use or are taking steps to introduce ISSB Standards'.

On 24 February 2026 the Foundation said requirements had already come into effect in 19 jurisdictions.

The two are different claims: taking steps is not the same as reporting being required.

The Foundation's register splits jurisdictions into profiles, where the approach is final, and snapshots, where it is still in progress; the UK is a snapshot.

What is the difference between IFRS S1 and S2 and UK SRS?

UK SRS S1 and S2 are IFRS S1 and IFRS S2 (as amended by the ISSB in December 2025) endorsed with a small set of differences, all listed in Annex A of the government's consultation response, which carries no count.

The effective dates were removed; references to SASB and the Industry-based Guidance changed from 'shall' to 'may'; the first-year option to publish later than the accounts was removed; the Scope 3 and climate-first reliefs lost their time limits; and paragraph B59A adds a duty to explain when financed emissions cannot be disclosed.

What changed in IFRS S1 and S2 in 2026?

The standards themselves did not change in 2026; the ISSB's last amendment was to IFRS S2 in December 2025, applying from 1 January 2027.

What changed was their use: the UK published UK SRS S1 and S2 on 25 February 2026 and the FCA finalised comply-or-explain rules on 30 September 2026, while elsewhere Brazil's securities regulator revoked mandatory reporting for public companies on 29 May 2026.

Sources

Primary sources

Every figure, date and status on this page traces to the instrument’s owner.

Secondary commentary is never the source for a number.

Checked against 27 sources fromIFRS FoundationComissão de Valores Mobiliários (Brazil)Department for Business and TradeFinancial Conduct AuthorityEUR-Lex
  1. IFRS Foundation
    IFRS S1 General Requirements (free HTML), ¶¶17–18, 25, 54–59, 72 and Appendix E

    Materiality, the four areas, sources of guidance, the compliance statement, and ¶E1: apply IFRS S2 at the same time.

  2. IFRS Foundation
    IFRS S2 Climate-related Disclosures, December 2025 text (free HTML), ¶¶C1–C1B

    Effective 1 January 2024; the December 2025 amendments from 1 January 2027.

  3. IFRS Foundation
    IFRS S1 — Navigator standard page

    Effective 1 January 2024, earlier application “as long as IFRS S2 … is also applied”.

  4. IFRS Foundation
    IFRS S2 — Navigator standard page
  5. IFRS Foundation
    ISSB issues IFRS S1 and IFRS S2 — issuance announcement, 26 June 2023

    The date of issue. A press release, not the Standards’ text.

  6. IFRS Foundation
    International Sustainability Standards Board — group page

    Formed 3 November 2021; the initiatives it built on.

  7. IFRS Foundation
    Who we are

    The ISSB “operates alongside—but independently from—the IASB”.

  8. IFRS Foundation
    ISSB issues targeted amendments to IFRS S2, December 2025
  9. IFRS Foundation
    Applying IFRS S1 when reporting only climate-related disclosures in accordance with IFRS S2, January 2025

    The climate-first relief in IFRS S1 ¶E5.

  10. IFRS Foundation
    ISSB update to the CMAC and GPF, 18 June 2026 (PDF)

    “Over 40 jurisdictions have already decided to use or are taking steps to introduce ISSB Standards.”

  11. IFRS Foundation
    Jurisdictional Readiness Assessment Guide and tool, 24 February 2026

    “Requirements in 19 jurisdictions have already come into effect.”

  12. IFRS Foundation
    Use of IFRS Sustainability Disclosure Standards by jurisdiction

    Profiles (final) and snapshots (in progress). The UK is a snapshot.

  13. IFRS Foundation
    Jurisdictional profile: Japan (updated 16 July 2026)
  14. IFRS Foundation
    Jurisdictional profile: Singapore
  15. IFRS Foundation
    Jurisdictional profile: Australia (updated 12 June 2025)
  16. IFRS Foundation
    Jurisdictional profile: Hong Kong SAR (updated 12 June 2025)
  17. Comissão de Valores Mobiliários (Brazil)
    CVM altera Resolução 193 para revogar obrigatoriedade…, 29 May 2026

    Mandatory reporting for Brazilian public companies revoked; comply-or-explain notice from 1 January 2027.

  18. Department for Business and Trade
    UK SRS S1 and UK SRS S2, published 25 February 2026
  19. Department for Business and Trade
    UK Sustainability Reporting Standards — guidance

    “Available for voluntary use, by any entity that chooses to do so.”

  20. Department for Business and Trade
    UK SRS consultation response, Annex A

    The difference tables; no count of amendments.

  21. Financial Conduct Authority
    PS26/19: Aligning listed issuers' sustainability disclosures with international standards

    Published 30 September 2026. Scope ¶3.6; commencement ¶3.12; reliefs ¶3.14, ¶3.20.

  22. Financial Conduct Authority
    PS26/19 — Policy Statement (PDF)

    ¶4.35: 89 secondary-listing and depositary-receipt issuers under the same requirements. No total company count.

  23. Financial Conduct Authority
    CP26/5 — the consultation PS26/19 finalises
  24. Financial Conduct Authority
    CP26/5 (PDF), Annex 2 ¶43

    Around 600 listed companies affected — the consultation’s estimate.

  25. EUR-Lex
    Directive (EU) 2026/470 (Omnibus I)

    CSRD scope: more than 1,000 employees and more than €450m net turnover, from financial years 2027.

  26. EUR-Lex
    Commission Delegated Regulation (EU) 2026/1563 — revised ESRS, Article 3
  27. IFRS Foundation
    ISSB and TCFD

    The TCFD disbanded in October 2023.

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