ISSB: Global Momentum for Sustainability Reporting

World

Senior Consultant

UK

Kriti Sinha

Kriti Sinha

Junior Consultant

Updated in December 2025

The standards released by the International Sustainability Standards Board (ISSB) in June 2023 are rapidly gaining traction across the world, but the pace and approach of adoption have been significantly varied. The standards are comprised of IFRS S1 on general sustainability-related financial disclosures, and IFRS S2 on climate-related disclosures, which we have unpacked in a previous article.

These standards will provide investors and other stakeholders with the comparable, decision-useful information they need to assess the financial impacts of sustainability and climate change on a company, and the adequateness of their governance and strategies to manage sustainability-related risks and opportunities.

In this article, we dive into how different jurisdictions are approaching and implementing the ISSB with our experts from around the world sharing their insights on key developments.

Europe

The European Union

The primary and most comprehensive sustainability disclosure framework in the EU is the Corporate Sustainability Reporting Directive (CSRD), under which the European Financial Reporting Advisory Group (EFRAG) has developed the European Sustainability Reporting Standards (ESRS). These standards cover the full range of sustainability-related issues and are intended to standardise sustainability reporting within the EU.

The EU has adopted European Sustainability Reporting Standards (ESRS) to comply with CSRD. Both The ISSB and the European Commission have highlighted the high degree of alignment between ESRS climate disclosure requirements and the ISSB standards.

EFRAG has expressed strong support for the ISSB and its standards, and highlights that the ESRS incorporate ISSB disclosures under a thorough interoperability approach. Entities preparing sustainability reports in compliance with the ESRS on climate change will therefore be meeting the requirements of the ISSB standards to a large extent, thus preventing the need for separate reporting under the ISSB standards.

The ESRS and IFRS S1 and S2 have been developed in parallel, ensuring a high degree of alignment between both sets of standards. EFRAG and the ISSB have recently released an interoperability map that illustrates this alignment.

Whilst in the EU, the CSRD remains the key ESG mandatory reporting framework, the commitment to interoperability from both the IFRS and EFRAG is crucial; especially for those companies headquartered outside the EU, but with significant operations within. We’re finally seeing more clarity on how the needs of both frameworks can be met, for example in materiality assessment and stakeholder engagement.”

Chris Shaw, Technical Director, Anthesis EMEA

The United Kingdom

On 25th June 2025, the UK Government announced the launch of three public consultations aimed at strengthening the UK’s sustainability reporting framework. These consultations cover the following key areas: 

  1. Adoption of International Sustainability Standards 
    The UK is proposing to adopt the International Sustainability Standards Board (ISSB) standards through the development of UK Sustainability Reporting Standards (UK SRS). The UK SRS will establish a consistent baseline for sustainability disclosures, closely aligned with global best practices. Feedback is sought on adopting these standards with minimal UK-specific modifications. 
  1. Mandatory Climate Transition Plans 
    The government is consulting on introducing mandatory requirements for Climate Transition Plans, ensuring organisations clearly articulate their strategies for aligning with climate goals. 
  1. Regulatory Oversight of Sustainability Assurance Providers 
    A new framework is being proposed to introduce regulatory oversight for sustainability assurance providers, enhancing trust and accountability in sustainability reporting. 

These consultations are a key step in the UK’s ambition to build a world-leading regulatory framework for sustainable finance, one that promotes transparency, accountability, and sustainable economic growth. 
All three consultations are open for comment until 17th September 2025. We strongly encourage UK businesses and stakeholders to engage with these consultations and provide their input to help shape the future of sustainability reporting in the UK. 

The exposure drafts of UK SRS S1 and UK SRS S2 closely align with the International Sustainability Standards Board (ISSB) Standards—IFRS S1 and IFRS S2. As part of its consultation, the UK Department for Business and Trade has proposed six minor amendments to tailor the standards for the UK context: 

  1. Removal of Initial Transition Relief: Reporting entities will be required to publish their sustainability disclosures at the same time as their financial statements from the first reporting year. The ISSB’s original one-year delay allowance has been removed. 
  2. Extension of Climate-First Transition Relief: Entities may focus solely on climate-related disclosures for the first two years, with broader sustainability-related risks and opportunities to be reported from Year 3 onwards. 
  3. Flexibility in Industry Classification: The requirement to use the Global Industry Classification Standard (GICS) has been removed. Entities may now use any appropriate industry classification standard to disaggregate disclosures, such as those for financed emissions.
  4. No Prescribed Effective Date: The UK SRS will be made freely available for voluntary use upon endorsement. The mandatory application will depend on a separate consultation on the implementation pathway. 
  5. Voluntary Reference to SASB Standards: The previously mandatory use of SASB standards for industry-specific disclosures has been made voluntary. Entities may refer to the IFRS S2 Industry-based Guidance, which draws from SASB standards, at their discretion. 
  6. Clarification on Application of Transition Reliefs: Entities will only be bound by the transition relief restrictions in IFRS S1 and S2 once mandatory reporting requirements apply to them. Voluntary early adopters can apply the full set of reliefs during their first reporting year. Reliefs cover areas such as: 
  • Greenhouse gas emissions methodologies 
  • Disclosure of Scope 3 emissions 
  • Provision of comparative information 

The ISSB is currently consulting on potential amendments to IFRS S2, including: 

  • The requirement to use GICS 
  • Possible exclusions to Scope 3 Category 15 emissions 

The UK Government is monitoring these developments closely and aims to minimise divergence between the UK SRS and the ISSB standards. 

The Government is particularly interested in: 

  • The costs and benefits associated with adopting UK SRS S1 and S2 
  • Areas where additional guidance would support effective implementation 

Next steps: 

  • Following this consultation, the Secretary of State for Business and Trade will decide on the final endorsement of UK SRS S1 and S2.

  • If endorsed, the final standards will be published in autumn 2025.

  • The Financial Conduct Authority (FCA) and the UK Government will consult separately on mandatory reporting implementation, including:

    • Which entities will be covered

    • Timelines for the first year of reporting for both listed and large unlisted companies

The Department for Energy Security and Net Zero has launched a consultation on introducing mandatory transition plan requirements for financial institutions and FTSE 100 companies. This proposal marks a significant step toward aligning corporate climate action with the 1.5°C goal of the Paris Agreement. 

  1. Entities would be required to explain why they have not disclosed a transition plan or transition plan-related information, or 
  2. Entities would be required to develop and disclose transition plans.

In addition to the implementation pathway, the consultation seeks comments on the following:  

  • Benefits and use cases of transition plans 
  • Implementation options 
  • Developing and disclosing a transition plan 
  • Mandating transition plan implementation 
  • Aligning transition plans to net zero by 2050 
  • Climate adaptation, resilience and nature alignment 
  • Scope and legal risk 
  • Related policy and frameworks 

Next steps:  

  • Responses to this consultation will be considered alongside responses to the other two consultations, after which the UK Government will propose a package that considers the UK’s sustainability-related regulatory landscape as a whole. 
  • The FCA will also consult on strengthening transition plan expectations for listed companies.  
  • The Government will consider the recommendations set out in the Transition Finance Market Review and has co-launched the Transition Finance Council alongside the City of London Corporation to drive ambition on these recommendations. 

 

North America

The United States of America

The US Securities and Exchange Commission (SEC) approved its own climate disclosure rulemaking in March 2024. The general disclosures mandated through this regulation are broadly aligned with the TCFD framework. In the final rule, the SEC emphasises disclosure of only those climate-related risks that have been found to be potentially material to the company as well as Scope 1 and 2 GHG emissions only if found to be material. Companies subject to the SEC’s rule will also be required to disclose the actual financial impacts from climate-related events and/or transition planning activities on their income statement and balance sheet for the reporting period, subject to a reporting threshold.

Upon approval of the final rule, the SEC faced litigation from various groups stating concerns such as the SEC’s authority to implement such regulations and arguments that the ruling does not go far enough. In light of these legal challenges, the SEC put a pause on implementation of the rule until litigation is resolved, with hearing expected in 2025.

Canada

In consultation

Canada has adopted ISSB standards by releasing its own set of standards, called the Canadian Sustainability Disclosure Standards (CSDS), which were developed based on ISSB Standards. These were released by the Canadian Sustainability Standards Board (CSSB) in December 2024, and comprise CSDS 1, i.e., General Requirements for Disclosure of Sustainability-related Financial Information, and CSDS 2, i.e., Climate-related Disclosures. Key modifications in relation to ISSB standards include an effective date from 1st January 2025, a year later than the global ISSB baseline, a Scope 3 emissions relief of three years (until 1st January 2028) before mandatory disclosure of Scope 3 emissions is required, and a transition relief of two years (until 1st January 2027) before needing to report beyond climate-related disclosures.

We welcome the proposed Canadian Sustainability Disclosure Standards (CSDS). Aligning disclosures on sustainability-related information with the rest of the world is crucial for Canada’s long-term economic success. The CSDS represent a significant step forward in ensuring Canadian companies continue to act for crucial sustainability risks and opportunities while remaining competitive and attractive to global investors through standardised and consistent disclosures, echoing the actions recently taken by key trading partners such as the US and the EU.”

Mari Desangles, Principal Consultant, and Bridie O'Boyle, Principal Consultant, Anthesis North America

Mexico

In January 2025, The Banking and Securities Commission of Mexico made several key amendments to Mexico’s security laws. The amendments require companies in Mexico to integrate sustainability information in their financial statements, in compliance with the ISSB Standards, IFRS S1 and S2.

Through these new changes, The Banking and Security Commission of Mexico has directed companies to report their sustainability information in their financial statements for 2025, reporting in 2026.

Additionally, from 2026 onwards, companies will be required to include assurance from an external auditor on their sustainability reports.

El Salvador 

In Consultation 

On August 2024, through Resolution 82, the Supervisory Board of the Public Accounting and Auditing Profession adopted the two IFRS standards, IFRS S1 and IFRS S2 on a voluntary basis from 1st January 2025. Decision on when applicable entities may be required to mandatorily report on ISSB standards is still to be determined. 

Asia-Pacific

The APAC region is leading the global response to the ISSB standards and implementation of these through the various national sustainability and climate reporting frameworks.

Australia

Adopted

Australia is among the first countries to implement mandatory climate reporting standards aligned with the ISSB standards, through its climate-related financial disclosure regulation Treasury Laws Amendment (Financial Market Infrastructure and Other Measures) Act 2024, which was passed in September 2024.

The Australian Accounting Standards Board (AASB) issued its final climate reporting standards in December 2024, ahead of the 1st January 2025 start date. The Australian Sustainability Reporting Standards (ASRS) comprise of AASB S1 – General Requirements for Disclosure of Sustainability-related Financial Information and AASB S2 – Climate-related Disclosures, align with ISSB standards with minimal variations, albeit only climate-related disclosures as a starting point.

Legislation to mandate the new ISSB-aligned reporting requirements was introduced to Parliament in March 2024. This includes a phased implementation timeline for mandatory reporting in the private sector over several years, with large listed and private entities meeting certain revenue, asset, employee, or emissions thresholds being required to publish mandatory climate-related disclosures. The legislation includes a phased approach to assurance requirements, with the expectation that companies will be required to obtain reasonable assurance over their full disclosure by FY2030. The Australian Auditing and Assurance Standards Board has been tasked with setting the roadmap to phase in assurance over a five-year period.

The Australian Government is separately developing mandatory climate-related disclosure requirements for the public sector based on the ASRS/ISSB tailored to Australian government entity circumstances, commencing for annual reports ending 30th June 2025. The Australian government is also running a pilot disclosure program for some government entities to include a limited sub-set of climate-related disclosures their annual report ending 30th June 2024.

As we move into this mandatory setting, companies will gain the most by focusing not only on compliance, but ultimately on the strategic benefits to gain deep business insights, improve resilience and performance and attract investment and other opportunities.”

Amy Quinton, Principal Consultant, Anthesis Australia

Singapore

In September 2024, the Singapore Exchange Regulation (SGX RegCo) announced it would enhance its sustainability reporting by requiring companies to report on climate and to refer to ISSB standards as the guiding framework. It prescribed the general requirements and conceptual foundations of IFRS S1 insofar as they relate to the climate-related risks and opportunities, along with IFRS S2 requirements with the exception of the disclosure of Scope 3 GHG emissions. Reporting beyond climate-related disclosures is currently encouraged but not mandated.

However, In August 2025, The Accounting and Corporate Regulatory Authority (ACRA) and Singapore Exchange Regulation (SGX RegCo) extended its timelines for implementation in order to support both listed and large non-listed companies to develop its capabilities to report in alignment with IFRS regulations.  

While the timeline and implementation of the standards are still subject to change, based on the new proposed timeline, the following is the expected approach for Listed Companies and Large non-listed Companies:  

Listed Companies:  

  1. Implementation of a three-tier structure to phase reporting obligations based on market capitalisation:  
    • Straits Times Index (STI) constituents  
    • Non-STI constituent listed companies with a market capitalisation of $1 billion and above; and  
    • Non-STI constituent listed companies with a market capitalisation of less than 1$ billion.  
  2. For all listed companies, reporting on Scope 1 and 2 Greenhouse Gas (GHG) emissions will remain mandatory from FY2025.  
  3. All STI constituent listed companies will be required to mandatory report on their Scope 3 GHG emissions from FY202. For other non-listed STI constituent companies, reporting on Scope 3 GHG emissions will remain voluntary.  
  4. For STI constituent listed companies, other ISSB-aligned climate-related disclosures will remain mandatory from FY2025. Non-STI constituent listed companies who have a market capitalisation of $1 billion or over will be required to report from FY2028, while those with a market capitalisation of less than $1 billion will be required to report from FY2030.  
  5. External limited assurance for Scope 1 and 2 GHG emissions has been extended to FY2029 for all listed companies.  

Large non-listed companies:  

  1. ISSB-based climate-related disclosures have been extended to FY2030. 
  2. Voluntary reporting on Scope 3 GHG emissions.  
  3. Extension to external limited assurance for Scope 1 and 2 GHG emissions to FY2032 

Singapore’s adoption and mainstreaming of the ISSB standards is a clear signal that it is fully committed to the green transition and demonstrating credibility in its climate initiatives. It is also the first Asian country to extend mandatory climate-related disclosures to non-listed companies while implementing support mechanisms to support capacity building in meeting the new reporting requirements. This helps to position Singapore as a leader in advancing sustainability reporting in Asia and enable Singaporean companies to become more resilient and adaptable in a low-carbon economy.”

Peggy Oh, Director, Anthesis Singapore

Read further regional insights below:

In consultation

Japan is actively moving towards adopting sustainability disclosure standards (SDS) based on the ISSB framework. The Sustainability Standards Board of Japan (SSBJ) published three exposure drafts in April 2024:

  1. Universal SDS Exposure Draft “Application of the Sustainability Disclosure Standards”
  2. Theme-based SDS Exposure Draft No. 1 “General Disclosures”
  3. Theme-based SDS Exposure Draft No. 2 “Climate-related Disclosures”

These drafts are largely based on the ISSB’s IFRS S1 and IFRS S2 standards, with some potential adjustments for the Japanese context.

In March 2025, the SSBJ issued the sustainability disclosure standards, i.e. SSBJ Standards. The final disclosure standards adopted are as mentioned above.  It is important to note that the SSBJ has divided the sustainability standards aligning with IFRS S1 standards into two standards, which are issued separately. The SSBJ has highlighted that the ‘Core content’ section of IFRS S1 is included in the ‘General Disclosures’, while the other requirements of IFRS S1 have been included in the ‘Application Standard.’

Adopted 

New Zealand pre-empted the ISSB by developing its own mandatory climate-related disclosure requirements through the Aotearoa New Zealand Climate Standards 1-3, in 2022. New Zealand companies are currently publishing climate-related disclosures[1] in line with the NZ CS, which are comprised of: 

  • NZ CS 1 Climate-related Disclosures 
  • NZ CS 2 Adoption of Aotearoa New Zealand Climate Standards 
  • NZ CS 3 General Requirements for Climate-related Disclosures 

These were established by the External Reporting Board (XRB), which closely monitored the ISSB’s development process and ensured a high degree of alignment between the NZ CS and the IFRS S1 and S2 standards. The XRB is continuing to monitor the development and implementation of the ISSB standards and is open to further aligning the NZ CS with the standards in the future, especially as the ISSB releases additional industry-specific or thematic standards.  In October 2023, the XRB published a comparison guide to demonstrate the alignment of the NZ CS and the ISSB standards. The XRB plans to publish a similar comparison guide against the Australian ASRS. 

The XRB plans to review New Zealand’s current climate standards in December 2025 to determine whether they need to make any changes to their current standards to align better with the present and future sustainability requirements. 

[1] The first tranche of reports are now publicly available on the New Zealand Government’s register: Climate Reporting Entities (companiesoffice.govt.nz) 

Adopted

In April 2023, the Stock Exchange of Hong Kong Limited (the Exchange) published a consultation paper seeking feedback on the implementation mandatory climate-related disclosures in line with IFRS S2 under its environmental, social and governance framework.

In December 2024, The Hong Kong Institute of Certified Public Accountants (HKICPA) published their sustainability disclosure standards, HKFRS S1 and HKFRS S2 which align directly with the ISSB standards, IFRS S1 and IFRS S2 respectively.

 

HKIPCA has suggested that these sustainability standards may be applied to ‘publicly accountable entities’ including listed entities and regulated financial institutions in Hong Kong initially, from the 1st of August 2025.

 

The timing and approach of adopting the sustainability standards, HKFRS S1 and S2 will be decided by individual regulators and authorities.

Most recently, in 2024, the HKEX also imposed new climate requirements based on IFRS S2 directed to listed issuers commencing from 1st January 2025.

In consultation

The Reserve Bank of India (RBI) has published the Draft Disclosure framework on Climate-related Financial Risks, 2024, which is proposed to implement mandatory climate disclosure requirements for commercial banks, cooperative banks, financial institutions, as well as non-banking financial companies in India. Proposed climate-related disclosure requirements have been developed in line with the four pillars of the TCFD and IFRS S2 – governance, strategy, risk management and metrics and targets – and would be phased in from FY2028 onwards.

Adopted

The Advisory Committee on Sustainability Reporting (ACSR) launched a consultation from February to March 2024 on the implementation of the ISSB standards for listed and large non-listed companies in Malaysia. The consultation aimed to seek feedback on the scope and timing for implementation, transition reliefs, and assurance-related matters. It is expected that the ISSB standards will form the baseline for the National Sustainability Reporting Framework in Malaysia.

Following the consultation, in September 2024, through the publication of The National Sustainability Reporting Framework (NSRF), Malaysia adopted the ISSB standards.

 

The ISSB standards, according to the NSRF is applicable to all listed companies on Bursa Malaysia’s main market and ACE market, along with, large non-listed companies whose annual turnover exceed RM 2 billion.

 

The NSRF highlights the adoption of the ISSB standards will follow a phased approach – from 2025 onwards, all large-listed issuers on the main market with a market capitalisation of RM 2 billion will apply these sustainable disclosures.

In 2026, all other main market issuers will have to adopt the sustainability standards, followed by ACE Market issuers and large non-listed companies adopting these sustainability standards by 2026.

In Consultation 

In December 2024, the Institute of Indonesia Chartered Accountant published its exposure draft of the Indonesian Sustainability Disclosure Standards, i.e. Sustainability Disclosure Standards (SPK), comprising of draft PSPK 1 and PSPK 2, in line with IFRS S1 and IFRS S2 respectively.  The draft exposure if approved would require publicly accountable entities, including listed entities and financial service industry to report against PSPK 1 and PSPK 2 from 1st of January 2027.  

In Consultation

Publicly listed companies in the Philippines currently have mandatory sustainability reporting requirements on a ‘comply or explain’ basis. In July 2025, The Securities and Exchange Commission (SEC) of the Philippines released a draft Memorandum Circular on the Adoption of Philippine Financial Reporting Standards (PFRS) on Sustainability Disclosures and Issuance of Reporting Guidelines for Publicly-listed Companies and Large non-listed Companies guidelines for public consultation. Under the new draft, Philippines aims to implement the regulations through a phased approach whereby (companies with a market size of more than ₱50 billion will be required to report under ISSB standards in 2027 for FY2026 data, while those Companies with a market size of more than ₱3 billion will be required to report against the standards in 2028 for FY2027 data. Additionally, Companies with a market size of ₱3 billion or less, or large non-listed companies with an annual revenue of more than ₱15 billion will be required to report again the standards in 2029 for FY2028 data.

In Consultation

Based on the public consultation that closed in December 2024, Thailand’s Securities and Exchange Commission (SEC Thailand) proposed that the ISSB standards will be implemented through a phased-in approach whereby listed companies categorised in the SET50 Index will be required to disclose in 2027, while the listed companies categorised in SET100 Index will be required to disclose in 2028. Additionally, all other companies listed on the Stock Exchange of Thailand (SET) will be required to start disclosing in 2030, while real estate investment trusts, infrastructure funds, infrastructure trust and property funds listed in SET will be required to start disclosing in 2031.

Adopted

In December 2023, the Sustainability Working Group of the Accounting Standards Board published a recommendations paper outlining the study, consultations and recommendations for implementing the ISSB standards in Pakistan.

Most recently, on 1st of January 2025, The Securities and Exchange Commission of Pakistan (SECP) announced the adoption of the IFRS standards, applying to only listed companies through a phased approach on criteria’s such as a company’s total assets, turnover and number of employees.

Large listed companies meeting the financial thresholds will be required to report after 1st July 2025, while the Companies falling under phase 2 and 3 will be required to report from July 2026 and July 2027 accordingly.

Adopted

In August 2023, the Financial Supervisory Commission of Taiwan published a roadmap for Taiwan-listed entities to align with the ISSB standards – both S1 and S2. These will be adopted from 2026, after which the FSC will continue assessing and endorsing ay additional standards released by the ISSB. Mandatory reporting will be phased in based on capital thresholds, and the same transition reliefs as are in the ISSB standards will be applied. In addition, entities may disclose qualitative information for matters involving a high degree of uncertainty and difficulty in quantification.

In consultation

In May 2024, The Korea Sustainability Standards Board (KSSB) published the Sustainability Disclosure Standards in Korea, KSSB 1, KSSB 2 and KSSB 101. The sustainability disclosure standards KSSB 1 and KSSB 2, follow the IFRS S1 and S2 standards respectively while KSSB 101 is an optional disclosure requirement which serves as a country specific set of standards that provides guidance on disclosure of sustainability related information is required by South Korean Laws.

The current scope and timing for when these disclosures will be implemented has not been confirmed yet.

Adopted

In December 2023, The Central Bank of Bangladesh, issued guidelines for the adoption of Sustainability Disclosures based on ISSB standards, specifically, IFRS S1 and IFRS S2 for banks and financial institutions.

The adoption of these Sustainability Disclosures will follow a phased approach in a three-year timeframe.

 

According to the Central Bank, financial institutions and banks will be required to file a limited intermediate report for June 2024, a limited supervisory report for December 2024 followed by a limited disclosures in annual reports in 2025, more detailed disclosures in 2026 and full disclosure in 2027.

Adopted

The Institute of Chartered Accountants of Sri Lanka (CA Sri Lanka) announced the mandatory adoption of the Sri Lanka Sustainability Disclosure Standards, SFLRS S1 and SFLRS S2, based on ISSB Standards, IFRS S1 and IFRS S2, commencing 1st January 2025 with full implementation expected by 2030.

Adoption of Sustainability Disclosure Standards will follow a phased approach:

Phase 1: First 100 entities listed in the Columbo Stock Exchange are mandated to comply with SFLRS S1 and SFLRS S2 by 2025, reporting in 2026.

Phase 2: All listed entities on the main board of CSE mandated to adopt SFLRS S1 and SFLRS S2, and report by 2027.

Phase 3: Entities with an annual turnover exceeding LKR 10 billion in the last two consecutive years mandated to comply with these standards by 2028, followed by entities with an annual turnover exceeding LKR 5 billion in the last two consecutive years adopting these standards in 2029.

Phase 4: All listed entities on CSE empower board, i.e., small and medium size companies required to adopt these standards by 2030.

In consultation

In May 2025, China’s Ministry of Finance published a draft sustainability disclosure standard, based on ISSB Standards termed ‘Corporate Sustainability Disclosure Standards – Basic Standard.’ This exposure draft outlines the general requirements for corporate sustainability information disclosures that all companies established in China are required to adhere to.

 

The adoption of these sustainability disclosure standards is planned to follow a phased approach, starting with listed companies and subsequently extending to non-listed companies.

China aims to implement the climate-related disclosure standard, based on IFRS S2, by 2027 on a voluntary basis. The entire suite of sustainability disclosures standards are expected to be fully issued by 2030.

Africa

South Africa has created a set of complimentary systems starting with the SA Green Finance Taxonomy, which defines what is to be considered a sustainable asset or project in the South African context. This feeds into the Johannesburg Stock Exchange Sustainability & Climate Disclosure guidance, which in turn aligns with the ISSB disclosure standards at an international level. What we are witnessing is the incremental infilling of identified gaps that when filled will enable local and international finance to flow towards increasingly sustainable projects inside our country.”

The ISSB is gaining traction in Africa, with several key developments having taken place in recent times:

Nigeria

Adopted

Nigeria is positioned to be another early adopter of the ISSB standards. The Financial Reporting Council (FRC) developed a Draft Roadmap Report for Adoption of Sustainability Disclosure Standards in Nigeria, which was open for consultation until March 2024 and in April 2024, the FRC published the completed roadmap for the adoption of the Sustainability Disclosure Standards in Nigeria. The Roadmap affirms the ISSB standards as the recommended framework for Nigerian entities, discusses assurance, monitoring and enforcement considerations,

Presently, Nigeria has adopted the sustainability disclosure standards on a voluntary reporting basis until 2026.

Mandatory reporting of the Sustainability Disclosure Standards will occur through a phased approach beginning in 2027, with full application of mandatory reporting applicable to all entities starting on or after January 1st 2028.

Ghana

Adopted

In 2023, The Institute of Chartered Accountants, Ghana (ICAG) announced the adoption of the ISSB standards, specifically IFRS S1 and IFRS S2. The adoption of the ISSB standards will follow a phased approach, starting with voluntary adoption for entities from January 2024. Mandatory adoption will apply to significant public entities from 1st January 2027, followed by other companies required to report from 1st January 2028, with full implementation for all public sector entities based on the timeline issued by the International Public Sector Accounting Standards Board (IPSASB).

Tanzania

Adopted

The National Board of Accountants and Auditors of Tanzania (NBAA) announced the adoption of ISSB Standards effective from 1st January 2025. 

Under this guidance, all public interest entities (PIEs) are directed to adopt and comply with these standards from 1st January 2025.

While public sector entities are not required to apply these standards, the timeline for mandatory adoption date for this sector will be reviewed by the NBAA based on the timeline by when IPSASB is issued, and until then the NBAA has encouraged public sector entities to voluntarily apply these sustainability disclosures.

Zambia

Adopted

The Zambia Institute of Chartered Accountants on the 21st of November 2023, announced adoption of the ISSB standards, specifically IFRS S1 and IFRS S2.

According to the Zambia Institute of Chartered Accountants, all publicly accountable entities (PAEs) are mandated to apply and comply with IFRS S1 and IFRS S2 and the Integrated Reporting framework for annual reporting periods beginning on or after January 2025.

 For all other companies, the reporting of these standards are voluntary until further updates.

Kenya

Adopted

The Institute of Certified Public Accountants of Kenya (ICPAK) issued a roadmap in September 2023 on the phased adoption approach of the ISSB standards, specifically IFRS S1 and IFRS S2  from January 1st 2024 in Kenya.

The adoption of these standards follows a phased approach:

  • Phase 1: Voluntary Adoption – all organisations are encouraged to voluntarily adopt the sustainability standards from 1st January 2024. Phase 2: Mandatory Adoption
  • Public Interest Entities (PIEs) – apply from 1st January 2027
  • Non-PIEs (Large Enterprises) – apply from 1st January 2028
  • Non-PIEs (SMEs) – apply from 1st January 2029
  • Phase 3: Public Sector Adoption – the timelines for public sector adoption will be reviewed based on IPSASB’s standards.

Uganda

Adopted

The Institute of Certified Public Accountants of Uganda (ICPAU) produced a roadmap for the adoption of ISSB standards, specifically the IFRS S1 and the IFRS S2.

The adoption of these standards follow a phased approach where by:

Public Interest Entities (PiEs), including listed companies, financial institutions and state-owned enterprises are encouraged to comply and apply the sustainability disclosures for the financial year 2026, reporting in 2027 voluntarily.

The mandatory adoption of PiEs will start with the period beginning on or after 1st January 2028.

All other Entities are encouraged to voluntarily report on the ISSB standards from 2029, based on 2028 financial year.

Zimbabwe

In consultation

The Public Accountants and Auditors Board (PAAB), the Zimbabwe Stock Exchange (ZSE) and the Victoria Falls Stock Exchange (VFEX) have mandated all listed companies to  submit their sustainability reports for financial years commencing on or after January 1st 2024, based on the ISSB Standards.

The PAAB is also working on an implementation roadmap for the implementation of IFRS S1 and IFRS S2 for all other companies.

Rwanda

In consultation

In May 2025, the Institute of Certified Public Accountants of Rwanda (ICPAR) published its roadmap to phase in the adoption of Rwanda’s IFRS Sustainability Disclosure Standards after a public consultation that closed in March 2025.

Based on the roadmap, listed entities and Tier I Financial Institutions, including banks and insurance companies will begin to adopt the standards from 1st January 2025, with full adoption by 1st January 2027. For public utility companies and Tier II, including deposit taking microfinance, micro insurers and Tier III Financial Institutions, including non-deposit taking financial service providers and mutual insurers, reporting period begins on the 1st of January 2026 with full adoption by 1st January 2028. Additionally, other entities that prepare financial statements using IFRS Accounting Standards as well as Tier IV Financial Institutions, including financial cooperatives report from 1st January 2027, with full adoption by 1st January 2029.

Central America

Costa Rica

Adopted

The College of Public Accountants of Costa Rica announced in December 2023 the adoption of the ISSB standards in full through a phased approach as follows:

  • Commencing 1 January 2024: voluntary for any entity
  • For the financial year ending 31 December 2025: mandatory for companies regulated by the National Council for Supervision of the Financial System (Consejo Nacional de Supervisión del Sistema Financiero/CONASSIF)
  • For FY ending 31 December 2026: mandatory for companies classified as large taxpayers

South America

Latin American jurisdictions have historically been leading the mandating of sustainability disclosures, with both Chile and Colombia having mandated TCFD disclosures and reporting in line with the standards published by the Sustainability Accounting Standards Board (SASB). Several South American nations are expressing growing interest in the ISSB standards. Recent developments in relation to the ISSB standards include:

  • Superintendency of Banks of Panama announced support for the ISSB in October 2023.
  • The IFRS Foundation published the Spanish and Brazilian Portuguese translation of IFRS S1 to support uptake of the standard across South America.
  • The Inter-American Development Bank and Latinex co-hosted an event focused how the IFRS Accounting and Sustainability Disclosure Standards can support a more resilient and competitive financial sector.

Brazil

Adopted

Brazil became the first South American country to adopt the ISSB standards in October 2023 when the Brazilian Ministry of Finance and the Comissão de Valores Mobiliários (CVM), the country’s securities regulator, announced that the ISSB standards would be incorporated into the Brazilian regulatory framework.

The CVM released Resolution No. 193, which sets out that publicly listed companies, securitisation firms and investments funds may choose to voluntarily disclose in line with IFRS S1 and S2 from 2024, while mandatory disclosures will be required for listed companies from 1st January 2026. A stringent assurance pathway has also been outlined beginning with limited assurance until the end of FY2025, after which reasonable assurance over disclosures will be required. More recently, in October 2024, the CVM published Resolution No. 217, 218 and 219 that made the adoption of The Brazilian Sustainability Pronouncements Committee (CBPS)’s technical pronouncements 01 and 02 mandatory for all listed companies.

Therefore the new Resolution mandates adoption of IFRS S1 and through the Brazilian Sustainability Pronouncements Committee (CBPS)’s technical pronouncements, CBPS Technical Pronouncement 01 General Requirements for Disclosure of Financial Information Related to Sustainability

  • CBPS Technical Pronouncement 02 Climate-related Disclosures

Through the CVM resolution No. 219, a new deadline of the voluntary adoption of the disclosures has been adopted.

Additionally, in 2024, the Brazilian Central Bank (BACEN) mandated that financial institutions under BACEN regulations are required to adopt the following CBPS standards under these specific timelines:

1. Larger financial institutions classified:  mandatory adoption beginning 1st Jan 2026.

2. For all other regulated financial institutions:  mandatory adoption beginning on 1st January 2028.

Bolivia

Adopted

The College of Auditors or Public Accountants of Bolivia (CAUB) published a resolution in April 2024, announcing the mandatory adoption of the ISSB standards for all entities ‘carrying out economic activities’ in Bolivia, starting from the 1st of January 2027.

While the mandatory adoption of these standards start in 2027, CAUB has encouraged early applications.

Chile

Adopted

In October 2024, The Financial Market Commission (CMF) of Chile announced the mandatory adoption of IFRS S1 and IFRS S2 standards commencing from 1st January 2026.

Exception:  entities whose average total consolidated assets for the two years has been lesser than UF 1million are exempt from reporting on IFRS S1 and S2 standards.

A ‘transition relief’ period of one year has been directed by CMF specifically for those entities who previously may not have reported on sustainability and corporate governance before.

Middle East

Turkey

Adopted

In December 2023, Turkey’s Public Oversight, Accounting and Auditing Standards Authority (KGK) announced that businesses meeting certain asset, revenue or employee thresholds, and regulated banks will be subject to mandatory sustainability disclosure requirements. The KGK has adopted IFRS S1 and S2 in Turkish, published as the Turkish Sustainability Reporting Standards (TSRS) 1 on general sustainability disclosures and TSRS 2 on climate-related disclosures.

 Sustainability disclosures will be subject to assurance under the International Auditing and Assurance Standards Board (IAASB)’s upcoming International Standard on Sustainability Assurance (ISSA) 5000: General Requirements for Sustainability Assurance Engagements.

Most recently, the Turkish Official Gazette made assurance mandatory on corporate sustainability matters from 2024. The Gazette directed that initially limited assurance will be completed in compliance with GDS 3000 and GDS 3410 till the SDG 5000 is issued.

Qatar

In Consultation

In December 2024, the Qatar Financial Centre Regulatory Authority opened consultation to introduce corporate sustainability reporting rules in alignment with the IFRS S1 and IFRS S2 standards, making these regulations mandatory for certain companies, including banks, insurers and other large entities. With the consultation ending in March 2025, QFCRA aims to implement the reporting requirement from 1st January 2026 for entities meeting the scope requirements.

Global collaboration

The ISSB is actively engaging with national and regional standard setters to facilitate the implementation of a global baseline of sustainability disclosures. With jurisdictions around the world starting to consult on and finalise the adoption of IFRS S1 and S2 into national regulatory frameworks to varying extents, the IFRS Foundation is developing an Adoption Guide to support these efforts. A high-level roadmap to the Adoption Guide has been published, which documents the mechanisms available to support implementation.

The ISSB is focusing on four key areas to enable globally aligned adoption, i.e.: proportionality, transition reliefs, consistency in phasing in and scaling requirements, and capacity building to support implementation.

Key challenges that the ISSB and IFRS Foundation are likely to see in the global uptake of the ISSB standards include:

  • Jurisdictional alignment: While the development of globally applicable standards consolidating several former best practice frameworks is a welcome step to standardising sustainability disclosures around the world, the inherent variations in jurisdictional contexts and market preparedness mean that modifications of the standards to some extent will be inevitable. The ISSB is emphasising the importance of maintaining a high level of alignment to ensure global comparability, which has been the key driver behind the development of the standards.
  • Capacity building: Fully aligning with the requirements of IFRS S1 and S2 will present a significant reporting burden for companies which have not previously considered and assessed climate or sustainability-related matters. Mandatory reporting regimes are largely being designed through phased approaches in recognition of varying levels of maturity. National regulators and standard-setters will need to supplement this with sufficient capacity building, guidance and implementation support to ensure that the implementation of mandatory reporting achieves the aim of enhancing the understanding of climate and sustainability-related financial impacts and the management of these issues.

The development of the ISSB standards and subsequent global uptake represent significant steps towards a more transparent and accountable global business environment. As jurisdictions around the world continue to engage with the ISSB standards, we can expect a new era of sustainability reporting to emerge. Companies around the world reporting on their climate-related disclosures should think beyond mere compliance, to focus on the wealth of opportunities, innovations, and efficiencies that arise from understanding and managing their climate and sustainability challenges. Proactively managing these risks will not only drive sustainable performance but also position businesses for resilience and prosperity in the years ahead.

How Anthesis can support

Anthesis helps organisations cut through the complexity of reporting frameworks and focuses on what matters to key stakeholders, with an end-to-end offering that sets the stage for ISSB-aligned disclosure, risk management and value creation.

While many organisations have carried out single materiality assessments to help shape their ESG strategies, most have not focused in on financial materiality of sustainability-related risks and opportunities. As a crucial step towards ISSB-aligned reporting, our materiality process helps organisations focus in on and prioritise sustainability-related risks and opportunities that could affect the organisation’s prospects. Our ISSB alignment offering extends beyond climate, using our experience across all areas of sustainability, industry, geography, and along the value chain.

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