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Module 03 of 1050 min readMixed

ISSB, IFRS S1/S2, TCFD and the new disclosure stack

The disclosure standards now codified globally. What ISSB asks for, what the SEC and EU CSRD layer on top, and where the gaps still live.

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Learning objectives

By the end of this module, you should be able to:

  • 01Describe what ISSB, IFRS S1, and IFRS S2 require
  • 02Identify the relationship between ISSB and other frameworks (TCFD, GRI, EU CSRD, SEC)
  • 03Recognise what's in a credible climate-related disclosure

The International Sustainability Standards Board (ISSB) was established by the IFRS Foundation in 2021 and published its first two standards — IFRS S1 (general sustainability disclosures) and IFRS S2 (climate-related disclosures) — in June 2023. As of 2026, ISSB is the closest thing to a global baseline for sustainability reporting that the world has ever had. It matters because investors finally have a comparable disclosure across jurisdictions.

The four pillars (from TCFD, preserved in ISSB)

  • Governance: how the board and management oversee climate-related risks and opportunities.
  • Strategy: how climate risks affect the business, strategy, and financial planning over short, medium, and long term.
  • Risk management: the processes for identifying, assessing, and managing climate-related risks.
  • Metrics and targets: emissions disclosures, climate-related targets, and performance against them.

Why TCFD became ISSB

The Task Force on Climate-Related Financial Disclosures (TCFD), set up by the FSB in 2015, did the hard intellectual work of designing the four-pillar disclosure framework. In 2023, TCFD was formally retired and its work absorbed into ISSB. If a company says it 'reports against TCFD', it now reports against IFRS S2 — same framework, new name.

The current jurisdictional stack

ISSB is the global baseline; most major jurisdictions are layering rules on top.

  • EU CSRD (Corporate Sustainability Reporting Directive): mandatory for ~50,000 EU and EU-active companies. Double materiality. Audited. Broader than just climate — includes social, biodiversity, governance.
  • UK SDR + TCFD-aligned: TCFD-aligned reporting mandatory for large UK companies since 2022; transitioning to ISSB-aligned via UK Sustainability Disclosure Standards (UK SDS).
  • US SEC climate rule: finalised 2024, requires Scope 1 and Scope 2 disclosure for large issuers, climate-risk strategy and governance. Scope 3 dropped from final rule. Currently subject to legal challenge.
  • Kenya, Nigeria, South Africa, Brazil, Japan, Singapore: ISSB-aligned national standards in adoption phase as of 2026.

What a credible disclosure looks like

A box-ticked disclosure restates the four pillars and reports a Scope 1 number. A credible disclosure does more:

  • Scope 3 is reported with methodology and data quality disclosed (most material for most companies, hardest to get right).
  • Scenario analysis includes at least one 1.5°C-aligned scenario and one delayed-transition scenario.
  • Financial impacts of climate risk are quantified — even if the quantification has wide uncertainty bands.
  • Transition plan includes specific, time-bound capex and operational commitments, not aspirational language.
  • Governance section names the board committee responsible and the frequency of climate discussions.

Audit is coming

ISSB and CSRD both require limited assurance on sustainability disclosures by 2026-2028, moving to reasonable assurance (the level required for financial statements) by 2030-2032. This is the change that makes box-ticked disclosures untenable — auditors will refuse to sign off on numbers that have no methodological basis.

Exercise

Pull the most recent IFRS S2 (or TCFD-aligned) disclosure from a listed company. Check it against the credibility checklist above. Which items are present and credible? Which are absent or boilerplate? What would a sophisticated investor flag as the weakest section?

Key takeaways

  • ISSB IFRS S1/S2 is the global baseline as of 2024 — adopted by Kenya, UK, Japan, Singapore, Brazil, and others.
  • TCFD has been formally subsumed into ISSB; the four pillars survive.
  • EU CSRD and US SEC add layers on top, with double materiality and audit requirements.
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