The map · ISSB, the EU regime and GRI
Global sustainability standards: how the systems relate, and where alignment stops
There are not a dozen global sustainability standards: there are two systems that create duties — the ISSB baseline and the EU’s CSRD — and GRI beside them.
The question worth asking of any two is not “are they aligned?” but “does the alignment change a single line of what I file?”
Three dates converge on 1 January 2027: the revised ESRS apply, the IFRS S2 greenhouse gas amendments take effect, and the FCA’s UK SRS rules start for listed companies.
The map
Two systems, and a third mistaken for one
The ISSB publishes a global baseline for investors; the European Union runs a broader statutory regime; GRI reports impacts to everybody else.
Everything else you are likely to be shown — TCFD, SASB, the CDSB, the Integrated Reporting Framework — is inside one of those, and has been since 2022 or 2023.
That consolidation is the single biggest thing to have happened in this territory, and most comparison tables have not caught up with it.
This page is about how the three relate and, more usefully, where they stop relating.
Each system has its own page: the ISSB on the ISSB framework, the EU regime on the ESRS, and the UK’s version on UK SRS S1 and S2.
The overview of every framework a UK company meets, including SECR and ESOS, is on UK sustainability reporting.
| System | Written for | Creates a duty? |
|---|---|---|
| ISSB standards (IFRS S1, S2) | Investors | Only where a jurisdiction adopts and requires them |
| EU: CSRD and the ESRS | Investors and everyone affected by impacts | Yes, for undertakings in scope |
| GRI Standards | Everyone affected by the organisation’s impacts | No — voluntary |
The baseline
The ISSB side: a baseline, adopted country by country
The International Sustainability Standards Board issued IFRS S1 and IFRS S2 in June 2023; S1 carries the general requirements for every topic, and S2 carries climate in detail.
Both are written for investors and organised around the four pillars inherited from the TCFD.
The ISSB is a standard-setter, not a regulator, so its standards create no duty anywhere until a jurisdiction writes them into law or rules.
Underneath sits the industry layer: the SASB Standards, 77 industries across 11 sectors, which the ISSB has owned since August 2022.
More than 45 jurisdictions have decided to use or are taking steps to introduce the standards (Trustees’ plan, 18 August 2026); requirements had come into effect in 19 as at 24 February 2026.
Those two numbers answer different questions, and neither substitutes for the other; the standards themselves are read on IFRS S1 and IFRS S2.
The regime
The European side: law, recently narrowed
The EU does not adopt the ISSB standards; it runs its own regime, the Corporate Sustainability Reporting Directive, reported against the European Sustainability Reporting Standards.
It was cut back hard in 2026: Directive (EU) 2026/470, Omnibus I, was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026.
The scope test is now cumulative: an undertaking is caught where it exceeds €450 million net turnover and an average of 1,000 employees — both, not either.
For a UK group the usual question is the third-country limb in Article 40a: more than €450 million of EU net turnover for each of the last two consecutive financial years, plus an EU subsidiary or branch above €200 million.
The two-year persistence test is a real filter, and the older €150 million and €40 million figures are still in older Commission material and most commentary.
The checker beside this text applies the Article 40a limbs to your figures; the UK-group view is on CSRD vs UK SRS.
Article 40a · scope check · € millions
No answer without the EU-generated turnover figures
Limb 1 is the whole of the first question: net turnover generated in the Union, at group level, for each of the last two financial years.
Most consolidated accounts do not present that number, because "EMEA" or "Europe" is not the Union.
Producing it is the first piece of work.
Rule: Directive 2013/34/EU Art 40a(1), as amended by Directive (EU) 2026/470 Art 2(13).
“Exceeding” is strict: €450.0m is not over the line.
A provisional reading of published thresholds, not a determination for your group.
The fork
The one difference every other difference follows from
Materiality decides what goes in the report, and the two systems answer it differently.
The ISSB applies financial materiality; the ESRS apply double materiality.
Read those twice and the practical consequence falls out: every ISSB disclosure has an EU analogue, because financial materiality is one of the EU’s two lenses.
The reverse is not true: the EU asks for impact reporting that the ISSB standards never require.
The commonest error in the whole territory lives here, and it is worth stating flatly: GRI does not use double materiality either.
The two lenses are compared on double materiality.
ISSB: could the information reasonably be expected to affect the entity’s cash flows, access to finance or cost of capital?
ESRS: is the matter material on impact, on financial grounds, or both?
The third system
GRI reports impacts, and not double materiality
GRI is the oldest of the three and the most widely used voluntarily; it exists to report an organisation’s most significant impacts on the economy, environment and people, to a general audience.
It applies impact materiality only, and attributes the other term to Brussels: “The European Union dubbed this concept ‘Double Materiality’”, with its standards representing “the impact side” of it (GRI).
A comparison table that puts “double materiality” in the GRI column is describing something that does not exist.
Using the standards is not the same as reporting in accordance with them: “in accordance” takes nine requirements, “with reference to” takes three.
GRI is also mid-renumbering: since 2024 the labels GRI 101, 102 and 103 mean Biodiversity, Climate Change and Energy, not the 2016 Universal Standards.
The detail is on GRI Standards and the frameworks compared on ESG standards.
Interoperability
What is actually aligned between the ISSB and the ESRS
One document settles this, and almost nobody quotes it: the ESRS–ISSB Standards Interoperability Guidance, published jointly on 2 May 2024.
The definition is aligned; the regime is not.
§1.1 points both definitions at the same thing — information material to primary users making decisions about providing resources to the entity — citing ESRS 1 ¶48 and IFRS S1 ¶18.
The same section says ESRS disclosures are subject to materiality as defined under the ESRS, which also covers the impact lens: a matter is material on impact, on financial grounds, or both.
So the sentence that survives contact with the source has two clauses, and must never be split.
The alignment was not created by the guidance: it is attributed to the ISSB and the European Commission services, together with EFRAG, working during the development of both sets of standards.
The UK comparison is on UK SRS vs ESRS.
The guidance, in its own words
“the definition of financial materiality in ESRS is aligned with the definition of materiality in IFRS S1”
“The disclosures to be provided under ESRS … are subject to materiality as defined under ESRS, which covers also the impact materiality lens.”
Source: Interoperability Guidance, Introduction and §1.1 (also on the IFRS Foundation’s site).
The fences
What that guidance does not do, in its own words
| Fence | The guidance says | What it means for you |
|---|---|---|
| Educational | It is “provided as educational material” and “does not override or adjust the requirements as set out in ESRS or ISSB Standards”. | It cannot satisfy an obligation; it explains why two sets of answers overlap. |
| Not equivalence | It “is not a formal statement of equivalence. The latter is in the remit of public authorities.” | No regulator can be pointed at it as a substitute report. |
| Dated | “This document was published on 2 May 2024. Future amendments to ESRS or ISSB Standards may change the analysis within.” | Both have since been amended; the tables are stale for financial years from 1 January 2027. |
One thing the guidance is routinely credited with saying, and does not: “both are built on the TCFD architecture”.
The string “TCFD” appears nowhere in its text; the claim is better sourced to the IFRS Foundation’s account of IFRS S2, which says so about itself.
The mapping tables cite ESRS (2023) paragraph numbers — ESRS 1 ¶¶28, 48 and 131(b) — and the July 2026 revision replaces the standards rather than amending them.
No reissued version had been located on EFRAG’s own page or either owner’s copy as at 10 September 2026, which is a finding about what could be found, not a statement that none exists.
The honest planning assumption: the only published ISSB–ESRS mapping expires with the standards it maps.
GRI and the ISSB
One operative mechanism, and it covers greenhouse gases
The GRI–ISSB relationship is described as interoperability far more often than it is described accurately.
Exactly one of four documents changes what a preparer files.
Organisations reporting under both may use the IFRS S2 Scope 1, 2 and 3 disclosures to meet the corresponding GRI 102 requirements — if measured on the GHG Protocol Corporate Standard (2004) and cross-referenced in the GRI content index.
It does not bite until GRI 102 takes effect on 1 January 2027, or on early adoption.
No disclosure-level correspondence table between the two has been published by either owner, and the boards “make decisions separately in accordance with their established standard-setting due processes”.
The emissions inventory every system reads is covered on Scope 1, 2 and 3 emissions and carbon accounting for UK SRS.
| Document | Date | Changes what you file? |
|---|---|---|
| Memorandum of understanding | 2022 | No |
| Joint statement on interoperability | May 2024 | No |
| GRI 102 / IFRS S2 GHG equivalence | 26 June 2025 | Yes — from 1 January 2027 |
| Joint framing statement | 26 May 2026 | No |
Report once?
What “report once, use many” can and cannot mean
Every standard-setter uses the word interoperability, and almost none defines it; three different things travel under it.
Strong: one set of figures satisfies two requirements — the GRI greenhouse gas equivalence is the only mechanism of that strength between these systems.
Middle: a mapping table, useful until the standard it maps is replaced, and then a liability.
Weak: a statement of intent — memoranda, joint framings, commitments to align — real, and changing nothing you file.
Applied honestly, a company inside both the EU regime and an ISSB jurisdiction can build one data set and one governance process, and will still file two reports with different boundaries.
The climate numbers travel; the impact reporting does not, because the ISSB standards never asked for it.
The claim-by-claim test is on the ISSB framework page; reporting mechanics are on UK SRS reporting.
The tail
What was absorbed, and what is still a live framework
| Framework or body | Status today | Source |
|---|---|---|
| TCFD | Disbanded 12 October 2023; a monitoring duty passed on from 2024. Its recommendations are frozen, not withdrawn. | FSB |
| CDSB | Consolidated into the IFRS Foundation, 31 January 2022; produces no further work. | IFRS Foundation |
| SASB Standards | Live; the ISSB has been responsible since August 2022 and is enhancing them. | IFRS Foundation |
| Integrated Reporting Framework | Live and untouched; the IRCC was wound up on 31 July 2026 and its mandate moved to the IFRS Advisory Council. | AC8, April 2026 |
Two opposite errors circulate about the last row: the Integrated Reporting Framework was not withdrawn, and the IRCC was not abolished.
In the UK the FCA’s final rules replace the existing TCFD-aligned listing rules; the mapping is on TCFD and UK SRS, and the frameworks a UK reader meets are compared on ESG frameworks in the UK.
The divergence
Adopting a standard is not mandating it
| Jurisdiction | What happened | Status |
|---|---|---|
| Brazil (CVM) | Obligation for public companies removed on 29 May 2026; comply-or-explain notice duty from 1 January 2027. Opt-in companies apply the standards in full. | Final |
| South Korea (FSC) | Threshold cut from ₩30 trillion to ₩10 trillion for 2028 reporting; ₩5 trillion from 2029. | Policy decision; legislation not confirmed |
| United States (SEC) | 2024 climate rules proposed for rescission on 29 May 2026; stayed and never effective; no merits ruling. | Proposed |
| Canada (CSA) | Work on a mandatory climate rule paused on 23 April 2025. | Final |
| European Union | Scope narrowed to €450m and 1,000 employees by Directive (EU) 2026/470. | Final, in force 18 March 2026 |
| United Kingdom (FCA) | Final rules: UK SRS on comply or explain for listed companies in five categories, periods from 1 January 2027. | Final, in force 1 January 2027 |
Three facts travel under one sentence, and through 2026 they stopped moving together: whether a jurisdiction adopted a standard, whether anyone must use it, and which regulator does the requiring.
The standards question has been settled in the ISSB’s favour; the mandate question is diverging by jurisdiction, and by regulator within a jurisdiction.
Any sentence beginning “country X has adopted the ISSB standards” answers the first fact and leaves the other two open.
The revision
The European standards were rewritten in 2026
On 3 July 2026 the Commission adopted revised European standards and a voluntary standard for undertakings protected by the value-chain cap.
Mandatory datapoints fall by 61%, from roughly 1,144 to about 500, and total datapoints by over 70% (explanatory memorandum).
Both delegated acts were published in the Official Journal on 21 September 2026, with different entry-into-force dates and one shared application year.
Undertakings reporting for financial year 2026 have three options: the 2023 ESRS, the 2023 ESRS with eight reliefs, or the revised ESRS in full.
One change inside is sharper than the datapoint count: under the revised ESRS 1 an undertaking “shall not disclose” information prescribed by a datapoint if it is not material (Annex to the act).
The Commission made that change against EFRAG’s advice, replacing “is not required to”, so a report padded with immaterial datapoints is now non-compliant rather than over-compliant.
The empowerment to adopt sector-specific ESRS was deleted, and so was the listed-SME standard; anyone planning against sector ESRS is planning against a power that no longer exists.
| Instrument | In force | Applies |
|---|---|---|
| DR (EU) 2026/1563 — revised ESRS | 10 November 2026 | Financial years beginning on or after 1 January 2027 |
| DR (EU) 2026/1560 — voluntary standard under the value-chain cap | 24 September 2026 | From financial years beginning on or after 1 January 2027 |
Assurance
European assurance is limited, and the escalation was deleted
CSRD assurance is limited assurance, full stop.
Directive (EU) 2026/470 gives the reason in recital (5): to avoid an increase in assurance costs, “the requirement to adopt reasonable assurance standards should be removed”.
The Commission must now adopt limited-assurance standards no later than 1 July 2027, up from 1 October 2026; any page citing the 2026 date is stale.
The opinion covers the sustainability reporting, the process used to identify the information reported, and compliance with the EU Taxonomy’s Article 8 disclosures.
Who may give it is a 27-way answer: the statutory auditor by default; a different auditor, and an independent assurance services provider, only where a Member State allows.
The UK position — where assurance is not required and listed companies say whether they obtained it — is on sustainability assurance.
The UK
Where the UK sits between the two systems
The UK took the ISSB baseline and endorsed it: UK SRS S1 and S2 were published on 25 February 2026 as the UK versions of IFRS S1 and S2, with the differences in Annex A of the government response.
That list has no total: the government consulted on proposed amendments in June 2025, some did not survive and others were added, so any number of “UK amendments” is not the government’s.
The standards were issued for voluntary use, as the government’s guidance says.
The FCA’s final rules, published on 30 September 2026, now require listed companies in five categories to report against them on a comply-or-explain basis for periods beginning on or after 1 January 2027; the consultation, CP26/5, had proposed a mandatory S2.
The IFRS Foundation’s UK snapshot pre-dates the rules and records the approach as not yet final.
New ISSB standards do not reach the UK automatically; the FRC says each must go through endorsement first.
So the UK is on the ISSB side of the map and outside the EU regime — though a UK group can still be caught by CSRD through Article 40a.
The UK standards are read on UK SRS S1, and every UK difference on UK SRS amendments.
Standards: UK SRS S1 and S2, 25 February 2026, the endorsed ISSB baseline.
Listed companies: comply or explain from periods beginning 1 January 2027 (PS26/19).
EU: reachable only through CSRD scope, on EU turnover.
Side by side
The ISSB standards and CSRD, row by row
| ISSB standards (and UK SRS) | CSRD and the ESRS | |
|---|---|---|
| What it is | Two standards from a private standard-setter | A directive, reported against delegated regulations |
| Creates a duty? | Only where a jurisdiction adopts it | Yes, for undertakings in scope |
| Written for | Investors and other primary users | Investors and a wider set of stakeholders |
| Materiality | Financial | Double |
| Climate standard | IFRS S2 / UK SRS S2 | ESRS E1 |
| Topics beyond climate | Through IFRS S1’s general requirements, with the SASB Standards as reference | Topical ESRS for environment, social and governance |
| Assurance | Not required by the standards; in the UK, listed companies say whether they obtained it | Limited assurance required |
| UK companies | UK SRS for listed companies, comply or explain from 2027 | Only through EU subsidiaries in scope or Article 40a |
“ISSB vs CSRD” compares a standard with a law, which is why the comparison so often goes wrong.
The like-for-like pairs are IFRS S2 against ESRS E1 for content, and an adopting jurisdiction’s rule against CSRD for the duty.
For a UK group the practical question is whether anything in the EU column applies at all — the checker above answers the Article 40a half of that.
The UK-specific version, with every difference cited, is on CSRD vs UK SRS.
In practice
Which system answers which question
The choice is rarely yours in full: jurisdiction decides most of it, and the rest is decided by who is asking.
If an investor asks what could affect the company’s prospects, the answer is built on the ISSB standards, whatever the local endorsement is called.
If an EU Member State asks, the answer is the ESRS, and it includes impact reporting the ISSB standards never require.
If a community, an employee or an NGO asks about the company’s effect on the world, that is GRI.
For a company inside more than one: build the greenhouse gas inventory once, on the GHG Protocol; document the materiality judgement once, recording both lenses separately; then produce the reports each regime requires.
What does not work is planning to file one document.
Who is asking?
Tick everyone who asks your company for sustainability information.
Nothing ticked yet.
Status from FCA PS26/19 ¶¶3.6, 3.12, 3.14; Directive 2013/34/EU Arts 19a, 29a, 40a as amended by Directive (EU) 2026/470; Delegated Regulations (EU) 2026/1563 and 2026/1560; GRI 1; IFRS S2 ¶29(a)(ii).
Nothing is stored or sent.
In flight
What is still moving, and what it will change
| Item | State on 1 October 2026 |
|---|---|
| Revised ESRS (DR (EU) 2026/1563) | Published 21 September 2026; in force 10 November 2026; apply for financial years beginning on or after 1 January 2027. |
| IFRS S2 greenhouse gas amendments | Published December 2025; effective for periods beginning on or after 1 January 2027. |
| ISSB taxonomy update | Comment period closed 28 September 2026; introduces no new requirement. |
| SASB enhancement | Exposure drafts; effective 12–18 months after issuance if finalised. |
| ESRS-40a — standards for third-country groups | EFRAG exposure draft out for consultation since 23 July 2026; EFRAG’s technical advice due by January 2027; Commission adoption after that, on no stated date. |
| GRI 102 and GRI 103 | Published June 2025; effective 1 January 2027. |
Published, in force and applicable are three different states, and this landscape has something in each.
For a UK parent, ESRS-40a is the one to watch: it is the standard Article 40a reporting would use, and it is still a draft — see ESRS 40a.
Nature is the ISSB’s next topic; where that stands is on TNFD.
What the ISSB publishes
Issued, supporting, in research: the ISSB’s outputs sorted by force
| Output | Kind | Force | State on 1 October 2026 |
|---|---|---|---|
| IFRS S1 | Issued standard | Requirements, once a jurisdiction adopts it | Effective 1 January 2024 for IFRS reporters |
| IFRS S2 | Issued standard | Requirements, once adopted | Effective 1 January 2024; December 2025 amendments effective 1 January 2027 |
| Industry-based Guidance on implementing IFRS S2 | Accompanying guidance | Must be considered under IFRS S2; optional under UK SRS S2 | Derived from the SASB Standards |
| SASB Standards | Maintained standards | Referenced by IFRS S1 ¶¶55, 58 | Enhancement exposure drafts in progress |
| Transition plan disclosure guidance | Educational material | None of its own | Published June 2025, drawing on TPT material |
| Jurisdictional readiness guide | Adoption support | None — for regulators | Published 24 February 2026 |
| ISSB digital taxonomy update | Tagging | Introduces no new requirement | Comment period closed 28 September 2026 |
| Nature-related disclosures | Proposed Practice Statement | Would be non-mandatory guidance | Exposure draft targeted for October 2026 |
| Human capital | Research project | None | Next step is to decide the project’s direction |
Searches for “ISSB standards” return a mixture of standards, guidance, educational material, staff papers and research, and only two items on that list are standards.
The ISSB has issued two standards, IFRS S1 and IFRS S2, and one set of amendments to IFRS S2.
Everything else it publishes either helps apply those two — guidance, educational material, the digital taxonomy — or is work towards something it has not yet issued.
The distinction matters because only an issued standard, once adopted by a jurisdiction, creates a requirement.
Guidance carries the weight the standard gives it: IFRS S2 tells an entity to refer to and consider the Industry-based Guidance, while UK SRS S2 makes that optional.
Educational material carries none: the transition plan guidance helps an entity apply IFRS S2’s existing requirements and adds no new ones.
The nature work is the one most often misdescribed: it is heading for a Practice Statement, which is non-mandatory, not a third standard.
The standards themselves are free to read in the IFRS Sustainability Standards Navigator; the UK versions are on GOV.UK.
Agenda papers and the monthly ISSB Update record the Board’s decisions as they are made, and are the place to check whether a project has moved.
The record
Key facts, each with its date
| Fact | As stated by its owner | As at |
|---|---|---|
| ISSB materiality | Financial: information that could reasonably be expected to affect the entity’s prospects | IFRS S1, June 2023 |
| ESRS materiality | Double: impact, financial, or both | ESRS 1 |
| GRI materiality | Impact only; GRI attributes “double materiality” to the EU | GRI guide |
| ESRS–ISSB alignment | The definition of financial materiality is aligned; the regime is not | 2 May 2024 guidance |
| Mapping tables | Built on ESRS (2023) paragraph numbers; stale for financial years from 1 January 2027 unless reissued | No reissue located, 10 September 2026 |
| GRI–ISSB mechanism | IFRS S2 Scope 1, 2 and 3 figures can meet GRI 102 — conditional, and not before 1 January 2027 | 26 June 2025 statement |
| CSRD scope | Net turnover above €450m and 1,000 employees | Directive (EU) 2026/470, in force 18 March 2026 |
| Article 40a | More than €450m EU net turnover in each of the last two years, plus an EU subsidiary or branch above €200m | Accounting Directive, consolidated |
| Revised ESRS | DR (EU) 2026/1563; in force 10 November 2026; apply for financial years from 1 January 2027 | OJ 21 September 2026 |
| EU assurance | Limited only; reasonable-assurance empowerment deleted; standards due by 1 July 2027 | Directive (EU) 2026/470 |
| ISSB adoption | Requirements in effect in 19 jurisdictions | 24 February 2026 |
| UK standards | UK SRS S1 and S2, published by DBT | 25 February 2026 |
| UK listed companies | Comply or explain against UK SRS, periods beginning on or after 1 January 2027 | PS26/19, 30 September 2026 |
| Consolidations | CDSB 31 January 2022; Value Reporting Foundation August 2022; TCFD disbanded 12 October 2023 | IFRS Foundation; FSB |
Corrections
Seven things said about these systems, true or false
Each of these is in wide circulation, and each is settled by an owner’s document.
The fourth comes from a political agreement that never reached the adopted text.
The seventh became false on 30 September 2026.
The bottom line of the whole map: three standard-setters, one measurement basis, and exactly one published mechanism that lets a figure count twice.
Global standards: true or false?
GRI uses double materiality.
The ISSB standards and the ESRS share an aligned definition of financial materiality.
The interoperability guidance makes the two standards equivalent.
CSRD catches companies with 1,750 employees.
The revised ESRS are mandatory for 2026 reports.
CSRD assurance escalates to reasonable assurance in 2028.
UK SRS S2 became mandatory for UK listed companies under the FCA’s final rules.
0 of 7 answered.
Nothing you choose is stored or sent.
Frequently asked
Global sustainability standards, answered
What are the global sustainability standards?
Two systems create reporting duties: the ISSB’s IFRS S1 and IFRS S2, a global baseline for investors that jurisdictions adopt one by one, and the EU’s regime, CSRD reported against the ESRS, which is law for undertakings in scope.
Beside them sits GRI, the most widely used voluntary standard for reporting impacts.
TCFD, SASB, the CDSB and the Integrated Reporting Framework are now inside the IFRS Foundation.
What is the difference between the ISSB standards and the ESRS?
Materiality, and everything follows from it.
The ISSB standards apply financial materiality: information that could reasonably be expected to affect the entity’s prospects.
The ESRS apply double materiality: a matter is material on impact, on financial grounds, or both.
So every ISSB disclosure has an EU analogue, and the reverse is not true.
The ISSB standards create no duty until a jurisdiction adopts them; the ESRS are law for CSRD-scope undertakings.
Are the ISSB standards and the ESRS interoperable?
Partly.
The joint interoperability guidance of 2 May 2024 says the ESRS definition of financial materiality is aligned with IFRS S1’s definition of materiality.
The regimes are not aligned, because the ESRS keep the impact lens on top.
The guidance says of itself that it is educational material and “is not a formal statement of equivalence”, and it maps the 2023 ESRS, which the revised standards replace for financial years beginning on or after 1 January 2027.
Does CSRD apply to UK companies?
Not because they are UK companies.
A UK group can be caught through Article 40a of the Accounting Directive: more than €450 million of net turnover in the EU for each of the last two consecutive financial years, plus an EU subsidiary or branch above €200 million.
An EU subsidiary of a UK group can also be in scope on its own figures — above €450 million net turnover and 1,000 employees.
What is the difference between CSRD and IFRS S2?
They are different kinds of thing.
CSRD is a directive that creates a reporting duty; IFRS S2 is a standard that says what climate disclosure contains.
The EU counterpart of IFRS S2 is ESRS E1.
On content the two climate standards are close; on scope ESRS E1 sits inside double materiality and asks for impact reporting IFRS S2 does not.
Does GRI use double materiality?
No. GRI applies impact materiality and says so itself: “The European Union dubbed this concept ‘Double Materiality’”, with its own standards representing “the impact side” of it.
Neither GRI nor the ISSB is a double-materiality standard on its own.
Which global sustainability standards are mandatory?
None in themselves; standard-setters do not create duties, jurisdictions do.
The ESRS are mandatory for CSRD-scope undertakings.
ISSB-based requirements were in effect in 19 jurisdictions as at 24 February 2026.
In the UK, listed companies in five categories report against UK SRS on a comply-or-explain basis from periods beginning on or after 1 January 2027; GRI is voluntary.
What happened to TCFD, SASB and the CDSB?
All three are inside the IFRS Foundation, by different routes.
The TCFD disbanded on 12 October 2023 and a monitoring duty passed on from 2024.
The CDSB was consolidated into the IFRS Foundation on 31 January 2022.
The Value Reporting Foundation, which held the SASB Standards and the Integrated Reporting Framework, consolidated in August 2022, and the ISSB is now responsible for the SASB Standards.
Can a company report once and satisfy both the ISSB standards and the ESRS?
Not as one filing; no mechanism published by any of the standard-setters delivers that.
One data set and one governance process can feed two reports.
The greenhouse gas figures travel, because every system reads the GHG Protocol; the impact reporting does not, because the ISSB standards never ask for it.
What changed in the revised ESRS?
The Commission adopted revised ESRS on 3 July 2026, cutting mandatory datapoints by 61% and total datapoints by over 70%.
They were published in the Official Journal on 21 September 2026 as Delegated Regulation (EU) 2026/1563, enter into force on 10 November 2026 and apply to financial years beginning on or after 1 January 2027.
Immaterial disclosure is now prohibited: an undertaking “shall not disclose” information that is not material.
Where does UK SRS sit among the global standards?
On the ISSB side.
UK SRS S1 and S2 are the UK’s endorsed versions of IFRS S1 and S2, published on 25 February 2026, with the differences in Annex A of the government response, which carries no count.
Since the FCA’s final rules of 30 September 2026, listed companies in five categories report against them on a comply-or-explain basis from 2027.
Is CSRD assurance going to become reasonable assurance?
Not under current law.
Directive (EU) 2026/470 deleted the empowerment to adopt reasonable-assurance standards, to hold assurance costs down.
CSRD assurance is limited assurance, and the Commission must adopt limited-assurance standards by 1 July 2027.
What standards has the ISSB issued?
Two: IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures, issued in June 2023 and effective for annual periods beginning on or after 1 January 2024, plus the December 2025 amendments to IFRS S2, effective from 1 January 2027.
The ISSB is also responsible for the SASB Standards.
Its guidance, educational material and research are not standards.
What are the latest changes to the ISSB standards?
The December 2025 Amendments to Greenhouse Gas Emissions Disclosures in IFRS S2, effective for periods beginning on or after 1 January 2027 with earlier application permitted.
The taxonomy update that tracks them closed for comment on 28 September 2026.
The nature work is heading for an exposure draft of a non-mandatory Practice Statement, targeted for October 2026.
How do the IFRS sustainability standards apply in the United Kingdom?
Through UK SRS.
The government endorsed IFRS S1 and S2 with amendments and published them as UK SRS S1 and S2 on 25 February 2026.
Under the FCA’s final rules, listed companies in UKLR 6, 14, 15, 16 and 22 report against them on a comply-or-explain basis for periods beginning on or after 1 January 2027.
New ISSB standards need UK endorsement first.
Is the ISSB a global standard?
It is a global baseline: written by the IFRS Foundation’s board for use anywhere, and adopted country by country.
Requirements based on it were in effect in 19 jurisdictions as at 24 February 2026. It does not apply anywhere on its own authority.
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.
- IFRS FoundationInternational Sustainability Standards Board
The global baseline and who it is written for.
- IFRS FoundationIFRS S1 — full text
The investor materiality test the ISSB side is built on.
- IFRS FoundationIFRS S2 — full text
The climate standard and its GHG Protocol measurement basis.
- EFRAG and the IFRS FoundationESRS–ISSB Standards Interoperability Guidance, 2 May 2024
Introduction and §1.1: the aligned definition, the unaligned regime and the three fences.
- EUR-LexDirective (EU) 2026/470 — Omnibus I
OJ 26 February 2026, in force 18 March 2026: €450m and 1,000 employees; assurance limited; sector standards deleted.
- EUR-LexAccounting Directive 2013/34/EU, consolidated 18 March 2026
Articles 19a, 29a, 34 and 40a as they now read.
- EUR-LexDelegated Regulation (EU) 2026/1563 — revised ESRS
OJ 21 September 2026; in force 10 November 2026; applies to financial years beginning on or after 1 January 2027.
- EUR-LexDelegated Regulation (EU) 2026/1560 — voluntary standard for undertakings under the value-chain cap
In force 24 September 2026; applies from financial years beginning on or after 1 January 2027.
- European CommissionCommission adopts revised sustainability reporting standards — 3 July 2026
The adoption, and the scale of the datapoint cut.
- GRIDouble materiality: the guiding principle for sustainability reporting
GRI attributes the term to the EU and claims the impact side.
- GRIGRI 102 and IFRS S2 — statement on equivalence, 26 June 2025
The one figure-level mechanism, and its conditions.
- GRI and the IFRS FoundationJoint statement, 26 May 2026
Two purposes side by side; decisions made separately.
- IFRS FoundationUse of IFRS Sustainability Disclosure Standards by jurisdiction
Profiles and snapshots.
- IFRS FoundationJurisdictional readiness guide and tool, 24 February 2026
Requirements in effect in 19 jurisdictions.
- Financial Stability BoardAnnual progress report, 12 October 2023
The TCFD disbanded.
- IFRS FoundationConsolidated organisations
The VRF and CDSB consolidations.
- Financial Conduct AuthorityPS26/19 — final rules
UK SRS on comply or explain for listed companies, periods from 1 January 2027.
- Department for Business and TradeUK SRS S1 and UK SRS S2
Published 25 February 2026, for voluntary use.
- Financial Reporting CouncilSustainability Reporting Developments — FAQs
New ISSB standards do not apply in the UK automatically.
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Read next
The ISSB framework
IFRS S1 and S2, who governs the ISSB, adoption, and the UK route to the FCA rules.
CSRD vs UK SRS
The two regimes set against each other, for UK groups.
The ESRS
What the European standards ask, and who they catch.
IFRS S2
The climate standard both systems’ greenhouse gas figures meet in.
GRI Standards
The nine requirements, the eight principles, and what a GRI claim means.
TNFD
Nature reporting, and where the ISSB’s Practice Statement stands.