IFRS S2 · checklist and gap analysis
IFRS S2 disclosure checklist: every paragraph, and your gaps
This checklist follows IFRS S2 paragraph by paragraph, so each line can be checked against the standard itself.
Tick what your current report already covers, and the list that remains is your gap analysis.
Gap check
What your report already covers
The gap check lists the disclosures IFRS S2 requires, grouped by pillar, each with its paragraph.
Tick the lines your current report already meets, and the tool lists what is left.
The financed-emissions line appears only if you select asset management, banking or insurance.
It checks coverage, not quality: a line is met only if the disclosure answers the paragraph, not merely mentions the topic.
IFRS S2 · what your report already covers
- The body or individual overseeing climate, how it is informed, its skills, and how it oversees targets and remuneration (¶6(a))
- Management’s role, any delegation, and the controls and procedures used (¶6(b))
- Each climate risk and opportunity, physical or transition, with its time horizon and how horizons are defined (¶10)
- Effects on business model and value chain, and where they concentrate (¶13)
- Responses and plans, any transition plan with assumptions and dependencies, how targets will be met, progress on earlier plans (¶14)
- Current and anticipated financial effects, quantitative or explained, with affected line items (¶¶15–21)
- Climate resilience assessed using scenario analysis, with inputs, assumptions and timing (¶22)
- Processes to identify, assess, prioritise and monitor climate risks and opportunities, and their integration (¶25)
- Gross Scope 1, 2 and 3 in tonnes CO2e, GHG Protocol measurement, approach, group/investee split, location-based Scope 2, Scope 3 categories (¶29(a))
- Amount and percentage of assets or activities vulnerable to transition and physical risks, and aligned with opportunities (¶29(b)–(d))
- Capital deployment, internal carbon price, and climate-linked executive remuneration (¶29(e)–(g))
- Industry-based metrics, having considered the industry-based guidance (¶32)
- Each climate target with its metric, scope, period, base year, milestones, validation, performance, and for GHG targets gross/net and carbon credits (¶¶33–36)
- Statement of compliance, made only if every requirement is met, with any reliefs used disclosed (IFRS S1 ¶72; S1 ¶E5; S2 ¶C4)
IFRS S2 ¶¶6–36 (December 2025 text); IFRS S1 ¶72.
A checklist of the paragraphs, not an assurance opinion.
Nothing you tick is stored or sent.
The checklist
IFRS S2, pillar by pillar
| Pillar | Disclosure | Paragraph |
|---|---|---|
| Governance | Oversight body or individual: terms of reference, skills, information flow, role in strategy and transactions, targets and remuneration | ¶6(a) |
| Governance | Management’s role, delegation, controls and procedures | ¶6(b) |
| Strategy | Climate risks and opportunities, physical or transition, time horizons and their definitions | ¶10 |
| Strategy | Effects on business model and value chain; concentrations | ¶13 |
| Strategy | Responses, plans, transition plan, how targets will be achieved, progress on earlier plans | ¶14 |
| Strategy | Current and anticipated financial effects; reasons and line items where not quantified | ¶¶15–21 |
| Strategy | Climate resilience using scenario analysis: results, inputs, assumptions, timing | ¶22 |
| Risk management | Processes and policies to identify, assess, prioritise and monitor; integration with overall risk management | ¶25 |
| Metrics and targets | Greenhouse gases: Scope 1, 2, 3; measurement; group/investee split; location-based Scope 2; Scope 3 categories; financed emissions | ¶29(a), ¶¶29A–29C |
| Metrics and targets | Transition risk, physical risk, opportunities, capital deployment, internal carbon prices, remuneration | ¶29(b)–(g) |
| Metrics and targets | Industry-based metrics | ¶32 |
| Metrics and targets | Targets: metric, objective, scope, period, base period, milestones, validation, performance, gross/net, carbon credits | ¶¶33–36 |
| General | Location of disclosures and cross-references; same time and period as the financial statements | IFRS S1 ¶¶60–64 |
| General | Statement of compliance only if every requirement is met; reliefs used disclosed | IFRS S1 ¶72; S1 ¶E5; S2 ¶C4 |
Each block has its own explainer: the four pillars, financial effects, scenario analysis, cross-industry metrics and Scope 3.
The method
From gap list to first report
The IFRS Foundation’s own suggestion is to read IFRS S1 and S2, find the gaps against current disclosures, fill them, and check whether governance, risk management, strategy and timing need to change (IFRS Foundation).
For a company starting from TCFD, the IFRS Foundation’s comparison table lists the additions, set out on IFRS S2 vs TCFD.
- 1
Map the standard
Each IFRS S2 paragraph against what the current report says.
- 2
Decide on the reliefs
Climate first, no Scope 3, prior measurement method — each disclosed if used.
- 3
Build the data
Gather what each gap needs from the value chain, finance and risk teams.
- 4
Connect to the accounts
Use assumptions consistent with the financial statements, and say where they differ.
- 5
Draft and review
Check every judgement is disclosed close to the figure it affects.
What regulators found
Where first reports fell short
Australia’s regulator reviewed 40 of the 312 reports lodged under AASB S2, the Australian standard based on IFRS S2, for years ending 31 December 2025 (ASIC REP 839).
It found clearer disclosure on current matters such as governance and risk management, and room to improve on forward-looking disclosures and those resting on judgement.
Its action items include connecting the report to the financial statements, giving quantitative financial effects where possible, disclosing judgements close to the figures, and not obscuring material information with extra material.
The detail is on what the first reports show.
In the UK
The same checklist for UK SRS S2
UK SRS S2 has the same paragraphs, with “may” instead of “shall” for the industry-based guidance and ¶B59A added for financed emissions.
Under the FCA’s comply-or-explain rules, a line a UK listed company cannot yet meet is not left silent: the company summarises the requirements not met, why, and its plans (UKLR 6.6.6R(7A)).
The FCA’s draft guidance on what an explanation should contain, TN 803.1, is out for comment until 28 October 2026.
Frequently asked
The checklist, answered
What should an IFRS S2 disclosure checklist cover?
The four pillars as IFRS S2 sets them out: governance (¶¶5–7), strategy including financial effects and scenario-based resilience (¶¶8–23), risk management (¶¶24–26), and metrics and targets including the seven cross-industry categories, industry-based metrics and targets (¶¶27–37).
Add the IFRS S1 general requirements on location, timing and the statement of compliance, and any reliefs used.
How do I do an IFRS S2 gap analysis?
Start from the standard, not from last year’s report.
Map each paragraph to what the current report already says, mark what is missing, and plan the data and process work behind each gap.
A company starting from TCFD can use the IFRS Foundation’s comparison table to find the additions.
What did regulators find in the first IFRS S2-based reports?
Australia’s regulator ASIC reviewed 40 reports under AASB S2, which is based on IFRS S2.
It found governance and risk management generally clear, and room to improve on forward-looking disclosures, quantitative financial effects, judgements and the connection to the financial statements.
Is this checklist enough for assurance?
No. It lists the paragraphs; an assurance engagement tests the evidence, processes and controls behind each disclosure.
Use it to scope the work, not to conclude on it.
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 FoundationIFRS S2, full text (December 2025)
¶¶5–37 and Appendix C: every line in the checklist.
- IFRS FoundationIFRS S1, full text
¶¶60–73: location, timing, comparatives and the statement of compliance.
- IFRS FoundationMaking the transition from TCFD to ISSB
The IFRS Foundation’s suggested steps.
- IFRS FoundationComparison: IFRS S2 with the TCFD recommendations (PDF)
A gap table for companies starting from TCFD.
- ASICREP 839: review of sustainability reports lodged for 31 December 2025 (21 September 2026, PDF)
Eight action items from the review of 40 AASB S2 reports.
- Department for Business and TradeUK SRS S2 (PDF)
The UK text the same checklist applies to.
- Financial Conduct AuthorityPS26/19 (PDF)
Comply or explain: a line not met is explained, with plans.
- IFRS FoundationIFRS S2 Accompanying Guidance (June 2023)
Illustrative examples and the industry-based guidance.
- Department for Business and TradeConsultation response (PDF), Annex A
The UK differences, including ¶B59A.
- Financial Conduct AuthorityDraft Technical Note TN 803.1 (September 2026, for consultation)
What the FCA proposes an explanation should contain.
Continue reading
Read next
What the first reports show
Findings from the first reports prepared under IFRS S2-based standards.
IFRS S2
The climate standard, paragraph by paragraph.
The four pillars
The core content the checklist follows.
UK SRS readiness assessment
A readiness check against the UK standards.
Effective date and reliefs
The reliefs a first report can use.
IFRS Sustainability Disclosure Standards
The whole ISSB family.