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IFRS S2 · the first reports

IFRS S2 disclosure examples: what the first reports show

The first mandatory reports under standards based on IFRS S2 were published in 2026, and regulators have started reviewing them.

The largest review so far is Australia’s: its regulator read 40 reports and published what worked, what did not, and anonymised examples of each.

The evidence

Why Australia’s review is the one to read

The IFRS Foundation says companies in 12 jurisdictions reported on ISSB-based standards for 2025 (IFRS Foundation).

Australia’s regulator, ASIC, published the most detailed review so far on 21 September 2026: 40 of the 312 reports lodged under AASB S2 for years ending 31 December 2025 (REP 839).

AASB S2 is Australia’s climate standard based on IFRS S2, so most findings map directly onto IFRS S2 paragraphs.

Some features are Australian, not IFRS: AASB S2 has no industry-specific requirement, and Australian law requires at least two scenarios, one limited to 1.5°C and one well above 2°C (IFRS Foundation profile; REP 839).

The findings

The first reports, in numbers

All figures are percentages of the 40 reports ASIC reviewed, not of every report lodged.

67.5%
Named the board as the body overseeing climate
42.5%
Linked executive remuneration to climate in some way
95%
Identified at least one climate risk or opportunity
37.5%
Gave only qualitative financial effects
47.5%
Disclosed transition plan information
~20%
Limited scenario analysis to qualitative narratives

ASIC found the quality, quantity and consistency of climate information had increased compared with earlier voluntary reporting, including from unlisted companies reporting for the first time.

Disclosures on current matters, such as governance and risk management, were clearer than forward-looking ones resting on assumptions and judgement.

Where financial effects were not quantified, the most common reason given was measurement uncertainty, relied on to some extent by 57.5% of the sample.

Better and weaker practice

Examples ASIC singled out

ASIC anonymised every example; these are its descriptions, condensed.

Source: ASIC REP 839. The AASB S2 paragraphs ASIC cites match IFRS S2’s numbering; the right-hand column gives the IFRS S2 paragraph.
TopicBetter practiceLess effective practiceIFRS S2
GovernanceDiagrams of the processes, controls and procedures used to oversee climate risksA risk matrix with likelihood and consequence ratings but no definition of either¶¶6, 25(a)(iii)
Risks and opportunitiesA value-chain diagram showing where risks and opportunities arise; an explanation of why physical risks were judged immaterial, citing adaptation already in placeOne physical risk at one asset, where earlier disclosures and announcements showed events at several sites, with no judgement explained¶¶10, 13
Financial effectsA sensitivity analysis giving a range of effects on future cash flows under disclosed assumptions; clear explanation of why numbers were unreliableAn impairment of a project linked to a disclosed opportunity, not mentioned in the sustainability report¶¶15–21
ResilienceAn appendix setting out scenario assumptions — carbon prices, targets, heat, flooding — without obscuring the assessmentAnticipated financial effects folded into the scenario analysis, with the ¶16 disclosure omitted¶¶16, 22
Scope 3Voluntary Scope 3 figures clearly labelled as suchScope 3 figures elsewhere in the report without saying how they were measured¶29(a), ¶C4

ASIC’s action items

Eight things to do differently

Explain how the sustainability report connects with the financial report, including for cross-industry metrics and financial effects.

Give quantitative financial effects where possible, and explain clearly where only qualitative information is given.

Consider past events, current conditions and forecasts, and the whole value chain, when identifying risks and opportunities.

Disclose judgements, assumptions and measurement uncertainty close to the figures they affect.

Count targets set by law or regulation as climate-related targets.

Do not obscure material information with additional information, meet the cross-referencing rules, and avoid disclaimers that conflict with the reporting framework.

Resilience and financial effects are different disclosures

“Anticipated financial effects reflect the entity’s current plan and expectations for the future.

Climate resilience reflects how the current plan would be impacted by the conditions described by the scenarios.”

ASIC REP 839, climate resilience.

For a UK preparer

What the first reports mean for UK SRS

UK listed companies report under UK SRS S2 from periods beginning on or after 1 January 2027, so the Australian first wave is early evidence of where reports fall short.

The findings map onto UK SRS S2 paragraph for paragraph, because the paragraphs ASIC cites in AASB S2 carry the same numbers in IFRS S2 and UK SRS S2.

The gaps ASIC found — financial effects, connectivity, judgements — are the ones the IFRS S2 checklist and financial effects pages address.

Frequently asked

The first reports, answered

Are there real examples of IFRS S2 reports?

Yes.

Companies in 12 jurisdictions reported on ISSB-based standards for 2025, according to the IFRS Foundation.

The largest published review so far is by Australia’s regulator ASIC, which examined 40 of the 312 sustainability reports lodged under AASB S2 — Australia’s standard based on IFRS S2 — for years ending 31 December 2025.

What did ASIC find in the first AASB S2 reports?

That quality and quantity improved compared with voluntary reporting, that governance and risk management were generally clear, and that forward-looking and judgement-based disclosures need work: 37.5% gave only qualitative financial effects, 82.5% used the Scope 3 relief, and some did not connect the report to the financial statements.

Are Australian reports a fair guide to IFRS S2?

Largely, with care.

AASB S2 is based on IFRS S2 but differs in places: for example, it does not require industry-specific disclosures, and Australian law requires at least two scenarios, one limited to 1.5°C and one well above 2°C. Those features are Australian, not IFRS S2.

Did the first reports get clean audit opinions?

In ASIC’s sample, none of the audit reports was modified; two included an emphasis of matter drawing attention to directors’ judgement that no climate-related risks or opportunities could reasonably be expected to affect the entity’s prospects.

Where can I find illustrative examples from the ISSB?

The IFRS S2 Accompanying Guidance includes illustrative examples, for example on disaggregating emissions and financed emissions, and the IFRS Foundation has published educational material on topics such as anticipated financial effects and scenario analysis.

They illustrate the standard; they do not interpret 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.

Checked against 10 sources fromASICIFRS FoundationDepartment for Business and TradeFinancial Conduct Authority
  1. ASIC
    REP 839: ASIC’s review of sustainability reports lodged for 31 December 2025 (21 September 2026, PDF)

    40 of 312 reports reviewed; findings, percentages and anonymised examples of better and less effective disclosure.

  2. IFRS Foundation
    Jurisdictional profile: Australia (PDF)

    AASB S2 is based on IFRS S2; the IFRS Foundation classes Australia as partially incorporating ISSB Standards.

  3. IFRS Foundation
    World Standard-setters Conference 2026 — ISSB update (PDF)

    First waves of reports prepared applying ISSB Standards; FY2025 reporting in 12 jurisdictions.

  4. IFRS Foundation
    World Standard-setters Conference 2026 — Application of IFRS S1 and IFRS S2 (PDF)

    First impressions of applying IFRS S1 and S2; educational material list.

  5. IFRS Foundation
    IFRS S2, full text (December 2025)

    The paragraphs each finding relates to.

  6. Department for Business and Trade
    UK SRS S2 (PDF)

    The UK text with the same requirements.

  7. IFRS Foundation
    IFRS S2 Accompanying Guidance (June 2023)

    The ISSB’s own illustrative examples.

  8. IFRS Foundation
    IFRS S1, full text

    Connected information and the statement of compliance.

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

    The jurisdictions whose companies are reporting.

  10. Financial Conduct Authority
    PS26/19 (PDF)

    UK SRS from periods beginning on or after 1 January 2027.

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