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IFRS S2 · Amendments to Greenhouse Gas Emissions Disclosures

The IFRS S2 amendments: four greenhouse gas changes from 2027

On 11 December 2025 the ISSB issued targeted amendments to the greenhouse gas requirements in IFRS S2, in response to problems companies met when they started applying it.

They apply to annual reporting periods beginning on or after 1 January 2027, and they are already in the text of UK SRS S2.

Why

Reliefs for problems found in the first reports

The ISSB said the amendments respond to “specific application challenges that were identified as companies started to apply the Standard” (IFRS Foundation).

They followed a consultation earlier in 2025 and discussions in the Transition Implementation Group, the ISSB’s forum for implementation questions.

The standard’s own history page says they aimed to reduce complexity, the risk of duplicative reporting and cost “while not significantly reducing the usefulness of information” (IFRS S2 standard history).

Three of the four changes are reliefs; the fourth, a classification freedom, comes with a new duty to explain the choice.

The four changes

What changed, paragraph by paragraph

Source: IFRS S2, December 2025 text; ¶C1A lists every amended and added paragraph.
ChangeBeforeAfterParagraphs
Category 15 limited to financed emissionsCategory 15 (investments) measured in full within Scope 3An entity may limit Category 15 to financed emissions — loans, project finance, bonds, equity, undrawn commitments and assets under management — and may exclude derivatives; it explains what it treated as a derivative and which activities it excluded¶¶29A–29B
Category 15 total and subtotalNo separate splitIf Category 15 is included in Scope 3, disclose the Category 15 total and the financed-emissions subtotal within it¶29C
Industry classification for financed emissionsBanks and insurers disaggregated by the Global Industry Classification Standard (GICS)Any industry-classification system that shows exposure to transition risk; a commonly used system is prioritised; the system and the reason are disclosed¶¶B62A, B63A
GHG Protocol jurisdictional reliefRelief where a jurisdiction or exchange required a different methodClarified to apply where the requirement covers the entity “in whole or in part”, for that part and for as long as it applies¶29(a)(ii), B24
Global warming potentialsLatest IPCC 100-year values, without exceptionA jurisdiction or exchange may require different values for all or part of the entity, for as long as the requirement applies¶¶B21–B22

Paragraph B25 keeps an important limit: a jurisdiction that requires only part of the emissions — for example Scope 1 and 2 — does not exempt the entity from disclosing Scope 1, 2 and 3 for the whole entity.

The same day, the ISSB made consequential amendments to align the financed-emissions metrics in three SASB Standards with the amended IFRS S2.

Category 15

Category 15: what a financial institution may leave out

Category 15 of the GHG Protocol Scope 3 Standard covers investments, and for a bank, insurer or asset manager it can reach well beyond the loans and investments on its balance sheet.

The Basis for Conclusions names two examples of other Category 15 emissions: facilitated emissions from investment banking and insurance-associated emissions from underwriting.

Under ¶29A an entity may leave those out and report financed emissions only, and it may exclude emissions attributable to derivatives.

In exchange, ¶29B requires it to explain what it treated as a derivative and to describe the financial activities it excluded.

The detailed financed-emissions requirements for asset managers, banks and insurers are on Scope 3 and financed emissions.

Paragraph 29A, in IFRS S2’s words

“An entity is permitted to limit what it includes in its measure of Scope 3 Category 15 greenhouse gas emissions to only its financed emissions.”

IFRS S2 ¶29A (December 2025); financed emissions are those attributed to loans and investments, including assets under management.

Transition

Comparatives, restated unless impracticable

An entity that already applied IFRS S2 adjusts its comparative information in the first year it applies the amendments, unless that is impracticable (¶C6).

An entity applying IFRS S2 for the first time from 2027 meets the amended text directly, with the usual first-year reliefs, including no Scope 3 under ¶C4(b), which the amendments updated to refer to the new financed-emissions paragraphs.

Every relief and date is on effective date and reliefs.

  1. 1

    Changed measurement under a jurisdictional relief

    Adjust the prior year as if the change had been made then (¶C6(a)).

  2. 2

    Category 15 included in Scope 3

    Give the prior-year Category 15 total and financed subtotal (¶C6(b)).

  3. 3

    New industry-classification system

    Re-present the prior year on the new system (¶C6(c)).

In the UK

Already in UK SRS S2, with one UK addition

UK SRS S2 was issued on 25 February 2026, after the amendments, and its text already contains ¶¶29A–29C, the global warming potential relief in ¶¶B21–B22 and the classification paragraphs B62A and B63A (UK SRS S2).

The UK had proposed removing the GICS requirement itself, and withdrew that proposal because the ISSB made the change.

The UK added one stricter paragraph, ¶B59A: where it is impracticable to estimate financed emissions for the same period as the financial statements, the entity must explain why (Annex A).

A UK listed company therefore meets the amended requirements from its first UK SRS period, on the FCA’s comply-or-explain basis, and every UK difference is on UK SRS amendments.

The ISSB’s proposed taxonomy update tags the amended disclosures for digital reporting and, in the Foundation’s words, “neither introduces new requirements nor affects a company’s compliance” (IFRS Foundation).

Frequently asked

The IFRS S2 amendments, answered

What are the December 2025 amendments to IFRS S2?

Targeted amendments to the greenhouse gas requirements, issued on 11 December 2025.

They let an entity limit Category 15 Scope 3 emissions to financed emissions, permit classification systems other than GICS for disaggregating financed emissions, clarify that the jurisdictional relief from the GHG Protocol is available when only part of the entity is required to use another method, and add a jurisdictional relief from using the latest IPCC global warming potential values.

When do the IFRS S2 amendments take effect?

For annual reporting periods beginning on or after 1 January 2027 (IFRS S2 ¶C1B).

Earlier application is permitted, and an entity that applies them early must disclose that it has done so.

Are the December 2025 amendments in UK SRS S2?

Yes.

UK SRS S2 was issued on 25 February 2026 and already contains the amended text, including paragraphs 29A–29C, the global warming potential relief in B21–B22 and the classification-system paragraphs B62A and B63A.

The UK had itself proposed removing the GICS requirement and withdrew that proposal because the ISSB made the change.

Does IFRS S2 require insurance-associated or facilitated emissions?

Not if the entity applies the Category 15 limitation.

Paragraph 29A permits an entity to limit Category 15 to financed emissions — emissions attributed to loans and investments, including assets under management — and the Basis for Conclusions gives facilitated emissions from investment banking and insurance-associated emissions as examples of other Category 15 emissions that can then be left out.

An entity using the limitation explains what it treated as a derivative and which activities it excluded (¶29B).

Do companies have to restate prior-year figures for the amendments?

An entity that previously applied IFRS S2 adjusts the comparative information for the preceding period in its first year under the amendments, unless that is impracticable (¶C6): for a change of measurement under the jurisdictional reliefs, for the Category 15 total and financed subtotal, and for a change of industry-classification system.

Do the amendments reduce what IFRS S2 requires?

They are reliefs and clarifications.

The ISSB said they aim to reduce complexity, duplicative reporting and cost without significantly reducing the usefulness of the information.

One addition runs the other way: an entity that includes Category 15 emissions must now disclose the total and the financed-emissions subtotal within it (¶29C).

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 11 sources fromIFRS FoundationDepartment for Business and TradeGHG ProtocolPCAF
  1. IFRS Foundation
    ISSB issues targeted amendments to IFRS S2 to support implementation (11 December 2025)

    The four changes; effective for periods beginning on or after 1 January 2027; consequential amendments to three SASB Standards.

  2. IFRS Foundation
    Amendments to Greenhouse Gas Emissions Disclosures — Amendments to IFRS S2 (PDF)

    The amending document and its Basis for Conclusions.

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

    ¶29(a)(ii), ¶¶29A–29C, B21–B25, B62–B63A, C1A–C1B, C4(b), C6 and the approval note.

  4. IFRS Foundation
    IFRS S2 — Navigator page and standard history

    The amendments aimed to reduce complexity, duplicative reporting and cost without significantly reducing usefulness.

  5. IFRS Foundation
    ISSB proposes update to the IFRS Sustainability Disclosure Taxonomy (29 July 2026)

    Proposed Update 1 tags the amendments; it introduces no new requirement.

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

    The amendments respond to challenges informed by Transition Implementation Group discussions.

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

    Issued 25 February 2026 with ¶¶29A–29C, B21–B22, B62A and B63A already in the text; ¶B59A added by the UK.

  8. Department for Business and Trade
    Consultation response (PDF), Annex A

    The B59A row: explain where financed emissions cannot be estimated for the same period.

  9. GHG Protocol
    Corporate Accounting and Reporting Standard (2004)

    The measurement basis in ¶29(a)(ii), and the method the jurisdictional relief departs from.

  10. GHG Protocol
    Corporate Value Chain (Scope 3) Standard (2011)

    Category 15, investments.

  11. PCAF
    Global GHG Accounting and Reporting Standard, Part A

    A widely used financed-emissions method; IFRS S2 does not name it.

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