IFRS S2 · the TCFD comparison
IFRS S2 vs TCFD: the same pillars, more requirements
IFRS S2 is built on the TCFD recommendations, and the IFRS Foundation says a company applying it meets them “and more” (IFRS Foundation).
The differences are with the TCFD’s guidance, not its recommendations, and they are mostly additions.
The relationship
Recommendations, turned into requirements
The TCFD framework is four core recommendations, eleven supporting recommended disclosures, and guidance that informs them but is not part of them.
The IFRS Foundation’s comparison says every difference between IFRS S2 and the TCFD sits in that guidance, not in the recommendations or recommended disclosures.
It classifies the differences three ways: different wording for the same information; the same information, in more detail; and additional requirements beyond the TCFD guidance.
The four pillars that carried over are set out on the four pillars.
“The requirements in IFRS S2 integrate, and are consistent with, the four core recommendations and 11 recommended disclosures published by the TCFD.”
Comparison: IFRS S2 with the TCFD recommendations.
Pillar by pillar
Where IFRS S2 asks for more
| Pillar | What IFRS S2 adds to the TCFD, per the IFRS Foundation |
|---|---|
| Governance | More detail — for example, how responsibilities appear in terms of reference, mandates and role descriptions |
| Strategy: risks and opportunities | Consider the industry-based disclosure topics; describe where in the business model and value chain risks concentrate |
| Strategy: effects | Responses and plans, any transition plan, how targets will be met; criteria for when quantitative or qualitative financial effects are required; reasonable and supportable information |
| Strategy: resilience | Additional information on resilience, without prescribing particular scenarios |
| Risk management | More detail on processes, and on how far opportunity processes are integrated |
| Metrics | The same cross-industry categories as the TCFD guidance, plus industry-based metrics; Scope 1 and 2 split between the group and other investees; location-based Scope 2; Scope 3 with a measurement framework; financed emissions |
| Targets | How the latest international agreement informed each target; third-party validation; sectoral decarbonisation approach; planned use of carbon credits |
The IFRS Foundation singles out three additions in its own announcement: industry-based metrics, the planned use of carbon credits for net targets, and more information on financed emissions (24 July 2023).
One way it asks for less
Materiality applies to emissions too
The TCFD’s 2021 guidance encouraged Scope 1 and 2 emissions to be disclosed independent of materiality, and Scope 3 “as appropriate”.
The ISSB Standards require information only if it is material, so the IFRS Foundation’s comparison records this as a difference.
IFRS S2 also does not require emissions to be broken down by constituent gas, though IFRS S1’s disaggregation rules require it where that is material.
Moving across
From a TCFD report to an IFRS S2 report
The IFRS Foundation suggests reading IFRS S1 and S2, using its comparison table to find the gaps, filling them, and checking whether governance, risk management, strategy or timing must change (knowledge hub).
It also notes that a company applying IFRS S1 and S2 will likely meet any TCFD-aligned requirements in its jurisdiction, but should confirm with its regulator.
The TCFD disbanded on 12 October 2023, and its recommendations remain available but are no longer maintained.
- 1
Read IFRS S1 and S2
Start from the standards, not the old TCFD index.
- 2
Use the comparison table
Identify the gaps between existing TCFD disclosures and IFRS S2.
- 3
Fill the gaps
Scope 3, industry metrics, financed emissions, target detail, financial effects.
- 4
Check governance and timing
IFRS S1 puts the disclosures alongside the financial statements, with a first-year relief.
The UK switch
UK listed companies: TCFD out, UK SRS in, from 2027
The FCA’s final rules say they “will replace the existing TCFD aligned disclosures” for listed companies (PS26/19 ¶1.10).
The switch applies to accounting periods beginning on or after 1 January 2027, and a company with an earlier period may keep the TCFD-aligned rules or adopt UK SRS early (¶3.19).
The UK standard is UK SRS S2, and the eleven TCFD disclosures mapped to its paragraphs are on moving from TCFD to UK SRS.
The Companies Act climate duty for large companies, which grew out of the TCFD, is separate, and is covered on TCFD requirements in the UK.
Frequently asked
IFRS S2 and TCFD, answered
What is the difference between IFRS S2 and TCFD?
The TCFD set out recommendations; IFRS S2 is a standard with requirements.
The IFRS Foundation says IFRS S2 is consistent with the TCFD’s four core recommendations and eleven recommended disclosures, and that the differences are with the TCFD’s guidance: IFRS S2 is more detailed and adds requirements, notably industry-based metrics, Scope 3 with a measurement framework, financed emissions, and information on planned use of carbon credits.
Does applying IFRS S2 meet the TCFD recommendations?
Yes.
The IFRS Foundation says a company that applies IFRS S1 and IFRS S2 will meet the TCFD recommendations “and more”, so it does not need to apply the TCFD recommendations as well.
It also advises checking local rules, because a jurisdiction’s TCFD-based requirement may have its own wording.
Is TCFD still in use after IFRS S2?
The Task Force disbanded on 12 October 2023 after its final status report, and the Financial Stability Board asked the IFRS Foundation to take over monitoring of climate-related disclosures.
The recommendations remain available, and some jurisdictions still refer to them.
Does IFRS S2 require Scope 1 and 2 regardless of materiality?
No. The TCFD’s 2021 guidance encouraged Scope 1 and 2 disclosure independent of materiality; the ISSB Standards require information only if it is material.
In practice, the IFRS Foundation notes, the detailed greenhouse gas requirements in IFRS S2 go further than the TCFD in other respects.
When does UK SRS replace TCFD reporting for UK listed companies?
For accounting periods beginning on or after 1 January 2027.
PS26/19 ¶1.10 says the new rules replace the existing TCFD-aligned disclosures.
A company with an earlier period may keep the TCFD-aligned rules or adopt UK SRS early (¶3.19).
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 FoundationComparison: IFRS S2 Climate-related Disclosures with the TCFD recommendations (PDF, updated November 2024)
Recommendation-by-recommendation differences, in three forms.
- IFRS FoundationMaking the transition from TCFD to ISSB
“A company that applies IFRS S1 and IFRS S2 will meet the TCFD recommendations (and more).”
- IFRS FoundationIFRS Foundation publishes comparison of IFRS S2 with the TCFD Recommendations (24 July 2023)
Industry metrics, carbon credits and financed emissions as additional requirements.
- IFRS FoundationISSB and TCFD
The recommendations are “fully incorporated into the ISSB Standards”.
- IFRS FoundationIFRS S2, full text (December 2025)
The requirements the comparison maps.
- IFRS FoundationIFRS S2 — Navigator page and standard history
IFRS S2 integrates and builds on the TCFD recommendations.
- TCFDFinal Report: Recommendations of the TCFD (June 2017, PDF)
The four core recommendations and eleven recommended disclosures.
- Financial Conduct AuthorityPS26/19 final rules (30 September 2026)
UK SRS replaces the TCFD-aligned listing rules from 2027.
- Financial Conduct AuthorityPS26/19 (PDF), ¶¶1.10 and 3.19
“These rules will replace the existing TCFD aligned disclosures.”
- Department for Business and TradeUK SRS S2 (PDF)
The UK version of IFRS S2.
Continue reading
Read next
TCFD
The Task Force, its recommendations and its legacy.
Moving from TCFD to UK SRS
The eleven disclosures mapped to UK SRS S2.
IFRS S2
The climate standard, paragraph by paragraph.
The four pillars
The structure IFRS S2 inherited from the TCFD.
TCFD and UK SRS
How the UK moves from one to the other.
IFRS Sustainability Disclosure Standards
The whole ISSB family.