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ISSB Rewrites Industry Metrics: What IFRS S2 Changes Cost

Socious Team
ISSB Rewrites Industry Metrics: What IFRS S2 Changes Cost

If your climate disclosure work is organised around IFRS S1 and IFRS S2, most of your attention has gone to the core standards. The layer underneath them is the part being actively rewritten right now.

In March 2026 the ISSB published Exposure Draft SASB/ED/2026/1, Proposed amendments to the SASB Standards and IFRS S2 Industry-based Guidance, with comments due by 24 July 2026 (IFRS Foundation). It is the second exposure draft in a programme the ISSB decided on in July 2024 to amend twelve prioritised SASB Standards. The July 2025 draft covered nine of them, and its comment period closed on 30 November 2025 (IFRS Foundation project page).

What is in this draft

Three standards, chosen for comprehensive review:

  • Agricultural Products
  • Meat, Poultry & Dairy
  • Electric Utilities & Power Generators

Alongside them sit proposed consequential amendments to the three corresponding volumes of the Industry-based Guidance on Implementing IFRS S2. That guidance is derived from the SASB Standards, and the ISSB is amending it in parallel to keep the two aligned. The exposure draft is direct about the relationship: the climate content of the SASB Standards is identical to the IFRS S2 industry-based guidance, except that SASB also carries financed emissions, which IFRS S2 handles in its Appendix B application guidance.

The ISSB ratified the draft in February 2026 and approved the consequential IFRS S2 amendments the same month. It was approved for ratification by 11 of the 12 board members. Dr Richard Barker voted against, and his alternative view is published with the draft, which is worth knowing when you weigh how settled these proposals are.

Why the industry layer matters even though it is not mandatory

IFRS S2 does not require you to apply the industry-based guidance. It requires you to refer to it and consider its applicability. For most preparers, and for the assurance providers reviewing them, that is the difference between a metric you may skip with a reason and a metric you may skip silently.

So a change to this layer is not cosmetic. It moves the reference point your disclosure is judged against, industry by industry.

Read the metric changes and the cost becomes obvious

Appendix A of the exposure draft lists the affected metrics side by side. Four from the Agricultural Products volume show the pattern.

Current metricProposed metric
FB-AG-110a.1 Gross global Scope 1 emissions(1) Gross Scope 1 emissions and (2) percentage subject to emissions-limiting regulations
FB-AG-110a.2 Discussion of long- and short-term strategy or plan to manage Scope 1 emissions, emissions reduction targets, and an analysis of performance against those targetsDescription of Scope 1 greenhouse gas emissions targets and analysis of performance against those targets
FB-AG-110a.3 Fleet fuel consumed, percentage renewable(1) Total fleet fuel consumed and (2) renewable fuel consumed
FB-AG-130a.1 (1) Total energy consumed, (2) percentage grid electricity and (3) percentage renewable(1) Operational energy consumed, (2) purchased electricity consumed and (3) renewable electricity consumed from (a) self-generation and (b) direct contracts

Only FB-AG-110a.2 is a writing change. It trades a discussion requirement for a description requirement, and a team that has been disclosing well already has the material.

The other three change what you have to hold.

FB-AG-110a.1 adds a percentage of Scope 1 emissions subject to emissions-limiting regulations. To produce that you need every emitting facility tagged against the regulatory regime it sits in, and you need that tagging to survive a review. Most emissions inventories are built to total correctly, not to be sliced by regulatory status.

FB-AG-130a.1 is the sharpest. Going from “percentage renewable” to renewable electricity split between self-generation and direct contracts means the number now depends on contractual provenance. You need to know which megawatt-hours came from your own generation and which came from a direct contract, per site, for the year. If you have been computing a renewable percentage from a supplier’s annual mix statement, you do not have that and cannot derive it.

FB-AG-110a.3 looks trivial and is not. You can report a percentage once you know the ratio. Two absolute quantities mean measuring and reconciling both denominators.

This is the recurring shape of standards maintenance. The disclosure text gets shorter and clearer while the data behind it gets more specific. The published rationale confirms the direction: the ISSB frames the project around international applicability, interoperability with other frameworks, nature and human capital topics, and terminology alignment, and states that the amendments are intended to improve the standards’ “clarity, conciseness and cost-effectiveness for preparers.” That is a real gain for the reader. It does not reduce what the preparer has to measure.

The timing question

The ISSB proposes an effective date between 12 and 18 months after issuance, with early application permitted, and will fix the date after considering feedback. Since the comment period closed in July 2026, that window plausibly lands the amendments in the same period as two mandates already on the calendar:

  • SSBJ in Japan. The final standards were issued on 5 March 2025 and phase in by market capitalisation — Prime-listed companies above ¥3 trillion report for the fiscal year ending March 2027, above ¥1 trillion from 2028, above ¥500 billion from 2029, finalised through a Cabinet Office Ordinance in February 2026. The SSBJ standards are the Japanese counterparts of IFRS S1 and IFRS S2.
  • CSRD in the EU. Directive (EU) 2026/470 has been in force since 18 March 2026, with the reduced scope applying from financial year 2027 and first reports landing in 2028.

We are not forecasting the ISSB’s decision. The point is arithmetic: the first year in which many companies report under either regime may also be a year in which the industry metric definitions move. Building a data model that assumes today’s metric wording is durable is a poor bet in that window.

What to do with this now

Check whether one of the three is yours. If you are in agricultural products, meat, poultry and dairy, or electric utilities and power generation, read Appendix A of the exposure draft against your current metric inventory and mark the ones whose inputs change rather than whose wording changes.

Separate the two kinds of change in your plan. A wording change is a drafting task and it closes in days. An input change does not, because it usually requires a new field at source, a new owner for that field, and a full year of that field before the first comparable disclosure.

Test your architecture against a redefinition. The practical question is what happens when a metric splits in two. If your reporting process starts from a spreadsheet that was assembled to answer last year’s metric list, a redefinition means going back to every site and asking again. If it starts from a single underlying dataset with contract-level and facility-level detail preserved, a redefinition is a remapping.

That second architecture is what we build. Socious Report takes one dataset and produces AI-drafted CSRD, SSBJ and ISSB reports from it, then adds an independent Socious Verify credential to the result. When a standard changes a metric, the work is a remap rather than another round of data collection.

If you want a baseline before you start, our free readiness check scores your position across seven dimensions in about three minutes: socious.io/ssbj-check.