The December 2025 amendments to IFRS S2

The first companies to apply IFRS S2 found some of its greenhouse gas requirements hard to apply in practice, especially banks and insurers measuring emissions linked to derivatives and underwriting, and groups whose subsidiaries must follow local rules. The ISSB responded with targeted amendments rather than waiting for a full review. This guide explains each change, works through a bank's category 15 disclosure, and covers the effective date, transition and how jurisdictions such as Australia have adopted the amendments.

By Hamza Fida, Chartered Accountant. Reviewed by Mirza Fahad Baig, Chartered Accountant. 3 minute read.

Short answer

The IFRS S2 amendments, Amendments to Greenhouse Gas Emissions Disclosures, were issued by the ISSB on 11 December 2025 and apply to annual periods beginning on or after 1 January 2027, with early application permitted. They make four changes to ease implementation. Companies with asset management, commercial banking or insurance activities may limit scope 3 category 15 to financed emissions, from loans, project finance, bonds, equity investments and undrawn commitments, and exclude emissions linked to derivatives, facilitated emissions and insurance-associated emissions, disclosing what they excluded. They no longer have to use GICS to break down financed emissions by industry, but must explain the classification they choose. A company required by a jurisdiction or exchange to use a different measurement method or different global warming potentials may use them for the part of the business affected. Companies already applying IFRS S2 adjust comparatives unless impracticable. In this guide's example, a bank reports 2,600 thousand tonnes of financed emissions and excludes 1,000 thousand tonnes under the relief.

At a glance

Issued
11 December 2025
Effective
From 1 January 2027
Category 15
Can be financed only
Industry breakdown
GICS no longer required
Local rules
Other methods and GWPs
Transition
Adjust comparatives
The December 2025 amendments to IFRS S2Issued: 11 December 2025; Effective: From 1 January 2027; Category 15: Can be financed only; Industry breakdown: GICS no longer required; Local rules: Other methods and GWPs; Transition: Adjust comparatives.KEY FACTS AT A GLANCEThe December 2025 amendments to IFRS S2Issued11 December 2025EffectiveFrom 1 January 2027Category 15Can be financed onlyIndustry breakdownGICS no longer requiredLocal rulesOther methods and GWPsTransitionAdjust comparativesTax BakersThe December 2025 amendments to IFRS S2Issued: 11 December 2025; Effective: From 1 January 2027; Category 15: Can be financed only; Industry breakdown: GICS no longer required; Local rules: Other methods and GWPs; Transition: Adjust comparatives.KEY FACTS AT A GLANCEThe December 2025 amendments toIFRS S2Issued11 December 2025EffectiveFrom 1 January 2027Category 15Can be financed onlyIndustry breakdownGICS no longer requiredLocal rulesOther methods and GWPsTransitionAdjust comparativesTax Bakers
Key facts at a glance, as set out in this guide.

What do the IFRS S2 amendments change?

  • Category 15 relief: a company with asset management, commercial banking or insurance activities may limit scope 3 category 15 to financed emissions, the emissions attributed to its loans, project finance, bonds, equity investments and undrawn loan commitments, and for asset managers the assets they manage. It may exclude emissions linked to derivatives, facilitated emissions, such as underwriting, and insurance-associated emissions.
  • Industry classification: the requirement to use the Global Industry Classification Standard when disaggregating financed emissions is removed; the company chooses a system that gives useful information about transition risk exposure and explains its choice.
  • Measurement method: where a jurisdiction or exchange requires a method other than the GHG Protocol for all or part of the company, it may use that method for the part affected.
  • Global warming potentials: where a jurisdiction or exchange requires values other than the latest IPCC ones, the company may use them for the part affected.

See IFRS S2 climate disclosures.

IFRS S2 amendments in practice: a bank's category 15

A bank measures the emissions attributed to its lending and investments using the PCAF standard, in thousand tonnes of CO2 equivalent. See financed emissions and PCAF.

ActivityThousand tonnes CO2eUnder the relief
Business loans and project finance1,800Included, financed emissions
Corporate bonds held400Included, financed emissions
Listed equity held300Included, financed emissions
Undrawn loan commitments100Included, financed emissions
Derivatives200May be excluded
Facilitated emissions from bond underwriting500May be excluded
Insurance-associated emissions of its insurance arm300May be excluded
A bank's category 15 under the relief (thousand tonnes CO2e)A bank's category 15 under the relief (thousand tonnes CO2e)2,600Reported as category 151,000Excluded under the reliefFinanced emissionsDerivativesFacilitated and insurance-associated
The relief narrows category 15 to financed emissions.

Applying the relief, the bank reports category 15 of 2,600 thousand tonnes, all financed emissions, and discloses the total of category 15 and the subtotal of financed emissions within it, here the same figure. It describes the activities it excluded, derivatives, underwriting and insurance, and how it defines a derivative for this purpose. It breaks down financed emissions by industry using the classification its banking regulator uses for climate stress tests, and explains why. Its insurance arm may use a different classification. See the 15 scope 3 categories.

How do the jurisdictional reliefs work?

IFRS S2 already allowed a company to use a different measurement method if a jurisdiction required it for the whole company. The amendments extend this to requirements that apply to only part of a company, and add the same relief for global warming potentials. For example, a group with an EU subsidiary reporting under the ESRS, or a Japanese subsidiary reporting under national rules, can use those methods or values for that subsidiary and the GHG Protocol and latest IPCC values for the rest. It discloses which parts use which method. See choosing emission factors and organisational boundaries.

When do the amendments apply?

For annual reporting periods beginning on or after 1 January 2027, with early application permitted. A company that has already applied IFRS S2 adjusts the comparative information for the preceding period as if the amendments had applied, unless that is impracticable. Australia's standard-setter approved matching amendments to AASB S2 on 15 December 2025, with the same effective date, and other jurisdictions that adopt IFRS S2 are expected to follow. The ISSB also amended the SASB Standards for asset management, commercial banks and insurance to match.

Why did the ISSB make these changes?

Banks and insurers told the ISSB that measuring emissions linked to derivatives, underwriting and insurance was not yet possible with reliable methods, and that GICS was costly and did not match how they manage risk. Groups subject to several regimes faced measuring the same emissions twice. The amendments keep the core requirement to report scope 1, 2 and 3 emissions while removing these obstacles, which the ISSB expects to make adoption easier. See ISSB transition reliefs and ISSB adoption by country.

Need help applying the standards?

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Questions people ask

What did the December 2025 amendments to IFRS S2 change?

They allow category 15 to be limited to financed emissions, remove the GICS requirement, and add jurisdictional relief for measurement methods and global warming potentials.

When are the IFRS S2 amendments effective?

For annual reporting periods beginning on or after 1 January 2027, with early application permitted.

Can banks exclude facilitated emissions under IFRS S2?

Yes. Under the amendments, emissions linked to derivatives, facilitated emissions and insurance-associated emissions may be excluded, with disclosure.

Do companies have to restate comparatives for the IFRS S2 amendments?

A company already applying IFRS S2 adjusts the preceding period's comparatives unless impracticable.

Sources

Every fee, date and rule on this page was taken from these official and primary sources.

  1. IFRS Foundation: Amendments to Greenhouse Gas Emissions Disclosures (Amendments to IFRS S2), December 2025
  2. EY: ISSB amends IFRS S2 greenhouse gas emissions disclosures, December 2025
  3. Deloitte Australia: amended relief for specific GHG emission disclosures in AASB S2
  4. IFRS Foundation: IFRS Sustainability Disclosure Standards (IFRS S1 and IFRS S2)

Rules and fees change. If you are reading this long after October 10, 2026, confirm the figures with the source before you rely on them.

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This guide is general information. It is not tax or legal advice for your situation.