How does ISSB adoption work?
The ISSB issued IFRS S1 and IFRS S2 in June 2023, effective for periods from 1 January 2024 where adopted. A jurisdiction can require the standards as issued, adopt them with local additions or reliefs, issue its own standards aligned with them, or permit companies to use them voluntarily. The IFRS Foundation publishes jurisdictional profiles describing each approach; in its September 2026 update, 22 profiles were finalised, 18 of them targeting full adoption, 3 climate requirements only and 1 partial incorporation. See IFRS S1 and IFRS S2.
How does ISSB adoption differ by country?
Australia requires its climate standard, AASB S2, for the largest companies from 2025, phasing in other entities to 2027, with AASB S1 voluntary. Japan's Financial Services Agency plans to require the SSBJ standards for Prime Market companies with a market value of 3 trillion yen or more from the fiscal year ending March 2027, then 1 trillion yen from March 2028 and 500 billion yen from March 2029, with assurance a year after each start. The UK government published UK SRS S1 and S2 in February 2026, and the FCA's final rules require listed companies to report against them on a comply or explain basis for periods from 1 January 2027. Singapore requires all listed companies to report scope 1 and 2 emissions from 2025 and Straits Times Index companies to give the full ISSB-based disclosures, but deferred full reporting for other listed companies to 2028 or 2030. Malaysia phases in Main Market companies in 2025 and 2026, and ACE Market and large unlisted companies in 2027, Brazil requires listed companies to report from 2026, and Kenya requires public interest entities from 2027.
ISSB adoption in practice: a Pakistani listed company
The Securities and Exchange Commission of Pakistan ordered on 31 December 2024 that listed companies apply IFRS S1 and IFRS S2 in three phases. A cement company listed on the Pakistan Stock Exchange, with turnover above Rs. 25 billion, more than 1,000 employees and total assets above Rs. 12.5 billion, falls in Phase I, for periods beginning on or after 1 July 2025, so its first sustainability disclosures cover the year to 30 June 2026. Pakistan has added no reliefs of its own, so the company can use those in the standards, such as reporting on climate only and omitting scope 3 in its first year, and it must make an explicit and unreserved statement of compliance. For the first year, it may publish the disclosures separately within nine months of the year end; from the second year, they sit with the financial statements, after the directors' report, and assurance begins. Mid-sized listed companies follow in Phase II from 1 July 2026, and remaining listed companies and certain public interest companies in Phase III from 1 July 2027. Its impairment testing should use carbon assumptions consistent with these disclosures. See climate risk in impairment testing. See ISSB transition reliefs.
How does the EU relate to the ISSB standards?
The EU did not adopt the ISSB standards. Companies in scope of the CSRD use the ESRS, which use double materiality and cover more topics, but the climate standard, ESRS E1, was designed to be largely interoperable with IFRS S2, and the ISSB and EFRAG have published guidance on reporting under both. See the revised ESRS and the CSRD for non-EU companies. See ISSB vs ESRS.
What about the United States and Canada?
There is no federal requirement in the United States: the SEC's 2024 climate rule never took effect. California's laws reach large companies doing business there, and SB 261 accepts IFRS S2 as a framework for climate risk reports. In Canada, the Canadian Sustainability Standards Board issued CSDS 1 and 2, based on the ISSB standards, in December 2024 for voluntary use, while securities regulators paused work on mandatory climate rules in 2025. See California SB 261.
Which jurisdictions are still deciding?
China has issued a basic sustainability standard and is developing climate standards aligned with the ISSB's, and its exchanges already require reports from some listed companies. Hong Kong's climate requirements for listed issuers are based on IFRS S2, with full ISSB-aligned requirements expected from 2028. Others, including South Korea, Indonesia, Thailand and Switzerland, are still deliberating or have set dates from 2028. Groups should track every jurisdiction where they or their subsidiaries are listed or registered, because reliefs, start dates and assurance requirements differ. See sustainability reporting explained.
Need help applying the standards?
Our Chartered Accountants help finance teams and students apply IFRS and US GAAP to real transactions.
Questions people ask
How many countries have adopted the ISSB standards?
By September 2026, the IFRS Foundation counted more than 45 jurisdictions that had adopted or were moving to adopt or otherwise use them.
Has the EU adopted the ISSB standards?
No. The EU uses the ESRS, which are designed to be largely interoperable with IFRS S2 on climate.
Does the United States require IFRS S1 and S2?
No. There is no federal requirement, although California's SB 261 accepts IFRS S2 as a framework.
When must Pakistani listed companies apply IFRS S1 and S2?
In three phases, for periods beginning on or after 1 July 2025, 1 July 2026 and 1 July 2027, depending on size.
Sources
Every fee, date and rule on this page was taken from these official and primary sources.
- IFRS Foundation: adoption of IFRS Sustainability Disclosure Standards, World Standard-setters Conference, September 2026
- IFRS Foundation: jurisdictional profile, Pakistan
- Japan Financial Services Agency: roadmap for mandatory SSBJ standards, April 2026
- A&O Shearman: FCA finalises UK SRS-aligned sustainability disclosure rules for listed issuers, October 2026
- Allen & Gledhill: ACRA and SGX RegCo extend timelines for most climate reporting requirements, September 2025
- 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.
Related guides
More in Sustainability
This guide is general information. It is not tax or legal advice for your situation.