Frequently Asked Questions
Plain, current answers to the questions companies actually ask about CSRD, ISSB, the EU Taxonomy, UK SRS, SECR, carbon accounting and the major national climate-disclosure regimes. Written for the person deciding what their business has to report, and by when.
Choosing a framework & key concepts
| ISSB (IFRS S1 & S2) | CSRD (ESRS) | |
|---|---|---|
| Set by | IFRS Foundation (global) | European Union (law) |
| Materiality | Financial only (investor focus) | Double (financial + impact) |
| Who it's for | Investors, capital markets | Broad stakeholders |
| Status | Voluntary unless a country adopts it | Mandatory for in-scope EU / EU-active companies |
| Assurance | Depends on jurisdiction | Limited assurance required |
| Emissions | Scope 1, 2 & 3 | Scope 1, 2 & 3 |
| Regime | Who it applies to | First reporting | Scope 3 |
|---|---|---|---|
| EU CSRD / ESRS | EU or EU-active, >1,000 employees & >€450m turnover | FY2027 for newly-scoped filers | Where material |
| UK SRS (S1 & S2) | Voluntary now; listed cos proposed from 2027 | Not yet mandatory | Proposed comply-or-explain 2028 |
| UK SECR | UK quoted + large unquoted cos / LLPs | In force since FY2019 | Not required (Scope 1 & 2) |
| Australia ASRS / AASB S2 | Phased by size; Group 1 first | FY beginning on/after 1 Jan 2025 | From year 2 |
| Hong Kong HKFRS S1 & S2 | HKEX issuers; LargeCap mandatory first | LargeCap from 1 Jan 2026 | Phased, LargeCap 2026 |
| Singapore SGX | All listed issuers; large NLCos later | Listed from FY2025 | STI cos from FY2026 |
| California SB 253 / 261 | Doing business in CA; >$1bn / >$500m revenue | First reports 2026 | SB 253 from 2027 |
| Canada CSDS 1 & 2 | Voluntary as of 2026 | FY beginning on/after 1 Jan 2025 | Relief in early years |
Which sustainability reporting framework applies to my company?#
The framework that applies depends mainly on where you operate, your size, and whether you are listed. EU-based or EU-active companies above certain thresholds fall under the CSRD and its ESRS standards; global and investor-focused reporters typically use the ISSB standards (IFRS S1 and S2); UK companies increasingly reference the UK Sustainability Reporting Standards (UK SRS), published in 2026 and based on the ISSB. Note that the EU's Omnibus I reforms, finalised in early 2026, narrowed CSRD scope to larger companies (broadly those with more than 1,000 employees), so many mid-sized firms that previously expected to report no longer must. A short readiness or gap analysis is the quickest way to confirm which regime, if any, currently binds you.
What is the difference between ISSB and CSRD?#
The core difference is scope of materiality and audience: the ISSB standards focus on financial materiality for investors, while the CSRD requires double materiality covering both financial and societal impacts. ISSB standards (IFRS S1 and S2) are issued by the IFRS Foundation and ask how sustainability issues affect a company's value; the CSRD is EU law, uses the ESRS, and additionally requires you to report how your company affects people and the environment. ISSB is being adopted voluntarily or into national rules around the world, including as the basis for the UK SRS. Many larger groups end up needing both, which is why aligned, single-data-entry reporting has become valuable.
What is double materiality?#
Double materiality is the principle that a company should report both how sustainability issues affect its financial position and how the company's own activities affect society and the environment. The first lens is often called financial materiality (outside-in) and the second impact materiality (inside-out); an issue is reportable if it is material under either. It is the defining requirement of the EU's CSRD and ESRS. This is broader than the investor-focused approach used by the ISSB standards, which centre on financial materiality alone.
What is the difference between single and double materiality?#
Single materiality considers only how sustainability matters affect a company's financial value, whereas double materiality also considers the company's impact on people and the planet. Single materiality (the ISSB and UK SRS approach) answers what investors need to price risk and opportunity. Double materiality (the CSRD and ESRS approach) adds an outward-looking assessment of environmental and social impacts, regardless of whether they are financially significant. In practice a double-materiality assessment captures everything a single-materiality one would, plus more, so companies subject to CSRD gather a wider dataset.
What are Scope 1, 2 and 3 emissions?#
Scope 1, 2 and 3 are the three categories of greenhouse gas emissions defined by the GHG Protocol. Scope 1 covers direct emissions from sources a company owns or controls, such as boilers and company vehicles; Scope 2 covers indirect emissions from purchased electricity, heat or steam; Scope 3 covers all other indirect emissions across the value chain, including purchased goods, business travel, and use of sold products. Scope 3 is usually the largest and hardest to measure, often accounting for the majority of a company's footprint. Most reporting frameworks now expect Scope 1 and 2 disclosure, with Scope 3 required where material.
What is a materiality assessment?#
A materiality assessment is the structured process of identifying which sustainability topics matter enough to your company and stakeholders to be worth reporting. It typically involves listing potential topics, gathering input from stakeholders such as investors, employees and customers, and scoring each topic by significance. Under financial materiality you assess impact on enterprise value; under double materiality you also assess your impact on society and the environment. The result shapes the scope of your report, so a defensible, well-documented assessment is the foundation of credible disclosure.
Do I need my sustainability report to be audited or assured?#
It depends on the framework: some mandatory regimes require independent assurance, while voluntary reporting generally does not. The EU's CSRD requires limited assurance of sustainability information, with a longer-term ambition to move towards reasonable assurance, though the timeline was eased under the 2026 Omnibus reforms. ISSB-based and UK SRS disclosures may attract assurance requirements depending on how each jurisdiction implements them. Even where assurance is not mandatory, keeping auditable records and a clear data trail makes future assurance cheaper and protects you against greenwashing claims.
What is the difference between mandatory and voluntary sustainability reporting?#
Mandatory reporting is required by law or listing rules for companies that meet defined thresholds, whereas voluntary reporting is done by choice to meet stakeholder, customer or investor expectations. Mandatory regimes such as the CSRD prescribe what you must disclose, in what format, and often to what assurance standard, with penalties for non-compliance. Voluntary reporting, for example against the ISSB standards before national adoption, gives more flexibility but still benefits from following a recognised framework for credibility. Many companies begin voluntarily to prepare for mandatory rules and to answer supply-chain data requests from larger customers.
Doing it with EcoLedger
What is EcoLedger?#
EcoLedger is UK self-serve software for sustainability and regulatory reporting, sold as annual licences. It lets companies collect their environmental, social and governance data once and produce reports aligned to major frameworks including the ISSB standards, CSRD and ESRS, the EU Taxonomy, and the UK SRS, alongside carbon accounting. It is designed for in-house teams to run reporting themselves rather than depending on a consultant for every cycle. You can find its products and a free readiness gap analysis at theecoledger.com.
How much does sustainability reporting software cost?#
Sustainability reporting software is typically sold as a fixed annual licence, which is usually far cheaper than consultant-led reporting that can run into tens of thousands of pounds per cycle. What you pay depends mainly on how many frameworks you need to cover and how deep the tool is. EcoLedger sells per framework or as an all-frameworks Suite (ISSB, CSRD, EU Taxonomy, UK SRS and carbon accounting from one dataset), with current prices published openly on each product page at theecoledger.com rather than quoted on request.
Is it cheaper to use software or a consultant for sustainability reporting?#
For recurring annual reporting, software is usually the cheaper option because the cost is a fixed licence rather than repeated professional fees. Consultants can charge tens of thousands of pounds per reporting cycle, and that expense recurs each year, whereas a software licence is a fixed annual cost, published openly on each product page. Consultants remain useful for one-off strategy, complex judgement calls or assurance readiness, and many companies combine the two: software for the ongoing data and disclosure work, and expert advice where it genuinely adds value. Over several reporting cycles the software-led approach typically costs far less.
Can one tool report to multiple frameworks at once?#
Yes. EcoLedger's Sustainability Reporting Suite lets you enter your data once and report to ISSB, CSRD, EU Taxonomy, UK SRS and carbon accounting, rather than rebuilding your dataset for each framework. Because frameworks share much of the same underlying data, such as emissions and governance information, a single source avoids duplication and inconsistency between reports. This is particularly useful for groups that face more than one regime, for example an EU obligation plus investor-driven ISSB disclosure. The Suite is available as a single annual licence covering all the included frameworks.
How do I know if my company is ready to report?#
Start with a gap analysis that checks which frameworks apply to you and which data and processes you already have in place. This tells you whether you are in scope of a mandatory regime such as the CSRD, and highlights gaps in areas like Scope 3 data, materiality assessment or governance disclosures before you commit time. EcoLedger offers a free readiness gap analysis at https://readiness.theecoledger.com. Running it early is worthwhile given that scope rules have shifted, notably under the EU's 2026 Omnibus reforms, so some companies are no longer required to report while others still are.
How long does it take to produce a sustainability report?#
A first sustainability report typically takes a few months, while subsequent annual reports are much faster once your data and processes are established. The main effort in year one is gathering data, especially Scope 3 value-chain emissions, and completing a materiality assessment; reporting software shortens this by structuring the data collection and generating framework-aligned outputs. In later years, with data flows and templates already in place, many teams complete a cycle in weeks. Using a single tool such as EcoLedger across multiple frameworks avoids repeating the groundwork for each one.
Do I need in-house sustainability expertise to use reporting software?#
No deep in-house expertise is required to get started, though some familiarity with your operational data helps. Self-serve tools like EcoLedger guide non-specialists through what each framework requires, structure the data collection, and generate the disclosures, which is why they suit finance, operations or compliance staff rather than only dedicated sustainability teams. You will still need people who can supply accurate data, such as energy use, travel and supplier information, and sign off on judgements. For genuinely complex or contested areas, targeted expert advice can supplement the software rather than replace it.
Buying & getting started
What is the best CSRD reporting software?#
The best CSRD software depends on your size and budget, and the market splits into two tiers. Enterprise platforms such as Workiva, Watershed and Persefoni are powerful but are sold through a sales team on enterprise budgets, which suits large listed groups. Self-serve tools such as EcoLedger publish their pricing openly on the product page and are built for mid-sized companies and advisers who want to run reporting themselves without a consultant. When comparing, look at ESRS datapoint coverage, whether double materiality is built in, assurance-readiness, and whether the same data can feed other frameworks you report against.
Do I need CSRD software, or can I use spreadsheets?#
Spreadsheets can work for a very small, first-time voluntary report, but they become risky once you are in scope of mandatory CSRD and need assurance. The ESRS involve hundreds of datapoints, a double materiality assessment, and an audit trail linking every figure back to its source, which is hard to maintain and version-control in Excel. Dedicated software structures the datapoints, runs the materiality assessment, applies emission factors consistently, and produces an assurance-ready output with lineage. The practical test is whether an auditor could follow your numbers from disclosure back to evidence; if not, a tool like EcoLedger pays for itself in reduced rework and audit risk.
How do I choose sustainability reporting software?#
Choose on five things: which frameworks it actually covers, whether it maps to the real standards rather than generic ESG questionnaires, assurance-readiness, total cost, and how quickly you can be up and running. Confirm the tool covers your specific obligation (for example CSRD/ESRS, ISSB, UK SRS or a national regime) and can reuse one dataset across several if you report to more than one. Check that figures carry calculation lineage and an evidence trail, because that is what makes external assurance affordable. Finally, weigh a transparent annual licence against enterprise 'contact sales' pricing and multi-month implementations, especially if you are a mid-sized company rather than a large listed group.
What features should CSRD reporting software have?#
At a minimum it should provide a built-in double materiality assessment, full ESRS datapoint coverage, greenhouse gas calculation with recognised emission factors across Scope 1, 2 and 3, and an evidence register that links each disclosure to its source for assurance. Useful extras include cross-framework reuse of data (so one input feeds ISSB, UK SRS, EU Taxonomy and more), automatic updates as standards change, and export in the format your auditor and filing require. Avoid tools that are really generic ESG survey platforms, because they rarely map cleanly to the standard's exact requirements. EcoLedger's software is built around the standards themselves, with datapoint mapping, calculation lineage and assurance-ready output.
Is it cheaper to use software or a consultant for CSRD?#
For recurring annual reporting, software is usually far cheaper, because a consultant-led CSRD project can cost tens of thousands of pounds and that expense repeats every year. A software licence is a fixed annual cost, published openly on each product page, and the workflow is reused each cycle. Consultants still add value for one-off strategy, complex judgements or assurance readiness, so many companies combine targeted advice with software for the ongoing data and disclosure work. Over two or three reporting cycles the software-led approach typically costs a fraction of a fully outsourced one.
How do I prepare a CSRD report step by step?#
At a high level there are six steps: confirm you are in scope, run a double materiality assessment to decide which ESRS topics apply, map the required datapoints, collect the underlying data (including Scope 1, 2 and 3 emissions and value-chain information), draft the disclosures against the ESRS, and obtain limited assurance before filing. The heaviest work in year one is the materiality assessment and data collection, especially Scope 3, so start early. Reporting software shortens each step by structuring the datapoints, guiding data collection and generating an assurance-ready draft. EcoLedger walks in-scope companies through this sequence and keeps an evidence trail for the auditor.
Can software make my sustainability report audit-ready?#
Yes, good reporting software is designed to produce assurance-ready disclosures, which matters because CSRD requires independent limited assurance. Audit-readiness comes from calculation lineage (every number traceable to its source), a documented methodology, and an evidence register the assurance provider can review. Software enforces this structure automatically, whereas spreadsheets often leave gaps that slow or fail an assurance engagement. EcoLedger produces disclosures with this trail built in, so the assurance process is faster and less costly.
What is the best carbon accounting software for a UK small business?#
For a UK SME, the best carbon accounting software is one that follows the GHG Protocol, uses the current UK Government (DESNZ) emission factors, and is priced for a smaller business rather than a large enterprise. You want straightforward Scope 1, 2 and 3 calculation, the ability to produce a SECR statement if you need one, and an output you can share with customers or use in a tender. Enterprise carbon platforms are often overkill and overpriced for an SME. EcoLedger's Carbon Accounting Software is a self-serve annual licence that covers Scope 1, 2 and 3 using recognised UK (DESNZ) factors, with pricing shown openly on the product page.
CSRD (ESRS)
CSRD Reporting Software (ESRS) →Do I have to comply with CSRD?#
As of 2026, you are only in scope of the CSRD if you are a large EU company with more than 1,000 employees and net turnover above €450 million. The Omnibus I directive, which entered into force on 18 March 2026, sharply narrowed the original scope, so many mid-sized companies and all listed SMEs that were previously caught are now out. Non-EU groups are caught separately if they generate more than €450 million turnover in the EU and have a qualifying EU subsidiary or branch. If you sit below these thresholds you may still report voluntarily, and large customers may still ask you for data.
Is CSRD being delayed or scrapped?#
CSRD has not been scrapped, but its scope and timeline were significantly cut back in 2026, which is the source of the confusion. The EU's Omnibus I package, in force from 18 March 2026, raised the size thresholds so that only companies with more than 1,000 employees and over €450 million turnover are in scope, removed listed SMEs, and delayed later reporting waves (the earlier 'stop-the-clock' directive of April 2025). So the framework is very much alive, but many mid-sized companies that expected to report no longer have to, and those that remain in scope have more time. If you are unsure, a quick gap analysis will confirm whether you are still caught (accurate as of 2026).
When is my first CSRD report due?#
Companies newly confirmed in scope under the 2026 Omnibus rules report for financial years beginning on or after 1 January 2027, with the first reports published in 2028 for calendar-year filers. So-called 'wave one' companies (500-plus employees) that had already begun reporting on financial year 2024 were given a transition exemption for 2025 and 2026 while the scope was being reset. The earlier 'stop-the-clock' directive of April 2025 delayed the later waves, and the Omnibus then removed most of those companies from scope entirely. Dates can still shift as member states transpose the directive, so confirm your national timeline (accurate as of 2026).
What is double materiality?#
Double materiality is the principle that you must report on sustainability topics that are financially material to your business and topics where your business has a material impact on people or the environment, even if that impact carries no direct financial consequence. It is the assessment that decides which ESRS topics and datapoints you actually have to disclose, so it sits at the front of any CSRD project. Double materiality was retained in the 2026 Omnibus reforms and remains the foundation of ESRS reporting. EcoLedger's CSRD Reporting Software runs the double materiality assessment and maps the outcome to every relevant ESRS datapoint, so your disclosure scope is defined by evidence rather than guesswork.
What is the difference between CSRD and ESRS?#
The CSRD is the EU law that requires companies to report sustainability information, while the ESRS are the detailed standards that set out exactly what to disclose. Put simply, the CSRD tells you that you must report and who is in scope, and the European Sustainability Reporting Standards tell you what data to publish and how. The CSRD is transposed into each member state's national law; the ESRS are common across the EU and are being revised and simplified to cut the number of mandatory datapoints. You comply with the CSRD by reporting in line with the ESRS.
What did the EU Omnibus package change about CSRD?#
The Omnibus I directive, finalised in February 2026 and in force from 18 March 2026, cut the number of companies in scope and eased the reporting burden. It raised the threshold to more than 1,000 employees and over €450 million turnover, removed listed SMEs entirely, and exempted earlier 'wave one' companies for 2025 and 2026. It also limits what large reporters can demand from smaller companies in their value chain and triggered a simplification of the ESRS themselves. Notably, the Parliament and Council chose not to amend the EU Taxonomy Regulation itself in the same package, so that framework was left legally unchanged (as of 2026).
Does a CSRD report need to be audited?#
Yes, CSRD sustainability information must be independently assured, and the requirement is limited assurance rather than the stricter reasonable assurance. The reforms kept limited assurance as the standard and dropped the earlier plan to escalate to reasonable assurance, with a dedicated limited assurance standard due to be adopted by 1 July 2027. In practice this means an external assurance provider checks that your disclosures are free from material misstatement, so your ESRS data needs a clear audit trail. Keeping evidence and calculations traceable from source to disclosure is what makes assurance manageable.
I supply a large company that reports under CSRD. Do I have to provide sustainability data?#
You may be asked, but the 2026 Omnibus introduced a value chain cap that protects smaller suppliers from open-ended demands. If you have fewer than 1,000 employees, a CSRD-reporting customer generally cannot require more than the information set out in the voluntary sustainability reporting standard for smaller companies (the VSME). This is designed to stop large reporters pushing their full ESRS data burden down the supply chain. You are not obliged to build a full CSRD report yourself, but having tidy, standardised figures ready makes responding to customers straightforward.
EU Taxonomy
EU Taxonomy Reporting Software →Which companies are in scope of the EU Taxonomy?#
Mandatory EU Taxonomy reporting applies to companies that are in scope of the CSRD, so after the 2026 Omnibus reforms that means EU companies with more than 1,000 employees and turnover above €450 million. Because Taxonomy scope follows CSRD scope, the same narrowing that removed many companies from CSRD also removed them from mandatory Taxonomy disclosure. Financial undertakings such as banks and asset managers have their own Taxonomy KPIs based on their portfolios. Companies below the threshold can choose to report on a voluntary basis (accurate as of 2026).
What is the EU Taxonomy?#
The EU Taxonomy is a classification system that defines which economic activities count as environmentally sustainable. It sets technical screening criteria across six environmental objectives, including climate change mitigation and adaptation, and an activity must make a substantial contribution to at least one objective while doing no significant harm to the others and meeting minimum social safeguards. Companies use it to report what proportion of their turnover, capital expenditure and operating expenditure is 'Taxonomy-aligned'. It exists to give investors a common, comparable measure of green economic activity and to reduce greenwashing.
What do I actually have to report under the EU Taxonomy?#
You report three headline KPIs: the share of your turnover, capital expenditure (CapEx) and operating expenditure (OpEx) that is Taxonomy-eligible and Taxonomy-aligned. For each you first identify eligible activities, then test them against the technical screening criteria, the do-no-significant-harm conditions and the minimum safeguards to determine alignment. The 2026 simplification reduced the number of mandatory datapoints substantially, but the core turnover, CapEx and OpEx disclosures remain. EcoLedger's EU Taxonomy Reporting Software runs the eligibility and alignment screening and produces the three KPIs with the underlying figures traceable to your accounts.
Did the Omnibus simplify EU Taxonomy reporting?#
Yes, an amending Delegated Act in force during 2026 cut the reporting burden significantly, even though the underlying Taxonomy Regulation was left unchanged. Non-financial companies may skip screening activities that represent less than 10% of turnover or CapEx, and may treat OpEx as non-material if it is immaterial to their business model, provided they disclose and justify this. The changes reduced mandatory datapoints by around 64% for non-financial undertakings and 89% for financial undertakings, and removed the separate detailed templates for non-aligned and fossil fuel activities. Financial undertakings that do not claim alignment can defer reporting until the end of 2027 (as of 2026).
What is the difference between Taxonomy-eligible and Taxonomy-aligned?#
'Eligible' means an activity is covered by the Taxonomy and has technical screening criteria defined for it, while 'aligned' means the activity actually meets those criteria and therefore counts as sustainable. An activity can be eligible but not aligned if it fails the substantial contribution test, causes significant harm to another objective, or breaches the minimum social safeguards. Eligibility is essentially a first filter; alignment is the outcome that matters for your green KPIs. You report both, because the gap between eligible and aligned tells investors how much of your in-scope activity genuinely qualifies.
Do I have to report EU Taxonomy if I'm below the CSRD threshold?#
No, if you fall below the CSRD thresholds you have no mandatory EU Taxonomy reporting obligation, because Taxonomy disclosure is tied to CSRD scope. Since the 2026 Omnibus raised the CSRD threshold to more than 1,000 employees and over €450 million turnover, many companies that would previously have reported are now outside the mandatory regime. You can still report voluntarily, which some companies do because lenders, investors and large customers ask for aligned CapEx or turnover figures. Voluntary reporting also lets you use the simplified 2026 rules rather than the full original framework (accurate as of 2026).
ISSB (IFRS S1 & S2)
ISSB (IFRS S1 & S2) Reporting Software →What is the ISSB?#
The ISSB (International Sustainability Standards Board) is the body that sets global baseline standards for company sustainability reporting, sitting alongside the IASB under the IFRS Foundation. It published its first two standards, IFRS S1 and IFRS S2, in June 2023. The aim is a single, comparable set of sustainability disclosures that investors can read the same way across markets, much as IFRS Accounting Standards did for financial reporting.
What is the difference between IFRS S1 and IFRS S2?#
IFRS S1 sets the general requirements for disclosing sustainability-related financial information, while IFRS S2 covers climate-related disclosures specifically. S1 asks you to report material risks and opportunities across any sustainability topic, using the same four pillars as the TCFD: governance, strategy, risk management, and metrics and targets. S2 applies those pillars to climate and requires disclosure of Scope 1, 2 and 3 greenhouse gas emissions.
Is ISSB reporting mandatory?#
ISSB standards are not mandatory by default; they only become compulsory when an individual jurisdiction adopts them into its own law or listing rules. IFRS S1 and S2 are a voluntary global baseline that regulators can require, encourage or adapt. As of 2026, more than 35 jurisdictions have adopted the standards or taken formal steps towards them, together representing a large majority of global GDP, but the specific obligations and start dates differ by country.
Which countries have adopted ISSB standards?#
As of 2026, jurisdictions that have adopted or are phasing in ISSB-aligned requirements include Australia, Singapore, Hong Kong, Malaysia, Brazil, Nigeria, Turkey and the UK, with Japan's SSBJ standards due to apply from around FY2027. Adoption is uneven: some markets mandate the full standards for large or listed entities, while others encourage voluntary use first. Because each jurisdiction sets its own scope and timing, companies operating internationally should check the rules in every market where they report.
How do ISSB standards relate to the TCFD?#
IFRS S2 builds directly on the TCFD (Task Force on Climate-related Financial Disclosures) framework and effectively supersedes it. The TCFD was disbanded in 2023 and the IFRS Foundation took over monitoring climate disclosures, with the ISSB standards carrying forward its four-pillar structure. Companies already reporting under the TCFD will find the transition to IFRS S2 familiar, though S2 goes further on emissions and industry-specific metrics.
What does ISSB reporting software do?#
ISSB reporting software helps companies collect, calculate and structure the disclosures required by IFRS S1 and S2, from governance narratives to Scope 1, 2 and 3 emissions figures. Good tools map your data to the standards' four pillars, apply recognised emission factors, and produce an audit-ready disclosure you can drop into your annual report. EcoLedger's ISSB (IFRS S1 & S2) Reporting Software is a self-serve annual licence built for teams preparing these disclosures without external consultants.
UK SRS (S1 & S2)
UK SRS S1 & S2 Reporting Software →What are the UK Sustainability Reporting Standards (UK SRS)?#
The UK SRS are the UK's own version of the ISSB's IFRS S1 and S2, setting out how companies should disclose sustainability and climate-related information. The final UK SRS S1 and S2 were published by the Department for Business and Trade on 25 February 2026, following an independent assessment of the international standards. They keep the ISSB baseline almost intact, with only a small number of UK-specific modifications.
Is UK SRS mandatory?#
As of August 2026, the UK SRS are not yet mandatory; they are available for voluntary use while the government and regulators consult on making them compulsory. The FCA is consulting (CP26/5) on requiring UK SRS S2 climate disclosures for listed companies from 2027, with Scope 3 emissions on a comply-or-explain basis from 2028 and wider sustainability disclosures from 2029. Separately, the government plans to consult during 2026 on Companies Act changes that could extend requirements to other large UK companies.
What is the difference between UK SRS and ISSB standards?#
UK SRS S1 and S2 are substantively the same as the ISSB's IFRS S1 and S2, with a handful of UK-specific tweaks made during endorsement. The main changes soften the reference to SASB standards from 'shall' to 'may' consider, remove certain fixed timeframes for transitional reliefs, and add rules on when relief-based exemptions can be claimed. In practice, a report prepared to UK SRS should be broadly interoperable with the global ISSB baseline.
Who will have to report under UK SRS?#
The likely first population is UK listed companies, if the FCA confirms its proposals to require UK SRS S2 disclosures from 2027. Beyond listed issuers, the government has signalled it will consult in 2026 on whether to mandate UK SRS for other large companies through the Companies Act, but the scope and thresholds are not yet decided. Until that legislation is settled, most private companies can adopt the standards voluntarily rather than being obliged to.
When do UK SRS reporting requirements start?#
No requirement is in force yet as of 2026, but the earliest proposed mandatory date is accounting periods beginning on or after 1 January 2027 for listed companies under the FCA's consultation. Under those proposals, Scope 3 emissions would move to comply-or-explain from 2028 and non-climate sustainability disclosures from 2029. Companies can report voluntarily against UK SRS now to build the systems and data trail ahead of any mandate.
How do I prepare a UK SRS report?#
Preparing a UK SRS report means gathering governance, strategy, risk and metrics information across S1, plus climate data and Scope 1, 2 and 3 emissions under S2, then structuring it to the standards. Because UK SRS closely mirrors the ISSB baseline, the same underlying data can serve both frameworks. EcoLedger's UK SRS S1 & S2 Reporting Software is a self-serve annual licence that guides UK companies through each disclosure and produces an audit-ready output.
UK SECR
UK SECR Software (Energy & Carbon Reporting) →What is SECR?#
SECR (Streamlined Energy and Carbon Reporting) is the UK framework that requires large companies and LLPs to disclose their energy use and carbon emissions in their annual reports. It has applied to financial years starting on or after 1 April 2019 and replaced the earlier CRC Energy Efficiency Scheme. The disclosures sit within the directors' report (or an equivalent energy and carbon report) and are filed at Companies House.
Who has to do SECR reporting?#
SECR applies to all UK quoted companies, plus large unquoted companies and large LLPs. An unquoted company or LLP is 'large' if it meets at least two of three tests: 250 or more employees, annual turnover of £36 million or more, and a balance sheet total of £18 million or more. Note that the April 2025 increase to Companies Act size thresholds did not change the SECR limits, so a business can be medium-sized for accounts purposes yet still fall within SECR.
What must a SECR report include?#
A SECR report must disclose UK energy consumption in kWh, associated Scope 1 and Scope 2 greenhouse gas emissions in tonnes of CO2e, and at least one intensity ratio, such as tonnes of CO2e per £million of turnover. You also need a narrative on energy efficiency measures taken during the year and a statement of the methodology used. Quoted companies report their global figures, while unquoted companies and LLPs report UK and offshore energy and emissions.
What emission factors are used for SECR?#
SECR reporting uses the UK Government greenhouse gas conversion factors, published annually by DESNZ (the Department for Energy Security and Net Zero, formerly BEIS and DEFRA). These factors convert activity data such as kWh of electricity or litres of fuel into tonnes of CO2e. You should apply the factor set that corresponds to your reporting year and state the methodology, typically the GHG Protocol, in your report.
What is the difference between SECR and ESOS?#
SECR is an annual disclosure requirement, whereas ESOS (the Energy Savings Opportunity Scheme) is a four-yearly energy audit obligation. Under SECR you publish energy and carbon figures in your annual report every year; under ESOS you must carry out a detailed assessment of energy use and identify savings opportunities, then notify the Environment Agency by each compliance deadline. Many organisations are caught by both, but they are separate schemes with different triggers and outputs.
Is there a low-energy exemption from SECR?#
Yes, organisations that consume 40 MWh or less of energy in the reporting period qualify as low energy users and are exempt from the detailed SECR disclosures. If you claim this exemption you must still state in your report that you are doing so. A small number of other narrow exemptions exist, such as where disclosure would be seriously prejudicial or the data is not practical to obtain, and each requires an explanatory statement. EcoLedger's UK SECR Software is a self-serve annual licence that calculates energy, Scope 1 and 2 emissions and your intensity ratio using the current DESNZ factors.
Carbon accounting / GHG Scope 1, 2 & 3
Carbon Accounting Software (Scope 1, 2 & 3) →What is the difference between Scope 1, 2 and 3 emissions?#
Scope 1 covers direct emissions from sources a company owns or controls, such as company vehicles, gas boilers and on-site fuel combustion. Scope 2 covers indirect emissions from the electricity, heat, steam or cooling the company purchases and uses. Scope 3 covers all other indirect emissions across the value chain, both upstream and downstream, including purchased goods and services, business travel, employee commuting and the use of sold products. The three-scope structure comes from the GHG Protocol Corporate Standard.
What is the GHG Protocol?#
The GHG Protocol is the most widely used global standard for measuring and reporting greenhouse gas emissions, developed by the World Resources Institute and the World Business Council for Sustainable Development. Its Corporate Standard defines the Scope 1, 2 and 3 framework that underpins schemes such as SECR and disclosure standards such as IFRS S2. Most carbon accounting and regulatory reporting in the UK is built on GHG Protocol methodology.
What is carbon accounting?#
Carbon accounting is the process of measuring, calculating and reporting an organisation's greenhouse gas emissions, usually expressed in tonnes of carbon dioxide equivalent (CO2e). It typically follows the GHG Protocol, breaking emissions into Scope 1, 2 and 3, and multiplies activity data such as fuel or electricity use by published emission factors. The result is a company carbon footprint that can be tracked over time, disclosed in reports, and used to set reduction targets.
What are Scope 3 emissions and why are they hard to measure?#
Scope 3 emissions are indirect emissions across a company's value chain that it does not own or control, split into 15 categories under the GHG Protocol. They are difficult to measure because the data sits with suppliers, customers and other third parties, so companies often rely on estimates, spend-based factors or supplier surveys rather than primary data. Scope 3 usually makes up the largest share of a company's total footprint, which is why disclosure standards increasingly focus on it.
What is the difference between location-based and market-based Scope 2?#
Location-based Scope 2 uses the average emissions intensity of the grid where electricity is consumed, while market-based Scope 2 reflects the specific electricity a company has chosen to buy, such as through renewable tariffs or power purchase agreements. The GHG Protocol Scope 2 Guidance asks companies to report both methods so that procurement choices are transparent. A business on a certified green tariff might show a low market-based figure but a higher location-based one.
How do you calculate a company's carbon footprint?#
You calculate a carbon footprint by collecting activity data for each emission source, multiplying it by the relevant emission factor, and summing the results across Scope 1, 2 and 3 to get total tonnes of CO2e. Activity data includes things like litres of fuel, kWh of electricity, business travel distances and purchased goods, while factors typically come from the DESNZ (UK Government) or comparable datasets. EcoLedger's Carbon Accounting Software for Scope 1, 2 and 3 is a self-serve annual licence that automates these calculations using recognised emission factors.
Australia ASRS / AASB S2
Australia ASRS / AASB S2 Software →What is AASB S2?#
AASB S2 is Australia's mandatory climate-related financial disclosure standard, issued by the Australian Accounting Standards Board and closely based on the ISSB's IFRS S2. It forms the core of the Australian Sustainability Reporting Standards (ASRS) and requires in-scope entities to disclose climate-related governance, strategy, risk management, and metrics and targets, including greenhouse gas emissions. Disclosures sit in a separate sustainability report lodged alongside the annual financial report and are subject to audit. It applies to financial years, with the first cohort reporting for periods beginning on or after 1 January 2025.
When are Australia's first climate reports due?#
Australia's largest entities (Group 1) must report under AASB S2 for financial years beginning on or after 1 January 2025, so the earliest reports are being lodged in 2026. Reporting then phases in: Group 2 from years beginning on or after 1 July 2026, and Group 3 from years beginning on or after 1 July 2027. The sustainability report is prepared for the same period as the financial report and lodged with ASIC. As of 2026, Group 1 is live and Group 2 entities should be preparing their first disclosures.
Who must report climate under AASB S2?#
Entities that already lodge financial reports under the Corporations Act and meet the size thresholds must report, phased across three groups. Group 1 captures entities meeting at least two of: consolidated revenue of AUD 500 million or more, consolidated gross assets of AUD 1 billion or more, or 500 or more employees (plus large NGER reporters). Group 2 lowers this to AUD 200 million revenue, AUD 500 million assets or 250 employees (and asset owners with AUD 5 billion or more under management), and Group 3 to AUD 50 million revenue, AUD 25 million assets or 100 employees. Group 3 entities only make full disclosures if they have material climate risks or opportunities; otherwise they lodge a statement to that effect.
Does AASB S2 require Scope 3 emissions?#
Yes, AASB S2 requires Scope 1, Scope 2 and Scope 3 greenhouse gas emissions, but Scope 3 is phased in. Entities are relieved from disclosing Scope 3 in their first year of reporting and must include it from the second annual reporting period onward. Scope 1 and 2 are required from year one. Managing this staged data collection is exactly what EcoLedger's Australia ASRS / AASB S2 Software is built for, keeping first-year and second-year requirements separated and audit-ready.
What is the directors' declaration under the ASRS regime?#
Directors must provide a formal declaration on the sustainability report, similar to the declaration on financial statements. In the early transitional years this is a declaration that the entity has taken reasonable steps to comply with the standards, before shifting to a declaration of compliance for later periods. The sustainability report is also subject to assurance, which phases up to reasonable assurance over time. This makes board-level ownership and a clear audit trail essential from the first reporting year.
Is there legal protection for early climate disclosures in Australia?#
Yes, a limited immunity or modified liability period applies to certain harder-to-verify disclosures during the transition. For a three-year window running to 30 June 2028, statements about Scope 3 emissions, scenario analysis, transition plans and other forward-looking climate information can generally only be the subject of action by ASIC, rather than private litigation. The relief is time-limited and does not cover all disclosures, so accurate underlying data still matters. As of 2026 this immunity remains in effect for eligible statements.
Hong Kong HKFRS S1 & S2
Hong Kong HKFRS S1 & S2 Software →What are HKFRS S1 and S2?#
HKFRS S1 and HKFRS S2 are Hong Kong's sustainability and climate disclosure standards, issued by the HKICPA and fully aligned with the ISSB's IFRS S1 and IFRS S2. HKFRS S1 covers general sustainability-related financial disclosures, while HKFRS S2 focuses specifically on climate, including governance, strategy, risk management, metrics and greenhouse gas emissions. They are designed to serve as the local implementation of the global ISSB baseline. Adoption is being phased in across listed and other publicly accountable entities under a government roadmap.
When does climate reporting become mandatory in Hong Kong?#
Climate reporting is phasing in through HKEX Listing Rules and the wider HKFRS roadmap. Under HKEX's enhanced climate requirements (Part D of Appendix C2), all Main Board issuers report on a comply-or-explain basis for financial years beginning on or after 1 January 2025, while Hang Seng Composite LargeCap Index constituents face mandatory reporting, including Scope 3, for years beginning on or after 1 January 2026. Scope 1 and Scope 2 disclosure is mandatory for Main Board issuers from 2025. As of 2026, LargeCap constituents are in their first mandatory year, with reports due in 2027.
Who must comply with HKFRS S2 in Hong Kong?#
The first mandatory cohort is Hang Seng Composite LargeCap Index constituents on HKEX's Main Board, who must report full climate disclosures from financial years beginning on or after 1 January 2026. Other Main Board issuers currently report on a comply-or-explain basis, and GEM issuers report voluntarily. Beyond listed companies, Hong Kong's roadmap extends full HKFRS S1 and S2 adoption to significant publicly accountable entities such as banks, insurers and large financial institutions. The scope therefore widens progressively rather than applying to all companies at once.
Does Hong Kong require Scope 3 emissions reporting?#
Yes, but on a phased basis tied to issuer size. Hang Seng Composite LargeCap constituents must disclose Scope 3 emissions as part of mandatory reporting for financial years beginning on or after 1 January 2026. Other Main Board issuers work up to Scope 3 through the comply-or-explain framework, supported by interim reliefs during the transition. Scope 1 and Scope 2 emissions, measured under the GHG Protocol, are the mandatory baseline for Main Board issuers from 2025. EcoLedger's Hong Kong HKFRS S1 & S2 Software helps issuers stage Scope 1, 2 and 3 data collection against these dates.
What is Hong Kong's roadmap for HKFRS S1 and S2?#
The Financial Services and the Treasury Bureau published a roadmap in December 2024 setting out a path to full HKFRS S1 and S2 adoption. It targets full adoption by publicly accountable entities, including listed issuers and major financial institutions, no later than 2028. HKEX is expected to consult on mandating the standards for listed issuers from financial years beginning 1 January 2028, with first mandatory reports around 2029. As of 2026 the roadmap remains the guiding framework, with HKEX's Part D requirements already in force for listed issuers.
What is the difference between HKEX Part D and HKFRS S1 and S2?#
HKEX Part D of Appendix C2 is the listing-rule mechanism that mandates climate disclosures for issuers, whereas HKFRS S1 and S2 are the underlying accounting standards those disclosures are built on. Part D is closely aligned with IFRS S2 and applies specifically to Main Board and GEM issuers through the Listing Rules, currently on a mix of mandatory and comply-or-explain bases. HKFRS S1 and S2 are broader and will eventually apply beyond listed companies under the FSTB roadmap. In practice, listed issuers meet Part D by preparing disclosures consistent with the HKFRS standards, which EcoLedger's software maps directly.
Singapore SGX Climate Reporting
Singapore SGX Climate Reporting Software →What is SGX climate reporting?#
SGX climate reporting is Singapore's mandatory climate-related disclosure regime for listed companies, based on the ISSB's IFRS S2 standard. Administered by SGX RegCo and ACRA, it requires issuers to disclose climate governance, strategy, risk management, and metrics including greenhouse gas emissions in their annual sustainability reporting. Singapore was an early adopter of the ISSB baseline, extending requirements over time to large non-listed companies as well. The disclosures are made on a financial-year basis and are progressively subject to external assurance.
Who must report climate under the SGX rules?#
All SGX-listed issuers must report climate-related disclosures aligned with ISSB standards, with the depth of requirements tiered by index membership and market capitalisation. Straits Times Index constituents lead, followed by other issuers with market capitalisation of S$1 billion or more, and then remaining issuers on later timelines. Large non-listed companies (NLCos) are also captured where they have annual revenue of at least S$1 billion and total assets of at least S$500 million. As of 2026, listed issuers are already reporting Scope 1 and 2 emissions, while NLCos have a later start date.
When are Singapore's climate reports due?#
SGX-listed issuers began reporting ISSB-aligned climate disclosures, including Scope 1 and 2 emissions, from financial year 2025. STI constituents add Scope 3 from FY2026, while broader ISSB disclosures phase in for other issuers around FY2028 and FY2030 depending on market capitalisation. Large non-listed companies are due to begin reporting from FY2030 following an extension announced in 2025. These timelines were revised by ACRA and SGX RegCo in August 2025 to give companies more preparation time.
Did Singapore delay its climate reporting timelines?#
Yes, ACRA and SGX RegCo announced extended timelines for most climate reporting and assurance requirements in August 2025. The most significant change deferred mandatory reporting for large non-listed companies to financial year 2030, from the previously planned FY2027, and pushed back several assurance deadlines. Listed issuers still began Scope 1 and 2 reporting from FY2025, so the core listed-company obligations were not delayed. The extensions were framed as support for companies building data and reporting capability rather than a rollback of the regime.
Is Scope 3 required under Singapore's climate rules?#
Scope 3 emissions reporting is mandatory only for the leading cohort of listed issuers and voluntary for others. Straits Times Index constituents must disclose Scope 3 from financial year 2026, while other listed issuers and large non-listed companies may report Scope 3 on a voluntary basis. Scope 1 and Scope 2 emissions are the mandatory baseline for listed issuers from FY2025. EcoLedger's Singapore SGX Climate Reporting Software helps issuers manage the phased move from Scope 1 and 2 into full Scope 3 inventories.
Is external assurance required for SGX climate reports?#
Yes, external limited assurance is being phased in rather than required immediately. For SGX-listed issuers, external limited assurance over Scope 1 and 2 greenhouse gas emissions is required from financial year 2029, following the extended timelines set in 2025. Large non-listed companies face assurance requirements from FY2032. As of 2026, assurance is not yet mandatory, so issuers have a window to strengthen data quality and controls before independent verification begins.
California SB 253 & SB 261
California SB 253 & SB 261 Climate Software →| SB 253 | SB 261 | |
|---|---|---|
| Covers | GHG emissions (Scope 1, 2 & 3) | Climate-related financial risk |
| Revenue threshold | > US$1 billion | > US$500 million |
| Based on | GHG Protocol | TCFD / IFRS S2 |
| Frequency | Annual | Biennial |
| Max penalty / yr | US$500,000 | US$50,000 |
Who has to comply with California SB 253?#
SB 253 (the Climate Corporate Data Accountability Act) applies to any US-formed company doing business in California with total annual revenue above 1 billion US dollars. It covers both public and private companies and is based on total global revenue, not just California revenue, so the threshold captures large out-of-state and foreign-parent groups with California operations. Covered entities must report Scope 1, Scope 2 and, from 2027, Scope 3 greenhouse gas emissions using the GHG Protocol. The California Air Resources Board (CARB) estimates that roughly 5,000 companies fall within scope.
What is the difference between SB 253 and SB 261?#
SB 253 covers greenhouse gas emissions disclosure, while SB 261 covers climate-related financial risk. SB 253 requires companies with over 1 billion US dollars in revenue to report Scope 1, 2 and 3 emissions with third-party assurance, whereas SB 261 requires companies with over 500 million US dollars in revenue to publish a biennial report on climate-related financial risks and mitigation measures, aligned with the TCFD framework (or IFRS S2 as its successor). The two laws have different revenue thresholds and different subject matter, so many companies are caught by both. Both apply to companies doing business in California regardless of where they are headquartered.
When is the first California climate report due?#
The first SB 253 Scope 1 and 2 emissions reports are due in 2026, covering fiscal year 2025 data, with Scope 3 emissions phased in from 2027. As of 2026 CARB is finalising the reporting mechanism and has signalled a good-faith enforcement approach for the initial cycle, meaning companies must report on the basis of information reasonably available. SB 261 climate-risk reports were originally due by 1 January 2026, but enforcement is currently paused pending litigation. Limited assurance for SB 253 is expected to begin with 2027 filings. EcoLedger's California SB 253 & SB 261 Climate Software helps in-scope companies compile GHG inventories and climate-risk reports against the current CARB timeline.
Is SB 261 still in force given the legal challenges?#
SB 261 remains on the statute books, but as of 2026 the courts have narrowed enforcement while a First Amendment challenge is heard. The case, brought by the US Chamber of Commerce and others against CARB, argues the disclosure mandates unlawfully compel speech; the courts have so far allowed the laws to stand in principle while limiting enforcement in the interim. Importantly, the challenge centres on SB 261, and CARB has indicated it will confirm a revised deadline once the position is resolved. Companies are generally advised to prepare their climate-risk disclosures now rather than wait, given the uncertainty is over timing, not the underlying obligation.
Do UK and other non-US companies have to comply with California SB 253?#
Yes, a UK or other non-US company can be caught by SB 253 if it does business in California and its total annual revenue exceeds 1 billion US dollars. The law tests global consolidated revenue and a California nexus, not the place of incorporation, so foreign parent groups with US subsidiaries, sales or operations in California can be in scope. Group structure matters, because revenue is typically assessed at the ultimate parent level while the 'doing business' test looks at California activity. Non-US groups should map which legal entities trigger the nexus before assuming they are exempt.
What are the penalties for non-compliance with California SB 253?#
SB 253 allows CARB to impose penalties of up to 500,000 US dollars per reporting year for violations such as non-filing. For the initial reporting cycle CARB has indicated penalties will focus on non-filing rather than on good-faith errors in emissions estimates, particularly for Scope 3. SB 261 carries separate penalties of up to 50,000 US dollars per reporting year. Enforcement discretion and the ongoing litigation mean the practical penalty exposure in 2026 is lower than the statutory maximums, but the obligations themselves remain.
Canada CSDS 1 & 2
Canada CSDS 1 & 2 Software →Is Canada's CSDS mandatory?#
No, the Canadian Sustainability Disclosure Standards (CSDS 1 and CSDS 2) are voluntary as of 2026. They were issued by the Canadian Sustainability Standards Board (CSSB) in December 2024 and take effect for annual periods beginning on or after 1 January 2025, but they only become mandatory if and when a regulator adopts them. In April 2025 the Canadian Securities Administrators (CSA) paused its work on a mandatory climate disclosure rule, so there is currently no securities-law requirement to apply CSDS. Many larger Canadian issuers are nonetheless adopting them voluntarily to prepare for likely future mandates and to meet investor expectations.
What are CSDS 1 and CSDS 2?#
CSDS 1 sets out general requirements for disclosing sustainability-related financial information, and CSDS 2 covers climate-related disclosures specifically. Together they form Canada's national sustainability reporting framework, published by the CSSB and modelled closely on the ISSB's IFRS S1 and S2. CSDS 1 addresses governance, strategy, risk management and metrics across sustainability topics, while CSDS 2 focuses on climate risks and opportunities, including greenhouse gas emissions. The standards are designed for capital-markets reporting and are intended to give investors decision-useful, comparable information.
How do Canada's CSDS standards relate to ISSB IFRS S1 and S2?#
CSDS 1 and CSDS 2 are based directly on the ISSB's IFRS S1 and IFRS S2, with Canadian-specific adjustments rather than wholesale changes. The core disclosure architecture is the same, so a report prepared under CSDS is broadly aligned with a global ISSB baseline. The main differences are in timing and transition relief: the CSSB built in more generous relief periods suited to the Canadian market. This alignment means companies reporting under CSDS can generally satisfy investors and counterparties expecting ISSB-style disclosures.
What transition reliefs apply under CSDS?#
The CSSB provides extended transition relief that goes beyond the ISSB's own reliefs. In the first year, entities may report on climate only before expanding to other sustainability topics, with relief of up to two years on broader topics. Scope 3 greenhouse gas emissions and comparative-period information also benefit from relief in the early reporting years, and there is relief on quantitative scenario analysis. These provisions are intended to ease first-time adoption; because the standards are voluntary as of 2026, companies can also phase in disclosures at their own pace.
Should Canadian companies report under CSDS now if it is voluntary?#
Many do, because voluntary early adoption reduces the scramble when disclosure becomes mandatory and meets rising demands from investors, lenders and global customers. Companies with international parents or subsidiaries already reporting under ISSB, or those in supply chains subject to mandatory regimes elsewhere, often find CSDS reporting is effectively required in practice even where Canadian law does not compel it. Building the data systems and governance now also spreads the cost and improves data quality over time. EcoLedger's Canada CSDS 1 & 2 Software lets companies structure disclosures against the CSSB standards and reuse the same data for ISSB-aligned reporting.
Qatar QFMA / QFCRA ISSB (IFRS S1 & S2)
Qatar QFMA / QFCRA ISSB (IFRS S1 & S2) Software →Does Qatar require ISSB (IFRS S1 and S2) reporting?#
Yes, Qatar is adopting the ISSB standards (IFRS S1 and IFRS S2) for sustainability and climate disclosure, with the requirement landing first on regulated financial entities. As of 2026, Qatar Central Bank (QCB)-regulated banks and insurers and Qatar Financial Centre entities regulated by the QFCRA are expected to report under IFRS S1/S2, with effect from 1 January 2026 and first reports following in the year. Listed companies on the Qatar Stock Exchange operate under the QFMA governance framework and QSE ESG guidance, which is moving towards ISSB alignment. The overall direction across Qatar's regulators is convergence on the ISSB baseline.
Who must comply with Qatar's IFRS S1 and S2 requirements?#
The clearest mandatory obligations fall on financial-sector entities: banks and insurers supervised by the Qatar Central Bank, and firms regulated by the Qatar Financial Centre Regulatory Authority (QFCRA) within the QFC. These entities are expected to apply IFRS S1 and S2 from 1 January 2026. Listed companies regulated by the Qatar Financial Markets Authority (QFMA) and the Qatar Stock Exchange face ESG disclosure expectations that are currently guidance-led and progressively aligning with ISSB. Companies should confirm which regulator supervises them, as the timeline and force of the obligation differ between the QFC and mainland Qatar.
What is the difference between QFMA and QFCRA sustainability requirements?#
QFMA and the QFCRA are different regulators covering different jurisdictions within Qatar. The QFMA (Qatar Financial Markets Authority) oversees securities markets and listed companies, where ESG and sustainability disclosure has been driven by the QSE's ESG reporting guidance and the corporate governance code, moving towards ISSB alignment. The QFCRA (Qatar Financial Centre Regulatory Authority) regulates firms operating within the Qatar Financial Centre, a separate legal and regulatory zone, and is applying IFRS S1/S2-based requirements to its regulated entities. A company's obligations therefore depend on whether it is a QSE-listed company, a QFC-based firm, or a QCB-supervised bank or insurer.
When do Qatar's ISSB-based rules take effect?#
The core effective date for financial-sector entities is 1 January 2026, with first IFRS S1/S2-based reports due during 2026. This applies to QCB-regulated banks and insurers and to QFCRA-regulated firms in the Qatar Financial Centre. Requirements for QSE-listed companies under QFMA oversight are being phased in through ESG guidance rather than a single hard deadline, and are expected to tighten as Qatar aligns further with the ISSB. Because dates and scope are still developing, companies should treat 2026 as the starting point and confirm current status with their regulator.
How should Qatari companies prepare for IFRS S1 and S2 reporting?#
Start by confirming which regulator applies, then build a greenhouse gas inventory and a climate risk and governance process aligned with IFRS S2, alongside the broader sustainability disclosures required by IFRS S1. Early data collection matters, because IFRS S2 requires Scope 1, 2 and eventually Scope 3 emissions plus scenario-based climate risk analysis, which take time to establish. Aligning with the global ISSB baseline also positions Qatari entities for cross-border investor and lender expectations. EcoLedger's Qatar QFMA / QFCRA ISSB Software helps entities assemble IFRS S1 and S2 disclosures and manage the underlying emissions and risk data.
UAE (SCA, ADX/DFM listed-company ESG)
UAE SCA GRI ADX/DFM Software →Do UAE listed companies have to publish ESG reports?#
Yes, companies listed on the Abu Dhabi Securities Exchange (ADX) and the Dubai Financial Market (DFM) are required to publish an annual sustainability report under the Securities and Commodities Authority (SCA) governance framework. The obligation stems from the SCA Corporate Governance Guide (Chairman of the Board Decision No. 3/R.M of 2020) and operates on a comply-or-explain basis. Both ADX and DFM have issued their own ESG disclosure guidance to support listed issuers. This makes annual ESG reporting a standing requirement for UAE-listed companies, not a voluntary exercise.
Which ESG reporting standard do UAE listed companies use?#
UAE listed companies primarily report against the Global Reporting Initiative (GRI) framework, supported by the ADX and DFM ESG disclosure guides, which also reference SASB and TCFD. The exchanges' guidance sets out a menu of core ESG metrics spanning environmental, social and governance topics that issuers are expected to disclose. As of 2026 the direction of travel is towards ISSB alignment (IFRS S1 and S2), but GRI-based disclosure remains the working baseline for most listed companies. Reports are typically published annually alongside or shortly after the financial statements.
What does SCA Decision 3/R.M of 2020 require?#
SCA Decision No. 3/R.M of 2020 (the Corporate Governance Guide for public joint-stock companies) requires listed companies to prepare and publish an annual sustainability report on a comply-or-explain basis. Companies that do not report must explain why, which in practice pushes most listed issuers to disclose. The report is expected to address material environmental, social and governance matters relevant to the company and its stakeholders. It sits alongside the exchange-level ESG disclosure guidance from ADX and DFM, which provide the detailed metrics.
When are UAE sustainability reports due?#
Sustainability reports for SCA-regulated listed companies are generally due on an annual basis, published within 90 days of the financial year-end or before the annual general meeting, whichever comes first. This aligns the ESG report closely with the annual reporting cycle. Companies with a December year-end therefore typically publish in the first quarter of the following year. Because deadlines and expectations are tightening, issuers should confirm the current filing window with their exchange each year.
Is the UAE moving towards ISSB IFRS S1 and S2?#
Yes, the UAE is progressively aligning with the ISSB standards, though GRI-based disclosure remains the current baseline for SCA-regulated listed companies as of 2026. Regulators and exchanges have signalled increasing harmonisation with international standards, and financial-sector rules from the Central Bank of the UAE are moving towards IFRS S1/S2-style climate and sustainability disclosure. Listed companies are advised to build data systems that can support both GRI reporting today and ISSB-aligned reporting as expectations evolve. EcoLedger's UAE SCA GRI ADX/DFM Software helps listed companies prepare GRI-based sustainability reports while keeping their data ready for an ISSB transition.
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