Authors: Ranjani Thirugnanasambandan, Sam Howley, Ying (Paris) Mo, Carli Schoenleber, Chika Acholonu, and Dana Weiss
December 16, 2024
Table of Contents
Highlights
As of 2024, the IFRS Foundation, which oversees the IFRS Sustainability Disclosure Standards, has assumed responsibility from TCFD for setting global standards for climate-related financial disclosures. No further updates to the TCFD recommendations are planned.[1]
For annual reporting periods beginning on or after January 1, 2024, companies currently reporting voluntarily to TCFD are expected to transition to the IFRS Sustainability Disclosure Standards, including IFRS S1 (General Requirements for Disclosure of Sustainability-Related Financial Information) and IFRS S2 (Climate-Related Disclosures).
IFRS S2 integrates and expands upon TCFD's recommendations by requiring additional disclosures on climate-related risks and opportunities, including specific industry-based metrics and requirements for reporting Scope 3 greenhouse gas (GHG) emissions. The “Real Estate” industry has 18 industry-based disclosures (see S2 Industry-Based Guidance, pg. 292).
The IFRS Sustainability Disclosure Standards only become mandatory for companies when adopted by the jurisdictions in which they operate. The standards have already been mandated in Brazil and Turkey and are expected to see further global adoption, notably in the United Kingdom and across the Asia-Pacific region, including in countries like Singapore and Australia.[2]
Introduction to TCFD and IFRS
The TCFD recommendations and IFRS Sustainability Disclosure Standards are two key frameworks that guide companies in transparently disclosing climate-related financial information.
What is TCFD?
Established in 2015, TCFD aimed to enhance climate-related disclosures from corporations. It provided a framework for publicly disclosing climate-related risks and opportunities across four categories: governance, strategy, risk management, and metrics and targets. TCFD's recommendations gained widespread adoption, particularly in the buildings sector.[3] According to the TCFD 2023 Status Report, which reviewed data up to 2022, 58% of companies aligned with at least five of the 11 TCFD recommendations when disclosing climate information, a sharp increase from 18% in 2020. Additionally, by 2022, 80% of the largest asset managers had aligned their reporting with TCFD.[4]
Several countries also mandated its use in the past five years, including the United Kingdom, Singapore, Brazil, and Canada.[5] Moreover, the U.S. and EU introduced their own mandatory climate-related reporting frameworks — the U.S. Securities and Exchange Commission (SEC) Climate-Related Reporting Rules (2024) and EU Corporate Sustainability Reporting Directive (CSRD) (2022) — both of which reflect TCFD’s four categories.[2]
As of 2024, the IFRS Foundation took over responsibility for overseeing corporate climate-related disclosures, marking the culmination of TCFD’s work.[6]
What are the IFRS Sustainability Disclosure Standards?
The IFRS Sustainability Disclosure Standards were finalized by the International Sustainability Standards Board (ISSB) in June 2023. ISSB is a standard-setting board within the IFRS Foundation. The IFRS Sustainability Disclosure Standards include IFRS S1: General Requirements and IFRS S2: Climate-Related Disclosures. The standards provide guidelines for organizations to disclose sustainability and climate-related risks and opportunities in a manner that is consistent, standardized, and beneficial to investors.[7]
The IFRS Sustainability Disclosure Standards are not to be confused with the IFRS Accounting Standards, which were originally developed in 2001 by another board within the IFRS Foundation, the International Accounting Standards Board (IASB). Use of the IFRS Accounting Standards is currently required in over 140 jurisdictions globally.[8] Akin to the IFRS Accounting Standards for financial disclosures, a key hallmark of the IFRS Sustainability Disclosure Standards is their intended role as a global baseline for sustainability financial disclosures, helping to reduce market confusion by providing a unified framework for all companies.[7]
Upon the release of the standards in 2023, the International Organization of Securities Commissions (IOSCO) endorsed them after a thorough review. IOSCO found that the standards provide a solid global framework for integrating sustainability-related financial information into capital markets, helping investors to assess risks and opportunities more effectively. Furthermore, IOSCO urged its 130 member jurisdictions, which regulate over 95% of the world’s financial markets, to consider adopting or integrating the ISSB Standards within their regulatory frameworks.[9]
According to the IFRS Foundation, jurisdictions representing 55% of global gross domestic product (GDP) have announced steps to adopt or align their sustainability disclosure standards with the IFRS Sustainability Disclosure Standards.[10] The standards are currently mandated in countries including Brazil, Turkey, and Bangladesh, with plans for mandatory adoption in the United Kingdom, Australia, and Singapore. Canada is considering their adoption on a voluntary basis.[2]
The IFRS Sustainability Disclosure Standards consolidate frameworks such as the Sustainability Accounting Standards Board (SASB) Standards, the Integrated Reporting Framework, and the Climate Disclosures Standards Board (CDSB) Framework, while also fully integrating the TCFD recommendations and aligning with the Global Reporting Initiative (GRI) Standards (see Figure 1).[11]
Figure 1. IFRS Sustainability Disclosure Standards: The 2021–2024 Transition from Fragmentation to Global Alignment in Sustainability-Related Financial Reporting
Transitioning from TCFD to IFRS
For reporting periods beginning on or after January 1, 2024, companies that voluntarily report climate-related financial information are expected to transition away from the TCFD recommendations and align with the IFRS Sustainability Disclosure Standards.
The ISSB explicitly based its climate-related disclosures standard (IFRS S2) on the recommendations of TCFD. Although the IFRS Foundation does not plan to provide further updates to the TCFD recommendations, they will continue to be available as a resource for companies preparing to comply with IFRS Sustainability Disclosure Standards.[12]
In this article
As we delve deeper into this article, we will explore the new requirements introduced by the ISSB, explain the key differences between the TCFD recommendations and IFRS Sustainability Disclosure Standards, and provide strategic guidance on how organizations can smoothly transition from TCFD to IFRS. This article aims to equip organizations to effectively navigate this transition and continue to provide transparent, meaningful, and investor-friendly climate-related financial disclosures.
IFRS S1: General Requirements
IFRS S1 (see PDF) is designed to be applied alongside other IFRS standards like IFRS S2 (Climate-Related Disclosures). IFRS S1 covers:
Requirements on disclosing sustainability risks and opportunities: Ensuring the comprehensive disclosure of sustainability-related risks and opportunities that could reasonably impact an entity's cash flows, access to finance, or cost of capital over the short, medium, or long term.
Guidelines for reporting sustainability-related financial disclosures: Specifying how and where sustainability-related financial information should be reported.[13]
What to report: Sustainability risks and opportunities
According to IFRS S1, companies are required to disclose information about their sustainability-related risks and opportunities across four core content areas, consistent with the four core TCFD categories — governance, strategy, risk management, and metrics and targets.
IFRS S1 mandates that a company disclose material information about the impact of sustainability-related risks and opportunities on the company’s business model and value chain, including all interactions, resources, and relationships connected to their business model and external environment. In contrast, the TCFD recommendations did not recommend assessing the value chain for climate-related risks and opportunities.
When evaluating the sustainability-related risks and opportunities with IFRS S1, the IFRS Foundation requires the use of SASB Standards for industry-specific reporting guidance when looking at any topics beyond climate (for which companies should use IFRS S2).[14] Per Figure 1 above, SASB was consolidated with Integrated Reporting into the Value Reporting Foundation (VRF) in 2021, and VRF was consolidated into the IFRS Foundation in 2022.[15]
How to report: Conceptual foundations
S1 establishes four conceptual foundations which outline the fundamental qualitative characteristics of useful sustainability-related financial information:
Foundation 1: Fair presentation
IFRS S1 requires that a full set of sustainability-related financial disclosures fairly presents all relevant risks and opportunities that could impact a company’s prospects. This involves providing a complete, neutral, and accurate depiction of these risks and opportunities.
Foundation 2: Materiality
IFRS S1 aims to provide investors with essential information by requiring companies to disclose significant sustainability-related risks and opportunities that could impact their prospects, using a definition of material information consistent with the IFRS Accounting Standards:
“…information is material if omitting, misstating or obscuring that information could reasonably be expected to influence decisions that primary users of general-purpose financial reports make on the basis of those reports…”
(pg. 8 of S1)
Foundation 3: Reporting entity
IFRS S1 mandates that the entity reporting sustainability-related financial disclosures be the same as the entity reporting financial statements. For instance, a parent company that presents consolidated financial statements must also include sustainability disclosures for itself and its subsidiaries.
Foundation 4: Connected information
IFRS S1 requires companies to provide information that helps investors understand the connections between various sustainability-related risks and opportunities and how these connect to governance, strategy, risk management, and metrics and targets. It also mandates consistency between sustainability-related financial disclosures and financial statements, ensuring that data and assumptions used in both are aligned whenever possible.
What to report: General requirements
S1 establishes five general corporate disclosure requirements as specified below:
Table 1. IFRS S1 Five General Corporate Disclosures
What to report: Judgments, uncertainties, and errors
When applying S1, companies must also explain significant judgments made in disclosure preparation, disclose the most significant uncertainties affecting the amounts reported, and restate comparative information relating to previously reported errors.
IFRS S2: Climate-Related Disclosures
The objective of IFRS S2 (see PDF) is to ensure that entities disclose information about climate-related risks and opportunities in a standardized manner that is valuable to users of general-purpose financial reports.
Specifically, it requires the disclosure of climate-related risks and opportunities that could reasonably be expected to impact the entity’s cash flows, access to finance, or cost of capital over the short, medium, or long term — factors collectively referred to as "climate-related risks and opportunities that could reasonably be expected to affect the entity’s prospects."[16]
IFRS S2: Required disclosures
Climate-related risks to which the entity is exposed, including:
Climate-related physical risks: financial and operational impacts on an entity caused by acute events, like storms or wildfires, and chronic shifts in climate patterns, such as rising temperatures and water scarcity.
Climate-related transition risks: financial and operational risks arising from the shift to a low-carbon economy, including regulatory changes, technological advances, and market shifts.
Climate-related opportunities available to the entity: the potential benefits for an entity from actions taken to mitigate or adapt to climate change.
TCFD alignment
The IFRS S2 Climate-Related Disclosures requirements are broadly consistent with the four categories (governance, strategy, risk management, and metrics and targets) and 11 recommended disclosures of TCFD.
IFRS S2 requires that entities provide information that helps users of general-purpose financial reports understand the following:
The governance processes, controls, and methods employed to supervise, regulate, and manage climate-related risks and opportunities
The organization's strategy for managing climate-related risks and opportunities
The methods used to identify, evaluate, rank, and track climate-related risks and opportunities, including their incorporation into the broader risk management process
The organization’s performance in managing climate-related risks and opportunities, including its progress towards meeting climate-related metrics and targets established by the organization or mandated by legal or regulatory requirements[15]
Comparing TCFD and IFRS S2 requirements
While IFRS S2 integrates the TCFD recommendations, the requirements of IFRS S2 are more comprehensive and stringent. The overarching differences can be summarized as follows:
TCFD’s framework consisted of recommended disclosures, whereas IFRS S2 outlines requirements designed for adoption and enforcement by jurisdictions globally.
There are 11 TCFD recommendations. IFRS S2 includes 37 standard requirements and 5–20 industry-based disclosures per industry. For instance, the “Real Estate” industry has 18 industry-based disclosures (see S2 Industry-Based Guidance, pg. 292).[17]
The TCFD recommendations did not specifically mandate the use of quantitative disclosures, while IFRS S2 delineates when quantitative and/or qualitative disclosures are required.
TCFD did not govern or restrict the use of terms such as “in alignment with TCFD,” “TCFD-aligned,” or “TCFD-compliant.” IFRS explicitly limits the use of “complying with IFRS Sustainability Disclosure Standards” to entities that comply with all the requirements of the IFRS Sustainability Disclosure Standards.
The IRFS Foundation released Comparison, IFRS S2 Climate-Related Disclosures with TCFD Recommendations in July 2023 (updated in November 2024), highlighting two main categories of differences:
Additional requirements in IFRS S2 that are not in the TCFD recommendations (highlighted as red bolded text in the July 2023 comparison document)
IFRS S2 disclosures that require additional specificity, but are otherwise in line with the TCFD recommendations (highlighted as black bolded text in the July 2023 comparison document)
The table below focuses only on the additional requirements (number 1 above). As such, Governance disclosures from IFRS S2 have been excluded from this table, as they closely follow the TCFD recommendations. The first two columns below feature original quotes from the comparison document, while the third column provides additional details sourced from the IFRS S2 standard. For more information on both additional disclosure requirements as well as additional specificity requirements please refer to IFRS S2 and the full comparison document.
Table 2. TCFD vs. IFRS S2 Climate-Related Disclosures: Key Differences and Additional Requirements
[1] The Sectoral Decarbonization Approach (SDA) is a science-based method developed to help companies set their GHG emissions reduction targets in line with the Paris Agreement’s goal to limit global temperature increase to well below 2°C above pre-industrial levels (Science Based Targets initiative).
Guidance for Reporting Entities
Reporting timeline (see IFRS S1)
The IFRS Sustainability Disclosure Standards (S1 and S2) are in effect for reporting periods starting on or after January 1, 2024. An entity must report its sustainability-related financial disclosures at the same time as its related financial statements. The entity’s sustainability-related financial disclosures must cover the same reporting period as the related financial statements.
Sustainability-related financial disclosures can be prepared for a 12-month period or for a 52-week period for practical reasons. When the covered period is longer or shorter than the acceptable two options, companies should include the following in their sustainability-related financial disclosures:
the period covered
the reason for doing so
the fact that the amounts disclosed are not entirely comparable
If an entity receives information about conditions that existed at the end of the reporting period before the sustainability disclosures are authorized, it must update related disclosures accordingly.
An entity must disclose conditions that occur after the end of the reporting period, but before the date on which the sustainability-related financial disclosures are authorized for issue, if omitting this information could influence decisions made by primary users of the financial reports.
If an entity is required to publish interim sustainability-related financial disclosures in accordance with the IFRS Sustainability Disclosure Standards, it may include a complete set of sustainability-related financial disclosures as specified in IFRS S1.
Location of disclosures (see IFRS S1)
An entity must provide disclosures required by IFRS Sustainability Disclosure Standards as part of its general-purpose financial reports.
Sustainability-related financial disclosures must be clearly identifiable and not obscured by additional information, whether in standalone reports or as part of other documents.
Sustainability-related financial disclosures could be included in (1) an entity’s management commentary (also known by names such as “management report,” “management’s discussion and analysis,” “operating and financial review,” “integrated report” or “strategic report”), (2) a similar report when it forms part of an entity’s general-purpose financial reports, (3) in the same location as information disclosed to meet other requirements, or (4) by cross-reference to another report published by the entity.
An entity may disclose information required by an IFRS Sustainability Disclosure Standard in the same location as information disclosed to meet other requirements, such as information required by regulators.
In September 2024, the IFRS Foundation released Voluntarily applying ISSB Standards – A guide for preparers, which helps companies navigate voluntary compliance with the IFRS Sustainability Disclosure Standards.
Transition reliefs
Both IFRS S1 and IFRS S2 specify transition reliefs that allow for a phased application of the standards while still maintaining compliance:
Climate-first reporting: In the first annual reporting period applying IFRS, companies can disclose only climate-related risks and opportunities (under IFRS S2). They are not required to disclose other sustainability-related risks and opportunities until the second year.
Timing of reporting: In the first annual reporting period, companies can delay the sustainability-related disclosures to coincide with half-year reports after publishing their main financial statements.
Comparative disclosures: Companies are not required to provide comparative information on sustainability-related risks, including climate-related risks, until the second year of disclosure.
Proportionality mechanisms
Available indefinitely, the proportionality mechanisms in IFRS S1 and IFRS S2 are designed to help companies balance their current readiness with the need for transparency to investors. These mechanisms allow companies to provide "reasonable and supportable" information at the time of reporting, without incurring “undue cost or effort.” Additionally, they enable companies to apply qualitative approaches (instead of quantitative) when they lack the necessary skills, resources, or capabilities to comply with full disclosure requirements.
The list of proportionality mechanisms below can be applied while still being able to make a statement of compliance, detailing which disclosures can be limited to what is “reasonable and supportable” (Items 1–6) and which disclosures allow qualitative approaches (Items 1–2):
Determination of financial effects (qualitative approaches allowed)
Climate scenario analysis (qualitative approaches allowed)
Measurement of Scope 3 emissions
Identification of risks and opportunities
Scope of the value chain
Calculation of cross-industry metrics [19]
Integration with other ESG reporting frameworks
GRESB
GRESB recognizes that IFRS S1 and S2 will supersede the TCFD recommendations in the near future. By integrating climate-related opportunities into its indicators, the GRESB standards will align more closely with IFRS. Future reviews will focus on further aligning the GRESB standards with IFRS, moving beyond TCFD.[20]
CDP
In 2022, CDP announced plans to incorporate IFRS S2 into its global environmental disclosure platform. As of 2024, CDP’s Corporate Questionnaire is aligned with IFRS S2 and TCFD.[21]
Global Reporting Initiative (GRI)
In January 2024, GRI published a report highlighting how GRI 305: Emissions 2016 and IFRS S2 can work together, particularly in relation to the GHG Protocol, including the disclosure of Scope 1, 2, and 3 GHG emissions. Companies already using the GRI Standards to disclose these emissions will be well-positioned to align with IFRS S2 requirements.[22]
Sustainability Accounting Standards Board (SASB)
As of August 2022, the ISSB assumed responsibility for the SASB Standards and used them to develop industry-based disclosure requirements for IFRS S2. In June 2023, the climate-related content in the SASB Standards was amended to align with the climate-related topics and metrics in IFRS S2.[23]
Frequently Asked Questions
Are the IFRS Sustainability Disclosure Standards mandatory?
On their own, the IFRS Sustainability Disclosure Standards are not mandatory. However, the standards were designed for jurisdictions everywhere to adopt as a unified global baseline for regulation-mandated sustainability-related financial disclosures. The standards are already required in several countries and are expected to be adopted in others, including the United Kingdom, Australia, and Singapore. Furthermore, key stakeholders (i.e. investors, lenders, industry organizations) may adopt the IFRS Sustainability Disclosure Standards as requirements of engagement.
Therefore, the standards only become mandatory for companies when adopted by the jurisdictions in which they operate, their financiers, or organizations in which they wish to maintain membership.
When do I need to switch from the TCFD recommendations to the IFRS Sustainability Disclosure Standards for voluntary reporting?
For companies voluntarily complying with IFRS, the standards are effective for reporting periods beginning on or after January 1, 2024. To ensure compliance, sustainability and climate reporting according to IFRS should be conducted alongside your company’s financial reporting.
While the work of TCFD has concluded, companies can still use the TCFD recommendations. However, it is anticipated that companies will soon face investor pressure to transition from TCFD to IFRS for voluntary climate-related financial reporting.[24]
How is aligning with TCFD different from aligning with IFRS?
Stating that your annual ESG report or climate program is "TCFD-aligned" refers to alignment with voluntary recommendations, while "IFRS-aligned" indicates compliance with stricter standards that require more detailed disclosures, including quantitative data and industry-specific metrics. Unlike TCFD, which allows flexibility in describing alignment (e.g., companies could align with only some of the TCFD recommendations and still claim alignment), a company cannot claim it has complied with the IFRS Sustainability Disclosure Standards unless it has met all requirements, ensuring greater accountability and consistency in reporting (see “Statement of compliance” in IFRS S1).
By fully complying with the IFRS Sustainability Disclosure Standards, companies will automatically be in alignment with all TCFD recommendations.
When should we start developing disclosures per the IFRS Sustainability Disclosure Standards?
Given the complexity and detailed nature of the standards’ requirements, it is advisable to start developing compliant disclosures as soon as possible. Companies that wait until a jurisdiction or third party imposes a deadline to disclose per IFRS will likely struggle to do so in time. The increased rigor of the IFRS Sustainability Disclosure Standards will necessitate additional data collection, risk assessments, and financial analysis. As such, the process to fully develop compliant disclosures will be elongated, requiring multi-stakeholder decision-making, interdepartmental collaboration, and thorough review of both quantitative and qualitative disclosures.
Conclusion
This article underscores the importance of transitioning to the IFRS Sustainability Disclosure Standards for organizations aiming to maintain transparency and investor confidence in their climate-related financial disclosures. The IFRS Standards not only build upon the foundation established by TCFD but also introduce more rigorous and comprehensive reporting requirements that help meet the evolving demands of global investors and regulators. By adopting IFRS S1 and S2, companies can ensure that their disclosures are aligned with the latest international standards, enhancing their credibility and positioning them at the forefront of sustainability reporting.
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Authors
Ranjani Thirugnanasambandan
Ranjani is an Associate ESG Manager with seven years of experience in green building, environmental science, and architecture. At Verdani Partners, she specializes in ESG reporting, regulatory compliance, supporting ESG due diligence processes, and developing net-zero roadmaps. She is a LEED Green Associate and Fitwel Ambassador, holding an M.Sc. in Building Performance and Sustainability from the National University of Singapore and a B.Arch. from Anna University.
Sam Howley
Sam is an Associate ESG Manager for Verdani Partners, bringing over six years of experience in sustainability and corporate responsibility. She manages ESG reporting, stakeholder engagement, and climate risk assessments for public and private clients. She also co-chairs Verdani's Resilience Committee, where she develops tools to enhance client resilience, mitigation, and adaptation efforts. Sam holds a B.S. in Environmental Science from the University of Vermont.
Ying (Paris) Mo
Paris is an ESG Manager at Verdani Partners with five years of experience in sustainability and corporate responsibility. She oversees the PRI submissions for all PRI reporting clients by providing organization-level directory guidance and account-specific support while managing GRESB and developing strategies for SFDR and other corporate sustainability programming. Paris holds an MBA and a MS in Real Estate from the University of San Diego and a B.A. in International/Global Studies from the University of California, Santa Barbara.
Carli Schoenleber
Carli is a Senior Communications Manager, Content and Engagement Specialist, for Verdani Partners, leading thought leadership and the Engagement Committee. She has a decade of experience in the sustainability field, working across diverse roles in environmental communication research, environmental planning, marketing, and wetland science. She holds a B.S. in Environmental Science, Policy, and Management from the University of Minnesota and a M.S. in Forest Ecosystems and Society from Oregon State University.
Chika Acholonu
Chika is an Associate Director of ESG for Verdani Partners. He acts as the account manager for various corporate ESG clients and oversees their ESG reporting, tenant engagement, and climate risk assessment efforts. Chika also develops and delivers trainings to colleagues and clients and serves as chair of the Verdani Diversity, Equity, and Inclusion (DEI) Committee. Chika holds a B.S. in Environmental Science and Resource Management from the University of Washington
Dana Weiss
Dana currently serves as an ESG Director for Verdani Partners and leads Verdani's Resilience Committee. She brings 15 years of experience in sustainable design and corporate responsibility. She has developed and implemented ESG policies and protocols for clients across the real estate sector and is currently advising on ESG for over $35 billion in client assets under management. Dana holds a Bachelor of Landscape Architecture and an MBA in Sustainable and Socially Responsible Business.
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