The December 2025 IFRS S2 amendments are reliefs and documentation obligations

A relief in an accounting standard is rarely a reduction in work. It is usually a redistribution — less measurement, more explanation of why you measured less. The December 2025 amendments to IFRS S2 follow that pattern closely.

There are four of them. All are described as easing application. Each one leaves behind something you now have to be able to show.

What the ISSB changed in December 2025

The ISSB issued targeted amendments to the greenhouse gas emissions disclosure requirements in IFRS S2 in response to application challenges companies hit once they started applying the standard.

Targeted is the right word. This is not a rewrite. It is four specific adjustments, each aimed at a problem preparers actually reported.

Category 15: the relief, and the subtotal it triggers

The first amendment clarifies that an entity is permitted to limit measurement and disclosure of Scope 3 Category 15 emissions to financed emissions as defined in IFRS S2.

If you are a bank, insurer or asset manager, that is meaningful. Category 15 as drawn in the GHG Protocol Value Chain Standard is broad; financed emissions as defined in the standard is narrower and more tractable.

Now read the condition, because this is the part that gets missed. Where an entity has included Category 15 emissions in its measure of Scope 3 emissions disclosed under paragraph 29(a)(i)(3), it must disclose the total Category 15 emissions and the subtotal of financed emissions included in that total.

So the relief narrows what you must measure. The condition widens what you must present. If you were hoping to fold financed emissions invisibly into a Scope 3 total, that route is now explicitly closed.

Industry classification: GICS is no longer the only option

The amendments permit alternative classification systems beyond the Global Industry Classification Standard for disaggregating financed emissions by industry.

This solves a practical problem. Entities that already classify counterparties under a different system were previously being asked to maintain a parallel GICS mapping purely for disclosure.

The documentation consequence: if you use an alternative, the choice becomes something to justify. Which system, applied consistently, and why it enables classification of counterparties by industry.

Jurisdictional relief when only part of the entity differs

The third amendment clarifies the availability of the jurisdictional relief from using the GHG Protocol where only part of an entity is required to use a different method for measuring emissions.

This is narrower than it first appears, and worth reading carefully rather than assuming it applies. It addresses the situation where a jurisdiction obliges part of your group onto a different measurement basis — not a general licence to mix methods for convenience.

If you rely on it, the record needs to show which part of the entity, under which requirement, on what basis.

Alternative GWP values

The fourth is a jurisdictional relief from using global warming potential values from the latest IPCC assessment report when converting emissions.

Useful where a regulator mandates a particular vintage. Also, quietly, one more thing that has to be recorded, because two GWP sets produce two different numbers from identical activity data.

That is the same failure mode described in could you reproduce this figure in eighteen months — a conversion input that changes the answer and typically goes unrecorded.

Why every one of these reliefs creates something to document

Notice the pattern. Each amendment converts a fixed requirement into a choice.

Before: you use GICS. After: you use a classification system, and which one is your decision. Before: you use the latest IPCC GWP values. After: possibly not, depending on your jurisdiction.

A fixed requirement needs no justification. A choice does. Every one of these reliefs adds a line to the list of decisions your assurer will ask you to evidence, which is the ground covered in The audit trail behind your climate numbers.

The ISSB has also published educational material on the GHG emissions disclosure requirements, which is worth reading alongside the project page if you are working out whether a relief is available to you.

Effective date and early application

The amendments apply for annual reporting periods beginning on or after 1 January 2027, with early application permitted.

The ISSB was explicit about why that date: jurisdictions need time to run the amendments through their own processes before they become effective locally. Which means the practical question is not what the ISSB decided but what your regulator has adopted.

The opinion: treat these amendments as a documentation exercise rather than a relief exercise. Every one of them replaces an instruction with a decision, and decisions are what get tested. Companies that take the reliefs without recording why they were available will find the saving evaporates the first time someone asks.

Common questions

When do the December 2025 IFRS S2 amendments take effect?

They apply for annual reporting periods beginning on or after 1 January 2027, with early application permitted. The ISSB set that date deliberately to allow jurisdictions time to work the amendments through their own endorsement processes.

Do the amendments mean I can ignore Category 15?

No. They permit an entity to limit measurement and disclosure of Scope 3 Category 15 emissions to financed emissions as defined in IFRS S2. That is a narrowing of measurement, not permission to omit the category. And if you have included Category 15 in your Scope 3 figure, you must disclose both the total Category 15 emissions and the subtotal of financed emissions within that total.

Is GICS still required for financed emissions?

No. The amendments permit the use of alternative industry classification systems beyond the Global Industry Classification Standard to disaggregate information about financed emissions. If you use an alternative, expect to explain which system you selected and why, because your assurer will ask.

What are the jurisdictional reliefs in the amendments?

Two. The first clarifies when relief from using the GHG Protocol is available where only part of an entity is required to use a different measurement method. The second permits alternative global warming potential values instead of those from the latest IPCC assessment report. Both depend on your jurisdiction, so check what your regulator has actually adopted rather than assuming the relief is available to you.