Frameworks · IFRS S2
IFRS S2, read as a structure rather than a summary.
IFRS S2 Climate-related Disclosures runs to thirty-seven numbered paragraphs and three appendices. Thirty-three of those paragraphs are the disclosure requirement itself. This page maps them: which paragraph carries which obligation, how the four pillars are actually sized, and where the application guidance sits. It is written for someone who has to produce the disclosure and needs to know where to look.
We do not reproduce the standard here. The binding wording is the IFRS Foundation's and is available from ifrs.org. Everything below is our own description, with the paragraph reference so you can check it against the source.
The map
Every part of the standard, and what it is for.
Two things about this table are worth noticing before you read it. The first is that each pillar opens with an objective paragraph and then a requirement paragraph: paragraph 5 states what the governance disclosure is for, and paragraph 6 states what you must disclose. The objective is not preamble. If your disclosure satisfies the list in paragraph 6 but does not achieve the objective in paragraph 5, it is not compliant.
The second is that all paragraphs carry equal authority, including the appendices. Appendix B is not commentary you may consult; it is part of the standard, and paragraph 29 sends you into it repeatedly.
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| Part | Paragraphs | Count | What it does |
|---|---|---|---|
| Objective | 1-2 | 2 | States the purpose and introduces the test that governs everything after it: a climate risk or opportunity only qualifies if it could reasonably be expected to move the entity's cash flows, its access to finance or its cost of capital, over any horizon. Paragraph 2 gives that mouthful its short name. |
| Scope | 3-4 | 2 | Three things are in: physical risk, transition risk, and opportunity. Paragraph 4 then puts everything failing the paragraph 2 test out, which is what stops the standard becoming an environmental report. |
| Core content · paragraphs 5-37 | |||
| Governance | 5-7 | 3 | Who oversees climate risk, how they are equipped and informed, and what management does. Paragraph 7 tells you to integrate rather than duplicate if you also report on other sustainability topics. |
| Strategy | 8-23 | 16 | The largest pillar by some distance. Identification of risks and opportunities, effects on the business model and value chain, the transition plan, financial effects for the period and anticipated, and climate resilience. |
| Risk management | 24-26 | 3 | The processes used to identify, assess, prioritise and monitor climate risk, and whether those processes are integrated into the entity's overall risk management rather than run alongside it. |
| Metrics and targets | 27-37 | 11 | The seven cross-industry metric categories, then targets. This is where the numbers are, and where nearly all of the application guidance points. |
| Appendices · equal authority | |||
| Appendix A | — | — | Defined terms. Words in the standard that carry a specific meaning, which is not always the meaning they carry in ordinary use. We list them in a separate reference. |
| Appendix B | B1-B71 | 73 | Application guidance, now 73 paragraphs after B62A and B63A were added in December 2025. Larger than the core content it supports. |
| Appendix C | C1-C6 | 8 | Effective date and transition. IFRS S2 applies to annual reporting periods beginning on or after 1 January 2024. The reliefs live here, and they are narrower than they are usually described. |
Counts are of numbered paragraphs, including sub-paragraphs only where the standard numbers them separately. Appendix C shows eight because C1A, C1B and C6 were added in December 2025.
Pillar one · paragraphs 5-7
Governance is a documentation requirement wearing a governance label.
Paragraph 6 asks you to identify the body or individual responsible for oversight, and then to answer five specific questions about them. Read as a preparer rather than as a lawyer, those five sub-paragraphs are a list of documents. Terms of reference that mention climate. A record of how the board concluded it had the right skills, or a plan to develop them. Meeting cadence. Evidence that climate was weighed in major transactions, including the trade-offs. And a record of the board overseeing targets, with the remuneration link if there is one.
Almost every first-cycle preparer we have spoken to can describe these arrangements accurately in conversation and cannot produce the paper that shows they existed during the reporting period. The disclosure is not usually the hard part. Being able to support it a year later is.
Pillar two · paragraphs 8-23
Strategy is five questions and sixteen paragraphs.
Paragraph 9 is the index for the whole pillar. It names five things a reader must be able to understand, and each one is delivered by a specific block of paragraphs further down. If you are planning work, plan it against paragraph 9 and treat the blocks as five separate exercises with different owners and very different difficulty.
Paragraph 22 and B1-B18
Scenario analysis is required. How much of it is your judgement, and you have to defend that judgement.
Paragraph 22 requires climate-related scenario analysis to assess resilience, and says the approach must be commensurate with the entity's circumstances. That single word is doing an enormous amount of work. It is the difference between a spreadsheet with two temperature pathways and a full quantitative model, and the standard does not tell you which one you need. Appendix B paragraphs B1 to B18 explain how to arrive at the answer, which is why they are eighteen paragraphs long for a one-paragraph requirement.
What paragraph 22 does pin down is what you must say about the analysis once you have done it. Which scenarios and where they came from. Whether the range was diverse. Whether one of them was aligned with the latest international agreement on climate change. The time horizons, the scope of operations covered, and the key assumptions, including assumptions about policy in the jurisdictions where you operate. In other words, a reader is entitled to see enough of your method to judge whether the conclusion is worth anything.
This is where proportionality is most often misread. A smaller entity may reasonably use a simpler method. It may not reasonably skip the disclosure of what that method was, and the simpler the method, the more visible the assumptions become. In practice the record that matters is the one nobody thinks to keep at the time: why you chose those scenarios, who agreed the assumptions, and on what date.
Proportionality is not a transition relief
The two get conflated constantly. Proportionality is a permanent feature of how several requirements are drafted. Transition reliefs are time-limited and sit in Appendix C. We have written up which reliefs exist and where each one ends, because the first-year ones expire in ways that surprise people.
Pillar three · paragraphs 24-26
Risk management is short, and its last clause is the one that gets tested.
Three paragraphs, and most of the content is a single list. The requirement that causes difficulty is paragraph 25(c): the extent to which climate processes are integrated into the entity's overall risk management process. Not run in parallel by the sustainability team. Integrated.
A great many organisations have a climate risk register maintained by one function and an enterprise risk register maintained by another, and the honest answer to 25(c) is that they are connected by a person rather than a process. That is a disclosable fact. Saying so plainly is compliant; implying an integration that does not exist is the kind of statement an assurance provider will ask you to evidence, and it is much harder to withdraw later than to qualify now.
Paragraph 25(a)(vi) also asks whether your process changed since the previous period, which quietly requires you to have recorded what it was.
Pillar four · paragraphs 27-37
Seven metric categories, and only one of them is emissions.
Paragraph 29 lists seven cross-industry categories. Emissions get the most attention and the most guidance, but the other six are requirements too, and in first-cycle reports they are where the gaps usually are. Categories (b) to (d) are subject to paragraph 30, which limits you to reasonable and supportable information available without undue cost or effort — a genuine constraint, but one you have to be able to demonstrate you reached.
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| Category | Ref | What has to be disclosed |
|---|---|---|
| Greenhouse gases | 29(a) | Absolute gross Scope 1, 2 and 3 in tonnes of CO2e, the measurement method, the approach and its inputs and assumptions, Scope 1 and 2 split between the consolidated group and other investees, location-based Scope 2 plus contractual instruments, and the Scope 3 categories included. Six sub-requirements, and the longest single provision in the standard. |
| Transition risk | 29(b) | How much of the business sits in the path of transition risk, given both as a figure and as a share of the whole. The requirement is short; the work is deciding what counts as exposed and then applying that definition consistently. |
| Physical risk | 29(c) | The same pair of numbers for physical risk. Usually the hardest of the three, because it needs asset-level location data that rarely lives in the finance system. |
| Opportunities | 29(d) | The same again, for the parts of the business positioned to gain rather than lose. |
| Capital deployment | 29(e) | The money actually committed against climate risks and opportunities, whether as capital spending, financing or investment. This figure has to sit sensibly beside the financial statements, and reviewers check that it does. |
| Internal carbon price | 29(f) | Whether and how a carbon price is applied in decision-making, and the price per tonne used. If you do not use one, say so. |
| Remuneration | 29(g) | Whether climate is factored into executive remuneration, and the percentage of current-period executive remuneration linked to it. A number, not a narrative. |
Paragraph 31 sends categories (b) to (g) to Appendix B paragraphs B64 and B65 before you measure anything.
Paragraphs 33-36
Every target carries eight attributes, and then three more paragraphs.
Paragraph 33 sets out eight things you must disclose for each target, whether you set it yourself or are required to meet it by law. Paragraphs 34 to 36 then add the review process, actual performance against it, and a further five items for emissions targets specifically. A target announced in a press release almost never carries all of this, which is why the target section of a first report is so often the one that gets sent back.
Paragraph 36(c) is the one people miss: disclosing a net target obliges you to disclose the associated gross target alongside it.
December 2025
What the amendments actually touched.
On 11 December 2025 the ISSB issued Amendments to Greenhouse Gas Emissions Disclosures. Paragraph C1A of the amended standard lists precisely which paragraphs moved, which is a more useful starting point than a summary, because it tells you whether anything you have already drafted is affected. They apply to annual reporting periods beginning on or after 1 January 2027, early application is permitted, and paragraph C1B requires you to say so if you apply them early.
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| Change | Paragraphs | Effect |
|---|---|---|
| Category 15 may be limited | 29A-29C added | Scope 3 Category 15 may be limited to financed emissions, derivatives may be excluded, and if you take it you must explain what you treated as a derivative and what you left out. Paragraph 29C then requires a Category 15 total with the financed emissions subtotal shown inside it. |
| Industry classification | B62A, B63A added | GICS is no longer the only permitted classification for disaggregating financed emissions. You choose a system, prioritise a widely used one where it does the job, and disclose which you picked and why it satisfies the requirement. A group that both lends and underwrites may classify the two books differently. |
| Measurement method relief | 29(a)(ii), B24 amended | Clarifies that the relief from the GHG Protocol applies where a jurisdiction or exchange requires a different method for part of the entity, and only for that part, and only for as long as the requirement holds. |
| Global warming potential values | B21-B22 amended | A parallel relief. Where a jurisdiction or exchange mandates different GWP values, those may be used instead of the latest IPCC assessment, for the part of the entity concerned. |
| Consequential | B28, B37, B59, B62(a), B63(a), C4(b) | Cross-references and disclosure of alternative methods updated to match. |
| Transition for the amendments | C6 added | If you already applied IFRS S2 and a relief changes how you measure, you adjust the comparative period as though you had measured that way then — unless doing so is impracticable. |
Every one of these reliefs replaces a measurement obligation with a documentation obligation. We have written separately on what that means in practice and on what a bank or insurer now has to produce.
Two things the map does not show
IFRS S2 does not stand on its own, and where it lands is a separate question.
IFRS S2 is written to be applied alongside IFRS S1, which carries the conceptual foundations, the requirement that disclosures sit in the general purpose financial report, the timing rules that tie them to the financial statements, and the materiality judgements. Compliance with the ISSB standards means an explicit and unreserved statement of compliance, and that statement is made under S1. You cannot read S2 alone and know what you have to produce.
Jurisdictions then vary this. Some adopt the two standards together, some adopt a climate-only version that folds the S1 requirements into S2 as a standalone instrument, and the dates differ everywhere. What binds you is your local instrument, not the ISSB text. Our adoption tracker records where each market has got to, and the deadline checker will tell you which cohort and first mandatory period apply to you.
Where to start
Against the map, not against the calendar.
The sequence that works is unglamorous. Confirm the instrument that binds you and the first period it bites. Walk paragraph 9 and assign each of its five blocks an owner. Establish the emissions boundary before measuring anything, because changing it later invalidates the comparatives. Then work backwards from paragraph 29 to the systems the numbers come out of, and find out now whether each figure can be traced to a source document and reproduced.
Governance and risk management can be drafted late. Metrics cannot, and neither can the record that supports them.
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