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Beginner6 min read·ISSB

ISSB Global Adoption Map

ISSB standards have been adopted or are in the process of adoption in 40+ jurisdictions since their publication in June 2023. Understanding which jurisdictions have mandated IFRS S1 and S2 — and when — is essential for multinational companies managing cross-border sustainability disclosure obligations.

Published
June 2023
Jurisdictions
40+ adopted or in process (March 2026)
UK
Mandatory from January 2025 (UKSSRS)
Australia
Mandatory from July 2024
Japan
Mandatory from March 2025
Canada
Adoption in progress
TL;DR

ISSB standards have been adopted or are in the process of adoption in 40+ jurisdictions since their publication in June 2023. United Kingdom: The UK Sustainability Disclosure Standards (UK SDS) — which mirror IFRS S1 and S2 with minor modifications — were endorsed for use from 1 January 2025.

Major jurisdiction adoption status

United Kingdom: The UK Sustainability Disclosure Standards (UK SDS) — which mirror IFRS S1 and S2 with minor modifications — were endorsed for use from 1 January 2025. Mandatory application for UK-listed companies is being phased in, starting with premium-listed companies for periods beginning on or after 1 January 2026.

Australia: Australian Sustainability Reporting Standards (ASRS) based on IFRS S1 and S2 became mandatory from 1 July 2024 for large Australian entities (Group 1 — entities with >A$500M revenue or >A$1B assets). Smaller entities phase in from July 2026 and July 2027.

Japan: The Financial Services Agency (FSA) adopted ISSB-aligned sustainability disclosure requirements for prime market-listed companies from the fiscal year ending March 2025. Japan made Scope 1 and 2 mandatory immediately; Scope 3 has a phase-in period.

Singapore: Singapore Exchange (SGX) mandated climate reporting aligned with IFRS S2 for large listed companies from FY2025, phasing to all listed companies by FY2027.

Brazil: The Brazilian Securities Commission (CVM) mandated IFRS S1 and S2 adoption from January 2026 for listed companies.

Canada: The Canadian Sustainability Disclosure Standards (CSDS) based on IFRS S1 and S2 are in final consultation — mandatory adoption expected from 2025/2026 for public companies.

The US position — SEC climate rules

The United States has taken a separate path from the ISSB framework. The SEC (Securities and Exchange Commission) adopted its own climate disclosure rules in March 2024 — requiring Scope 1 and 2 GHG emission disclosure and climate risk disclosure for US-listed companies.

Key differences from IFRS S2: the SEC rules require only Scope 1 and 2 (Scope 3 was dropped from the final rule); use financial materiality consistent with existing SEC standards; and do not require SASB industry metrics. The SEC rules are significantly narrower than IFRS S2.

Legal challenges: the SEC climate rules faced immediate legal challenges after adoption. Several provisions were stayed pending litigation in 2024–2025. The regulatory status of the full SEC rules remains uncertain as of March 2026 — monitor SEC announcements.

For US multinationals also subject to CSRD or ISSB: US companies with EU subsidiaries meeting CSRD thresholds must report under ESRS regardless of SEC rule status. US companies listed on ISSB-adopting exchanges (London, Sydney, Tokyo) must comply with local ISSB-based requirements.

Implications for multinational companies

Companies operating across multiple jurisdictions face the most complex disclosure landscape. A typical EU-headquartered multinational with global operations may face:

CSRD/ESRS: mandatory for EU operations meeting size thresholds.

UK SDS/IFRS S2: if listed on London Stock Exchange or with significant UK operations.

Australian ASRS: if Australian subsidiary meets ASRS thresholds.

Japan FSA: if listed on Tokyo Stock Exchange prime market.

The interoperability between ESRS and ISSB significantly reduces duplication — approximately 70% of ESRS E1 content satisfies IFRS S2. The primary additional effort for dual reporters is: SASB industry metrics (S2 specific), formatting differences between ESRS and IFRS narrative structures, and jurisdiction-specific filing requirements.

Best practice for multinationals: prepare one master climate disclosure document that satisfies ESRS E1 (the broadest standard) and then map to IFRS S2 for relevant jurisdictions. Maintain a jurisdiction-specific disclosure mapping table showing which sections of the master document satisfy each framework's requirements.

Frequently asked questions

Does adopting ISSB mean a country is using the same standards as the EU?

No — ISSB adopters use IFRS S1 and S2 (financial materiality, investor-focused). The EU uses ESRS (double materiality, broader stakeholder focus). The frameworks are designed to be interoperable but are not identical. A company subject to both must satisfy both sets of requirements — the interoperability guidance shows where one disclosure satisfies both.

Will the US eventually adopt ISSB?

Unknown as of March 2026. The SEC's own climate rules take a different approach from ISSB. However, several US state-level disclosure requirements (California SB 253 and SB 261) are closer to ISSB in scope. Many US multinationals voluntarily align with ISSB ahead of any federal mandate. Monitor FASB and SEC announcements.

What is the IFRS Foundation's role in monitoring adoption?

The IFRS Foundation (which oversees the ISSB) monitors and publicly reports on jurisdictional adoption progress. The Foundation publishes an adoption tracker on its website showing the status of ISSB adoption in each jurisdiction — confirmed adoption, consultation in progress, or no current plans. This is the authoritative source for current adoption status.

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