Local adoption of IFRS S1 / S2 (ISSB Standards)

Brazil's PNRS makes manufacturers, importers, distributors and retailers responsible for reverse logistics of listed products, including packaging, e-waste, batteries, tyres and lubricant containers. Decreto 10.936/2022 consolidated the general rules and reporting through SINIR. Decreto 12.688/2025 created a plastic packaging system with national recovery targets of 32% in 2026 rising to 50% in 2040, plus recycled-content targets of 22% in 2026 rising to 40% in 2040 for manufacturers and importers.

Enforcement

Mandatory

Effective date

Lei 12.305 enacted 2 August 2010, in force from 3 August 2010; Decreto 10.936 enacted 12 January 2022; Decreto 12.688 in force 21 October 2025, with plastic packaging recovery targets from 2026 and recycled-content targets mandatory from January 2026 for large companies and July 2026 for small and medium companies

Covered entities

Manufacturers, importers, distributors and retailers of products subject to mandatory reverse logistics, including pesticides, lubricant oils and packaging, tyres, batteries, fluorescent lamps, household electrical and electronic equipment (Decreto 10.240/2020), household medicines (Decreto 10.388/2020), plastic packaging and comparable plastic products (Decreto 12.688/2025), and general packaging covered by sectoral agreements. Plastic packaging recycled-content targets apply to manufacturers and importers

Australia has adopted ISSB-aligned sustainability standards. AASB S2 (climate) is mandatory for entities within Chapter 2M of the Corporations Act and is phased in across three groups from 2025 to 2027. AASB S1 (general sustainability) is voluntary. ASIC administers the regime and has published guidance in RG 280.

Enforcement

AASB S1: voluntary. AASB S2: mandatory under Corporations Act 2001 for in-scope entities.

Effective date

Financial years beginning on or after 1 January 2025 (Group 1), 1 July 2026 (Group 2) and 1 July 2027 (Group 3). AASB S2025-1 amendments apply to annual periods beginning on or after 1 January 2027, with early application permitted.

Covered entities

Entities that must prepare annual financial reports under Chapter 2M of the Corporations Act and meet a s292A threshold. Group 1: at least two of consolidated revenue of AUD 500m or more, consolidated gross assets of AUD 1bn or more, and 500 or more employees; or NGER registered corporations in groups that meet the s13(1)(a) NGER threshold. Group 2: at least two of revenue of AUD 200m or more, assets of AUD 500m or more, and 250 or more employees; all other NGER registered corporations; and registered schemes, RSEs and retail CCIVs with assets of AUD 5bn or more. Group 3: at least two of revenue of AUD 50m or more, assets of AUD 25m or more, and 100 or more employees.

UK SRS S1 and S2 are the UK government's endorsed versions of IFRS S1 and S2, published on 25 February 2026 for voluntary use. Voluntary users can apply the Scope 3 and non-climate reliefs with no time limit. The FCA has consulted on listing rules that would make UK SRS S2 climate reporting mandatory for listed companies, with Scope 3 emissions and UK SRS S1 non-climate reporting on a comply-or-explain basis.

Enforcement

Voluntary at publication. FCA proposes mandatory UK SRS S2 for listed issuers (Scope 3 and broader sustainability on comply-or-explain).

Effective date

Voluntary use: no effective date (entities apply the standards when they choose). FCA proposal, subject to the final policy statement: rules in force 1 January 2027 for accounting periods beginning on or after 1 January 2027; using the transitional reliefs, Scope 3 reporting from periods beginning on or after 1 January 2028 and UK SRS S1 non-climate reporting from periods beginning on or after 1 January 2029.

Covered entities

Any entity (voluntary). The FCA proposal covers issuers in the commercial companies (UKLR 6), non-equity and non-voting equity shares (UKLR 16), transition (UKLR 22), secondary listing (UKLR 14) and depositary receipts (UKLR 15) categories. No mandate yet for unlisted companies.

CSSB issued final CSDS 1 and CSDS 2 on 18 December 2024, aligned with IFRS S1 and S2 with extra transition reliefs. The standards are voluntary. The CSA paused its mandatory climate disclosure rulemaking on 23 April 2025. In April 2026 the CSSB proposed CSDS 2 amendments matching the ISSB's IFRS S2 amendments: limiting Scope 3 Category 15 to financed emissions, allowing an industry classification other than GICS, and allowing other GHG measurement methods or GWP values where a jurisdictional authority or exchange requires them.

Enforcement

Voluntary

Effective date

Standards effective for annual reporting periods beginning on or after 1 January 2025, for entities that choose to apply them (with transition reliefs). Voluntary; no mandatory reporting date exists.

Covered entities

Any Canadian entity (voluntary). CSA paused work on mandatory rule citing global developments.

SSBJ published its Application, General and Climate Standards on 5 March 2025, and the SSBJ and ISSB confirm they are functionally aligned with IFRS S1 and S2. The FSA amended the Cabinet Office Order on Disclosure of Corporate Affairs on 20 February 2026 to require SSBJ-based disclosures in Annual Securities Reports for large Prime Market companies from the fiscal year ending March 2027, with third-party assurance one year later.

Enforcement

Mandatory for Tokyo Stock Exchange Prime Market companies, phased by market cap, through Annual Securities Reports under the Cabinet Office Order on Disclosure of Corporate Affairs. Voluntary for other entities.

Effective date

Voluntary for annual periods ending on or after 5 March 2025. Mandatory for Prime Market companies by average market cap (average of the last five fiscal year-ends): ¥3 trillion or more from the fiscal year ending March 2027; ¥1 trillion or more from the fiscal year ending March 2028; ¥500 billion or more from the fiscal year ending March 2029. Timing for other Prime Market companies to be decided later. Mandatory assurance starts one year after each cohort's first mandatory year.

Covered entities

Tokyo Stock Exchange Prime Market companies with average market capitalization of ¥500 billion or more, in three cohorts (¥3 trillion, ¥1 trillion, ¥500 billion). Timing for other Prime Market companies not yet set.

HKICPA published HKFRS S1 and HKFRS S2 on 12 December 2024, fully aligned with IFRS S1 and S2. The Hong Kong SAR Government's December 2024 Roadmap sets out the phased path to mandatory adoption for publicly accountable entities.

Enforcement

Voluntary at HKICPA level. The Hong Kong SAR Government's roadmap (10 December 2024) sets out phased mandatory adoption for publicly accountable entities.

Effective date

Annual reporting periods beginning on or after 1 August 2025

Covered entities

Any Hong Kong entity (voluntary). Mandatory phased rollout per government roadmap.