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Philippines-ISSBSEC Memorandum Circular No. 16, Series of 2025 (dated 22 December 2025) adopts PFRS S1 and S2 on a tiered basis from FY2026, replacing the SEC Sustainability Reporting Guidelines (MC No. 4, s. 2019)

Local adoption of IFRS S1 / S2 (ISSB Standards)

Philippines · Securities and Exchange Commission (SEC), with the Financial and Sustainability Reporting Standards Council (FSRSC) and Professional Regulatory Board of Accountancy (BOA)

The Philippine SEC issued Memorandum Circular No. 16, s. 2025, adopting PFRS S1 and S2 (local versions of IFRS S1 and S2) with limited extra transition reliefs, including a two-year Scope 3 relief for all tiers. The largest listed companies start with FY2026, mid-sized listed companies with FY2027, and smaller listed companies, PDEx-only debt issuers and large non-listed companies with FY2028. Limited assurance over Scope 1 and 2 emissions follows two years after each tier starts.

Category
ISSB-aligned sustainability disclosure
Enforcement
Mandatory
Effective date
Tier 1 (PSE-listed, market cap above PHP 50bn as of 31 December 2025): FY beginning on or after 1 January 2026, reporting in 2027. Tier 2 (PSE-listed, market cap above PHP 3bn up to PHP 50bn): FY beginning on or after 1 January 2027, reporting in 2028. Tier 3 (PSE-listed with market cap of PHP 3bn or less; companies with debt securities listed only on PDEx; large non-listed entities with annual revenue above PHP 15bn): FY beginning on or after 1 January 2028, reporting in 2029. Limited assurance on Scope 1 and 2 required two years after each tier's first adoption.
Covered entities
Publicly listed companies (tiered by market capitalization), companies whose debt securities are listed only on PDEx, and large non-listed entities with annual revenue above PHP 15bn. Until their adoption year, listed companies continue to follow SEC MC No. 4, s. 2019.
Notes
The MC is signed 22 December 2025 and takes effect 15 days after newspaper publication (24 December 2025); the IFRS profile (updated 10 July 2026) dates it 23 December 2025. Assurance must follow ISSA 5000 and may be provided by accountants or non-accountants. Other frameworks (for example GRI, ESRS) may be included in the same report if they do not conflict with or obscure PFRS disclosures.

Sources

Related regulations

In force

The Philippines' Extended Producer Responsibility Act of 2022 makes large enterprises responsible for recovering a rising share of their plastic packaging footprint, from 20% in 2023 to 80% by 2028 and beyond. DENR oversees registration, audited compliance reports and PRO recognition under DAO 2023-02.

Enforcement
Mandatory
Effective date
RA 11898 lapsed into law on 23 July 2022 without the President's signature and took effect 15 days after publication (14 August 2022 [uncertain: publication date not re-verified]); IRR (DAO 2023-02) signed January 2023; recovery targets of 20% by 31 December 2023, 40% by 2024, 50% by 2025, 60% by 2026, 70% by 2027 and 80% by 31 December 2028 and every year after
Covered entities
Large enterprises (total assets above the medium-enterprise ceiling under RA 9501, PHP 100 million) that generate plastic packaging waste; enterprises sharing the same brand, label or trademark are obligated when their combined assets exceed that ceiling
Primary source ↗Verified 2026-09-23
Effective. Group 1 has reported since financial years beginning 1 January 2025 and Group 2 since financial years beginning 1 July 2026. Treasury is consulting on changes to reduce reporting costs (closes 2 October 2026).

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

UK Sustainability Reporting Standards (UK SRS S1 and UK SRS S2)

United Kingdom · UK Government (Department for Business, Innovation, Science and Trade, renamed from DBT in July 2026) / FRC; FCA for listed-entity application
Final standards published 25 February 2026 for voluntary use; FCA consultation CP26/5 closed 20 March 2026; FCA policy statement expected autumn 2026 (not published as of 23 September 2026)

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.
Canada-CSDS

CSDS 1 and CSDS 2 – Canadian Sustainability Disclosure Standards

Canada · Canadian Sustainability Standards Board (CSSB), under FRAS Canada
Final standards published (voluntary); CSA mandatory rule paused since April 2025 (no resumption found); CSDS 2 GHG emissions amendments proposed April 2026

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.
Japan-SSBJ

SSBJ Sustainability Disclosure Standards (Application, General, Climate)

Japan · Sustainability Standards Board of Japan (SSBJ)
Final standards published 5 March 2025; mandatory under the FSA's Cabinet Office Order amendment promulgated 20 February 2026, first cohort from the fiscal year ending March 2027

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.
HongKong-HKFRS

HKFRS S1 and HKFRS S2 – Hong Kong Sustainability Disclosure Standards

Hong Kong · Hong Kong Institute of Certified Public Accountants (HKICPA)
Adopted (effective 1 August 2025; voluntary use until mandated by relevant authority)

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.