Local adoption of IFRS S1 / S2 (ISSB Standards)

In-scope Swiss companies must operate a supply chain management system, traceability and risk management aligned with the OECD Due Diligence Guidance for minerals and the ILO-IOE child labour due diligence guidance, and publish an annual report. False or missing reports can trigger fines up to CHF 100,000 under Art. 325ter of the Swiss Criminal Code.

Enforcement

Mandatory

Effective date

1 January 2022; one-year transition meant first reporting period was FY2023

Covered entities

Companies with registered office, head office, or principal place of business in Switzerland that import or process tin, tantalum, tungsten, gold (3TG) above annual volume thresholds set in the DDTrO annex, and companies that offer products or services where there is reasonable suspicion of child labour. SMEs and low-risk companies are exempt under defined conditions.

Australia has issued ISSB-aligned sustainability standards. AASB S2 (climate) is mandatory under the Corporations Act for in-scope entities; AASB S1 (broader sustainability) is voluntary.

Enforcement

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

Effective date

Annual reporting periods beginning on or after 1 January 2025 (phased by entity size)

Covered entities

Group 1, 2, 3 entities under AASB thresholds (large entities first; phased rollout to mid-size and smaller large entities)

The UK government has endorsed IFRS S1 and S2 as UK SRS S1 and S2 for voluntary use. The FCA is consulting on listing rules that would make UK SRS S2 mandatory for listed issuers, with Scope 3 and non-climate sustainability 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

TBD pending FCA listing-rule outcome

Covered entities

Any UK entity (voluntary). FCA proposal targets in-scope listed issuers.

CSSB issued final CSDS 1 and CSDS 2 on 18 December 2024, aligned with IFRS S1 and S2 with extra transition reliefs. Standards are voluntary. The CSA paused its mandatory climate disclosure rulemaking on 23 April 2025.

Enforcement

Voluntary

Effective date

Annual reporting periods beginning on or after 1 January 2025 (with transition reliefs)

Covered entities

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

SSBJ published final sustainability disclosure standards on 5 March 2025: an Application Standard, a General Standard, and a Climate Standard. The standards are essentially equivalent to IFRS S1 and S2. Mandatory application phases in by market capitalization.

Enforcement

Voluntary now. Mandatory under FSA disclosure framework on phased basis by market cap.

Effective date

Voluntary for periods ending on or after 5 March 2025. Mandatory phased: FY ending March 2027 for issuers with market cap >¥3T, expanding through FY ending March 2029.

Covered entities

Listed issuers in Prime Market (phased by market cap)

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.