Navigating ISSB Jurisdictional Differences: What Businesses Need to Know
IFRS Sustainability Jurisdictional Consultations
The International Financial Reporting Standards (IFRS) Foundation’s jurisdiction consultations on the International Sustainability Standards Board (ISSB) represent another interesting step toward global consistency in sustainability reporting. While the ISSB aims to establish a uniform global baseline for sustainability disclosure, its adoption across jurisdictions remains varied, posing both compliance challenges and strategic opportunities for businesses.
With growing pressure from regulators and investors for transparent, comparable sustainability information, companies must now understand not just the standards themselves, but how different jurisdictions are implementing them.
Examples from Early ISSB Adopters:
Among the jurisdictions moving swiftly to adopt the ISSB framework, Australia and Singapore stand out as early adopters. Their proactive engagement with the IFRS S1 and S2 standards signals not only regulatory ambition but also a recognition of the strategic value of high-quality, globally aligned sustainability disclosures.
Australia: A Climate-First, Phased Implementation
Australia has adopted a climate-first approach, prioritising climate-related disclosures under a phased implementation plan. The Australian Accounting Standards Board (AASB) has introduced two new standards:
AASB S1 (based on IFRS S1): General sustainability-related disclosures (currently voluntary)
AASB S2 (based on IFRS S2): Climate-related disclosures (mandatory from 2025)
The mandatory application of AASB S2 began in January 2025 for large listed and unlisted entities (Group 1), with smaller organisations phased in over time. While AASB S2 incorporates selected elements of S1 to support standalone use, Australia’s decision to delay mandatory general sustainability disclosures has prompted concern from investors seeking alignment with global standards and comparability across markets.
Singapore: Mandating Full ISSB Standards with Digital Focus
Singapore is taking a comprehensive approach, mandating both IFRS S1 and IFRS S2 for listed companies from 2025. The regime, led by the Accounting and Corporate Regulatory Authority (ACRA) and Singapore Exchange Regulation (SGX RegCo), will expand to large non-listed companies from 2027.
Key components of Singapore’s framework include:
Mandatory reporting of Scope 1 and 2 greenhouse gas emissions from 2025
Phased introduction of Scope 3 emissions reporting
Digital disclosure requirements via XBRL format to enhance transparency
Singapore is also actively exploring the future integration of broader sustainability disclosures, reinforcing its alignment with international best practices.
A Global Trend, with Local Complexity
Beyond Australia and Singapore, other jurisdictions are also moving toward ISSB alignment:
Canada has introduced Canadian Sustainability Disclosure Standards, largely aligned with IFRS S1 and S2 but with regional modifications.
Malaysia and Hong Kong are implementing phased adoption strategies focused on listed and large companies.
The European Union is integrating ISSB guidance into its broader sustainability framework, though with additional requirements under the Corporate Sustainability Reporting Directive (CSRD).
How Businesses Prepare for Jurisdictional Differences:
Preparing for jurisdictional readiness in sustainability reporting requires businesses to move beyond compliance and adopt a strategic, integrated approach. Annual benchmarking by the World Business Council for Sustainable Development (WBCSD) shows that companies leading in this area are forming cross-functional teams - spanning finance, sustainability, legal, and IT - to monitor regulatory developments and translate complex ISSB standards into actionable business plans. The analysis highlights that organisations investing in cross-departmental knowledge and governance are better positioned to anticipate challenges and respond to new stakeholder expectations.
Evidence from PwC and KPMG further demonstrates that businesses most prepared for the future treat sustainability reporting as a core element of enterprise risk management and value creation, not just a compliance task. This means embedding sustainability data in core business operations, investing in ongoing staff training, and engaging early with assurance providers to ensure audit readiness.
As sustainability reporting becomes mandatory across more jurisdictions, organisations with robust internal controls and a culture of transparency are most likely to earn investor trust and maintain competitive advantage.
The Strategic Imperative for ESG-Ready Reporting
As the IFRS Foundation continues jurisdiction consultations, businesses must not wait for uniform global regulation. Preparing now for ISSB-aligned sustainability reporting is a strategic imperative, not just a compliance task or tick-box exercise.
At ESG360°, we help companies navigate the complexity of jurisdictional ESG requirements and implement data-driven, investor-ready sustainability reporting systems. The shift toward global ESG comparability is gaining pace - ensure your organisation is not left behind.