Strengthening IFRS S2: Five Practical Enhancements for Global Impact

As part of our submission to the ISSB’s Exposure Draft on amendments to IFRS S2, Eco Sustainability has formally registered its stance.

In this opinion editorial, we offer our insights and position. To view our Technical Opinion, please see the full text of our formal submission.

Full Text From ISSB Exposure Draft

Question 6 — Other Comments

The ISSB invited additional comments or suggestions beyond the specific questions outlined in the Exposure Draft.

Eco Sustainability supports the ISSB’s vision to create robust, globally comparable climate disclosures. However, as a firm working closely with governments, regulators, and corporates across Asia Pacific and emerging markets, we believe certain proposed changes could unintentionally dilute the clarity, transparency, and credibility that IFRS S2 seeks to uphold.

To support implementation in the real world, we offer a structured commentary framed through a Human–Machine–Method–Legal–Environment lens.

1. Human Resources and Expertise

Widen the Gate Beyond Financial Professionals

Sustainability disclosures should not be the domain of financial analysts alone. ISSB should explicitly include technical experts such as ISO 14064-certified professionals, life cycle assessors, and sectoral emissions modelers in disclosure and verification processes.

Formalize Qualification Criteria

Introduce minimum qualification thresholds and a renewal mechanism. This could be based on completed projects, audit hours, or verified disclosures, similar to IAF- or ISO-based schemes. This ensures accountability and maintains quality as the field grows.

2. Methodology and Technology

Develop a Centralized Reporting Platform

ISSB or an aligned body should build an open-access reporting platform that integrates emissions factor databases, GHG Protocol tools, scenario models, and verification modules. This improves standardization, reduces subjectivity, and promotes audit-readiness.

Share Responsibility for Methodological Risk

Allow platform-integrated expert reviews to validate estimation approaches. This helps distribute the risk of calculation errors and ensures technical robustness beyond financial assumptions.

3. Audit Scope and Oversight

Expand the Pool of Verifiers

Do not limit verification to finance-linked assurance firms. Recognize ISO-compliant bodies (e.g., ISO 17029, 14064-3) with proven track records in emissions verification. This introduces technical depth and reduces over-reliance on a small set of global assurance players.

Encourage Sector-Specific Auditors

Broader assurance ecosystems can better account for nuances in sectors like energy, transport, and manufacturing. A diverse verifier pool also prevents gatekeeping in the emerging climate disclosure economy.

4. Legal Clarity and Enforcement

Clarify Where S2 Sits in the Regulatory Ladder

Today, S2 disclosures exist in a grey area between best practice and regulation. ISSB should define where it fits in the legal hierarchy - whether as voluntary guidance, enforceable codes, or binding regulatory standards. This improves enforceability and clarity for stakeholders.

Guard Against Greenwashing by Influential Actors

There is growing risk that large institutions will use S2-style disclosures for ESG marketing rather than real decarbonization. ISSB should:

• Require disclosure of assumptions and estimation logic

• Introduce consistency checks year-over-year

• Scrutinize scope boundaries and supply chain claims

5. Environmental Impact and Systemic Outcomes

Keep Emissions Reduction at the Center

Disclosure should be a means, not the end. S2 should explicitly link reporting to environmental outcomes, not just administrative compliance. Companies must be guided to reduce real-world emissions across Scopes 1, 2, and 3.

Align Disclosure with Policy Tools

Work with jurisdictions to link disclosures with real levers - including carbon pricing, CBAMs, tax incentives, and subsidies - so that sustainability reports have material implications for business operations.

Conclusion

While we support the intent of the ISSB’s amendments, we urge the Board to prioritize implementation integrity, practical accountability, and environmental outcomes. Standards cannot rely solely on principles - they must be structured, verifiable and enforceable.

About Eco Sustainability

As a trusted advisor on sustainability and climate policy, Eco Sustainability is not only aligned with global standards. We help shape them by actively engaging in technical consultations and contributing to international standard-setting processes.