Why an Early Effective Date Supports Better Climate Disclosure

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 5 — Effective date

The ISSB proposes to add paragraphs C1A–C1B which would specify the effective date of the amendments. The ISSB expects the amendments would make it easier for entities to apply IFRS S2 and would support entities in implementing the Standard. Consequently, the ISSB proposes to set the effective date so that the amendments would be effective as early as possible and to permit early application.

Paragraphs BC50–BC51 of the Basis for Conclusions describe the reasons for the proposal.

Do you agree with the proposed approach for setting the effective date of the amendments and permitting early application? Why or why not?

o Broadly agree

o Broadly disagree

o Neither agree nor disagree

Optional: Please explain

We Broadly Agree

Eco Sustainability broadly agrees with the proposal to set the effective date as early as possible and to permit early application. This approach enables jurisdictions and companies that are ready to move forward without delay, while generating valuable lessons for others still building capacity.

Why This Matters

1. Encourages Practical Learning and Feedback

Early adopters will surface real-world implementation issues sooner. These insights will help improve future technical guidance, build better tools, and inform phased onboarding across markets.

2. Acknowledges Readiness Gaps Without Penalizing Progress

In ASEAN and other emerging regions, there is wide variation in disclosure maturity. Early application lets frontrunners act now, while others benefit from the lessons learned. We recommend a one-year buffer before mandatory compliance to support transition readiness.

3. Helps Companies Build Resilience

Post-COVID and geopolitical disruptions have made supply chain and emissions data harder to collect. Early implementation gives companies the chance to adapt their internal systems and governance structures to withstand future shocks.

4. Aligns Strategy Across Value Chains

With more lead time, companies can:

• Train internal teams and decision-makers

• Inform suppliers and clients about upcoming expectations

• Integrate climate data into core business functions like procurement, lending, and risk management

Our Recommendation

Proceed with an early effective date and permit early application. However, this must be paired with:

• Detailed technical guidance

• Outreach and training (especially for emerging markets)

• A recommended buffer period before mandatory application

This two-track system ensures fairness and global readiness - without slowing momentum where it’s already building.

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.