Originally posted on Social Housing on 23rd July 2025
Sustainability for Housing (SfH) was pleased to submit a formal response to the International Sustainability Standards Board’s (ISSB) consultation on proposed targeted amendments to the IFRS S2 Climate-related Disclosures framework, which closed on the 27th of June.
The aim of this blog is to explain the background and aims of the ISSB, the purpose of its recent consultation and its relevance to the UK social housing sector.
What is the International Sustainability Standard Board (ISSB)?
The International Sustainability Standards Board (ISSB) was formed by the IFRS Foundation in November 2021 at COP26 in Glasgow. Its purpose is to create and maintain a set of comprehensive, international sustainability disclosures that can be adopted across countries and jurisdictions, forming a global baseline for sustainability reporting.
The ISSB issued its inaugural sustainability reporting standards – IFRS S1 and IFRS S2 – in June 2023. IFRS S1 sets out disclosures which enable companies to communicate their broad sustainability-related risks and opportunities to investors in a transparent and comparable manner. The disclosures set out in IFRS S2 are similar but climate-focused, allowing companies to report their climate-specific risks and opportunities.
IFRS S1 and S2 are designed to be used together, providing investors with a complete picture of reporting companies’ exposure to sustainability-related risks and opportunities. They are fully aligned with the Task Force on Climate-related Financial Disclosures (TCFD) framework.
Since IFRS S2 and IFRS S2 were released, 36 jurisdictions across the globe have adopted, used, or are in the process of adopting them. For more information about the ISSB and its aims, please visit the ISSB’s website.
What is the consultation about?
In April 2025, the ISSB published an Exposure Draft proposing targeted amendments to IFRS S2 in response to market feedback. The aim of these proposed amendments is to provide certain reliefs to ease the reporting burden for Scope 3 greenhouse gas (GHG) emissions.
Specifically, the Exposure Draft seeks to provide:
- Relief from disclosing Scope 3 Category 15 GHG emissions associated with derivatives and some financial activities
- Relief from the use of the Global Industry Classification Standard (GICS), in some circumstances, when disclosing disaggregated financed emissions information
- Clarification on the jurisdictional relief available to use a measurement method other than the Greenhouse Gas Protocol for measuring GHG emissions
- Permission to use jurisdiction-required Global Warming Potential (GWP) values that are not from the latest Intergovernmental Panel on Climate Change (IPCC) when relevant
The Exposure Draft was open for comment for 60 days, during which time SfH submitted a formal public response. Following a review of stakeholder feedback, the ISSB aims to finalise the amendments by the end of 2025.
Why does it matter to SfH and to the social housing sector?
SfH is tasked with stewarding and evolving the Sustainability Reporting Standard for Social Housing (SRS), which was launched in 2020 and remains the only sustainability reporting framework for the UK’s social housing sector.
Part of SfH’s ongoing role is to ensure the SRS remains relevant and useful amidst a quickly evolving global sustainability reporting landscape. In order for the SRS to serve its purpose effectively, it must strike the balance between maintaining year-on-year consistency and undergoing measured evolution to align with changing international standards. Through achieving this equilibrium, the SRS can remain a valuable tool for social housing providers and funders alike.
Considering the ISSB’s position as the world’s leading body for international sustainability reporting standards, it is important for SfH to establish and maintain a productive working relationship with the ISSB. This will enable us to align the SRS with the ISSB’s standards where possible and relevant, as well as act as an influential thought leader for the ISSB on behalf of the social housing sector.
As set out in the opening cover letter from Piers Williamson, Chair of SfH, we believe there is significant mutual knowledge sharing potential between SfH and the ISSB. As one of the UK’s leading examples of a sector-specific sustainability reporting standard, we believe there is much that the ISSB can learn from the social housing sector’s adoption of the SRS. SfH is keen to share its knowledge with the ISSB, as well as contribute feedback to IFRS S2 and IFRS S2 when opportunities arise.
With the UK Government having recently published its own exposure draft for the newly proposed UK Sustainability Reporting Standards, UK SRS 1 and UK SRS 2, which are based on IFRS S2 and IFRS S2, joining the dots between the social housing sector and the ISSB has just become even more essential.
You can read SfH’s public response to the consultation in full here.
