IFRS S1 Company-Specific Disclosures: What to Do When No Dedicated ISSB Standard Exists

The practical risk is not a lack of terminology. It is that a familiar framework, dataset or metric is treated as a complete reporting conclusion without testing the governing IFRS requirements, materiality, evidence and publication claim.

The absence of a dedicated ISSB topical Standard does not remove the disclosure obligation. IFRS S1 requires the entity to identify sustainability-related risks and opportunities that could reasonably be expected to affect its prospects and to provide material information about them. The source hierarchy helps the entity identify information; it does not transfer the compliance basis to the external source.

The selected information must be relevant to investor decisions and faithfully represent the risk or opportunity. The entity also applies fair presentation, materiality, aggregation, connected information, reporting-entity, timing, comparative and judgement requirements. A metric can therefore be well known in another framework yet still be unsuitable if its scope, definition or objective does not meet the IFRS S1 information need.

Figure 1. IFRS S1 establishes a controlled hierarchy from issued ISSB requirements to supporting sources and entity-specific information, with materiality and judgement gates throughout.

IFRS S1 explicitly permits consideration of GRI and ESRS in Appendix C when they help the entity meet the IFRS S1 objective and do not conflict with ISSB Standards. This permission is useful where another framework contains a mature topic-specific disclosure. It does not mean that the entire framework, its materiality lens or its compliance claim is imported into the IFRS disclosure.

TNFD is not named in Appendix C. An entity may consider it through the broader permitted-source logic only when it is an appropriate investor-focused source and helps produce relevant, faithfully representative information without conflict. The entity should document the basis for using TNFD, the specific recommendation or metric considered and any adjustments made for IFRS S1.

A hypothetical payment-services company identifies a sustainability-related opportunity and risk related to maintaining a skilled cyber-security workforce. No dedicated ISSB Human Capital Standard exists. The company refers to relevant SASB topics and metrics but concludes that the available metrics do not fully capture the concentration of critical skills and internal succession coverage.

It develops an entity-specific metric for the percentage of critical cyber roles with an approved successor meeting defined competence criteria. The metric definition identifies the role population, competence assessment, reporting date, exclusions, data owner and validation. The disclosure explains why the metric is relevant to service continuity and growth, identifies the SASB and internal sources used, and describes the significant judgement involved.

Assuming “no dedicated Standard” means “no disclosure requirement”.

Skipping the mandatory SASB refer-and-consider step.

Importing another framework’s materiality conclusion without applying IFRS S1.

Using a peer metric without testing definition, boundary or investor relevance.

Creating a bespoke KPI that cannot be recalculated or compared.

Failing to identify the external source or explain how a metric was adjusted.

Obscuring material ISSB information with a large volume of immaterial framework content.

Making an unreserved compliance statement when ISSB requirements have not been fully applied.