Sustainability teams face a growing challenge: multiple climate disclosure frameworks now require physical risk data, scenario analysis, and asset-level exposure metrics. IFRS S2, CSRD, CDP, and others each define these requirements differently, with distinct thresholds, timelines, and levels of prescriptiveness.
This guide compares 10 climate disclosure frameworks side by side, covering who must report, what physical risk data each framework demands, and where requirements overlap. Broader sustainability reporting frameworks like GRI and SASB address ESG reporting beyond climate risk. This guide focuses specifically on frameworks with climate-related disclosure mandates.
10 Climate Disclosure Frameworks at a Glance
The table below maps the core requirements of each climate disclosure framework. Every framework name links to our detailed guide for that standard.
| Framework | Jurisdiction | Mandatory? | Who Must Report | Effective Date | Materiality | Scenario Analysis | Physical Risk Requirement | Assurance | Status (Oct 2026) |
|---|---|---|---|---|---|---|---|---|---|
| IFRS S2 | Global | Voluntary baseline | All entities (via national adoption) | Jan 2024 | Single (financial) | Required; approach suited to entity’s circumstances | Para 29(c): amount and % of assets vulnerable | Left to regulators | Active global baseline |
| UK SRS S2 | UK | Comply or explain (FCA rules) | UK-listed companies | Periods from 1 Jan 2027; first reports 2028 | Single (financial) | Identical to IFRS S2 | Para 29(c): identical to IFRS S2 | Not required; disclose whether obtained | FCA final rules published 30 Sep 2026 |
| CSRD / ESRS E1 | EU | Mandatory | EU companies with more than EUR 450M net turnover AND more than 1,000 employees (post-Omnibus) | Wave 1: FY 2024; post-Omnibus scope: FY 2027; non-EU: FY 2028 | Double (financial + impact) | High emission scenarios inform hazard identification; scenario analysis optional from FY 2027 | E1-9: assets at material physical risk before adaptation; from FY 2027, E1-11 carrying amount | Limited only (Omnibus deleted reasonable escalation) | In effect (Wave 1) |
| CDP | Global | Voluntary | Any organization (investor/customer request) | Annual cycle | Scoring-based | TCFD-aligned; SSP/NGFS accepted | question 3.1.1: 29 hazard categories, per-risk table | Voluntary | Active (2026 cycle) |
| TCFD | Global | Disbanded (Oct 2023) | Was voluntary; 4,800+ supporters | 2017-2023 (now ISSB) | Single (financial) | 2C or lower scenario recommended | Acute/chronic; EBRD: 6 first-order impacts | N/A | Disbanded; ISSB builds on it |
| TNFD | Global | Voluntary | None required; any organization may adopt | Sep 2023 | Financial baseline (ISSB); impact optional | TNFD nature scenarios; used in LEAP Assess | Nature-related physical risks (location-specific) | Voluntary | Active, growing adoption |
| SEC Climate Rule | US | Adopted, never effective | SEC registrants, phased | Never enforced | Single (financial) | Not required | Material physical risks with property locations (Item 1502); 1% financial statement threshold | Limited to reasonable (phased) | Stayed; rescission proposed |
| CA SB 261 | California | Mandatory | US firms, $500M+ revenue, doing business in CA | Jan 2026 (paused) | Single (financial) | Resilience under climate scenarios expected; may be qualitative (CARB checklist) | TCFD-aligned: acute/chronic physical risks | None | Under injunction |
| AASB S2 | Australia | Mandatory | Groups 1-3 (revenue AU$500M to AU$50M, two-of-three size tests; NGER reporters; AU$5B asset owners) | Group 1: Jan 2025 | Single (financial) | Legislated: at least 1.5°C and well exceeding 2°C | Para 29(c): identical to IFRS S2 | Mandatory: limited to reasonable | In effect (Groups 1 and 2) |
| BRSR | India | Mandatory | Top 1,000 listed (market cap) | FY 2022-23 | Principle-based | Not required | Q24: material ESG issues (qualitative) | Assessment or assurance (BRSR Core, phased) | In effect |
Framework-by-Framework Summaries
IFRS S2 (Global Baseline)
IFRS S2, issued by the International Sustainability Standards Board (ISSB), sets the global baseline for climate-related disclosures. It requires entities to identify and classify physical and transition risks, assess climate resilience through scenario analysis (Paragraph 22), and report the amount and percentage of assets vulnerable to physical risks (Paragraph 29(c)). The standard uses financial materiality and requires scenario analysis, leaving the choice of scenarios to the entity, which must disclose whether it used a diverse range and a Paris-aligned scenario.
More than 45 jurisdictions are using the ISSB Standards or taking steps to introduce them, according to the IFRS Foundation in August 2026. UK SRS S2 and AASB S2 are both built on IFRS S2 with jurisdiction-specific modifications. Read our full IFRS S1 and S2 guide.
UK SRS S2 (United Kingdom)
The UK Sustainability Reporting Standards are based on IFRS S2, with a small number of UK changes to transition reliefs, the effective date, compliance statements, financed emissions and the status of industry guidance. The core physical-risk paragraphs are unchanged. For UK-listed companies moving from TCFD, Paragraph 29(c) turns a metric the TCFD only suggested into a requirement: the “amount and percentage of assets or business activities vulnerable to climate-related physical risks.”
UK SRS became available for voluntary use on February 25, 2026. Under its final rules (PS26/19, September 30, 2026), the FCA applies them to listed companies on a comply-or-explain basis for periods starting on or after January 1, 2027. UK SRS S1 also drops the first-year relief that lets companies report after their financial statements. Read our full UK SRS guide.
CSRD and ESRS E1 (European Union)
The Corporate Sustainability Reporting Directive (CSRD) requires reporting under European Sustainability Reporting Standards (ESRS). ESRS E1 covers climate change. Today, companies describe how they identify physical climate hazards, considering at least high emission climate scenarios, and report the amount and share of assets at material physical risk before adaptation (E1-9). The revised ESRS, Delegated Regulation (EU) 2026/1563, applies from FY 2027. It asks for the key elements of the screening method (E1-2) and for the carrying amount of assets at material physical risk before adaptation, plus the percentage covered by adaptation actions (E1-11).
CSRD is the only mandatory framework in this guide that uses double materiality, assessing both financial risk and environmental impact. The Omnibus simplification limited the CSRD to companies with more than EUR 450 million in net turnover and more than 1,000 employees, cutting coverage from an estimated 50,000 to around 5,000 EU companies. Wave 2 was delayed to FY 2027 via the Stop-the-Clock directive. See also: CSRD reporting requirements.
CDP (Global, Voluntary)
CDP’s climate change questionnaire provides one of the most granular physical risk disclosure mechanisms. Question 3.1.1 requires reporting each physical risk with a specific hazard from a dropdown of 29 categories (16 acute, 13 chronic), along with time horizon, likelihood, magnitude, and financial impact. Quantifying financial effects across all three time horizons in question 3.1.1 earns points at the Management level and above.
CDP accepts IPCC SSP and NGFS scenarios for scenario analysis. While CDP is technically voluntary, investor and customer requests make it functionally mandatory for large companies. Under the CDP A-List criteria, physical risk depth still separates the A List from lower scores, although CDP removed its risk-process criteria at the Management and Leadership levels in 2026. See also: CDP scoring methodology.
California SB 261 and SB 253 (United States)
California’s two climate laws target different aspects of disclosure. SB 261 requires climate-related financial risk reports, prepared under the TCFD recommendations, the ISSB standards, or an equivalent government reporting requirement, from US companies with over $500M in annual revenue that do business in California. SB 253 mandates GHG emissions reporting (Scopes 1, 2, and 3) from US companies with over $1B in revenue, and CARB has set a first deadline of November 10, 2026.
SB 261 has been under a Ninth Circuit injunction since November 2025, and CARB accepts voluntary reports in the meantime. CARB’s board approved an initial regulation in February 2026. CARB revised it and resubmitted it for final state approval on September 21, 2026. SB 253 is not subject to that injunction.
TCFD (Disbanded in 2023)
The Task Force on Climate-related Financial Disclosures established the foundational four-pillar structure (Governance, Strategy, Risk Management, Metrics and Targets) that most subsequent frameworks build on. The TCFD disbanded in October 2023, and the IFRS Foundation states that its recommendations are fully incorporated into IFRS S1 and IFRS S2.
TCFD remains relevant as the framework SB 261 names for its reports and as a stepping stone for entities not yet adopting IFRS S2. The EBRD’s 2018 supplementary guidance on physical risk remains one of the most specific: it suggests value-at-risk from probabilistic estimates, such as 1-in-100 or 1-in-200 events. Read our full TCFD guide.
AASB S2 (Australia)
AASB S2 carries over IFRS S2’s physical risk requirements, including Paragraph 29(c), and the Corporations Act adds a scenario rule on top. Climate resilience must be assessed using at least two scenarios: one that limits warming to 1.5°C and one that well exceeds 2°C. ASIC guidance, citing the Explanatory Memorandum, treats 2.5°C or higher as well exceeding 2°C. IFRS S2 itself asks only whether the entity used a scenario aligned with the latest international agreement on climate change.
Group 1 entities began mandatory reporting for financial years starting on or after 1 January 2025 and Group 2 from 1 July 2026, with Group 3 following from 1 July 2027. For financial years starting between 1 January 2025 and 31 December 2027, modified liability shields statements on scenario analysis, Scope 3 and transition plans from private lawsuits, though ASIC actions and criminal proceedings can still proceed. Assurance starts at limited and reaches reasonable for financial years starting on or after 1 July 2028 for Group 1, 1 July 2029 for Group 2 and 1 July 2030 for Group 3.
TNFD (Global, Voluntary)
The TNFD framework addresses nature-related financial disclosures through its LEAP approach (Locate, Evaluate, Assess, Prepare). Physical climate risks intersect directly with nature risks: flooding damages ecosystems, drought affects water-dependent supply chains, and wildfire degrades natural capital. In defining nature-related physical risks, the TNFD states that “these risks are usually location-specific,” making geospatial data foundational to TNFD-aligned reporting.
TNFD is voluntary, and no jurisdiction requires it by name, but nature disclosure is already required in places: EU companies in CSRD scope report on biodiversity under ESRS E4 when it is material, and France requires certain financial institutions to report biodiversity risks. As of July 2025, 620 organizations with over USD 20 trillion in assets under management had committed to TNFD-aligned reporting. In July 2026 the ISSB approved balloting an exposure draft of a proposed IFRS Practice Statement on nature-related disclosures, with a 120-day comment period.
SEC Climate Disclosure Rule (United States)
The SEC climate disclosure rule (Release No. 33-11275) takes a distinct approach from other frameworks. Its financial statement rule names seven example events (hurricanes, tornadoes, flooding, drought, wildfires, extreme temperatures, sea level rise). It uses bright-line thresholds of 1% of pre-tax income or loss for expensed costs, and 1% of stockholders’ equity for capitalized costs. Amounts under $100,000 and $500,000 are exempt.
The rule was adopted in March 2024 and stayed by the SEC in April 2024. The SEC ended its defense in March 2025, and the Eighth Circuit put the case on hold in April 2025. In May 2026 the SEC proposed rescinding it. Comments closed on August 3, 2026, and as of October 2026 the SEC has not voted on a final repeal. The court case remains on hold, and on May 21, 2026 the court refused to restart it. The rule has never gone into effect. Scope 3 emissions were eliminated from the final rule entirely.
BRSR (India)
BRSR is SEBI’s sustainability reporting mandate for India’s top 1,000 listed companies by market cap. Climate risk surfaces primarily through Question 24, which requires identifying material ESG issues and their financial implications. BRSR does not require scenario analysis or specify physical hazards, and it treats climate risk qualitatively.
BRSR Core, a subset of nine key ESG attributes, requires third-party assessment or assurance on a phased schedule: top 150 entities from FY 2023-24, expanding to all top 1,000 by FY 2026-27. The framework’s Principle 6 covers environmental disclosures including energy, water, and emissions.
Physical Risk Disclosure Requirements Compared
Every climate disclosure framework requires some form of physical risk reporting, but the specifics vary widely. IFRS S2 and AASB S2 demand quantified asset-level vulnerability metrics. BRSR asks only for qualitative identification of material issues. This table compares what each framework actually requires for physical climate risk data, which matters for teams trying to build a single data pipeline that satisfies multiple frameworks.
| Framework | Hazard Types | Scenario Analysis | Time Horizons | Data Granularity | Financial Impact |
|---|---|---|---|---|---|
| IFRS S2 | Physical or transition for each risk (para 10(b)); acute and chronic defined in Appendix A | Required; discloses whether Paris-aligned used | Short/medium/long (entity-defined) | Assets or business activities (Para 29c) | Quantitative preferred |
| UK SRS S2 | Identical to IFRS S2 | Identical to IFRS S2 | Identical to IFRS S2 | Assets or business activities (Para 29c) | Identical to IFRS S2 |
| CSRD / ESRS E1 | Acute/chronic with documented sources | High emission scenarios inform physical hazard identification | Short (0-1yr), Medium (1-5yr), Long (5+yr) | Assets at material physical risk, with location of significant assets (E1-9); E1-11 from FY 2027 | Amount before adaptation; % addressed by adaptation (carrying amount from FY 2027) |
| CDP | 29 dropdown categories (16 acute + 13 chronic) | TCFD-aligned; SSP/NGFS accepted | Short/medium/long per risk entry | Per-location with likelihood and magnitude | Quantitative for Management tier+ |
| TCFD | Acute + chronic; EBRD: 6 first-order impacts | 2C or lower; EBRD: 1:100/1:200 VaR | Company-determined | Asset and portfolio level | Business interruption, repair, impairment |
| TNFD | Nature degradation risks; land-use change a key driver | TNFD nature scenarios; used in LEAP Assess | Aligned with risk horizon | Location-specific | Nature dependency/impact quantification |
| SEC Rule | 7 named hazards | Not required | Not prescribed | Property/asset-level (S-K Item 1502) | 1% threshold (pre-tax income or equity) |
| CA SB 261 | TCFD-aligned (not enumerated) | Resilience under climate scenarios expected; may be qualitative (CARB checklist) | Short, medium and long term; reports every two years | Not specified (narrative report) | Describe impacts where material; may be qualitative |
| AASB S2 | Same as IFRS S2 (acute and chronic, entity-identified) | Legislated: at least 1.5°C + well exceeding 2°C | Entity-defined short, medium and long term | Assets or business activities (Para 29c) | Quantitative unless Paras 19-20 apply; modified liability for financial years starting 1 Jan 2025 to 31 Dec 2027 |
| BRSR | Not enumerated (Q24) | Not required | Not prescribed | Location-level | Qualitative (financial implications narrative) |
Platforms like Continuuiti address these requirements by assessing 12 climate hazards across multiple SSP scenarios and time horizons, providing the structured hazard data and flood damage estimates that feed into asset vulnerability disclosures under IFRS S2 Paragraph 29(c), ESRS E1-9 (E1-11 from FY 2027), and CDP question 3.1.1. For a deeper look at how scenario analysis requirements compare across frameworks, see our dedicated guide.
Organizations building a single data pipeline to satisfy multiple frameworks at once can use Continuuiti’s Climate Risk API for the underlying physical-risk layer. The same 12-hazard output is formatted to satisfy IFRS S2, ESRS E1, and CDP requirements simultaneously.
Which Framework Applies to You?
Most companies are subject to more than one climate disclosure framework. The primary driver is jurisdiction, but listing status, revenue thresholds, and voluntary commitments also determine obligations.
EU companies with more than EUR 450 million in net turnover and more than 1,000 employees fall under CSRD from FY 2027, and non-EU groups with more than EUR 450 million of EU turnover and an EU subsidiary or branch above EUR 200 million report from FY 2028. Climate (ESRS E1) is the one topic a company must explain in detail if it concludes it is not material. Companies with more than 5,000 employees and EUR 1.5 billion in net worldwide turnover also face CSDDD due diligence obligations from July 2029.
UK-listed companies should prepare for UK SRS S2, which listed companies apply on a comply-or-explain basis for periods starting on or after January 2027. Those reporting under TCFD will need to move from mostly narrative risk descriptions to the Paragraph 29(c) metric.
US-based public companies face an uncertain federal landscape, with the SEC rule stayed and proposed for rescission. California’s SB 253 (GHG reporting, $1B+ revenue) is in effect, and CARB has set a first deadline of November 10, 2026. SB 261 (climate risk reporting, $500M+ revenue) is paused by injunction.
Australian companies meeting Group 1, 2, or 3 thresholds report under AASB S2, which is already in effect for Groups 1 and 2. Australia’s Corporations Act requires at least a 1.5°C scenario and one that well exceeds 2°C.
Indian listed companies in the top 1,000 by market cap file BRSR reports annually. BRSR Core assessment or assurance is expanding from the top 150 to the top 1,000 entities by FY 2026-27.
Any company facing investor or customer pressure to disclose should consider CDP, which functions as a de facto mandatory standard for companies in global supply chains. TNFD is voluntary but gaining traction for companies with nature-related dependencies.
How Climate Disclosure Frameworks Overlap
Companies subject to multiple frameworks often ask whether the same physical risk data can satisfy more than one standard. Largely yes, because most frameworks trace back to TCFD’s four-pillar structure or IFRS S2’s global baseline.
| If you comply with… | You also substantially cover… | Key gap to fill |
|---|---|---|
| IFRS S2 | TCFD (fully), UK SRS S2 (largely), AASB S2 (mostly), CDP physical risk section | The Corporations Act requires a 1.5°C scenario and one well exceeding 2°C for AASB S2 reports; CSRD adds impact materiality |
| CSRD / ESRS | IFRS S2 (mostly, via the joint EFRAG and IFRS Foundation interoperability guidance), CDP climate disclosure | CSRD’s double materiality and value chain scope exceed IFRS S2’s financial-only lens |
| CDP (A-List level) | TCFD (fully), IFRS S2 physical risk metrics (substantially) | CDP’s 29-hazard dropdown is more granular than IFRS S2’s open taxonomy; CDP says its questionnaire does not strictly fulfil IFRS S2 |
| TCFD | SB 261 (directly referenced), partial coverage of CDP and IFRS S2 | IFRS S2 adds industry metrics and makes the Paragraph 29 cross-industry metrics required |
The practical takeaway: companies that build a location-level, scenario-based physical climate risk assessment pipeline can reuse that data across IFRS S2, CSRD, CDP, and SB 261 disclosures. The differences sit mainly in reporting format and materiality framing, and the underlying climate data is largely the same. For the connection between physical and transition risk, and how they interact in portfolio-level disclosure, see our dedicated guide. Background on the scenario frameworks themselves is covered in our climate scenario analysis and NGFS scenarios guides.
Frequently Asked Questions
What are the main climate disclosure frameworks?
The main climate disclosure frameworks are IFRS S2 (global baseline), CSRD/ESRS E1 (EU), CDP (voluntary, global), UK SRS S2 (UK), AASB S2 (Australia), BRSR (India), the SEC Climate Disclosure Rule (US, stayed and proposed for rescission), and California’s SB 261 and SB 253. TCFD was the foundational framework; it disbanded in October 2023, and IFRS S2 builds on it. TNFD covers nature-related disclosures with significant climate overlap.
Is TCFD still required?
The TCFD disbanded in October 2023, and its recommendations are voluntary. The IFRS Foundation states that companies applying IFRS S1 and IFRS S2 will meet the TCFD recommendations. Some rules still refer to them. UK listing rules require listed companies to report against TCFD on a comply or explain basis, and the FCA’s final rules move them to UK SRS for periods starting on or after January 1, 2027. California’s SB 261 accepts reports prepared under the TCFD recommendations, the ISSB standards, or an equivalent government reporting requirement, but a court injunction has paused enforcement since November 2025.
What is the difference between CSRD and ISSB?
CSRD and ISSB differ primarily in materiality approach. CSRD uses double materiality, assessing both financial risk and environmental impact. IFRS S2 uses single financial materiality focused on investor decision-making. CSRD requires reporting under ESRS standards, where physical hazard identification must consider high emission climate scenarios, while IFRS S2 gives entities more flexibility. The IFRS Foundation and EFRAG published joint interoperability guidance in May 2024 showing where the two align. See our full CSRD vs ISSB comparison.
Which climate disclosure frameworks require scenario analysis?
IFRS S2, UK SRS S2, CSRD/ESRS E1, CDP, and AASB S2 all require or recommend scenario analysis. In Australia, the Corporations Act requires AASB S2 scenario analysis to use at least two scenarios: one that limits warming to 1.5°C and one that well exceeds 2°C. Under CSRD, physical hazard identification must consider high emission climate scenarios, and from FY 2027 companies that run scenario analysis say whether they used one. CDP accepts IPCC SSP and NGFS scenarios. The SEC rule and BRSR do not require scenario analysis. For the first SB 261 reports, CARB’s guidance asks for a discussion of how strategy holds up under climate scenarios, and that discussion can be qualitative.
Do climate disclosure frameworks require asset-level data?
Most major frameworks require or recommend asset-level data. IFRS S2, UK SRS S2, and AASB S2 Paragraph 29(c) require the “amount and percentage of assets or business activities vulnerable to climate-related physical risks,” which in practice usually needs location-level assessment. CSRD’s ESRS E1 requires the amount of assets at material physical risk (E1-9 today; the carrying amount under E1-11 from FY 2027). CDP calls for per-location risk reporting. BRSR requires only location-level risk identification without quantitative metrics. See our physical climate risk assessment guide for methodology details, or learn more about our climate risk methodology.
