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 (Apr 2026) |
|---|---|---|---|---|---|---|---|---|---|
| IFRS S2 | Global | Voluntary baseline | All entities (via national adoption) | Jan 2024 | Single (financial) | Entity chooses; diverse range recommended | Para 29(c): amount and % of assets vulnerable | Left to regulators | Active global baseline |
| UK SRS S2 | UK | Mandatory (proposed) | FCA-listed companies | Jan 2027 (proposed) | Single (financial) | Identical to IFRS S2 | Para 29(c): identical to IFRS S2 | TBD by FCA | FCA consultation open |
| CSRD / ESRS E1 | EU | Mandatory | 1,000+ employees (post-Omnibus) | Wave 1: FY 2024; Wave 2: FY 2027 | Double (financial + impact) | High-emissions scenario mandatory | E1-2: hazard screening; E1-11: carrying amount of exposed assets | 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 | C2.3a: 29 hazard categories, per-risk table | Voluntary | Active (2025 questionnaire) |
| TCFD | Global | Dissolved (Oct 2023) | Was voluntary; adopted by ~30 jurisdictions | 2017-2023 (now ISSB) | Single (financial) | 2C or lower scenario recommended | Acute/chronic; EBRD: 6 first-order impacts | N/A | Dissolved into ISSB |
| TNFD | Global | Voluntary | Any organization | Sep 2023 | Double (financial + impact) | LEAP approach; climate scenarios inform assessment | Nature-related physical risks (location-specific) | Voluntary | Active, growing adoption |
| SEC Climate Rule | US | Mandatory (if enforced) | Large Accelerated and Accelerated Filers | Never enforced | Single (financial) | Not required | 1% materiality threshold; 7 hazards named | Limited to reasonable (phased) | Stayed, undefended |
| CA SB 261 | California | Mandatory | $500M+ revenue in CA | Jan 2026 (paused) | Single (financial) | TCFD-aligned (not required Year 1) | TCFD-aligned: acute/chronic physical risks | None | Under injunction |
| AASB S2 | Australia | Mandatory | Groups 1-3 (AU$500M to AU$50M) | Group 1: Jan 2025 | Single (financial) | Legislated: 1.5C AND >2.5C | Para 29(c): identical to IFRS S2; 10 NCRA hazards | Mandatory: limited to reasonable | In effect (Group 1) |
| BRSR | India | Mandatory | Top 1,000 listed (market cap) | FY 2022-23 | Principle-based | Not required | Q24: material ESG issues (qualitative) | Reasonable (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 leaves scenario selection to the reporting entity, though it recommends a diverse range including Paris-aligned pathways.
Over 30 jurisdictions have adopted or are adopting IFRS S2 as their national standard. 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 adopt IFRS S2 almost verbatim, with 9 amendments. None of these amendments change the physical risk disclosure requirements. UK-listed companies moving from TCFD to mandatory UK SRS reporting face a step change in quantitative rigor: Paragraph 29(c) requires the “amount and percentage of assets vulnerable to climate-related physical risks,” moving beyond TCFD’s qualitative narrative approach.
Voluntary application began February 25, 2026. Mandatory reporting is proposed from January 1, 2027 under FCA Consultation CP26/5, with no first-year timing relief. 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, including a physical risk screening requirement (E1-2) that mandates at least one high-emissions scenario and documented data sources. E1-11 requires disclosure of the carrying amount of materially exposed assets before adaptation measures and the percentage covered by adaptation actions.
CSRD is the only major framework using double materiality, assessing both financial risk and environmental impact. The Omnibus simplification raised the scope threshold to 1,000+ employees, reducing coverage from ~50,000 to ~10,000 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 C2.3a 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. Completing C2.3a with quantified financial effects across all three time horizons is a requirement for Management-tier scoring 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. CDP A-List criteria require comprehensive physical risk assessment. 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 TCFD-aligned climate-related financial risk reports from companies with $500M+ revenue doing business in California. SB 253 mandates GHG emissions reporting (Scopes 1, 2, and 3) from companies with $1B+ revenue, with the first deadline on August 10, 2026.
SB 261 is currently under a Ninth Circuit injunction (November 2025), though CARB approved implementing regulations in February 2026 and approximately 100 entities submitted voluntary reports. SB 253 is not subject to that injunction and remains in effect.
TCFD (Dissolved into ISSB)
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 officially dissolved in October 2023, with IFRS S2 fully incorporating all 11 TCFD recommendations.
TCFD remains relevant as the reference framework for SB 261 and as a stepping stone for entities not yet adopting IFRS S2. The EBRD’s supplementary guidance on physical risk remains one of the most specific: it recommends probabilistic estimates (1:100 or 1:200 return periods) for forward-looking value-at-risk calculations. Read our full TCFD guide.
AASB S2 (Australia)
AASB S2 adopts IFRS S2’s physical risk requirements (including Paragraph 29(c)) but adds a distinctive feature: the Corporations Act legislates exactly two scenario analysis temperatures. Entities must assess resilience under a 1.5C scenario and a “well exceeding 2C” scenario, which ASIC has clarified means 2.5C or higher. No other framework prescribes specific temperature thresholds by law.
Group 1 entities (AU$500M+ revenue) began mandatory reporting from January 2025. A three-year modified liability provision protects entities from civil litigation related to scenario analysis and Scope 3 disclosures, though ASIC enforcement actions are not covered. Assurance begins at limited and escalates to reasonable from Year 4 (approximately July 2030 for Group 1) under ASSA 5000.
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. The TNFD explicitly states that “nature-related physical risks are usually location-specific,” making geospatial data foundational to compliance.
TNFD remains voluntary with no regulatory mandate globally as of April 2026, but adoption is growing among large financial institutions and asset managers. EU regulators are considering nature-related disclosures in future CSRD revisions.
SEC Climate Disclosure Rule (United States)
The SEC climate disclosure rule (Release No. 33-11275) takes a distinct approach from other frameworks. It names seven specific physical hazards (hurricanes, tornadoes, flooding, drought, wildfires, extreme temperatures, sea level rise) and uses financial statement materiality thresholds rather than scenario analysis: expensed losses of at least 1% of pre-tax income or $100,000, and capitalized costs of at least 1% of stockholders’ equity or $500,000.
The rule was adopted in March 2024 but voluntarily stayed in April 2024. The SEC withdrew its defense in March 2025, and the Eighth Circuit has ordered the SEC to either rescind or renew its defense. 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. Unlike IFRS S2 or CSRD, BRSR does not require scenario analysis, does not specify physical hazards, and addresses climate risk qualitatively rather than quantitatively.
BRSR Core, a refined subset of nine key ESG attributes, requires mandatory reasonable 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 | Acute/chronic (entity determines) | Entity chooses; diverse range incl. Paris-aligned | Short/medium/long (entity-defined) | Asset-level (Para 29c) | Quantitative preferred |
| UK SRS S2 | Identical to IFRS S2 | Identical to IFRS S2 | Identical to IFRS S2 | Asset-level (Para 29c) | Identical to IFRS S2 |
| CSRD / ESRS E1 | Acute/chronic with documented sources | High-emissions mandatory for physical risk | Short (0-1yr), Medium (1-5yr), Long (5+yr) | Asset-level for financial effects (E1-11) | Carrying amount before adaptation; % covered |
| 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 | Climate-related nature risks; LULC changes | LEAP approach; climate scenarios inform phases | 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) | TCFD-aligned (not required Year 1) | Biennial reporting | Asset and portfolio level | Qualitative; quantitative encouraged |
| AASB S2 | IFRS S2 + 10 NCRA priority hazards | Legislated: 1.5C + >2.5C | 2030/2040/2050 | Asset-level (Para 29c) | Quantitative; 3-year modified liability |
| 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 E1-11, and CDP C2.3a. 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-headquartered or EU-operating companies with 1,000+ employees fall under CSRD (post-Omnibus threshold). ESRS E1 climate disclosures apply automatically. Companies with significant supply chains also need to prepare for CSDDD due diligence obligations from July 2029.
UK-listed companies should prepare for UK SRS S2 mandatory reporting from January 2027. Those currently reporting under TCFD will need to shift from qualitative risk narratives to quantitative asset-level metrics.
US-based public companies face an uncertain federal landscape with the SEC rule stayed and undefended. California’s SB 253 (GHG reporting, $1B+ revenue) is in effect with a first deadline of August 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 Group 1. Australia’s legislated scenario temperatures (1.5C and >2.5C) are the most prescriptive of any jurisdiction.
Indian listed companies in the top 1,000 by market cap file BRSR reports annually. BRSR Core reasonable 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. The short answer: 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 (fully), AASB S2 (mostly), CDP physical risk section | AASB S2 requires legislated temperature scenarios; CSRD adds impact materiality |
| CSRD / ESRS | IFRS S2 (mostly, via EFRAG interoperability mapping), 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 |
| TCFD | SB 261 (directly referenced), partial coverage of CDP and IFRS S2 | IFRS S2 adds industry metrics and Paragraph 29 quantitative thresholds beyond TCFD |
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 are primarily in reporting format and materiality framing, not in the underlying climate data. 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, currently stayed), and California’s SB 261 and SB 253. TCFD was the foundational framework but dissolved into the ISSB (IFRS S2) in October 2023. TNFD covers nature-related disclosures with significant climate overlap.
Is TCFD still required?
TCFD officially disbanded in October 2023 and its recommendations were fully incorporated into IFRS S2. Companies applying IFRS S2 automatically satisfy all TCFD requirements. TCFD remains the reference framework for California’s SB 261 and is still used by entities that have not yet transitioned to IFRS S2. The UK is moving from TCFD to UK SRS S2, with mandatory reporting proposed from January 2027.
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 with a mandatory high-emissions scenario, while IFRS S2 gives entities more flexibility. EFRAG has published interoperability guidance 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. AASB S2 is the most prescriptive, legislating specific temperatures (1.5C and above 2.5C). CSRD mandates at least one high-emissions scenario for physical risk. CDP accepts IPCC SSP and NGFS scenarios. The SEC rule, SB 261 (Year 1), and BRSR do not require scenario analysis.
Do climate disclosure frameworks require asset-level data?
Most major frameworks require or recommend asset-level data. IFRS S2 Paragraph 29(c), UK SRS S2 Paragraph 29(c), and AASB S2 Paragraph 29(c) require the “amount and percentage of assets vulnerable to climate-related physical risks,” which necessitates location-level assessment. CSRD’s ESRS E1-11 requires the carrying amount of exposed assets. 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.
