Willis highlights divergence in climate reporting rules

Data compiled by Willis highlights increased divergence in climate disclosure regimes, as economic conditions and policy changes affect timelines and scope.

According to the risk adviser’s latest Climate Reporting Comparative Table, published today, adoption of the International Sustainability Standards Board’s IFRS S2 standard is advancing, with jurisdictions representing almost 60% of global GDP moving towards mandatory use. However, progress varies across regions.

In the EU, Omnibus amendments to the Corporate Sustainability Reporting Directive, adopted on 24 February 2026, reduce its scope to companies with more than 1,000 employees and over €450m in net turnover, and delay reporting for many firms. Further revisions to the European Sustainability Reporting Standards are expected.

In the US, California’s SB 253 is progressing, with Scope 1 and 2 emissions disclosures expected in 2026 and Scope 3 to follow. SB 261 remains paused due to ongoing litigation.

The UK published Sustainability Reporting Standards S1 and S2 on 25 February 2026, based on IFRS standards, for voluntary use. The Financial Conduct Authority is consulting on mandatory rules for listed companies, with implementation expected from January 2027, including requirements to quantify climate-related financial risks.

Separately, the European Commission introduced changes to the EU Taxonomy from January 2026, including a 10% materiality threshold and simplified reporting templates.

Muhammed Anwar, a senior director at the firm’s climate practice, said: “External stakeholders continue to judge and value businesses on responses to climate-related risks and regulations. Many lenders and investors in particular continue to embed climate and sustainability factors into their own processes and decision-making.

“This means if a business is unable to demonstrate a detailed understanding of their climate risks and plans to manage them effectively, capital may become more expensive. It may shift toward organisations with more persuasive positions on climate risk, including those committed to staying on the front foot by embracing climate reporting requirements. Customers may also choose businesses with stronger climate risk stories.”



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