IFRS S2 Mandatory in Mexico: What Listed Companies Must Disclose by 2026
IFRS S2 Mandatory in Mexico: What Listed Companies Must Disclose by 2026
Mexico's CNBV made IFRS S2 mandatory for all companies listed on the BMV (Mexican Stock Exchange) and BIVA on January 29, 2025. Companies must disclose climate-related financial information across four pillars — Governance, Strategy, Risk Management, and Metrics & Targets — with the first report covering fiscal year 2025 data, due in 2026. This makes Mexico the first country in North America to mandate ISSB standards.
CNBV Mandate — Key Facts
Fact | Detail |
|---|---|
Regulatory authority | CNBV (Comisión Nacional Bancaria y de Valores) |
Mandate date | January 29, 2025 |
Legal instrument | Amendment to Circular Única de Emisoras |
Applies to | All issuers listed on BMV and BIVA |
First report | FY2025 data, filed in 2026 |
Limited assurance | FY2026 data, filed 2027 |
Reasonable assurance | FY2027 data, filed 2028 |
Mandatory Disclosures Under IFRS S2 — Four Pillars
Pillar 1: Governance
Companies must disclose:
The board's role in overseeing climate-related risks and opportunities
Which board committee (audit, sustainability, risk) has climate oversight
Management's role in assessing and managing climate issues
How the board ensures management accountability for climate targets
Pillar 2: Strategy
Companies must disclose:
Climate-related risks and opportunities identified for short, medium, and long-term horizons
Impact of these risks on business model, value chain, strategy, and financial planning
Effects on financial position, performance, cash flows, financing, and cost of capital
Transition plan (if the company has one)
Climate scenario analysis — qualitative or quantitative analysis using at least two scenarios (one must be consistent with 1.5°C or 2°C warming)
Climate resilience of strategy
Pillar 3: Risk Management
Companies must disclose:
Processes used to identify and assess climate-related risks
Processes used to manage (prioritize, monitor, respond to) climate risks
How climate risk management is integrated into the enterprise risk management (ERM) framework
Pillar 4: Metrics and Targets
Mandatory quantitative disclosures:
Metric | Details |
|---|---|
Scope 1 GHG emissions | Direct emissions from owned or controlled sources (tCO₂e) |
Scope 2 GHG emissions | Indirect emissions from purchased energy — both market-based and location-based (tCO₂e) |
Scope 3 GHG emissions | All indirect value chain emissions — 15 categories (tCO₂e) [transition relief through 2026] |
Physical risk exposure | Quantitative or qualitative assessment of assets/revenues exposed to climate physical risks |
Targets | Climate-related targets, timeframe, baseline, milestones, and performance |
Climate Scenario Analysis — What's Required
This is the most technically demanding disclosure. Under IFRS S2, Mexican issuers must:
Use at least two climate scenarios (one consistent with 1.5°C or well-below-2°C)
Assess both physical risks (floods, drought, extreme heat) and transition risks (carbon pricing, policy changes)
Explain the time horizons used (short: 0-5 years, medium: 5-20, long: 20+ years)
Identify which climate risks and opportunities are material to the business
Describe the impact on financial position under each scenario
Scenario sources accepted: IPCC, IEA (Net Zero Emissions by 2050, Stated Policies), NGFS
Scope 3 — The Challenge and the Relief
IFRS S2 requires Scope 3 disclosures but grants a transition relief period:
First year of compliance (FY2025): Scope 3 not required
From FY2026 onward: Scope 3 required (reported in 2027)
Why this matters: Building Scope 3 data collection capability takes 12-18 months. Companies that haven't started are already behind.
The 15 Scope 3 categories to eventually report:
Purchased goods and services
Capital goods
Fuel and energy-related activities
Upstream transportation
Waste in operations
Business travel
Employee commuting
Upstream leased assets
Downstream transportation
Processing of sold products
Use of sold products
End-of-life treatment of sold products
Downstream leased assets
Franchises
Investments
Key Differences from Voluntary ESG Reporting
Companies already filing voluntary sustainability reports (GRI, CDP, TCFD) will find differences:
Aspect | Voluntary GRI | Mandatory IFRS S2 |
|---|---|---|
Materiality | Double (financial + impact) | Single financial materiality |
Assurance | Optional | Required from 2027 |
Format | Flexible | Structured, standardized |
Auditor involvement | Rare | Increasing from 2027 |
Primary audience | Broad stakeholders | Investors, regulators |
What "Audit-Ready" Data Actually Means
For limited assurance in 2027, every sustainability disclosure must have:
Source documentation: Utility bills, travel records, supplier invoices
Calculation methodology: Which emission factors were used, from which source, for which year
Data trail: Who collected the data, when, from which system
Controls: Internal review process, approval chain
Manual Excel-based collection fails this standard. A company with 20+ plants, multiple subsidiaries, or complex supply chains needs automated data collection to survive external review.
Frequently Asked Questions
Can we use our existing CDP or TCFD report to comply with IFRS S2?
Partially. IFRS S2 is based on the TCFD framework, so TCFD-aligned disclosures address the structure. However, IFRS S2 requires more specific quantitative disclosures, climate scenario analysis to specific standards, and will eventually require external assurance. Your CDP or TCFD report is a good starting point, not a complete solution.
Are small listed companies exempt from any disclosures?
CNBV's mandate applies uniformly to all issuers. The IFRS S2 standard does allow for proportionality considerations in some judgments, but there are no formal size exemptions for the core disclosure requirements.
What does "climate scenario analysis" require in practice?
At minimum, select two publicly available scenarios (e.g., IEA's Net Zero 2050 and Stated Policies Scenario), identify which physical and transition risks are material to your business, and explain the impact of those risks under each scenario on your business model and financial position. The analysis can initially be qualitative for some elements.
When does the CNBV mandate limited assurance?
Limited assurance applies starting with FY2026 disclosures (to be filed in 2027). This means the data you collect in 2026 will need to withstand external review in 2027. Starting your assurance readiness process in 2025 is the recommended approach.
Get Audit-Ready for CNBV's IFRS S2 Mandate
Climatta provides an audit-ready platform for collecting Scope 1, 2, and 3 GHG data — built specifically for Mexican listed companies preparing for CNBV's IFRS S2 mandate. Request a demo to see how we can help your team meet the 2026 disclosure deadline with confidence.