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Sustainability Disclosure in Pakistan: What the SECP's Adoption of IFRS S1 and S2 Means for Companies

Which Pakistani companies must report under IFRS S1 and S2, from when, the size thresholds for each phase, assurance, and how to prepare.

PIVRA · 15 October 2026 · 7 min read

Pakistan has made the International Sustainability Standards Board’s standards mandatory. The SECP adopted IFRS S1 (general sustainability disclosures) and IFRS S2 (climate-related disclosures) in phases, and the second phase began with reporting periods starting on 1 July 2026. This guide sets out who is covered, from when, and how to prepare.

What was adopted

By an order of 31 December 2024 under section 238 of the Companies Act 2017, the SECP mandated IFRS S1, General Requirements for Disclosure of Sustainability-related Financial Information, and IFRS S2, Climate-related Disclosures (SECP press release; IFRS Foundation, Pakistan jurisdiction profile).

Who is covered, and when

PhaseReporting periods beginning on or afterCompanies covered
I1 July 2025Listed companies meeting any two of: turnover above Rs 25 billion in the last two consecutive years, more than 1,000 employees, total assets above Rs 12.5 billion
II1 July 2026Listed companies meeting any two of: turnover above Rs 12.5 billion, more than 500 employees, total assets above Rs 6.25 billion
III1 July 2027All other listed companies, and non-listed public interest companies licensed or registered with the SECP

Source: IFRS Foundation, Pakistan jurisdiction profile. Early application is permitted and encouraged.

Reliefs and assurance

  • For the first annual reporting period, companies may publish the sustainability report separately within nine months of the financial year end.
  • Assurance on the disclosures is required from the second year of reporting.

What the standards ask for

IFRS S1 requires disclosure of sustainability-related risks and opportunities that could reasonably be expected to affect a company’s prospects, organised around governance, strategy, risk management, and metrics and targets. IFRS S2 applies the same structure to climate: physical and transition risks, the resilience of the strategy, greenhouse gas emissions and climate targets. Both are designed to sit alongside the financial statements, for investors.

How to prepare

  1. Confirm your phase against the thresholds above, using the last two years of figures.
  2. Run a gap assessment of current reporting, board oversight and data systems against IFRS S1 and S2.
  3. Identify material risks and opportunities for your sector and value chain.
  4. Build the data, starting with greenhouse gas emissions, which take the longest to collect reliably.
  5. Plan for assurance from the second year, so that processes and evidence are audit-ready.

For the wider policy context, see PIVRA’s report Embedding ESG in Pakistan’s Sustainable Development Agenda and our discussion paper on Pakistan’s first homegrown ESG index.

How PIVRA can help

PIVRA’s ESG and sustainability advisory covers gap assessments against IFRS S1 and S2, materiality assessments, drafting of sustainability reports and SDG alignment, alongside your auditors. Request a quote.

Questions

Frequently asked questions

Is sustainability reporting mandatory in Pakistan?

Yes, for listed companies and, from 2027, non-listed public interest companies. The SECP mandated IFRS S1 and IFRS S2 by an order of 31 December 2024 under section 238 of the Companies Act 2017, in three phases.

Which companies must apply IFRS S1 and S2 from July 2026?

Phase II covers listed companies meeting any two of: turnover above Rs 12.5 billion, more than 500 employees, or total assets above Rs 6.25 billion, for annual reporting periods beginning on or after 1 July 2026.

Is assurance required on sustainability disclosures in Pakistan?

Assurance is required from the second year of reporting.

Can companies apply IFRS S1 and S2 early?

Yes. Early application is permitted and encouraged.

Tell us what you need in Pakistan

Send a short outline of your organisation, your question and your timeline. We reply within two business days with questions or a fixed quote. The first conversation is free and confidential.