Impact PartnersClimate & Sustainability
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ESG reporting · Climate risk · GHG accounting

Sustainability disclosures that stand up to scrutiny.

When a regulator, a customer or an investor asks, we help companies in Pakistan and the United States measure their emissions, understand climate risk and report under IFRS S1 and S2, GRI and SASB, with every figure traced to its source.

Why now

Regulators now require it. Investors and customers now ask for it.

In Pakistan, SECP requires listed companies to report under IFRS S1 and S2, phased in by size from 2025. In the United States, the demand comes from investors, lenders, customers and California’s climate law.

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Pakistan: IFRS S1 and S2, in three phases

  1. July 1, 2025 · Phase I

    Larger listed companies meeting any two of: turnover above Rs 25 billion in each of the last two financial years; more than 1,000 permanent and contractual employees; total assets above Rs 12.5 billion.

  2. July 1, 2026 · Phase II

    Listed companies meeting any two of: turnover above Rs 12.5 billion in each of the last two financial years; more than 500 permanent and contractual employees; total assets above Rs 6.25 billion.

  3. July 1, 2027 · Phase III

    All other listed companies, and non-listed public-interest companies licensed or registered with SECP.

Year one: the report can be published separately, within nine months of your financial year-end. After that, it sits in the annual report, after the directors’ report, approved by the board in the same way as the financial statements.

Year two: Scope 3 emissions, and assurance by your auditors. The systems you build in year one need to hold up to review.

What it means for your first deadline

Your phaseJune 30 year-endDecember 31 year-end
Phase IFirst report covers the year to June 30, 2026; due by March 31, 2027Covers the year to December 31, 2026; due by September 30, 2027
Phase IICovers the year to June 30, 2027; due by March 31, 2028Covers the year to December 31, 2027; due by September 30, 2028
Phase IIICovers the year to June 30, 2028; due by March 31, 2029Covers the year to December 31, 2028; due by September 30, 2029
Phase I

June 30 year-end: first report covers the year to June 30, 2026; due by March 31, 2027.

December 31 year-end: covers the year to December 31, 2026; due by September 30, 2027.

Phase II

June 30 year-end: covers the year to June 30, 2027; due by March 31, 2028.

December 31 year-end: covers the year to December 31, 2027; due by September 30, 2028.

Phase III

June 30 year-end: covers the year to June 30, 2028; due by March 31, 2029.

December 31 year-end: covers the year to December 31, 2028; due by September 30, 2029.

Source SECP, Order: Adoption of Sustainability Disclosure Standards, December 31, 2024

Dates are calculated from the Order.

Our work in Pakistan
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United States: driven by investors, customers and California

  • California: companies formed in the US, including US subsidiaries of foreign groups, with more than $1 billion in annual revenue that do business in California must report their Scope 1 and 2 emissions each year under SB 253.
  • The first reports were due on November 10, 2026.
  • The law also requires independent assurance of these figures, rising from limited to reasonable assurance by 2030.
  • On November 9, 2026 a federal appeals court let this reporting go ahead. It ruled that the Scope 3 requirement, and SB 261’s climate-risk reports, should be blocked while the case continues.

Source California Health and Safety Code (SB 253, as amended in 2025) · CARB, Initial Regulation, approved October 12, 2026

US Court of Appeals for the Ninth Circuit, Chamber of Commerce v. Sanchez, November 9, 2026.

  • Investors and lenders: questionnaires on climate risk and emissions, often built on SASB and ISSB metrics.
  • Customers: requests for supplier emissions data, and the evidence behind it.
  • Voluntary reporting: IFRS S1 and S2, chosen by companies that want one investor-grade framework.
Our work in the United States

How we work

What working with us looks like.

01

A call, then a written proposal. We agree what you need to report, for whom and by when, and send a proposal with the scope and the timeline.

02

One focused data request. We ask only for what the work needs, explain why, and work with what you already hold.

03

Drafts with the evidence attached. We calculate and draft, and document every source, emission factor and assumption, so anyone reviewing the work can follow it.

04

Your judgment, your sign-off. Your management makes the judgments and approves the final report. We brief your board and explain our methods to your auditors.

Who you will work with

Partner-led, in both markets.

Khalil Raza

Khalil Raza

Partner · Pakistan

Energy transition and climate disclosure expert

Khalil leads the firm’s work on climate disclosure, GHG accounting and ESG reporting.

M. Faisal Khokhar

M. Faisal Khokhar

Partner · Houston, Texas

Sustainability through an investor’s lens

Faisal brings the investor’s view to the firm’s work: what lenders and investors look for in a company’s climate and sustainability disclosures.

Meet the partners
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Have a deadline or a request in front of you?

Tell us what you need to report, for whom and by when. We will tell you plainly what it takes.

Talk to us