Insights · Pakistan
IFRS S1 and S2 in Pakistan: what SECP’s Order means for your company
Which phase you are in, when your first report is due, who approves it and who assures it, and what to do this quarter.
If your company is listed in Pakistan, sustainability reporting is no longer a choice. On December 31, 2024, the Securities and Exchange Commission of Pakistan (SECP) ordered listed companies to report under IFRS S1 and IFRS S2, in three phases by size.
Phase I is already under way. For a Phase I company with a June 30 year-end, the first reporting year closed on June 30, 2026, and the first report is due by March 31, 2027. Phase II companies with a June 30 year-end entered their first reporting year on July 1, 2026.
This article sets out what the Order requires, in plain terms, and what to do about it.
Which phase is your company in?
The Order sorts companies by size. A listed company falls into a phase if it meets any two of that phase’s three tests.
| Phase | Applies to annual periods beginning on or after | Who |
|---|---|---|
| Phase I | July 1, 2025 | 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 |
| Phase II | July 1, 2026 | 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 |
| Phase III | July 1, 2027 | All other listed companies, and non-listed public-interest companies licensed or registered with SECP |
The Order also encourages every company to adopt the standards earlier than its phase requires.
When is your first report due?
In the first year, the report can be published separately, within nine months of your financial year-end. That gives these dates:
| Your phase | June 30 year-end | December 31 year-end |
|---|---|---|
| Phase I | Covers the year to June 30, 2026; due by March 31, 2027 | Covers the year to December 31, 2026; due by September 30, 2027 |
| Phase II | Covers the year to June 30, 2027; due by March 31, 2028 | Covers the year to December 31, 2027; due by September 30, 2028 |
| Phase III | Covers the year to June 30, 2028; due by March 31, 2029 | Covers the year to December 31, 2028; due by September 30, 2029 |
These dates are calculated from the Order. After the first year, the report sits in the annual report, after the directors’ report.
What goes into the report?
IFRS S1 sets the general requirements for sustainability-related financial disclosures. IFRS S2 covers climate. Together they ask for disclosures in four areas:
- Governance: who oversees sustainability-related risks and opportunities;
- Strategy: how those risks and opportunities affect the business, including how resilient the strategy is to climate change;
- Risk management: how the company identifies, assesses and manages them;
- Metrics and targets: the numbers, including greenhouse gas emissions.
IFRS S2 expects emissions to be measured under the GHG Protocol. Under the Order, Scope 3 emissions join from your second year of reporting.
Who approves it, and who checks it?
Two parts of the Order matter most to directors and finance teams:
- The board approves it. The report is approved in the same way as the financial statements.
- Your auditors assure it from year two. From the second year of reporting, the company’s auditors provide assurance on the report, under the International Standards on Auditing as adopted in Pakistan, in a format that SECP notifies.
What this means in practice
This part is our view, not the Order’s text.
Year one is the year you build; year two is the year it gets tested. The data for this report sits in plants, finance, HR and procurement, and most of it has never been collected to an audit standard. A company that treats the first report as a writing exercise will meet its auditors in year two with numbers it cannot trace.
The nine months go quickly. A Phase I company with a June year-end is inside that window now. A first emissions inventory, a first climate risk assessment and a board that has not approved this kind of report before all take longer the first time.
Start from what you have. Most listed companies already hold much of the raw material: energy and fuel records, an existing sustainability or CSR section, risk registers, board committee papers. The first job is to find the gaps.
Five things to do this quarter
- Confirm your phase and your first deadline. Test the three size criteria against your last two sets of financial statements.
- Name an owner. One senior person, with finance, operations and the company secretary at the table.
- Run a gap assessment against IFRS S1 and S2: what you can disclose today, what is missing, who will supply it, and by when.
- Start the emissions inventory. Scope 1 and 2 first, with a record of every source and emission factor, so that the numbers hold up when your auditors review them.
- Brief the board early. The directors will approve this report; they should see the plan before they see the draft.
Source
SECP, Order: Adoption of Sustainability Disclosure Standards, December 31, 2024: https://esgsustain.secp.gov.pk/wp-content/uploads/2025/10/Order-Adoption-of-Sustainability-Disclosure-Standards.pdf
As of November 11, 2026. General information, not legal advice. We are not a law firm.
Not sure which phase you are in? We can confirm it in a short call. Talk to us, or see our work in Pakistan.
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.