ISSB Launches Nature Disclosure Consultation at COP17 as EU ESRS Countdown Begins

ISSB Opens Nature Disclosure Consultation Live from COP17

In one of the most consequential sustainability reporting developments of the year, the International Sustainability Standards Board (ISSB) launched a formal consultation on proposed nature-related disclosure guidance on October 22, 2026 — timed to coincide with the UN Biodiversity Conference (COP17) in Yerevan, Armenia, which runs through October 30. The proposal takes the form of an IFRS Sustainability Disclosure Practice Statement that would set out incremental disclosure requirements beyond those already contained in IFRS S1 and IFRS S2, according to reporting by Linklaters and the IFRS Foundation. The 120-day comment period closes on February 19, 2027.

The ISSB chose a non-mandatory Practice Statement format rather than a standalone standard, a deliberate decision intended to minimise disruption to the ongoing global roll-out of IFRS S1 and S2 while still responding to clear investor demand for nature-related information. ISSB Chair Emmanuel Faber has previously noted that providing material nature-related disclosures is already implicitly required under IFRS S1. The consultation draws heavily on the Taskforce on Nature-related Financial Disclosures (TNFD) framework, including its LEAP methodology, and is designed to complement rather than duplicate existing biodiversity-focused work. Analysis published by Asuene highlighted that the draft addresses how companies should disclose their dependencies and impacts on nature and how those factors give rise to financial risks and opportunities.

EU's Revised ESRS Set to Enter Into Force November 10

On the European front, the clock is ticking toward another landmark date. Bloomberg Law's October 2026 Global Regulatory Brief confirmed that the revised European Sustainability Reporting Standards — formally Commission Delegated Regulation (EU) 2026/1563 — will enter into force on November 10, 2026, with mandatory application beginning for financial years starting on or after January 1, 2027. First reports under the revised standards are therefore expected in 2028. EFRAG has simultaneously opened a consultation on a draft XBRL taxonomy to underpin digital sustainability reporting, which closes November 11, 2026.

The revised ESRS are a significant simplification of the original standards adopted in 2023. Climate-x.com and Coolset have both reported that the revision cut roughly 60% of mandatory data points — from approximately 1,100 down to around 430 — while eliminating voluntary data points altogether. The climate-specific standard, ESRS E1, was expanded from nine to eleven disclosure requirements and renumbered accordingly, but all topical disclosures are now fully subject to a materiality assessment, removing the prior rule that climate disclosures were mandatory regardless of materiality. The changes stem from the broader Omnibus I package, which also narrowed the CSRD's company scope to undertakings with more than 1,000 employees and more than €450 million in net turnover.

SEC Rescission Still Pending as Global Divergence Widens

In the United States, the contrast with global momentum could hardly be starker. The Legal 500 reported in mid-October that the SEC's proposed rescission of its 2024 climate disclosure rule remains in process; in a status report filed August 31, 2026, the SEC told the Eighth Circuit that it is still reviewing public comments received before the August 3 deadline. Until a final rescission vote — expected no earlier than late 2026, and possibly 2027 — the 2024 rules remain stayed and the agency's 2010 interpretive guidance continues to apply. California's SB 253 deadline, meanwhile, has been pushed to November 10, 2026 for initial Scope 1 and 2 reports, keeping sub-federal pressure on large companies even as the federal regime recedes.

Taken together, this week's developments underscore a widening regulatory split: the ISSB is actively expanding its disclosure baseline into nature, the EU is cementing a simplified but still-demanding mandatory framework, and the US federal government is moving in the opposite direction entirely.