Before you approve a sustainability reporting budget, settle two questions: which reporting period applies to your company, and what evidence will support the report? A polished document cannot resolve an uncertain reporting boundary or explain a number whose source has been lost. Our view is that the first budget should fund those decisions before it funds page design.
For a Phase I company with a June 30 year-end, the first reporting period has already closed. The March 31, 2027 deadline below is our calculation from the December 31, 2024 Order of the Securities and Exchange Commission of Pakistan (SECP), assuming a normal annual period and no subsequent change to the applicable requirements. [1] Confirm any later SECP notifications before relying on the timetable.
Confirm the phase before you set the work plan
The Order adopts IFRS S1 and IFRS S2 in phases. Phase I covers listed companies meeting any two tests: turnover above Rs 25 billion in the last two consecutive financial years, more than 1,000 permanent and contractual employees at the last year-end, or assets above Rs 12.5 billion at that year-end. Phase II lowers those thresholds to Rs 12.5 billion, 500 employees and Rs 6.25 billion. Phase III includes the remaining listed companies and non-listed public-interest companies licensed or registered with SECP. [1, paragraph 1]
Our recommendation is to make the phase decision a short, signed internal memo. Attach the financial statements used for turnover and assets, identify the employee record and its date, and show the result for each test. If the company meets the criteria of more than one phase, plan for the earliest phase that applies. Do not let the memo become an unsupported label in a project presentation.
If the company has changed its year-end, acquired a business or sits close to a threshold, give that question to the company secretary and legal advisers before fixing the timetable. Keep the answer beside the original assessment so the reporting team can understand the basis for its instructions.
The first deadline is the end of a preparation window
Exhibit: Work backward from the first reporting period, not the publication date.
| Phase | Annual periods begin on or after | First June 30 year-end | First report within nine months |
|---|---|---|---|
| I | July 1, 2025 | June 30, 2026 | March 31, 2027 |
| II | July 1, 2026 | June 30, 2027 | March 31, 2028 |
| III | July 1, 2027 | June 30, 2028 | March 31, 2029 |
Source: SECP Order, paragraphs 1 and 2. Period ends and publication dates are our calculations for a June 30 year-end. [1]
The Order allows first-year reporting within nine months of the year-end. It otherwise places the report after the directors’ report in the annual report. Scope 3 disclosure and assurance by the company’s auditors start in the second reporting year. [1, paragraphs 2 and 3]
Our view is that the useful deadline is the date each piece of evidence must reach its reviewer. Work backward from publication to approval, internal review, calculations and data collection. Leave time to resolve gaps. A schedule that gives the writer the full nine months but leaves the reviewer a few days is a weak starting point.
For a December year-end, do the calculation again rather than copying the exhibit. Identify the first annual period that starts on or after the phase date, then count nine months from its close. Record both the period covered and the publication deadline wherever the project timetable is shared. Those are different dates and serve different purposes.
Build a record that another person can reproduce
The reporting content is broader than the adoption timetable. The IFRS Foundation and GRI describe ISSB reporting as information for investors about sustainability risks and opportunities that can affect cash flows, financing or the cost of capital. [2] The Order alone does not provide a checklist of every disclosure in IFRS S1 and S2.
Our recommended first exercise is to connect each proposed disclosure to an owner and an evidence location. For a fuel figure, retain the original record, the period, the unit, any adjustment and the calculation. For a statement about risk oversight, retain the relevant mandate or meeting record.
Use a simple review question: could a colleague who did not prepare this item explain how it reached the report? If the answer is no, identify what is missing. Sometimes it will be a source document. Sometimes it will be an explanation of a judgment. Avoid treating both problems as a request for more data.
Keep an issues log alongside the draft. Name the issue, its effect on the disclosure, the person responsible and the next decision date. Resist replacing a missing record with an unqualified claim that a process is comprehensive. A specific explanation of what the team has established is more useful than language that sounds complete but cannot be checked.
Prepare the review process before drafting the narrative
The Order refers approval to section 232 of the Companies Act. It requires the company’s auditors to provide assurance from year two in the notified format, using relevant International Standards on Auditing adopted by ICAP. It does not specify an assurance level in its text. [1, paragraphs 2 and 3]
Our recommendation is to involve the company secretary in the approval schedule and discuss future assurance preparation with the auditors early. Ask what records and explanations they expect to review. Keep management’s responsibility for preparing the information clear. Early discussion prepares the ground; it does not anticipate the auditors’ conclusion.
For the next management meeting, bring a decision pack small enough to use: the phase memo, the reporting calendar, an initial disclosure gap list and a named owner for every unresolved item. Let management decide where to assign resources. This makes the budget a response to identified work instead of an estimate for producing a document of an arbitrary length.
Our suggested next actions are:
- Confirm the applicable phase, reporting period and any later notifications with the company secretary.
- Assign one accountable reporting owner and agree when finance, operations and other contributors will deliver evidence.
- Trace a sample disclosure from source record to draft, then repair the process before expanding it.
- Schedule approval preparation and the discussion of year-two assurance needs now.
Related service: Climate disclosures. Talk to us.
As of November 12, 2026. General information, not legal advice.
Sources
[1] Securities and Exchange Commission of Pakistan, Order: Adoption of Sustainability Disclosure Standards, December 31, 2024, paragraphs 1–3. Retrieved November 10, 2026; saved source reread November 11, 2026. Order.
[2] IFRS Foundation and GRI, Facilitating efficient reporting when using the GRI and ISSB Standards, May 26, 2026, pages 1–2. Retrieved November 11, 2026. Joint statement.
