Summary
- Mexico's CNBV now requires all securities issuers on the Mexican Stock Exchange to report under IFRS S1 (general sustainability disclosures) and S2 (climate disclosures), with the GHG Protocol explicitly mandated as the measurement standard.
- The first reports covering FY2025 data are due in 2026, with Scope 3 reporting required for large issuers from 2027 and medium issuers from 2028.
- The regulation covers approximately 86% of Mexico's equity market capitalisation, and its supply chain ripple effects will reach suppliers across the US, Canada, and Latin America through Scope 3 data requests.
- Companies that already report under the GHG Protocol, TCFD, CDP, or CSRD have a head start — the ISSB standards are designed to build on these frameworks, reducing the burden of duplicative reporting.
Mexico's Comisión Nacional Bancaria y de Valores (CNBV) published a landmark resolution on January 28, 2025 requiring all securities issuers on the Mexican Stock Exchange to adopt the two sustainability standards published by the International Financial Reporting Standards (IFRS): S1 on general sustainability disclosures and S2 on climate disclosures. Both were developed by IFRS’ International Sustainability Standards Board (ISSB). IFRS develops global accounting standards that bring consistency, transparency, and comparability to financial statements worldwide.
With this move, Mexico became the first country in North America to mandate ISSB standards — setting a new precedent for climate accountability across the region.
The final rules are now in-force, and the first reporting cycle covers FY2025 data due in 2026. For companies with operations in Mexico, supply chain exposure to Mexican markets, or listings on the Bolsa Mexicana de Valores, the compliance clock is already ticking.
Here's what you need to know.
What the New Resolution Require
The regulation mandates comprehensive sustainability disclosures aligned with the International Sustainability Standards Board (ISSB) frameworks:
- IFRS S1 (General Requirements for Disclosure of Sustainability-related Financial Information): Companies must disclose material sustainability-related risks and opportunities that could reasonably be expected to affect their cash flows, access to finance, or cost of capital.
- IFRS S2 (Climate-related Disclosures): Companies must report on climate-related risks and opportunities, including governance, strategy, risk management, and metrics and targets, following the familiar TCFD-aligned four-pillar structure.
Critically, the GHG Protocol Corporate Accounting and Reporting Standard (2004) is explicitly mandated through IFRS S2 paragraph 29(a)(ii), meaning companies must use the GHG Protocol as the basis for their emissions measurement and reporting across Scope 1, 2, and 3.
Who Is In Scope?
The regulation applies to all securities issuers listed on the Bolsa Mexicana de Valores (BMV), excluding financial institutions, states, and municipalities. This covers approximately 86% of the market capitalisation of Mexico's primary equity index.
Key distinctions for different types of entities:
- Listed companies on the BMV: Full IFRS S1/S2 compliance required from FY2025.
- Foreign issuers: May comply using home-country standards, provided equivalence with IFRS S1/S2 is documented. Companies already reporting under the EU's CSRD or other ISSB-aligned frameworks may leverage existing disclosures.
- Private Mexican companies: Those reporting under Mexican Financial Reporting Standards (Normas de Información Financiera) must include sustainability footnotes from FY2025 onwards under separate NIS standards.
If your company does business with listed Mexican entities, expect increasing pressure from customers and partners to provide emissions data and climate risk disclosures as part of their Scope 3 and value chain reporting.
Key Dates and Milestones
The CNBV has set out a phased implementation timeline that progressively raises the bar for disclosure quality and scope:
|
Milestone |
Measurement Year |
Reporting Date |
|---|---|---|
|
First report — Scope 1 & 2 only |
FY2025 data |
2026 |
|
Scope 3 reporting — all issuers |
FY2026 data |
2027 |
|
Limited assurance required |
FY2026 data |
2027 |
|
Reasonable assurance required |
FY2027+ data |
2028+ |
Several aspects of this timeline are worth highlighting:
-
Scope 3 is mandatory. In-scope companies must begin Scope 3 reporting from 2027 (for FY2026 data). Given the complexity of Scope 3 measurement, companies should begin baselining their value chain emissions now.
-
Assurance requirements escalate quickly. Limited assurance is required from 2027, moving to reasonable assurance from 2028 onwards. This means companies will need not only robust emissions data, but also auditable processes, documentation, and internal controls.
Why This Matters Beyond Mexico
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Mexico's adoption of ISSB standards signals a broader shift across North America and Latin America. Here's why this regulation has implications far beyond companies listed on the BMV:
1. Supply chain ripple effects. Listed Mexican companies will need Scope 3 data from their suppliers, many of whom are based in the United States, Canada, and across Latin America. If your company supplies goods or services to Mexican-listed entities, expect data requests for emissions factors, product-level carbon footprints, and climate risk assessments.
2. Regulatory convergence is accelerating. Mexico's move aligns with the global trend toward ISSB adoption. With the EU's CSRD already in force, California's SB 253/261 advancing, and jurisdictions across Asia-Pacific adopting ISSB frameworks, the window for companies to treat sustainability reporting as voluntary is rapidly closing.
3. North American precedent. As the first North American country to mandate ISSB standards, Mexico is likely to influence regulatory discussions in the United States and Canada. Companies that get ahead of this curve now will be better positioned as similar requirements emerge across the region.
How Should Companies Prepare
Whether your company is directly in scope or anticipates being drawn into reporting through supply chain requirements, there are practical steps you can take now:
-
Start with your GHG inventory. The explicit mandate for the GHG Protocol means companies need a solid foundation of Scope 1, 2, and 3 emissions data. If you haven't yet established a comprehensive carbon footprint, now is the time to baseline.
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Map your value chain exposure. Identify where your operations, supply chain, and customer base intersect with Mexican-listed entities. Understanding these connections will help you anticipate data requests and allocate resources accordingly.
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Build assurance-ready processes. With limited assurance required as early as 2027, companies need to move beyond spreadsheet-based tracking and implement systems that produce auditable, verifiable emissions data with clear documentation trails.
-
Leverage existing frameworks. If you already report under the GHG Protocol, TCFD, CDP, or CSRD, much of your existing work can be adapted for IFRS S1/S2 compliance. The ISSB standards were designed to build on these established frameworks, reducing the burden of duplicative reporting.
How Terrascope Can Help
Terrascope's AI-powered platform has already helped leading Mexican brands, like Sigma Alimentos, prepare for the rigours of IFRS reporting through:
- Comprehensive emissions measurement: Measure your Scope 1, 2, and 3 emissions using GHG Protocol-aligned methodologies, giving you the data foundation required under IFRS S2.
- Audit-ready reporting: Generate disclosures that meet assurance standards, with full documentation trails and methodology transparency — so you're ready when limited and reasonable assurance requirements take effect.
- Supply chain intelligence: Engage your suppliers, collect primary data at scale, and identify emissions hotspots across your value chain — critical for Scope 3 reporting under the CNBV timeline.
- Multi-framework alignment: Report across ISSB, CSRD, CDP, and other frameworks from a single platform, eliminating duplicative effort as regulatory requirements converge globally.
Are you ready to get ahead of Mexico's IFRS S1/S2 requirements? Submit the form below to speak to a Terrascope expert today.
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