IFRS’s New ISSB Map Puts Thailand in 2027. Its Thailand Snapshot Still Says 2026

At the IFRS Foundation’s World Standard-setters Conference in London on 28–29 September 2026, the Foundation’s regulatory affairs team presented a one-page map of when ISSB-based disclosures take effect around the world. Thailand appears in the 2027 reporting-year group, alongside Japan, South Korea and Indonesia. Malaysia and Singapore are two rows earlier, in 2025. The Philippines is in 2026.

The map has Thailand right. The SEC’s final roadmap makes SET50 companies apply IFRS S1 and S2 from FY2027, with the first reports filed in 2028. The problem is the IFRS Foundation’s own Thailand jurisdictional snapshot, the document an overseas analyst finds when they click through for detail. It is still dated 12 June 2025 and still describes the 2024 consultation draft, which put SET50 a year earlier. This post sets out what the map shows, where the snapshot is out of date, and what that means for the English record of your ISSB position.

What the IFRS Foundation showed in London

The plenary session Adoption of IFRS Sustainability Disclosure Standards was presented by Jonathan Bravo, Director of Regulatory Affairs, Sue Lloyd, ISSB Vice-Chair, and Anna Hemmant, Regulatory Affairs Manager. The slides were published on ifrs.org on 1 October. They carry the standard disclaimer that the views are the presenters’, not necessarily those of the Foundation or the ISSB.

Slide 5, “When to expect ISSB-based disclosures by jurisdictional effective dates”, sorts jurisdictions into five rows: the 2025 reporting year, 2026, 2027, 2028 or later, and to be determined. The deck also reports 22 jurisdictional profiles, which the Foundation produces only when an approach “is finalised and no longer subject to consultation”, and 14 snapshots, described as information on “jurisdictions still deliberating their approaches.” Thailand, Indonesia, South Korea and China are among the snapshots.

Where Thailand sits against ASEAN peers

Source: IFRS Foundation, World Standard-setters Conference 2026, plenary slides “Adoption of IFRS Sustainability Disclosure Standards”, slide 5. Row placement read from the slide layout. Other jurisdictions omitted for space.

For a Thai issuer competing for the same regional allocations, the map says two things. Thailand is not an outlier: it sits with Japan and South Korea, two of Asia’s largest markets. But a fund comparing Thai and Malaysian or Singaporean companies is comparing a market where mandatory ISSB-based reports already exist with one where they arrive in 2028. We looked at the Malaysian side of this in our post on Malaysia’s assurance deferral.

The Thailand snapshot still describes the 2024 draft

Each country on the map links to a profile or snapshot. Thailand’s snapshot, downloaded from ifrs.org on 9 October 2026, is marked “Updated 12 June 2025” and gives the regulatory stage as “In progress.” It says the SEC’s consultation closed on 19 December 2024 and that the SEC “plans to conduct a further consultation.” It then lists the phase-in proposed in that consultation, which is not the one the SEC adopted.

Sources: IFRS Foundation, Jurisdictional Snapshot: Thailand, updated 12 June 2025; SEC Thailand roadmap (news 298/2568) as restated on SET’s Thailand ISSB Standards Information Hub, read 9 October 2026. Thai years 2570–2574 converted to 2027–2031.

The final roadmap moved SET50 and SET100 back by one year each and left the later tiers unchanged. The transition reliefs in the snapshot (five years climate-first, five years without Scope 3, a separate filing date, and continued use of non-GHG Protocol methods) broadly match what the SEC adopted. The timing for the two largest tiers does not. The Foundation is open about this. The snapshot says:

The detailed Thai rulebook is also still being written. The SEC’s progress report on its strategic plan for the first quarter of 2569 says a consultant delivered a draft ISSB manual on 25 January 2026, which is being revised after further comment. The SEC, SET, the ESG Network and the Federation of Accounting Professions are still agreeing the data points that companies will file. In September 2026 SET published a Thai-language Board Handbook for ISSB Standards Readiness, which states that it is not an official document or an official translation.

The map, prepared in September 2026, shows the 2027 date. The detailed document behind it still shows 2026. An analyst who reads only the snapshot will expect SET50 climate reports a year before they are due, and may read their absence in 2027 as a gap.

Singapore’s Scope 3 head start

The sharpest regional contrast is Scope 3. Singapore’s ACRA and SGX RegCo confirmed on 25 August 2025 that Straits Times Index constituents must report Scope 3 emissions from FY2026, while Scope 1 and 2 reporting has been mandatory for all listed companies since FY2025. Thailand’s roadmap lets each tier omit Scope 3 for its first five years, so a SET50 company could report its first Scope 3 figure for FY2032.

The relief is optional. The SET hub notes that a company can choose to disclose under the ISSB standards without using the transition period. For a SET50 company whose investors also hold Singapore STI names, publishing Scope 3 earlier than the roadmap requires is a commercial choice, not a compliance one. Our guide to Scope 1, 2 and 3 under TGO CFO covers where that data comes from.

Passporting and the “as issued” baseline

The second half of the session concerned ISSB passporting, which the slides describe as an option granted by regulators that “allows foreign issuers or local subsidiaries of foreign entities to comply with local requirements by using the ISSB Standards as issued by the ISSB as the basis for reporting.” Japan and Hong Kong are given as examples already in place. The presenters’ case is that diverging national versions risk turning a voluntary “alphabet soup” into a regulatory one.

Thailand has not announced passporting. But the logic matters for any Thai group with a Singapore listing, a Hong Kong subsidiary or Japanese shareholders. The standards are issued in English and, as we noted in our post on the missing Thai text of IFRS S1 and S2, there is no official Thai version. A report that maps cleanly to the “as issued” wording will travel more easily than one written only to the local reading.

Why your own English report has to state the facts

Before an overseas investor reads a Thai company’s ISSB disclosures, they often check the regulatory regime in English summaries such as the IFRS snapshot. When that summary is out of date, the company’s own English report is the best place to correct it. It should state, in plain terms, which roadmap tier the company belongs to, its first mandatory year, and which reliefs it is using. That sentence costs nothing, and it stops the reader filling the gap from a 2025 summary.

The same English record is read by others. FTSE Russell scores from public disclosure without a questionnaire, and the six key research languages in its FAQ (v1.5, §1.8) do not include Thai. SET’s own Q&A on the FTSE process recommends, but does not require, English disclosure because FTSE Russell assesses mainly from English. CDP does not score responses in Thai. None of this means the English edition decides a score. It means the English edition is the version a global analyst is most likely to read, so its accuracy is worth controlling. See how FTSE Russell reads Thai disclosure and our IFRS S1/S2 bilingual disclosure service.

Where the evidence runs out

• The map is a conference slide. It carries a disclaimer that the views are the presenters’, and it gives no per-country footnotes. We read each country’s row from the slide layout.
• The snapshot may be updated at any time. It invites corrections to [email protected]. We do not know why Thailand has not yet moved to a finalised profile, and we do not speculate.
• We have no evidence that any investor has been misled by the snapshot. The risk we describe is plausible, not documented.
• English is not a differentiator against Singapore or Malaysia. Their companies already report in English as a matter of course. For Thai issuers, accurate English disclosure is what brings them up to their regional peers. It does not put them ahead.
• Timing is not quality. An earlier effective date says nothing about how good a jurisdiction’s reports are. SET’s published FTSE Russell data show Thai companies averaging 3.6 out of 5 in the 2025 round, up from 3.0.

What SET50 teams should do now

The IFRS map shows a Thailand that is on schedule within its Asian group and two years behind its two closest ASEAN rivals. The year before FY2027 starts is the time to make sure your English record says so accurately. Read about the risks in ESG translation, see our technical translation for regulated filings, and follow the dates on our regulatory tracker →

Sources, read 9 October 2026: IFRS Foundation, World Standard-setters Conference 2026, plenary slides “Adoption of IFRS Sustainability Disclosure Standards” (slides 5, 7, 8, 11, 17–22, 39); IFRS Foundation, conference calendar entry; IFRS Foundation, Jurisdictional Snapshot: Thailand, updated 12 June 2025; SET, Thailand ISSB Adoption Roadmap by the SEC; ACRA and SGX RegCo, release of 25 August 2025; ACRA, public consultation on the Singapore Sustainability Disclosure Standards, 27 July 2026; FTSE Russell ESG Scores and Indices FAQ v1.5 §1.8; SET, Questions from Q&A sessions, item 16; CDP Terms of Disclosure §12.3; SET × FTSE Russell 2025 round infographic; SEC, strategic-plan performance report Q1 2569; SET, Board Handbook for ISSB Standards Readiness, September 2569.