As the November meeting of the International Sustainability Standards Board (ISSB) concluded, anticipation filled the room. Observers half-jokingly waited for “white smoke” to rise a Vatican-style signal announcing the birth of a new sustainability standard. But no such signal came. Instead, the board took a significant, if cautious, step forward: a unanimous vote to begin preparatory work on standard-setting for nature-related risks and opportunities. There would be no immediate unveiling of an “IFRS S3.” The decision marks a commitment to progress tempered by caveats, debate, and divergent philosophies about what should come first: education or regulation.

From Climate to Nature: Building on the TNFD Foundation

This was the second in a trilogy of votes that could shape the future of corporate nature disclosures. The first, earlier in the week, had seen ISSB members unanimously agree to base their nature-related efforts on the Taskforce on Nature-related Financial Disclosures (TNFD) recommendations a predictable but pivotal foundation. The third vote focused on sequencing: should the board issue educational material before embarking on formal standard-setting? While the answer ultimately leaned toward “not yet”, the discussion revealed a deeper tension at the heart of the ISSB’s strategy, how to balance urgency with rigor, and awareness with governance.

Education vs. Regulation: The Board’s Central Debate

Much of the conclave revolved around whether to release educational materials as a first step. Board member Elizabeth Seeger championed that idea, warning that the market’s understanding of sustainability reporting especially under IFRS S1’s requirement to disclose all sustainability-related risks and opportunities is still “poorly understood.” She argued that educational material could help companies interpret IFRS S1 and IFRS S2 in practice, demonstrate how nature-related topics integrate into those frameworks, and build capacity in emerging markets. In her view, the market tends to compartmentalize issues climate here, biodiversity there when the ISSB’s intent is to show the interconnections across sustainability themes.

Seeger also cautioned that launching a new, climate-scale disclosure framework too soon could overwhelm preparers: “The world is not ready for another IFRS S2-level standard right now.” Education, she suggested, could bridge the gap until the groundwork for nature disclosures matures.

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The Counterpoint: A Call for Conceptual Clarity

Her colleague Richard Barker, however, pushed back sharply. He argued that without clear definitions or agreed concepts, educational materials would lack legitimacy: “You can’t educate the market on something the board hasn’t yet defined.”

Barker’s concern was twofold due process and perception. Educational materials, unlike formal standards, are not subject to public consultation, which could give the impression that the ISSB was crafting guidance behind closed doors. “Releasing guidance without transparency risks looking like the board is working in an ivory tower,” he said, warning that it could undermine trust in the board’s governance model. He also noted the practical costs: limited ISSB staff capacity means that time spent producing early guidance would slow down the development of an actual standard. Barker instead urged the board to move swiftly on defining the foundations scope, metrics, and ecosystem services drawing heavily on TNFD’s technical framework.

The Middle Ground: Timing and Governance

Vice Chair Jingdong Hua acknowledged both sides. He recognized that educational tools could play an important role in building capacity, particularly for companies still struggling with basic climate reporting. However, he agreed with Barker that sequencing matters: education should follow standard-setting, not precede it. Vice Chair Sue Lloyd echoed this position, emphasizing that while supplementary materials would eventually be valuable for implementation, they should come only after the board had established a coherent set of concepts through the due process of standard creation. This consensus paved the way for the final motion to produce educational material only after or alongside the standard-setting process, but not before. The motion passed, with Seeger as the lone dissenting voice.

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A Path Forward But Still No “White Smoke”

The November conclave ended not with the adoption of a new standard, but with a signal of intent. The ISSB will begin developing nature-related disclosure requirements, rooted in TNFD’s architecture and aligned with IFRS S1 and S2’s principles of materiality and interconnectedness. Still, major decisions lie ahead. The exact form, timing, and scope of the new nature standard will be the subject of separate discussions in the months to come. The vote was a green light for progress but not yet ignition. The metaphorical smoke remains dark, but movement is visible. For now, the ISSB’s message is one of careful optimism: nature is officially on the agenda, but getting from conversation to codification will take time, resources, and consensus. When the next ISSB gathering convenes perhaps at or after COP30, the world will watch again, waiting to see if this time the chimney of global sustainability reporting finally emits a puff of white smoke.

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