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Deferral of Sustainability Disclosure Requirements in Annual Reports

Corporate
Focos

The Chilean Financial Market Commission (Comisión para el Mercado Financiero, or “CMF”) has postponed by one year the mandatory implementation of the IFRS S1 and S2 standards required for annual reports.

On July 27, the CMF issued General Rule No. 572 (“NCG No. 572”), amending General Rule No. 519 (“NCG No. 519”) in order to defer by one year the requirement to include certain sustainability indicators in the annual reports of publicly held corporations, special corporations, securities issuers and, more generally, companies required to prepare an annual report pursuant to NCG No. 30.

Amended Regulation

NCG No. 519 introduced the requirement for these companies to disclose in their annual reports information regarding the existence of policies relating to corporate governance, diversity and, more generally, sustainability.

DISCLOSURES REQUIRED UNDER NCG NO. 519 FOR ANNUAL REPORTS

Corporate Governance

 

 

 

Corporate Governance Codes: adoption of corporate governance codes and OECD principles.

Board Diversity: policies aimed at ensuring diversity among candidates nominated to the Board of Directors.

Workplace Diversity and Inclusion

 

 

 

Protocols and Training: percentage of employees trained in the prevention of workplace harassment and violence.

Reporting of Complaints: number of workplace harassment and violence complaints, broken down by type and gender.

Sustainability

 

 

 

 

 

SASB Standards: sustainability metrics reported in accordance with the standards of the Sustainability Accounting Standards Board (SASB).

Optional Assurance: companies may voluntarily obtain independent assurance of their sustainability reporting, specifying the information subject to assurance and the standard applied.

These requirements have been phased in pursuant to a timetable established by the CMF and are currently applicable to all relevant companies, with the exception of the requirements relating to IFRS S1 and S2.

IFRS S1 and S2 Standards

NCG No. 519 established the obligation to report in accordance with IFRS S1, relating to general requirements for the disclosure of sustainability-related financial information, and IFRS S2, relating to climate-related disclosures, both issued by the International Sustainability Standards Board (ISSB).

Initially, these requirements were scheduled to become effective as of December 31, 2026 and would therefore have applied beginning with annual reports for fiscal year 2026.

The recently issued NCG No. 572 has deferred the effective date of these requirements by one year. The CMF has cited the existence of “significant challenges in the industry’s preparation” as the reason for the postponement.

As a result of this deferral, the obligation to report in accordance with IFRS S1 and S2 will become effective as of December 31, 2027, and will therefore apply beginning with annual reports for fiscal year 2027.

CMF Support

The CMF has nevertheless invited companies to report voluntarily in accordance with IFRS S1 and S2 for fiscal year 2026 and has offered technical feedback to companies that elect to do so.

In addition, during the current year, the CMF will implement an ongoing monitoring program to track the global development of these standards and will undertake initiatives intended to facilitate their implementation.

Recommendations

  • Review the current state of readiness of the information required under NCG No. 519 and the IFRS S1 and S2 standards.

  • Consider taking advantage of the CMF’s technical feedback, including the option to adopt these standards voluntarily for the 2026 annual report.

  • Develop an implementation timetable taking into account the extended deadline of December 31, 2027.

  • Monitor CMF announcements, training initiatives and further guidance relating to the implementation of these requirements.

Informational summary; this does not constitute legal advice. 

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