Pakistan SECP IFRS S
SECP Order of 31 Dec 2024 (Companies Act 2017, s.238; no S.R.O. no. cited) — Adoption of IFRS S1/S2
Topic : ESG disclosure · Level : National
Today
Phase I listed firms apply IFRS S1/S2 for periods from 1 Jul 2025; Phase II from 1 Jul 2026; all listed from 1 Jul 2027.
Summary
Pakistan's SECP adopted IFRS S1 and S2 by order of 31 Dec 2024. Large listed firms (Phase I) apply them for periods from 1 Jul 2025, mid-size from 1 Jul 2026, all listed and public interest firms from 1 Jul 2027. Assurance is required from year two.
Who is concerned
- Turnover
- Ph I >PKR25bn; Ph II >PKR12.5bn (2 of 3 tests)
- Employees
- Ph I >1,000; Ph II >500
- Listed company
- cotées et non cotées
- Sectors
- All sectors
- Triggering activities
- PSX listing
- 2 of 3 tests: turnover, staff, total assets
- Unlisted public interest company (Phase III)
- Extraterritorial reach
- No
non précisé
- Examples
- PSX-listed textile exporter (Phase I)
- Pakistani cement maker with Chinese kilns
- CPEC power producer listed on PSX
What the law requires
- Report sustainability and climate disclosures under IFRS S1 and S2 per phase
- Use first-year relief: file separately within 9 months of year end
- Obtain assurance from the second reporting year
Penalties
General Companies Act 2017 enforcement by SECP; no penalty specific to IFRS S1/S2 published (checked 4 Nov 2026).
What this changes for a supplier in China
Pakistani textile and industrial firms using Chinese machinery, fibres and chemicals will request climate data as Scope 3 relief phases out.
Expected evidence
- Scope 1-2 GHG data
- Product carbon footprint for inputs
- Energy use records
Tiers : Tier 1