Why Mexico’s CNBV decision matters for sustainability reporting globally
On 28 January 2025, Mexico’s National Banking and Securities Commission (CNBV) published a resolution in the Diario Oficial de la Federacion (DOF) that modified the reporting provisions for securities issuers. The resolution makes sustainability reporting under ISSB standards mandatory for all publicly listed companies in Mexico. This is not a voluntary framework or a comply-or-explain regime. It is a binding regulatory requirement.
Mexico is the first country in North America to adopt IFRS S1 (General Requirements for Disclosure of Sustainability-related Financial Information) and IFRS S2 (Climate-related Disclosures) as mandatory reporting standards. While Canada, the United States, and other economies in the region continue to debate the scope and timing of sustainability disclosure requirements, Mexico has moved ahead with a clear timeline and enforceable obligations.
The decision aligns Mexico with the global convergence trend led by the ISSB. Jurisdictions including the United Kingdom, Australia, Singapore, Nigeria, and several others have already signalled adoption of ISSB standards. Mexico’s move adds a significant Latin American economy to that list and creates direct implications for multinational companies with operations or listings on the Bolsa Mexicana de Valores (BMV) or the Bolsa Institucional de Valores (BIVA).
For companies already reporting under the EU’s Corporate Sustainability Reporting Directive (CSRD), the overlap with ISSB standards is substantial. Both frameworks require disclosure of climate risks, opportunities, governance structures, and GHG emissions across scopes 1, 2, and 3. Companies operating across both jurisdictions can build a single data collection infrastructure that serves multiple frameworks, reducing duplication and improving data consistency.
Timeline and scope: who must report, and when
The CNBV resolution establishes a phased implementation with specific deadlines that securities issuers must meet.
First mandatory report: 2026 (covering fiscal year 2025 data). All securities issuers regulated by the CNBV must file their first sustainability report aligned with the Normas de Informacion de Sostenibilidad (NIS), which incorporate IFRS S1 and IFRS S2 as issued by the ISSB. This means companies need to have collected fiscal year 2025 data under the new framework. If your company has not yet started this data collection, the urgency is real.
Limited assurance: mandatory from the 2026 report (filed in 2027). Starting with the report covering fiscal year 2026, companies must obtain limited assurance over their sustainability disclosures. This requires engaging an independent third party to verify the data. Companies should begin selecting assurance providers and establishing internal controls now, rather than waiting until 2027.
Reasonable assurance: mandatory from the 2027 report (filed in 2028). The escalation from limited to reasonable assurance within just one year is aggressive by international standards. Reasonable assurance requires more extensive testing, larger sample sizes, and deeper verification procedures. Companies that treat limited assurance as a temporary minimum will struggle to scale their processes in time for reasonable assurance.
Scope of application. The mandate applies to all securities issuers regulated by the CNBV. This covers companies listed on BMV and BIVA, along with other entities subject to CNBV’s disclosure requirements. Financial institutions are currently excluded while the CNBV analyses how NIS requirements will apply to their specific regulatory context. This exclusion is temporary and subject to future rulemaking.
Temporary relief provisions. Two specific areas receive transitional relief. Scope 3 GHG emissions reporting and sustainable investment disclosures may be deferred until the end of fiscal year 2026. This means the first mandatory report (covering FY2025) does not require full scope 3 data, but the second report (covering FY2026) does. Companies should treat this relief as preparation time, not as permission to delay scope 3 data collection entirely.
Private companies and the NIS A-1/B-1 standards
For private (non-listed) companies, a parallel set of standards applies. The Consejo Mexicano de Normas de Informacion Financiera (CINIF) has issued NIS A-1 and NIS B-1, which provide simplified sustainability reporting requirements. These standards are designed for companies that are not subject to CNBV regulation but want to align with international sustainability reporting practices.
CINIF has stated that NIS A-1 and B-1 will progressively converge with ISSB standards over time. Private companies that begin adopting these standards now will benefit from a smoother transition if they later seek public listing or if the regulatory perimeter expands to include non-listed entities.
How to prepare: practical steps for companies listed on BMV
Compliance with NIS/ISSB requirements demands coordinated action across sustainability, finance, legal, and operations teams. The following steps address the most critical preparation areas.
Map your current reporting against IFRS S1 and S2
Start with a gap analysis. If your company already publishes a sustainability report under GRI, SASB, or the GHG Protocol, compare your current disclosures against the specific requirements of IFRS S1 and IFRS S2. Key gaps typically include: governance-level disclosure of sustainability risk oversight, quantitative scenario analysis for climate risks and opportunities, and granular GHG emissions data broken down by scope and category.
IFRS S1 requires disclosure of how sustainability-related risks and opportunities affect a company’s financial position, financial performance, and cash flows. This goes beyond narrative descriptions. Companies must connect sustainability factors to financial outcomes using quantitative data where possible.
IFRS S2 focuses specifically on climate. It requires disclosure of climate-related risks and opportunities, including transition risks (policy changes, technology shifts, market dynamics) and physical risks (acute events, chronic changes). The standard also requires disclosure of GHG emissions across scopes 1, 2, and 3 using the GHG Protocol methodology.
Build your data collection infrastructure
The single largest barrier to ISSB compliance is data. Sustainability data typically resides across dozens of internal systems and external sources: utility bills, supplier invoices, fleet management platforms, HR systems, financial accounting software. Collecting, validating, and consolidating this data manually is time-consuming and error-prone.
Dcycle’s automated data collection platform connects directly to these sources, extracting the data companies need for IFRS S1 and S2 compliance. This eliminates manual spreadsheet workflows and reduces the risk of errors that trigger audit findings. For scope 1 and 2 emissions, the platform calculates emissions using verified emission factors. For scope 3, it supports supplier engagement workflows and estimation methodologies aligned with the GHG Protocol.
Establish assurance readiness from day one
Given the rapid escalation from limited to reasonable assurance, companies should design their sustainability data processes with assurance in mind from the start. This means establishing clear data ownership for each disclosure metric, documenting data sources and calculation methodologies, implementing internal review and approval workflows, and maintaining audit trails for all data transformations.
Dcycle’s carbon footprint measurement capabilities include built-in audit trail functionality, ensuring that every data point can be traced back to its source. This is exactly what assurance providers will require when performing their verification procedures.
Address scope 3 strategically
The temporary relief on scope 3 reporting is not a reason to ignore it. Scope 3 emissions typically represent 70% to 90% of a company’s total GHG footprint. Building the supplier engagement processes, estimation models, and data collection channels for scope 3 takes 12 to 18 months in most organizations.
Companies that begin scope 3 preparation now will have quality data ready for their second mandatory report (covering FY2026). Those that wait until the relief period expires will face compressed timelines and higher costs.
For companies with complex supply chains, start by mapping your highest-emitting scope 3 categories (typically purchased goods and services, upstream transportation, and business travel). Focus data collection efforts on the categories that represent the largest share of your total emissions, then expand coverage over time.
Implications for multinational companies operating in Mexico
The CNBV mandate creates specific obligations for international companies with Mexican listings or significant Mexican operations.
Dual-framework reporting. Companies also subject to CSRD, SEC climate rules, or other national sustainability disclosure requirements will need to map NIS/ISSB requirements against their existing obligations. The good news: ISSB standards were designed for interoperability. The ISSB and EFRAG have published detailed interoperability guidance showing how IFRS S1/S2 and ESRS disclosures can be prepared from a common dataset. Dcycle’s platform supports multi-framework reporting from a single data layer, which is precisely the approach multinational companies need.
Consolidation challenges. Parent companies with Mexican subsidiaries must determine how Mexican NIS disclosures will integrate with group-level sustainability reporting. Questions of consolidation boundaries, intercompany data flows, and internal assurance processes need to be resolved well before the first filing deadline.
Competitive positioning. Mexico’s decision signals to investors, customers, and regulators across Latin America that mandatory sustainability disclosure is arriving. Companies that build robust ISSB reporting capabilities now will be better positioned as other jurisdictions in the region follow Mexico’s lead. Brazil, Chile, and Colombia have all taken steps toward mandatory sustainability reporting, and Mexico’s move accelerates that regional trend.
Next steps
The CNBV resolution leaves no ambiguity. Securities issuers in Mexico must report under ISSB-aligned NIS standards starting with fiscal year 2025 data. Limited assurance follows immediately, and reasonable assurance arrives one year later. Companies that have not begun preparation are already behind schedule.
For a detailed view of how your current data infrastructure maps to ISSB requirements, request a demo of the Dcycle platform. The platform’s automated data collection, multi-framework calculation engine, and audit-ready reporting capabilities are designed for exactly this type of regulatory transition.
Additional context on how international sustainability standards are evolving is available in the carbon footprint reporting collection, which covers GHG Protocol, ISSB, and ESRS interoperability in depth.