# What did the December 2025 IFRS S2 amendments change for banks' financed emissions?

Canonical: https://senseible.earth/answers/ifrs-s2-category-15-financed-emissions-relief

The December 2025 amendments let banks and other financial institutions limit Category 15 to financed emissions from loans and investments, leaving out derivatives, facilitated emissions and insurance-associated emissions, and drop the fixed GICS industry split. They apply from 1 January 2027, with earlier use permitted. Lending and investment emissions are still required.

## What changed for Category 15

- Scope of Category 15: a company may limit it to financed emissions, meaning loans and investments (plus assets under management for asset managers), leaving out emissions linked to derivatives, facilitated emissions (such as underwriting a bond issue) and insurance-associated emissions. It must describe the financial activities it excluded, and where it reports Category 15 it shows financed emissions as a subtotal.
- Industry breakdown: banks no longer have to use the Global Industry Classification Standard (GICS) to split financed emissions by industry; they may use another classification, such as one a regulator already uses.
- Measurement method: where a jurisdiction requires another method for measuring emissions, the relief from the GHG Protocol can apply to the parts of the group it covers.
- Global warming potentials: a company may use the GWP values its jurisdiction requires instead of the latest IPCC assessment.

## What did not change

Financed emissions from loans and investments stay in. Banks still disclose absolute gross financed emissions, split by industry and asset class, with the approach used. A business loan to an MSME is exactly the kind of exposure that remains in scope.

## Dates and status in India

The amendments apply to annual periods beginning on or after 1 January 2027, and a company may apply them earlier. India has not made IFRS S2 mandatory for banks as of this review; check RBI's current climate-related disclosure directions on rbi.org.in. The amendments matter to an Indian bank or NBFC that reports under IFRS S2 voluntarily, for a foreign parent, or for international investors.

## What this means for an MSME borrower

Requests for your emissions will not stop. Banks commonly score financed emissions with PCAF data quality scores, where reported emissions from the borrower score better than estimates from revenue or loan size. Sending your own Scope 1 and 2 figure, with the bills behind it, moves your loan out of the estimated bucket.

## What Senseible does here

Senseible gives borrowers document-backed Scope 1 and 2 figures, each traced to its bill or invoice, that a bank can use as reported emissions in its PCAF scoring, and its lender dashboard shows PCAF alignment signals for the borrowers a bank follows.

- [Financed emissions for Indian banks](https://senseible.earth/climate-intelligence/financed-emissions-banks-india)
- [Does IFRS S2 apply in India?](https://senseible.earth/answers/does-ifrs-s2-apply-in-india)
- [IFRS S2 cross-industry metrics](https://senseible.earth/answers/ifrs-s2-cross-industry-metrics-list)

Sources: [Amendments to Greenhouse Gas Emissions Disclosures, Amendments to IFRS S2, ISSB, December 2025 (ifrs.org)](https://www.ifrs.org), [PCAF Global GHG Accounting and Reporting Standard for the Financial Industry](https://carbonaccountingfinancials.com)

Last reviewed 2026-10-16. Confirm the final wording, scope and effective date of the December 2025 IFRS S2 amendments on ifrs.org, and any RBI climate disclosure rules for Indian banks.