Summary
Details
- Mexico
Mandatory for covered issuers and other specified market participants subject to the CNBV dispositions.
Exceptions typically relate to:
entity type (not all companies, only those under CNBV market rules),
transitional provisions (phased assurance or phased scope),
simplified regimes where permitted by the dispositions.
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What’s Required
Under the CNBV modification to the “Disposiciones de carácter general aplicables a las emisoras de valores y a otros participantes del mercado de valores,” covered entities must:
Prepare and publish a standalone annual sustainability report (or sustainability information within the required structure), aligned to ISSB standards referenced by CNBV (IFRS S1 and IFRS S2, and future ISSB standards as applicable).
Disclose governance, strategy, risk management, and metrics/targets consistent with ISSB architecture, including climate-related disclosures under IFRS S2.
Integrate reporting into annual filing workflows: establish internal controls, sign-offs, and documentation comparable to financial reporting processes.
Address assurance expectations: market guidance and professional commentary indicate staged assurance (limited then reasonable) as the regime matures, so issuers should design evidence-ready processes.
Important Deadlines
Publication date: 28 January 2025 (DOF publication via SIDOF).
Phasing: Implementation staging is referenced in market guidance and should be mapped to the issuer’s annual reporting calendar and CNBV filing requirements.
Current Status
In force / effective as updated CNBV reporting requirements, with the consolidated CNBV dispositions reflecting the DOF publication date.
Penalties for Non-Compliance
Potential consequences include:
CNBV administrative enforcement for incomplete, late, or misleading disclosures,
market consequences (investor actions, listing-related scrutiny),
potential liability exposure where disclosures are false or insufficiently supported.
Examples of Known Violations
Common disclosure-regime failure modes include:
reporting that is not aligned to the mandated standards (partial alignment, missing required pillars),
weak climate scenario analysis or lack of documented methodology,
unsupported metrics (emissions, financed emissions if applicable, targets),
greenwashing risk from inconsistent statements across investor materials vs CNBV filings.
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