Mexican issuers filed their first sustainability report in 2026, with 2025 data. They could do it without an auditor, because the transitional provisions allow it for that report only. The 2027 report does not: it needs at least limited assurance, and the ones after it, reasonable assurance.
That means the greenhouse gas inventory for fiscal year 2026, the one being built right now, is the first an auditor will review. This guide explains the two standards behind it, CINIF's NIS and the CNBV rule, and where they overlap and where they do not.
Two standards, two audiences
It helps to separate them from the start, because they get mixed up.
| CINIF's NIS | CNBV article 82 Bis | |
|---|---|---|
| Who issues it | CINIF, the council that issues the NIF | The CNBV, by amending the issuer regulations |
| Who it applies to | Entities preparing financial statements under NIF | Issuers registered in the Registro Nacional de Valores |
| What it asks for | 30 basic sustainability indicators in the notes | A sustainability report aligned with IFRS S1 and S2 |
| From when | Fiscal years starting January 1, 2025 | 2026 report with fiscal year 2025 data |
| Assurance | Not required by the standard | None in 2026, limited in 2027, reasonable after that |
A mid-sized company that is not listed falls in the first column. An issuer falls in both: it discloses the NIS B-1 indicators in its notes and also files the full report the CNBV asks for.
The NIS: what they contain
CINIF published the first two standards on May 13, 2024. They came into force on January 1, 2025, so the first period reported under them is fiscal year 2025, in the financial statements filed in 2026.
NIS A-1 is the conceptual framework. It defines what sustainability information is, what its qualitative characteristics are and how it relates to the NIF. It is always applied together with a specific standard.
NIS B-1 is that specific standard. It sets 30 Basic Sustainability Indicators, the IBSO: 21 quantitative and 9 qualitative, all of which are disclosed. The quantitative ones are presented in absolute and relative terms, and all of them with comparative figures for the previous period.
The environmental indicators cover energy and water consumption, waste and greenhouse gas emissions by scope. Scope 3 is the only one with an explicit relief: the standard allows omitting it in the year following January 1, 2025. Comparatives are not required in the first year of application either.
CINIF says the NIS were developed in line with the first international sustainability standards, but they are not a copy of the IFRS S standards. They are anchored in the Mexican NIF and ask for a fixed set of indicators, while the ISSB standards ask for whatever is material to the investor. For an entity that only prepares NIF, the practical difference is that the list of what to measure is already written.
For small and mid-sized companies, CINIF released a free greenhouse gas calculator in July 2025, developed with support from GIZ. It walks the user through energy and fuel consumption and produces a report aligned with the Basic Sustainability Indicators.
The CNBV rule
The reform was published in the Diario Oficial de la Federación on January 28, 2025 and came into force the next day. It added article 82 Bis to the general provisions applicable to securities issuers.
The article requires issuers to prepare a sustainability report in accordance with the ISSB's sustainability disclosure standards: IFRS S1, on general requirements, and IFRS S2, on climate-related disclosures, plus whatever the ISSB issues later.
Three scope rules:
- Financial entities that are issuers, and issuers whose subsidiaries are mainly financial, follow the sustainability rules the financial authorities issue for each type of entity. The CNBV described this as a gradual incorporation.
- States and municipalities are excluded.
- Foreign issuers may use their home country's standards. If they do, they must state that the report does not follow the IFRS S standards, or explain its interoperability or equivalence.
The report is part of the annual information already listed in articles 33 and 37 of the same provisions.
The assurance timeline
The reform's transitional provisions set three steps:
| Report | Data from | Assurance |
|---|---|---|
| 2026 | Fiscal year 2025 | May be filed without external auditor assurance |
| 2027 | Fiscal year 2026 | At least limited |
| 2028 onwards | Fiscal year 2027 and later | Reasonable |
Reasonable assurance is the same level as a financial statement audit. For the emissions inventory, that means the auditor will ask for the activity data, the emission factor and the document behind each figure, and will recalculate a sample.
What IFRS S2 asks about emissions
IFRS S2 requires disclosing gross scope 1, 2 and 3 emissions, measured with the GHG Protocol unless an authority requires another method. Scope 3 is broken down by the standard's fifteen categories. Scope 2 is reported with the location-based method, and any contractual instrument, such as renewable energy certificates, is explained.
In December 2025 the ISSB published amendments to IFRS S2 that simplify these disclosures: they allow limiting scope 3 category 15 to financed emissions, widen the use of methods and warming potentials required by a local authority and relax the industry classification. They apply to periods beginning on January 1, 2027, with early adoption permitted.
The standard itself grants reliefs for the first period it is applied: no comparatives and no scope 3 emissions. For a Mexican issuer, that first period is the 2026 report, so scope 3 comes in with the 2027 one.
If your inventory already follows the GHG Protocol, the work is presentation. If you built it under ISO 14064-1, the GHG Protocol and ISO 14064 guide shows how categories map to scopes.
The other pieces on the board
The sustainability report is not the only emissions obligation in Mexico. Plants above 25,000 tonnes of CO2 equivalent report every year to the RENE through the COA, and several states levy carbon taxes with far lower thresholds. The RENE and COA guide explains who is required and when.
The useful part is that all three use the same data: tonnes of CO2 equivalent by source, with the fuel and electricity behind them. A well-documented inventory serves all three reports.
What we would do in your place
If you are an issuer, treat fiscal year 2026 as the first audited one, because it is. Close the organizational boundary, choose the base year and keep the invoice behind every activity figure. Limited assurance is earned with a tidy inventory; reasonable assurance, with a traceable one.
If you prepare NIF and are not listed, NIS B-1 already applies to you. The 30 indicators are disclosed in the notes with comparatives, so fiscal year 2026 needs the 2025 figure next to it. If you did not measure 2025, measure 2026 properly and document why the comparative is missing.
If you are a financial entity, your report follows the rules of your own regulator, which the CNBV announced as gradual. Check your circular before assuming the issuers' timeline, and start with the scope 3 of your lending, which is where IFRS S2 puts the focus for the sector.
Grumbic calculates emissions from your fuel and electricity invoices, classifies them by scope under the GHG Protocol and ISO 14064-1 and keeps every figure linked to the document it came from. That backing is what an auditor reviews in a reasonable assurance engagement.
See the platform or talk to us.
Sources
Information reviewed on October 17, 2026 in the Diario Oficial de la Federación and in documents from CINIF, the CNBV and the firms that analysed the reform. This guide is informative and does not replace legal or accounting advice.
- Resolution amending the general provisions applicable to securities issuers and other market participants, Diario Oficial de la Federación, January 28, 2025
- Sustainability Reporting Standards 2024, Greenberg Traurig analysis, June 2025
- IFRS S1 and S2: mandatory for securities issuers in Mexico, Forvis Mazars, January 28, 2025
- The CNBV and international sustainability standards for issuers, KPMG Mexico, February 2025
- CINIF opens its greenhouse gas calculator to the public, Corresponsables, July 2025
- CINIF, Colegio and IMCP present the greenhouse gas calculator, Colegio de Contadores Públicos de México, July 2025 (in Spanish)
- ISSB publishes amendments to IFRS S2 on greenhouse gas emissions disclosures, BDO, December 2025
- Support document for preparing the sustainability report, CNBV, March 2026
- IFRS S2 Climate-related Disclosures, IFRS Foundation


