Mexico has introduced comprehensive sustainability reporting requirements that will significantly impact both private companies and public issuers. If your company operates in Mexico or has Mexican subsidiaries, here's what your ESG team needs to prepare for.

Connection to Global ESG Frameworks

Mexico's new sustainability standards represent a significant step toward global convergence in ESG reporting. The Mexican standard setter (CINIF) has committed to aligning with IFRS Sustainability Disclosure Standards, with public companies directly applying ISSB standards starting in 2026.

How this connects to your existing reporting: If you're already reporting under GRI, SASB, TCFD, or CDP, you likely have much of the required data. The emissions reporting follows GHG Protocol, and many indicators mirror common GRI metrics. However, Mexico's approach is more prescriptive—all 30 indicators must be reported with no materiality assessment, unlike most global frameworks that allow companies to focus on what's material to their business.

What's missing: The current NIS standards don't yet include the full governance and risk management disclosures required by TCFD or ISSB, though CINIF plans to address this gap with future standards, starting with climate-related financial disclosures.

Two Paths: Private vs. Public Companies

Private Companies (NIS Standards)

All entities using Mexican Financial Reporting Standards must include sustainability disclosures in their financial statement footnotes starting with fiscal years beginning January 1, 2025. This includes foreign subsidiaries reporting under Mexican standards.

Public Companies (ISSB Standards)

Issuers on Mexican stock markets must prepare separate annual sustainability reports following full ISSB standards (IFRS S1 and S2), with first reports due in 2026 covering 2025 data. Foreign issuers may use home country standards if they explain differences.

Understanding the 30 Required Indicators

The heart of the private company requirements is NIS B-1, which mandates reporting on 30 specific Basic Sustainability Indicators (IBSO). There's no materiality threshold—every indicator must be reported, even if the value is zero. Both absolute and relative values are required for quantitative metrics.

Environmental Indicators (16 total)

Climate and Energy: Scope 1, 2, and 3 GHG emissions; total and renewable energy consumption; sustainable investment

Water Management: Water intake (including from water-stressed areas), reuse, and discharge; treated wastewater percentage

Waste and Land Use: Total waste generated, recycled, and hazardous waste; land use near biodiversity areas; dependency on ozone-depleting substances

Social Indicators (6 total)

Workforce Metrics: Gender pay gap, training hours per employee, percentage receiving performance evaluations, work-related accidents causing disability or death

Policies Required: Equal opportunities and decent work policies; health and safety management policies

Governance Indicators (8 total)

Board Diversity: Women on the board of directors (the only quantitative governance metric)

Required Policies and Structures: Board structure and independence, risk management policy, sustainability strategy, code of ethics, information security measures, third-party data protection

Key Implementation Considerations

Timeline and Transitions

Private companies begin reporting for 2025 fiscal years with no comparative data required in year one. Companies can delay Scope 3 emissions and sustainable investment reporting until 2026 if they disclose this election. Public companies face a phased approach: reporting in 2026, adding limited assurance in 2027, and upgrading to reasonable assurance in 2028.

Assurance and Audit Requirements

The Mexican Institute of Public Accountants clarified that IBSO indicators don't require auditing despite being in financial statement footnotes. They're considered "other information" and may be labeled as unaudited, though voluntary third-party assurance is permitted. Public companies, however, must obtain external assurance beginning in 2027.

Who's Exempt

Companies using IFRS Accounting Standards or US GAAP aren't subject to NIS requirements. Financial institutions that are issuers will have separate requirements from Mexican financial authorities. Federal entities and municipalities are also excluded.

Practical Steps for ESG Teams

• Immediate Actions: Start by determining which requirements apply to your organization and assessing your current data readiness for all 30 indicators. Map existing sustainability data collection against the specific IBSO requirements to identify gaps.

• System Preparation: Establish clear calculation methodologies following NIS B-1 specifications and implement controls that match your financial reporting processes since disclosures will be in financial statement footnotes. Create templates and workflows that your finance team can work with.

• Governance Setup: Brief leadership on the prescriptive nature of these requirements—this isn't a materiality-based exercise. Assign clear ownership for each indicator and establish review processes that integrate with your financial reporting calendar. Consider whether voluntary assurance would benefit your organization even before it's required.

Key Takeaways

The timeline is tight, especially for companies with January year-ends who need to report by early 2026. Unlike other frameworks, there's no flexibility to focus on material topics—all 30 indicators are mandatory. The integration with financial statements means these disclosures will receive the same scrutiny as your financial data.

While these requirements may seem extensive, they represent Mexico's commitment to standardized sustainability transparency. Companies already reporting under international frameworks have a head start, but will need to ensure they capture Mexico's specific requirements. Starting preparation now will help ensure smooth implementation and avoid year-end scrambles.

Resources for Further Information

Review the full NIS standards from the Instituto Mexicano de Contadores Públicos (IMCP) and monitor CINIF announcements for upcoming standards on climate and other topics. For public company requirements, check CNBV updates and ISSB developments. Consider engaging local sustainability reporting experts familiar with Mexican requirements to ensure compliance.