Regulatory Guide 2026

    IFRS S1 for Infrastructure in Mexico: 2026 Guide

    IFRS S1 establishes general requirements for BMV and BIVA-listed issuers to disclose material information about sustainability-related risks and opportunities in their annual reports. CNBV made it mandatory starting January 2025, with the first report covering FY2025 data due in 2026. IFRS S1 acts as the umbrella standard that complements IFRS S2 on climate-specific matters.

    Infrastructure concessionaires face the longest-term physical climate risk among BMV issuers — their assets have a 30-50 year horizon and are exposed to intensification of extreme events (hurricanes, floods, droughts). IFRS S2 requires 1.5°C/2°C/4°C scenario analysis for infrastructure assets, including adaptation and resilience costs that PINFRA and OHL must incorporate in their disclosed business plans.

    Why IFRS S1 Applies Differently in Infrastructure

    CFO and Sustainability Director of BMV-listed infrastructure concessionaires (roads, bridges, tunnels)

    Companies in this sector:PINFRAOHL MéxicoICAControladora Vuela

    Vehicle emissions on toll highways (Scope 3 Cat 13 — use of leased/concession assets) — calculation method based on vehicle count and fuel mix that varies by corridor

    Diesel consumption in construction and maintenance machinery distributed across 50+ simultaneous work fronts without sub-metering per project

    Physical climate risks in long-term assets (50-year concession) — climate scenario analysis for critical infrastructure required by IFRS S2

    Emissions from civil construction subcontractors (Scope 3 Cat 1 and Cat 2) — >60% of work executed by third parties without emissions data

    Critical IFRS S1 KPIs for Infrastructure

    Required KPIData SourceDifficulty
    tCO2e per km of managed highwayDirect combustion (Scope 1)High 🔴
    Diesel consumption in maintenance per km (liters/km/year)Electricity bills (Scope 2)High 🔴
    Percentage of projects with subcontractors reporting emissions (%)Cat 13 - Vehículos en autopistas concesionadasHigh 🔴
    Environmental incidents in construction zones (# per year)HR / payroll systemMedium 🟡
    Energy intensity at toll booths and equipment (kWh/vehicle-equivalent)ERP / accounting systemMedium 🟡

    Hard-to-Collect Data in Infrastructure

    Vehicle emissions by type (trucks, cars, motorcycles) at toll booths — requires emission factor per vehicle category and differentiated count

    Diesel consumption of subcontractors at remote work fronts without standardized timesheets

    Land use change data for biodiversity analysis in rights-of-way

    That is why manual Excel-based processes will not pass the 2027 assurance. Without automated traceability, an external auditor cannot verify the completeness or accuracy of emissions data.

    Checklist: 8 Steps to Comply with IFRS S1 in Infrastructure

    1. 1

      Identification and disclosure of all sustainability-related risks and opportunities material to the enterprise

    2. 2

      Description of board and management oversight of sustainability risks

    3. 3

      Scenario analysis to assess strategy resilience under different sustainability futures

    4. 4

      Description of processes for identifying, assessing, and managing sustainability risks integrated into corporate governance

    5. 5

      Disclosure of metrics and targets used to manage and monitor material risks and opportunities

    6. 6

      Connect data sources (ERP, meters, suppliers) to a centralized platform

    7. 7

      Review with internal audit team and adjust consolidation perimeter

    8. 8

      Generate report in CNBV/CINIF format ready for external assurance

    How Climatta Automates IFRS S1 for Infrastructure

    Automated Collection

    Eliminate spreadsheets in Infrastructure. Climatta connects your systems and automatically collects tCO2e per km of managed highway and other critical KPIs.

    Auditor-Grade Traceability

    Every data point has source, date, and owner documented. The 2027 assurance auditor can trace every figure to its origin in your systems.

    IFRS S1 Report Ready

    Generates the report in the exact CNBV format — tables, metrics, and narrative. No last-minute manual reformatting.

    Onboarding in 4 Weeks

    Climatta connects to Infrastructure systems in 4 weeks. No months-long IT project or external implementation consultant.

    FAQ: IFRS S1 in Infrastructure

    Yes. Infrastructure concessionaires face the longest-term physical climate risk among BMV issuers — their assets have a 30-50 year horizon and are exposed to intensification of extreme events (hurricanes, floods, droughts).

    The first report covers FY2025 and must be submitted in 2026 to CNBV. Aseguramiento limitado requerido desde 2027.

    IFRS S1 requires: Identification and disclosure of all sustainability-related risks and opportunities material to the enterprise; Description of board and management oversight of sustainability risks; Scenario analysis to assess strategy resilience under different sustainability futures. For Infrastructure, the most critical are: tCO2e per km of managed highway, Diesel consumption in maintenance per km (liters/km/year), Percentage of projects with subcontractors reporting emissions (%).

    Issuers that fail to submit the IFRS S1 report to CNBV in 2026 face formal observations, potential suspension of stock exchange operations, and reputational damage with ESG investors. Aseguramiento limitado requerido desde 2027.

    With Climatta, typical onboarding for Infrastructure takes 4–8 weeks: 2 weeks connecting to existing systems, 2 weeks validating historical data, and 2–4 weeks generating the pilot report in CNBV format.

    Ready to comply with IFRS S1 in Infrastructure?

    Climatta centralizes all data collection, generates the report in regulatory format, and leaves it ready for 2027 external assurance. No spreadsheets.