Regulatory Guide 2026

    IFRS S1 for Mining 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.

    Mining has the highest Scope 1 complexity in Mexico due to process emissions (explosives, heavy machinery diesel, beneficiation plants). IFRS S1 requires physical risk disclosure for tailings under extreme rainfall and transition risk from potential carbon tax that would affect operating costs at ~15-20 USD/t CO₂. Fresnillo and Grupo México have simultaneous exposure to UK and Canadian regulators.

    Why IFRS S1 Applies Differently in Mining

    VP of Sustainability and CFO of mining groups listed on BMV/LSE with simultaneous CNBV (IFRS S1/S2) and international regulator obligations

    Companies in this sector:Grupo MéxicoPeñolesFresnilloIndustrias Peñoles

    Fugitive emission calculation from open-pit blasting: ANFO explosive emission factor is not standardized in mining GHG Protocol and CNBV auditors will question it

    Groundwater consumption per mine in Chihuahua and Sonora aquifers: CONAGUA concessions vs. actual consumption diverge and IFRS S1 requires quantified water risk disclosure using AQUEDUCT methodology

    Scope 3 category 10 (processing of sold products): smelting and refining of metal concentrates by third parties generates emissions the miner must report even without operational control

    Historical environmental liabilities (tailings, slag) valued under NIF but not under IFRS S1 which requires physical risk analysis of collapse from extreme rainfall (Sonora cyclones)

    Critical IFRS S1 KPIs for Mining

    Required KPIData SourceDifficulty
    Carbon intensity: tCO₂e per tonne of fine metal produced (copper, silver, gold)Direct combustion (Scope 1)High 🔴
    Water consumption: m³ per tonne of processed ore broken down by source (surface, groundwater, recycled)Electricity bills (Scope 2)High 🔴
    Water recovery rate in closed-loop beneficiation circuitCat 1 - Explosivos y reactivos de proceso compradosHigh 🔴
    Tonnes of tailings generated per year and certified structural stability (NOM-141-SEMARNAT)HR / payroll systemMedium 🟡
    Energy intensity: GJ per tonne of extracted ore (differentiating open-pit vs. underground)ERP / accounting systemMedium 🟡

    Hard-to-Collect Data in Mining

    Fugitive methane emissions from blasting and tailings dust: require direct field measurement with portable analyzers, no valid generic factors exist by mineral type in Mexico

    Groundwater consumption per individual mine when wells are shared between operations in the same aquifer

    Hazardous waste by mineral type and process (cyanide leaching, flotation with reagents) broken down by destination: landfill, co-processing, recycling

    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 Mining

    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 Mining

    Automated Collection

    Eliminate spreadsheets in Mining. Climatta connects your systems and automatically collects Carbon intensity: tCO₂e per tonne of fine metal produced 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 Mining systems in 4 weeks. No months-long IT project or external implementation consultant.

    FAQ: IFRS S1 in Mining

    Yes. Mining has the highest Scope 1 complexity in Mexico due to process emissions (explosives, heavy machinery diesel, beneficiation plants).

    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 Mining, the most critical are: Carbon intensity: tCO₂e per tonne of fine metal produced (copper, silver, gold), Water consumption: m³ per tonne of processed ore broken down by source (surface, groundwater, recycled), Water recovery rate in closed-loop beneficiation circuit.

    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 Mining 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 Mining?

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