Regulatory Guide 2026

    IFRS S2 + NIS B-1 for Infrastructure in Mexico: 2026 Guide

    BMV and BIVA issuers face the unique challenge of simultaneously complying with IFRS S2 (CNBV) and NIS B-1 (CINIF) for the same fiscal year, implying two regulatory frameworks, two regulators, and potentially two external assurance processes. Without a centralized platform, companies end up with sustainability and finance teams operating in silos, collecting redundant data in non-auditable spreadsheets. The overlap between IBSO indicators and IFRS S2 metrics is significant but not total, requiring precise mapping.

    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 S2 + NIS B-1 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 S2 + NIS B-1 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 S2 + NIS B-1 in Infrastructure

    1. 1

      Mapping and reconciliation of all 30 IBSO indicators with IFRS S2 metrics requirements to avoid duplication of effort

    2. 2

      Unified GHG emissions data collection for Scope 1, 2, and 3 serving both frameworks simultaneously without double measurement

    3. 3

      Management of two distinct assurance processes: CNBV's limited assurance under IFRS S2 and CINIF's review under NIS B-1, ideally with the same auditor

    4. 4

      Alignment of reporting calendars — the integrated sustainability report must meet both deadlines from a single data collection cycle

    5. 5

      Implementation of robust internal controls over sustainability information capable of supporting third-party assurance under both frameworks from 2027

    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 S2 + NIS B-1 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 S2 + NIS B-1 Report Ready

    Generates the report in the exact CNBV + CINIF 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 S2 + NIS B-1 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 + CINIF. Aseguramiento limitado IFRS S2 + revisión NIS B-1 desde 2027.

    IFRS S2 + NIS B-1 requires: Mapping and reconciliation of all 30 IBSO indicators with IFRS S2 metrics requirements to avoid duplication of effort; Unified GHG emissions data collection for Scope 1, 2, and 3 serving both frameworks simultaneously without double measurement; Management of two distinct assurance processes: CNBV's limited assurance under IFRS S2 and CINIF's review under NIS B-1, ideally with the same auditor. 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 S2 + NIS B-1 report to CNBV + CINIF in 2026 face formal observations, potential suspension of stock exchange operations, and reputational damage with ESG investors. Aseguramiento limitado IFRS S2 + revisión NIS B-1 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 + CINIF format.

    Ready to comply with IFRS S2 + NIS B-1 in Infrastructure?

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