Sustainability disclosure in Colombia (Financial Superintendence)

Colombia has no general law requiring every company to publish a sustainability report. What it has are circulars from the Financial Superintendence of Colombia (SFC) aimed at securities issuers and supervised entities, plus a convergence process towards international standards that is still unfinished.

The point third-party content most often gets wrong: IFRS S1 and S2 are not mandatory in Colombia as of August 2026. The Technical Council of Public Accounting (CTCP) is proposing a progressive, differentiated and initially voluntary convergence, and no decree imposes them.

External Circular 031 of 2021: disclosure for securities issuers

Issued on 22 December 2021, it adds an annex to Chapter I, Title V, Part III of the Basic Legal Circular covering disclosure of social and environmental matters, including climate-related ones.

• Who it applies to: securities issuers registered in the national securities and issuers registry.
• What is disclosed: practices, policies, processes and indicators on social, environmental and climate matters, assessed on financial materiality.
• Against which reference: the TCFD recommendations and the SASB standards.
• Where and when: in the year-end periodic report, and in quarterly reports where there are material changes.
• Transition: issuers had to submit an implementation plan, and the transition regime led to full compliance in 2024.

One clarification worth making about those references: the TCFD task force disbanded in 2023 and its recommendations were folded into IFRS S2, while the SASB standards now sit under the ISSB within the IFRS Foundation. In practice, a Colombian issuer preparing its Circular 031 disclosure today is already working very close to the IFRS S structure.

External Circular 015 of 2025: risk management, not just disclosure

Issued on 3 October 2025, it adds a new chapter to the Basic Accounting and Financial Circular on the management of environmental and social risks, including climate risks, in SFC-supervised entities.

It requires identifying, measuring, controlling and monitoring those risks systematically, with minimum elements such as an initial applicability filter based on product type and amount, categorisation of transactions by risk level, assessment of borrower risk, enhanced due diligence on high-risk transactions and periodic reporting to the board.

The deadlines: Circular Letter 067 of 2025 set the minimum content of the implementation plan, which had to reach the SFC by 3 April 2026, with a maximum of 18 months for full implementation.

Although the circular binds banks and insurers, the effect travels downstream: if you apply for credit or project finance, your lender will need environmental data from you to categorise the transaction and document its due diligence.

Green taxonomy and other pieces

The SFC issued instructions on adopting the Colombian Green Taxonomy through External Circular 005 of 2022, and has added further rules on sustainability-linked bonds and on integrating ESG factors into collective investment fund disclosure.

Where IFRS S1 and S2 actually stand in Colombia

This is the section where most of the misinformation circulates. The real state of play as of August 2026:

• On 21 February 2026 the CTCP published its strategic direction document on convergence towards the international standards for sustainability-related financial disclosure, with a comment period running into March 2026 that was later extended.
• In July 2026 the CTCP presented a roadmap with seven stages: diagnosis, scope, awareness, standard-setting, voluntary application, evaluation and monitoring.
• The approach is progressive, differentiated and initially voluntary convergence. The first phase contemplates voluntary application by securities issuers and public interest entities; only at the end of the process would the CTCP recommend to the relevant ministries whether to keep it voluntary or make it mandatory.
• No decree has brought IFRS S1 and S2 into the Colombian framework. Decree 0701 of 2026 adopted amendments to accounting standards, not sustainability standards.

It is worth not confusing Colombia with Mexico, where issuers already have to report under these standards. You can see the contrast in our article on IFRS S1 and S2 becoming mandatory for Mexican issuers.

What to do if you are a Colombian company

IFRS S not being mandatory does not mean nobody will ask you for the data. If you are an issuer, Circular 031 already binds you. If you are not, the pressure arrives through three channels: your bank, which has to comply with Circular 015; your European customers, who need value chain data; and funds and investors applying their own criteria. Building your report on the IFRS S1 and S2 structure of governance, strategy, risk management, and metrics and targets is the safe bet, because it serves all three.

Frequently asked questions

Are IFRS S1 and S2 mandatory in Colombia?

No. As of August 2026 they sit in a convergence process led by the CTCP, with an initially voluntary approach and no decree making them mandatory.

Who does External Circular 031 of 2021 apply to?

Securities issuers, which must disclose social, environmental and climate matters on a financial materiality basis in their year-end periodic report.

What changes with External Circular 015 of 2025?

It requires SFC-supervised entities to run a formal environmental, social and climate risk management system, with an implementation plan filed by 3 April 2026 and up to 18 months to implement it fully.

Which standards does a Colombian issuer use today?

Those set by Circular 031: the TCFD recommendations, now folded into IFRS S2, and the SASB standards, now under the ISSB. Many companies add voluntary reporting standards on top.

The hard part of any of these frameworks is not the narrative, it is the numbers and their traceability. Manglai calculates and documents the environmental data behind the disclosure. Start with our carbon footprint solution.