NCG 461 compliance guide for Chile

Preparing the NCG 461 integrated annual report is not a writing problem, it is a data collection problem. The order that works is: first set the calendar backwards from the shareholders' meeting, then close the perimeter, then decide your SICS industry classification, and only then go looking for the numbers. Reversing that order is the most common reason reports stall in March.

This guide walks through that process, with particular attention to the milestone shaping the current cycle: the obligation to report under IFRS S1 and IFRS S2 enters into force on 31 December 2026 and applies to reports covering the 2026 financial year.

Step 0. Confirm whether it applies to you, and from when

NCG 461 applies to issuers registered in the Securities Registry of the Financial Market Commission, phased in by consolidated total assets measured at the start of the financial year:

• Publicly held corporations above 20 million UF: from 31 December 2022.
• Publicly held corporations above 1 million UF: from 31 December 2023.
• Registered special corporations and all other issuers: from 31 December 2025, following the one-year deferral introduced by NCG 519.

If your entity fell into the last group, the 2025 financial year was your first integrated report and 2026 will be your first under IFRS. Two debuts in a row: agree the plan with the board early.

Step 1. Set the calendar from the meeting, not the accounting close

This is the most expensive planning mistake. For publicly held corporations, the report must be ready no later than the date of the first notice convening the ordinary shareholders' meeting, and made available to shareholders at that same time. For other entities, the deadline is four months after the financial year end.

Because the convening notice is published before the meeting, the real closing date for the report usually sits weeks earlier than people assume. Work backwards from there and reserve a block for verification if you plan to verify.

Step 2. Close the perimeter before requesting a single figure

Define and document which entities and facilities are in scope. Three decisions to put in writing:

• Which subsidiaries and associates are consolidated, and whether the sustainability perimeter matches the financial statements perimeter. If it does not, you need to be able to explain why.
• Which consolidation approach you use for emissions: operational control, financial control or equity share. ISO 14064 and the GHG Protocol allow several, but you have to be consistent year on year.
• Which establishments are registered in the RETC Single Window. If the report says one thing and the RETC another, the inconsistency is visible to the regulator.

Step 3. Decide your SICS classification and your SASB metrics

The rule requires reporting the SASB metrics that are material for your industry, in line with the SASB standard in force on 1 January of the reported year, using the Sustainable Industry Classification System the board considers most appropriate.

Three practical rules that get overlooked:

1. If you have substantial business in several industries, you must consider metrics beyond those of your primary sector.
2. Each metric is identified with its SASB code and reported in the standard's format. Monetary values go in millions of the same currency as your financial statements.
3. If you cannot estimate a metric, or doing so would require disproportionate cost or effort, you cannot silently omit it: the reasons must be stated explicitly.

The SICS decision drives all the collection that follows, because it determines which indicators you will have to chase. Take it in the first month.

Step 4. Go and get the data, knowing who holds it

This is the real work. The table below reflects where the data the report asks for usually sits, and who owns it inside an average company.

The legal and regulatory compliance section deserves separate attention: the rule asks for environmental compliance models or programmes, the number of final sanctions in the Public Sanctions Registry of the SMA, total fines, and the number of compliance programmes approved and successfully completed, along with environmental damage repair plans submitted and completed. If you do not have such programmes, you must say so explicitly and explain why.

Step 5. Treat climate risk as seriously as the rule requires

NCG 461 is not satisfied by a generic mention of climate change. Within the risk management framework, it requires describing:

• Physical and transition risks over the short, medium and long term, and the opportunities over the same horizon.
• The impact of those risks on operating costs, revenue, use of capital and access to financing.
• The scenarios used, if any, with a brief description.
• The role of the board and senior management in identifying, assessing, managing and monitoring those risks.

The original text of the rule named the TCFD among the possible references. That list was replaced with COSO, COBIT and ISO, consistent with the TCFD being disbanded in 2023 and its content absorbed into IFRS S2. If last year's report said the entity adheres to the TCFD, update it.

Step 6. Add the IFRS S1 and S2 layer for the 2026 financial year

NCG 519 introduced the obligation to report under IFRS S1, on general requirements for sustainability-related disclosures, and IFRS S2, on climate-related disclosures, both from the ISSB and covering the same annual period as the report. It enters into force on 31 December 2026.

What changes in practice:

• Information is structured around the standard's four pillars: governance, strategy, risk management, and metrics and targets.
• The bar rises for connection with the financial statements: current and anticipated financial effects have to be described, not hinted at.
• The emissions inventory stops being an annex and becomes a central metric of the report.
• In the first period of application, the transition regime of the standards themselves applies, and the entity must state explicitly in the report which of its provisions it is relying on.
• SASB metrics do not disappear: they coexist with IFRS inside the sustainability section.

Early adoption is possible and voluntary, provided it is stated explicitly. If your entity has a parent or investors already reporting under IFRS sustainability standards, moving early saves a year of double bookkeeping.

Step 7. Decide on verification

The rule does not impose external assurance of sustainability information, but it does require you to disclose whether it took place, over what set of information, and against which standard. In practice, stating that nothing was verified is a signal investors read.

If you are going to verify, decide the scope early: verifying only scopes 1 and 2 is far faster and cheaper than verifying the entire sustainability block, and is a reasonable starting point. If you already take part in HuellaChile, that programme's verification report covers the inventory and can be reused as supporting evidence.

Step 8. File through the SEIL module

The report is submitted as a PDF through the CMF's SEIL module. In addition, certain metrics are filed separately in the form the Commission provides within that same module, including those in the sustainability section. The report must also be published on the entity's website.

Allow time for the form: it requires metrics in the standard's exact format, not the free prose of the PDF. It is where most teams discover, too late, that a figure was in the wrong unit.

Where teams get stuck

1. The calendar. Planning against the accounting close instead of the meeting convening notice. Weeks disappear that never come back.
2. A moving perimeter. Requesting data before settling which subsidiaries are in scope, then having to redo the consolidation halfway through.
3. Scope 2 and renewable energy certificates. Contracts and certificates such as I-REC or those registered in RENOVA are treated differently depending on the calculation method. Document which method you use and do not switch criteria between years without explaining it.
4. Scope 3. This is where data is missing and where the temptation to estimate without traceability is greatest. Prioritise material categories, document the method and keep the evidence.
5. SASB metrics you cannot calculate. Omitting them without explanation is non-compliance. The rule requires stating the reasons explicitly.
6. Sanction data. Nobody has it consolidated. You have to go to the SMA Public Sanctions Registry and cross it with internal case files, and that takes time across several subsidiaries.
7. Inconsistency between channels. The report, the RETC declaration and the HuellaChile submission must tell the same story. When they do not, the explanation always costs more than the prevention.
8. Traceability. A verifier does not ask how much you emitted: they ask where that number comes from. If the answer is a spreadsheet with no source document, the process drags.

Frequently asked questions

When do I have to apply IFRS S1 and S2?

From 31 December 2026, in the report covering the 2026 financial year. Early adoption is voluntary and must be stated.

Can I stop reporting SASB metrics once IFRS applies?

No. SASB metrics by sector, using the SICS classification, remain required alongside the IFRS information.

What do I do with a metric I cannot estimate?

Report explicitly that you cannot estimate it and explain the reasons, including where doing so would involve disproportionate cost or effort.

Is my HuellaChile report useful for the annual report?

Yes, as an input. The inventory verified under NCh-ISO 14064/1:2019 supports the emissions metrics in the report, although the report demands far more than the inventory.

What currency do monetary metrics use?

Millions of the same currency used in the entity's financial statements.

The part that eats 80% of the time is gathering the figure and being able to trace it to its origin, not writing the report. Our carbon footprint solution is built for exactly that: one figure, with its document behind it, serving the annual report, the RETC and HuellaChile at once.