PEGS ESG Framework Version 1 - Phase 1 Public Consultation Paper: Doctrine and Architecture

Document Ref: PEGS/PROD/PCP/v1.0/2026
Template Version: 1.0 (May 2026)
Methodology Version: ESG-900 v1.0
Status: Phase 1 Public Consultation Paper - Doctrine and Architecture
Prepared by: PEGS Standards & Systems Pvt. Ltd.
Date: 20 May 2026

Executive Summary

PEGS Standards & Systems Pvt. Ltd. has published the PEGS ESG Framework Version 1, methodology version ESG-900 v1.0, applied to Earth-based real estate constructed assets. The framework replaces benchmark-based ESG scoring with planetary threshold scoring, retains the architectural discipline familiar to ESG raters (three pillars, equally weighted parameters and indicators, 900 total points), and removes geography, climate zone, jurisdiction, local peer average, local market practice and local regulatory minimum from the scoring path.

This Phase 1 Public Consultation Paper invites stakeholder input on the doctrine and architecture of the framework. A subsequent Phase 2 Public Consultation Paper, to be published 6 to 9 months after the close of Phase 1, will cover thresholds and evidence rules.

The Phase 1 consultation window is 60 days from publication. Responses may be submitted through an online consultation portal, by email, through a structured response template, or in-person at consultation workshops convened in major markets. The PEGS Standards Body, governed under the Governance Charter for PEGS Standards Body, will publish a consolidated response document.

Stakeholders are particularly invited to consider:

• Whether the PEGS planetary doctrine is sound, defensible, and operable for asset-level ESG scoring.
• Whether the equal-weight architecture (three pillars at 300 points each; equal-weight parameters and indicators within each pillar) is appropriate.
• Whether the dual materiality test (planetary alignment plus long-term asset value) is the right framing.
• Whether the architecture is portable to other asset classes and future habitats.
• Whether the claims discipline is sufficient to prevent greenwashing.

1. Purpose

This paper opens the Phase 1 public consultation on the PEGS ESG Framework Version 1. It is the consultation document under which PEGS Standards & Systems Pvt. Ltd. invites broad stakeholder input on the framework's doctrine and architecture.

The paper serves four purposes:

1. To present, in accessible language, the PEGS position on doctrine and architecture so that all interested parties can engage without prior technical familiarity.
2. To set out structured consultation questions that stakeholders can respond to.
3. To define audience-specific question sections recognising that investors, developers, academics, and public-interest stakeholders have distinct perspectives.
4. To explain how responses will be collected, synthesised, and published.

This paper does not duplicate the technical content of the methodology documents. Technical content remains in the methodology document set referenced in §6 below. Stakeholders may consult those documents alongside this paper.

2. Scope of Phase 1 Consultation

The Phase 1 consultation covers:

• The PEGS planetary doctrine.
• The PEGS architecture (three pillars, 15 parameters, 44 indicators, 900 points).
• The equal-weight doctrine for parameters and indicators.
• The dual materiality doctrine.
• The five-band score system and the three-tier assessment system.
• The trust infrastructure framing (BASTION, UAIN, UEIN at the doctrinal level).
• The claims discipline.
• The governance architecture of the PEGS Standards Body.
• The asset-class portability of the architecture (future extension to metals, automobiles, infrastructure, orbital assets, planetary habitats).

The Phase 1 consultation does not cover (these are reserved for Phase 2):

• Exact threshold values for individual indicators.
• Detailed evidence rules per indicator.
• The Accepted Authorities Register's specific entries.
• The Indicator Dictionary's detailed validation checks.
• SOPHIE confidence calibration values.
• BASTION cryptographic specifics.

Phase 2 will publish 6 to 9 months after the close of Phase 1, informed by Phase 1 synthesis.

3. How to Read This Paper

The paper is organised into the following parts.

Readers may engage with the paper at three levels: the executive summary (5 minutes), the position paper (60 minutes), or the full consultation including audience-specific questions (2 to 4 hours).

4. Audience and Track Mapping

This paper serves four audience tracks. A respondent may belong to one or more tracks; respondents are encouraged to identify their primary track when submitting.

All audience tracks share the cross-cutting questions in §9. The audience-specific sections add questions relevant to each track's perspective.

5. Relationship to Other PEGS Documents and Processes

This Phase 1 Public Consultation Paper sits alongside the PEGS ESG Framework Version 1 document set. It is distinct from the Peer Review Submission Pack.

Public Consultation Paper (this document)
  - Audience: broad stakeholder base across investors, developers, academics, policymakers, NGOs, civil society, users.
  - Purpose: open public input on doctrine and architecture at v1.0 publication.
  - Duration: 60 days (Phase 1); Phase 2 to follow.

Peer Review Submission Pack (PEGS/PROD/PRS/v1.0/2026)
  - Audience: technical reviewers across four reviewer tracks (academic, ratings/standards bodies, audit/assurance, institutional investors).
  - Purpose: structured technical peer review of the full methodology document set.
  - Duration: up to 16 weeks per reviewer.

Stakeholders engaging through public consultation are not required to also engage through peer review. Peer review and public consultation are independent processes designed to capture different inputs at appropriate depths.

This paper draws on the methodology documents but does not replace them. Where a respondent wishes to engage at the methodology-document level of detail, the documents are referenced in §17.

6. PEGS Position - Doctrine

6.1 What PEGS Is

PEGS means Planetary ESG for Growth and Sustainability. The PEGS ESG Framework is an asset-level ESG scoring methodology designed to measure sustainability performance at the constructed asset level against planetary thresholds.

ESG-900 v1.0 is the first formal implementation of the PEGS architecture, applied to Earth-based real estate constructed assets. Future PEGS asset-class methodologies may apply the same architecture to metals, automobiles, infrastructure, paintings, orbital assets and planetary habitats.

The framework is published for Phase 1 public consultation in advance of empirical pilot evidence and any market certification activity. Peer review is in progress through a separate Peer Review Submission Pack.

6.2 The Planetary Doctrine

PEGS scores are referenced to planetary operating discipline rather than to local peer distributions, sector medians, jurisdictional norms, or geographic context.

The rule, expressed throughout the framework, is:

Context may explain performance.
Context must not change the PEGS score.

The rule operationalises into specific prohibitions: thresholds may not be modified by geography, climate zone, jurisdiction, local peer average, local market practice or local regulatory minimum; thresholds may not be tuned to a desired score outcome or a desired certification rate.

The case for the planetary doctrine rests on three points.

1. Sustainability impact is planetary in consequence. Carbon emitted in one city operates on the same atmosphere as carbon emitted in another. A score that varies by location cannot signal planetary alignment.
2. Cross-jurisdiction comparability is weakened by jurisdiction-adjusted thresholds. Investors deciding capital allocation across borders cannot rely on locally adjusted scores.
3. Jurisdiction adjustment imports the ambition deficits of low-ambition jurisdictions into the framework. A framework using local minimums as thresholds is bounded by the slowest-moving jurisdictions in its coverage.

The cost of the planetary doctrine is that some assets will receive lower scores than they would receive under benchmark-based systems. This is the intended behaviour. Performance below a planetary threshold should produce a lower score regardless of how that performance compares to local peers.

6.3 The Equal-Weight Doctrine

PEGS uses equal-weight distribution within parameters and within pillars. Each pillar carries 300 points. Within each pillar, parameters are equally weighted. Within each parameter, indicators are equally weighted.

The case for equal-weight rests on three points.

1. Reproducibility. Weight assumptions are a principal driver of ESG rating divergence. Equal-weight distribution removes weighting as a contested design choice.
2. Transparency. Equal-weight is explicit and defensible. No specific weight for any indicator requires private justification.
3. Simplicity. Equal-weight is operable by competent assessors and reproducible by independent reviewers.

Equal-weight distribution does not preclude considering importance differentials elsewhere. The Materiality and Investor Use Case Paper discusses, indicator by indicator, the use-case dimensions on which each indicator is most material. Users wanting to apply their own decision-specific weights may do so, but the canonical PEGS score uses equal-weight.

6.4 The Dual Materiality Doctrine

PEGS treats an issue as material if it satisfies either of two tests:

Test 1 - Planetary alignment.
Does the issue affect the asset's alignment with planetary
sustainability operating limits?

Test 2 - Long-term asset value.
Does the issue affect the asset's long-term economic value,
risk profile, resilience, insurability, compliance posture,
financing access, or capital allocation suitability?

An indicator is included in PEGS only if it can be argued under at least one test and is observable at the constructed-asset level. The dual test bridges single materiality (financial, ISSB-aligned) and double materiality (financial plus impact, ESRS-aligned) without picking sides. Where the two tests agree, materiality is unambiguous. Where they diverge, the framework retains the issue and discloses it.

6.5 The Claims Discipline

PEGS Certification is certification under ESG-900 v1.0 only. It does not constitute:

• Net-zero certification.
• GRI, BRSR, ISSB, ESRS, GRESB, CDP, NABERS, LEED, BREEAM, SASB, HKEX, or JSE compliance or certification.
• Any external framework certification.

PEGS outputs may support external reporting preparation. The claims doctrine, codified across multiple methodology documents, treats greenwashing as a structural risk to address through claims discipline rather than only through assurance.

7. PEGS Position - Architecture

7.1 Three Pillars, Fifteen Parameters, Forty-Four Indicators

ESG-900 v1.0 uses three pillars, fifteen parameters and forty-four indicators, totalling 900 points.

The fifteen parameters across the three pillars are:

• Environmental: Energy Consumption, GHG Emissions, Water Consumption, Waste Generation, Natural Habitat State.
• Social: Occupant Satisfaction, Health and Safety Incidents, Community Initiatives, Affordability Index, Social Stability.
• Governance: Regulatory Compliance, Ethics Violations, Governance Stability, Sustainability Reporting, Transparency and Accountability.

Each parameter has between one and five indicators. Each parameter carries 60 points. Indicators share parameter points equally.

7.2 Score Bands

PEGS uses five score bands.

7.3 Assessment Tiers

PEGS uses three assessment tiers. Both the score band and the assessment tier must be disclosed together.

A "PEGS Gold - Basic Assessment" is not equivalent to a "PEGS Gold - Certification". The two carry materially different evidence depth.

7.4 Trust Infrastructure

PEGS uses three infrastructure layers to support institutional reliance.

BASTION supports integrity. It does not replace evidence review or third-party assurance. Detailed BASTION technical positioning is published in the BASTION Score Anchoring Technical Note.

7.5 Architectural Portability

The PEGS skeleton is permanent across asset classes. Future PEGS methodologies may apply to:

• Metals as an asset class.
• Automobiles as an asset class.
• Paintings and art assets.
• Infrastructure.
• Movable assets.
• Orbital assets.
• Planetary habitats.
• Mars-based constructed assets.

Future asset classes may define different parameters, indicators, evidence rules, and threshold values. They must preserve the PEGS skeleton: three pillars at 300 points each, equal-weight distribution, planetary threshold doctrine.

For non-Earth contexts, planetary alignment is redefined for the relevant habitat operating limits rather than reintroducing local benchmarking.

8. Governance and Independence

The PEGS Standards Body is governed under the Governance Charter for PEGS Standards Body. The Body has five governance bodies:

1. Board of Standards - highest authority; approves methodology, threshold values, and major decisions. Founder retains permanent Chair seat.
2. Methodology Team - drafts and maintains methodology documents.
3. Certification Committee - reviews and approves certification decisions where committee review applies.
4. Independent Appeals Body - hears second-stage appeals with binding decisions; members independent of Methodology Team and Certification Committee.
5. Advisory Board - provides stakeholder input across four categories; non-voting on Board decisions; nominates non-chair Board members.

The Standards Body is sponsor-hosted at v1.0 by PEGS Standards & Systems Pvt. Ltd. The Charter documents a phased evolution toward operational independence over five years.

Methodology changes follow tiered public consultation: major changes 60-day public consultation; minor changes 30-day stakeholder consultation; patch updates notification only.

9. Cross-Cutting Consultation Questions

The following questions apply across all audience tracks. Respondents are invited to answer all questions that are relevant to their expertise and interest.

9.1 On Planetary Doctrine

1. Is the PEGS planetary doctrine (geography, climate zone, jurisdiction, local peer average, local market practice and local regulatory minimum as non-scoring metadata only) sound for asset-level ESG scoring?
2. Are there contexts in which planetary thresholds should be modulated by local conditions? If yes, how can such modulation be reconciled with the planetary doctrine?
3. Is the rule "Context may explain performance. Context must not change the PEGS score" operable in practice? What implementation challenges do you foresee?
4. Should the framework allow for explicit "transition pathways" by which assets in particular conditions are evaluated against an expected improvement trajectory rather than a single threshold? If yes, how can this be reconciled with planetary discipline?

9.2 On Architecture

1. Is the three-pillar, fifteen-parameter, forty-four-indicator structure appropriate for Earth-based real estate constructed assets?
2. Is the equal-weight distribution (within pillars and within parameters) defensible against alternative weighting schemes (expert-elicited weights, materiality-weighted, performance-driven weights)?
3. Are 900 points appropriate as the total score range, or would another total (e.g., 100, 1000) be preferable?
4. Are the five score bands (Platinum, Gold, Silver, Bronze, Unrated) appropriately defined?
5. Are the three assessment tiers (Indication, Basic Assessment, Certification) appropriately defined and operable?

9.3 On Materiality

1. Is the PEGS dual materiality test (planetary alignment plus long-term asset value) the right framing?
2. How does it compare against single materiality (ISSB-aligned) and double materiality (ESRS-aligned)?
3. Should PEGS adopt a more explicit position on dynamic materiality?

9.4 On Claims Discipline

1. Is the PEGS claims discipline (no automatic equivalence with external frameworks, no net-zero claims, prohibited statement list) sufficient to prevent greenwashing?
2. Should additional claims controls be introduced at v1.0 or reserved for Phase 2?

9.5 On Architectural Portability

1. Is the PEGS skeleton (three pillars, equal-weight, planetary doctrine) sound for asset-class extension to metals, automobiles, infrastructure, paintings, orbital assets, and planetary habitats?
2. What architectural constraints would the framework need to address to support non-Earth contexts?

9.6 On Governance

1. Is the five-body governance architecture (Board of Standards, Methodology Team, Certification Committee, Independent Appeals Body, Advisory Board) appropriate for a young sustainability standard?
2. Is the phased evolution toward operational independence (sponsor-hosted at v1.0, operational independence target by Year 5) defensible?
3. Is the founder permanent Chair seat acceptable in a v1.0 founding configuration?
4. Should the Advisory Board's academic-research weight be calibrated differently?

10. Audience-Specific Question Sections

Respondents are encouraged to answer questions in their primary audience track. Cross-track responses are welcomed.

10.1 Track A - Institutional Investors, Lenders, and Insurers

The following questions are directed to capital allocators, debt providers, and underwriters.

1. Does the PEGS planetary doctrine produce scores that are useful for cross-border portfolio decisions, or does the absence of local context create barriers to use?
2. How would your institution use a PEGS score in credit risk assessment, sustainability-linked instrument structuring, or underwriting?
3. Is the dual disclosure of score band, assessment tier, and (where applicable) PEGS assurance level (Limited or Reasonable) adequate to inform your institutional decisions?
4. Is the PEGS Data Confidence Score (separate from the PEGS ESG score) useful in your diligence?
5. What additional disclosures would your institution require from a PEGS assessment to rely on it for material decisions?
6. How does PEGS compare in your view against benchmark-based ESG ratings (e.g., GRESB, MSCI, Sustainalytics) for asset-level decisions?
7. Should PEGS provide indicator-level public disclosures, or is pillar-level disclosure adequate for institutional reliance?
8. What role do you see for PEGS in supporting ISSB IFRS S1/S2, ESRS, BRSR, TCFD, and similar disclosure obligations?

10.2 Track B - Developers, Owners, Operators, and Corporate Finance Teams

The following questions are directed to parties that own, develop, operate, or finance constructed assets.

1. Is the PEGS framework operable from an asset owner or operator perspective? What are the principal implementation challenges?
2. How does the planetary doctrine affect the feasibility of achieving PEGS Certification in your local market?
3. Are the evidence requirements at Basic Assessment and Certification tier proportionate to the value of the resulting score for your institutional uses?
4. Is the certification validity (5 years with annual check-in) commercially viable for the asset lifecycle of your portfolio?
5. What retrofit and capex priorities does the framework's indicator structure surface for your existing assets?
6. Are the assessment-tier evidence requirements (30% Basic, 70% Certification) achievable for your portfolio, or do they require evidence collection beyond your current operational capability?
7. Should the framework provide explicit guidance for mixed-use assets, hospitality assets, industrial assets, and institutional assets beyond the current asset-function categorisation?
8. How should the framework treat assets in development (pre-operational) versus operating assets?

10.3 Track C - Academic and Research Institutions

The following questions are directed to academic researchers, planetary boundary scientists, sustainability science institutions, and research bodies.

1. Is the PEGS planetary doctrine methodologically defensible against alternative approaches (peer benchmarking, sector medians, jurisdiction-adjusted)?
2. Are the threshold types (planetary-aligned, maximum tolerable, absolute requirement, proportional, integrity, red-flag, future placeholder) sufficient and complete?
3. How does the PEGS architecture relate to existing planetary boundaries downscaling work (e.g., Häyhä et al. 2016; Ryberg et al. 2018; O'Neill et al. 2018)?
4. Is the architecture portable to absolute sustainability assessment frameworks (Hauschild et al. 2013; Bjørn et al. 2016)?
5. What replicability standards should be required for asset-level scoring methodologies of this nature?
6. Are there specific research gaps the framework needs to address before pilot deployment?
7. How does the dual materiality framing relate to ongoing materiality debates in sustainability science and corporate reporting?
8. What inter-rater variance levels should be expected for a framework like PEGS, and how should they be measured?

10.4 Track D - Policymakers, Regulators, NGOs, Civil Society, Asset Users and Tenants

The following questions are directed to public-interest stakeholders including policymakers, regulators, NGOs, community representatives, and asset users.

1. Does the PEGS planetary doctrine align with public-interest objectives for sustainable real estate?
2. How does the framework interact with national and sub-national sustainability regulation? Are there alignment gaps?
3. Is the framework's affordability indicator (SMAI2.1 Housing Cost to Income Ratio at 30% full-credit threshold) appropriate for protecting social-foundation outcomes?
4. Are the community-initiative indicators (SMCI3 cluster) and equal-access indicators (SMSS5.4) sufficient to capture community and social-licence dimensions?
5. How should the framework engage with rights-based concerns, including discrimination, accessibility, and grievance resolution?
6. Are the red-flag conditions sufficient to prevent a high PEGS score from masking severe community or environmental harm?
7. How should the framework engage with informal-settlement contexts, where evidence rules may be harder to satisfy and where affordability may be most acute?
8. Should the framework provide a public-facing accessible summary of each scored asset for the benefit of users, tenants, and surrounding communities?
9. How should the framework interact with regulator-led ESG disclosure regimes (e.g., BRSR in India, ESRS in the EU)?
10. What independence safeguards do you consider necessary for the PEGS Standards Body to merit public trust?

11. Response Mechanism

Responses may be submitted through the following channels.

11.1 Online Consultation Portal

The primary channel is an online consultation portal operated by PEGS Standards & Systems Pvt. Ltd. The portal accepts:

• Structured responses against the consultation questions in §9 and §10.
• File uploads for longer submissions.
• Optional respondent identification with attribution preferences.

Portal access details are published with this paper.

11.2 Email Submissions

Respondents preferring email may submit responses to the consultation address published with this paper. Submissions should reference the question numbers in §9 and §10. PEGS confirms receipt of email submissions within five working days.

11.3 Structured Response Template

A downloadable structured response template is provided alongside this paper. Respondents complete the template and submit via the portal or by email. The template structure mirrors §12.

11.4 In-Person Consultation Workshops

PEGS convenes in-person consultation workshops in major markets during the consultation window. Workshops are designed for:

• Academic and research institutions.
• Institutional investors, lenders, and insurers.
• Developer and asset-owner associations.
• Policymakers, regulators, and multilateral institutions.
• Civil society organisations and community representatives.

Workshop dates, locations, and registration details are published with this paper. Workshop discussions are captured under Chatham House Rule unless a participant explicitly agrees to attribution. Workshop summaries are integrated into the consolidated response document.

11.5 Languages

The primary language of consultation is English. Translated summaries of the position paper and consultation questions may be made available in additional languages where stakeholder demand and PEGS capacity allow. Translations are published with the consultation paper where available.

11.6 Accessibility

PEGS aims to make the consultation accessible to respondents with diverse needs. Accessibility accommodations (alternative formats, extended time, interpreter support at workshops) may be requested through the consultation address.

12. Response Template

Respondents are encouraged to structure their submissions using the following template.

12.1 Respondent Identification

Respondent name:               ______________________________________
Respondent organisation:       ______________________________________
Primary audience track:        A / B / C / D
Secondary track(s) if any:     ______________________________________
Country / region:              ______________________________________
Attribution preference:        Attributed / Anonymous / Mixed
Date:                          ____ / ____ / ________

12.2 Responses to Cross-Cutting Questions

For each question in §9 you wish to answer, provide:

• Question reference (e.g., §9.1 Q2).
• Response.
• Supporting reasoning or evidence.

12.3 Responses to Audience-Specific Questions

For each question in your audience-track section (§10.1, §10.2, §10.3, or §10.4) you wish to answer, provide:

• Question reference.
• Response.
• Supporting reasoning or evidence.

12.4 General Observations

Respondents may provide additional observations not captured by the structured questions.

12.5 Recommendations for Phase 2

Respondents may indicate specific threshold values, evidence rules, or other Phase 2 considerations they would like to see addressed when the Phase 2 consultation opens.

12.6 Disclosures

Respondents are invited to disclose any material interest in PEGS, its partners, or affected assets.

13. Phase 1 Timeline

PEGS may adjust the timeline in exceptional circumstances and will communicate any changes through the consultation portal.

14. Phase 2 Preview - Thresholds and Evidence Rules

Phase 2 of the v1.0 public consultation will open 6 to 9 months after the close of Phase 1. The Phase 2 paper will cover:

• The current threshold values for individual indicators (currently published in PEGS/PROD/CTV/v1.0/2026 as peer-review considerations).
• The accepted authorities and evidence equivalence rules.
• The indicator-by-indicator evidence rules.
• The data confidence calibration values.
• The SOPHIE inference confidence model.
• The mandatory verified-data list at Certification tier.

Phase 2 consultation will be informed by:

• Phase 1 synthesis and Board of Standards decisions on doctrine and architecture.
• Pilot evidence collected during the Phase 1 window.
• Peer review responses arriving through the Peer Review Submission Pack.
• Specific Phase 2 recommendations submitted in Phase 1 responses (§12.5).

Phase 2 will also follow a 60-day public consultation under the Governance Charter §13.2.

15. PEGS Response Commitment

PEGS Standards & Systems Pvt. Ltd. commits to publishing a structured response to material consultation input.

15.1 Response Categories

Each material response will be categorised as:

15.2 Publication

The Phase 1 consolidated response document will be published as part of the v1.0 final release or with the next methodology release that incorporates the responses. The response document will identify each material input by respondent (subject to attribution preferences under §16), categorise the response, provide PEGS reasoning, and cross-reference the affected methodology document and section.

15.3 Respondent Pre-Publication Review

Named respondents will be offered the opportunity to review the PEGS response to their own input before the response document is published. Pre-publication review does not extend to other respondents' inputs or to PEGS's editorial decisions.

16. Anonymity and Attribution

PEGS handles respondent identity as follows.

• Respondents are attributed by default in the published consolidated response document.
• Respondents may request anonymity in writing at any point during the consultation window. If anonymity is requested, the published response document identifies the respondent only by an audience track and a serial identifier.
• Respondents may request redaction of specific responses while remaining attributed for other responses.
• PEGS retains internal records of respondent identity for audit and governance purposes regardless of public attribution status.

Workshop discussions are captured under Chatham House Rule unless a participant explicitly agrees to attribution.

17. Confidentiality and Intellectual Property

17.1 Confidentiality of the Consultation Paper

This paper is published openly. Respondents may share, quote, distribute, and discuss this paper freely.

17.2 Confidentiality of Respondent Submissions

Respondent submissions are treated as follows.

• Attribution and content for material inputs are eligible for publication in the consolidated response document.
• Detailed respondent reasoning that is not material to the consolidated response may be retained internally and not published.
• Confidential information explicitly marked by the respondent will be retained internally and not published unless the respondent later consents.
• Personal data is processed in accordance with applicable data protection regimes.

17.3 Intellectual Property

Respondents grant PEGS Standards & Systems Pvt. Ltd. a non-exclusive, worldwide, royalty-free licence to use submitted responses for the purposes of methodology development, governance, and publication of the consolidated response document. Respondents retain ownership of their submissions.

PEGS retains intellectual property in the PEGS ESG Framework methodology and supporting documents. Use of the methodology by external parties is governed by separate licensing arrangements.

18. Limitations

This paper has the following limitations.

• The consultation covers Phase 1 (doctrine and architecture) only. Threshold values and evidence rules are reserved for Phase 2.
• The consultation timeline of 60 days reflects the Governance Charter §13.2 standard major-change consultation. It may be insufficient for the most extensive academic engagement; respondents requesting extended time may submit through the published process.
• The consultation language is primarily English. PEGS aims to extend language coverage as capacity allows.
• Workshop locations are limited by PEGS capacity at v1.0; not every market may be served by an in-person workshop.
• Phase 2 timing is indicative (6 to 9 months after Phase 1 close). Phase 2 will not commence until Phase 1 synthesis is sufficiently advanced.

19. Open Items

The following items are tracked for v1.0 completion or Phase 2 reservation.

20. References

20.1 PEGS Methodology Documents

• PEGS ESG Framework Master Standard, ESG-900 v1.0, 20 May 2026 (PEGS/PROD/MST/v1.0/2026).
• PEGS Planetary Threshold Methodology Note, ESG-900 v1.0, 20 May 2026 (PEGS/PROD/PTM/v1.0/2026).
• PEGS ESG-900 Formula Register for Earth-Based Real Estate Constructed Assets, ESG-900 v1.0, 19 May 2026 (PEGS/PROD/FRM/v1.0/2026).
• PEGS Indicator Threshold Register and Rationale, ESG-900 v1.0, 19 May 2026 (PEGS/PROD/THR/v1.0/2026).
• PEGS Current Threshold Values for Peer Review and Score Replication, ESG-900 v1.0, 19 May 2026 (PEGS/PROD/CTV/v1.0/2026).
• PEGS Accepted Authorities and Evidence Equivalence Register, ESG-900 v1.0, 19 May 2026 (PEGS/PROD/AER/v1.0/2026).
• PEGS Indicator Dictionary and Evidence Manual, ESG-900 v1.0, 20 May 2026 (PEGS/PROD/IDM/v1.0/2026).
• PEGS Assessment and Certification Protocol, ESG-900 v1.0, 19 May 2026 (PEGS/PROD/ACP/v1.0/2026).
• PEGS Materiality and Investor Use Case Paper, ESG-900 v1.0, 20 May 2026 (PEGS/PROD/MIU/v1.0/2026).
• PEGS Third-Party Assurance Protocol, ESG-900 v1.0, 20 May 2026 (PEGS/PROD/TAP/v1.0/2026).
• PEGS Peer Review Submission Pack, ESG-900 v1.0, 20 May 2026 (PEGS/PROD/PRS/v1.0/2026).
• PEGS Data Quality and Confidence Methodology, ESG-900 v1.0, 20 May 2026 (PEGS/PROD/DQC/v1.0/2026).
• PEGS SOPHIE Inference Methodology Note, ESG-900 v1.0, 20 May 2026 (PEGS/PROD/SIM/v1.0/2026).
• PEGS BASTION Score Anchoring Technical Note, ESG-900 v1.0, 20 May 2026 (PEGS/PROD/BAN/v1.0/2026).
• PEGS Governance Charter for PEGS Standards Body, ESG-900 v1.0, 20 May 2026 (PEGS/PROD/GOV/v1.0/2026).
• PEGS Version Control and Change Log Policy, ESG-900 v1.0, 20 May 2026 (PEGS/PROD/VCP/v1.0/2026).
• PEGS Document Reference Format Guide, PEGS/LEGAL/PRV/v1.0/2026.

20.2 External References

• ISEAL Code of Good Practice for Setting Social and Environmental Standards.
• WTO Agreement on Technical Barriers to Trade (TBT) Annex 3 - Code of Good Practice for the Preparation, Adoption and Application of Standards.
• ISSB IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information.
• ISSB IFRS S2 Climate-related Disclosures.
• European Sustainability Reporting Standards (ESRS).
• SEBI Business Responsibility and Sustainability Report (BRSR) framework.
• Task Force on Climate-related Financial Disclosures (TCFD) Recommendations.