The update incorporates technical progress as the ISSB considers the feedback it received on the draft IFRS Sustainability Disclosure Standards, including headway towards interoperability. They also share the latest on institutional progress in establishing the ISSB, and insights into key announcements from COP27 towards the implementation of IFRS Sustainability Disclosure Standards in 2023.
Developing Standards on General Sustainability-related Disclosures and Climate-related Disclosures
The ISSB received over 1,400 responses from key stakeholders around the world to its consultation on draft Standards and is grateful to all stakeholders that took the time to respond. It is looking to complete discussions on the feedback received by the end of this year, to enable final Standards to be issued as early as possible in 2023.
To date, the ISSB has discussed the following based on feedback received:
- On information needs of investors, through the consultation the ISSB received feedback that some of the language that had been used in the draft Standards to describe what information is material to investors was not easily understood and could cause confusion when preparing disclosures. Feedback highlighted that the terms ‘enterprise value’ and ‘significant’, which had been used within the objective and assessment of materiality were not clear in their meaning.
As such, the ISSB is looking at better ways to communicate how it describes which sustainability risks and opportunities must be reported on, without changing the intent.
To this end, the ISSB will use the same definition of material as is used in IFRS Accounting Standards ie information so important that its absence or misstatement could be reasonably expected to influence investor decisions. It will also consider how to use existing materials to better articulate the scope of information that is required to be provided, including considering using concepts of capital from the Integrated Reporting Framework.
- On GHG emissions, the ISSB has heard that companies and investors cannot fully understand transition risks without the disclosure of absolute gross scope 1, 2 and 3 GHG emissions, as proposed in the draft IFRS S2. It has also heard concerns about challenges in how to measure this.
As such, the ISSB has confirmed that, when material, companies will be required to disclose Scope 1, 2 and 3 emissions.
However, to address the challenges raised the ISSB will discuss potential Scope 3 reliefs, including discussing ‘safe harbour’ provisions with regulators to address concerns about the risk of liability associated with disclosing this information and guidance on how to measure and estimate GHG emissions in a scalable manner.
- On scenario analysis, the ISSB confirmed that companies are required to use climate-related scenario analysis to report on climate resilience and to explain whether and how this was used to identify climate-related risks and opportunities.
Feedback through the consultation indicated questions around what is meant by the term ‘climate-related scenario analysis’, so the ISSB also agreed to provide guidance to preparers including making use of materials developed by the Task Force for Climate-Related Financial Disclosures (TCFD) to provide guidance on how to undertake scenario analysis, so as to enable and support the delivery of high-quality disclosures. The way in which climate-related scenario analysis must be undertaken will also be scaled based on what a company is able to do – the criteria to determine this will be discussed by the ISSB at a later meeting.
- On industry-based disclosure, investors said they find industry-specific disclosures decision-useful, but there was some feedback that further consideration may be needed to ensure that the industry-based climate disclosures that were proposed will provide relevant information internationally and that time is needed to consider potential implementation challenges.
Therefore, while companies will be required to provide industry-specific climate disclosures, for now Appendix B of IFRS S2 will be non-mandatory guidance, illustrating examples of appropriate disclosures, as the ISSB takes time to ensure disclosures are relevant across jurisdictions, with a view to making them mandatory in the future following further consultation.
- On timing of reporting, feedback indicated support for the requirement to publish sustainability-related information and financial statements at the same time, but that there are implementation challenges around delivering this in the near term.
The ISSB therefore decided to keep the requirement to publish this information at the same time – something the ISSB and stakeholders through the consultation see as critical for giving investors a complete picture - but will allow companies to report its annual sustainability-related financial disclosures at the same time as its H1/Q2 earnings reporting for a short period of time as a transition relief. The length of the relief will be decided at a future meeting of the ISSB.
The ISSB has always been clear that interoperability and a ‘building block approach’ are key to delivering a truly global baseline of sustainability-related disclosures for capital markets.
Through the Jurisdictional Working Group and the upcoming Sustainability Standards Advisory Forum, as well as bilateral discussions, the ISSB is prioritising work to facilitate compatibility between the baseline and these ‘building blocks’. The ISSB also regularly consults with IOSCO in preparation for potential IOSCO endorsement of its Standards.
In progressing the development of the IFRS Sustainability Disclosure Standards, the ISSB has prioritised agreeing clarifications and amendments that support and further progress towards interoperability. This includes confirming use of the TCFD architecture as the basis for its Standards and modifying some disclosures and language in relation to transition plans.
The ISSB is also working with the European Commission and EFRAG towards a shared objective to agree as soon as practicable a framework for maximising interoperability of their standards and aligning on key climate disclosures.
While the ISSB’s mandate is to meet the needs of investors and the European Union (EU) has a focus on meeting broader information needs, there is a commonality of interest in meeting the information needs of investors and other providers of capital. That intersection forms the basis of and need for interoperability of the ISSB and EUs’ bodies of sustainability-reporting standards, which is what the ISSB is working towards.
The ISSB is clear that alignment of disclosure requirements is essential for global comparability of sustainability disclosures and for preventing unnecessary duplications in reporting for companies.
Watch this video to find out more about our progress from Glasgow to Sharm El-Sheikh in establishing the ISSB, setting out key developments including:
- The ISSB is now fully operational with a diverse 14-member board supported by a strong technical staff team.
- The IFRS Foundation has implemented a multi-location model with current offices in Frankfurt, Montreal, London, San Francisco and Tokyo.
- The Climate Disclosure Standards Board and Value Reporting Foundation (Integrated Reporting Framework and SASB Standards) have been consolidated into the IFRS Foundation.
- The ISSB is collaborating with global and regional partners and has established a number of advisory bodies to enable deep engagement with experts around the world.
- The G7 has welcomed the inauguration of the ISSB and its progress on delivering the global baseline of sustainability disclosure standards. The G20, Financial Stability Board (FSB) and African ministers have also offered support.
At COP27, the ISSB announced further steps in its delivery of the architecture needed for a global baseline, as well as partnerships that will help jurisdictions prepare for its implementation.
Recognising that the IFRS Foundation’s responsibilities do not stop at standard setting, the ISSB launched its new Partnership Framework, with around 30 partner organisations, designed to support preparers, investors and other capital market stakeholders as they prepare to use IFRS Sustainability Disclosure Standards.
And in a continued alignment with key initiatives, crucial to reducing market fragmentation, CDP and the ISSB announced that CDP will incorporate the IFRS S2 Climate-related Disclosure requirements into its global environmental disclosure platform. The announcement means that CDP’s 17,000+ voluntary users will disclose data structured to IFRS S2 in the 2024 disclosure cycle.
One year on from the announced establishment of the ISSB at COP26, the ISSB is now fully operational and committed to issuing its first two Standards in 2023.
The ISSB has set out its priorities for furthering this progress, including supporting adoption and application, developing a digital taxonomy, improving the international applicability of the SASB Standards, driving connectivity with the International Accounting Standards Board (IASB) and interoperability with others (including GRI), as well as consulting on new areas of work in the first half of 2023.
We hope you find this update and summary of achievements helpful in giving you some insight into the ISSB’s progress since its formation. If you would like to discuss any of the points raised, please speak to your usual Grant Thornton contact or your local member firm.