The meeting began with three presentations: A representative of the European Financial Reporting Advisory Group (EFRAG) introduced ESRS E1 Climate Change; a representative of the International Public Sector Accounting Standards Board (IPSASB) discussed the consultation paper Advancing Public Sector Sustainability Reporting; and Acting Chief Accountant Paul Munter presented on the proposed US Securities and Exchange Commission (SEC) rule The Enhancement and Standardization of Climate-Related Disclosures for Investors.
The objective of ESRS E1 is to specify disclosure requirements that would enable users of sustainability reporting to understand how an undertaking affects climate change in terms of actual or potential impacts, the undertaking’s past, current and future mitigation efforts, the plans and capacity of the undertaking to adapt its business model(s) and operations, the nature, type and extent of the material physical and transition risks and opportunities, and the effects of climate-related risks and opportunities on the undertaking’s development, performance, position over the short, medium and long term and its ability to create enterprise value. The proposed requirements are very comprehensive and granular, so while the overall feedback was generally supportive, there were calls to simplify and clarify. The IFASS members also commented on the degree of detail, but were told that while EFRAG was working hard on identifying possible simplifications, there was little room for them and that there was also the need to balance granularity for comparability against the call for simplifications.
The IPSASB consultation is not about about standard-setting per se, but more about the question whether the IPSASB should move into the area of sustainability reporting. Triggering the IPSASB's initiative was the clear realisation that there is a marked gap in the public sector that needs to be filled, especially since natural resources are a major source of income of governments in some jurisdictions. Feedback to the consultation showed that stakeholders agreed that the public sector needs sustainability reporting, that the IPSASB should lead the development of public sector sustainability reporting guidance, and that the IPSASB should work in collaboration with other international bodies to address global inconsistencies. Comments from the room echoed the feedback that a global approach is needed and that the IPSASB should not start from scratch but should build on existing frameworks (especially on the ISSB standards) and adjust them to public sector needs. The IPSASB representative admitted that sustainability reporting was not a political priority for jurisdictions and also not an area of IPSASB expertise. So further steps of the IPSASB regarding sustainability reporting need to be carefully thought about.
The Acting Chief Accountant noted that the SEC proposed rule amendments that would require a domestic or foreign registrant to include certain climate-related information in its registration statements and periodic reports as investors have expressed a need for more consistent, comparable and reliable information about the effects of climate-related risks on a company’s business and as current climate-related disclosure practices are fragmented and inconsistent. He explained that the rule amendments are not aimed at telling businesses what to do, but if they do something, then the rule amendments would detail how to report on it. He also noted that many companies already report on sustainability outside of their filings, but to require them to include this information in their filings would streamline the reporting and, most importantly, ensure that the information reported is prepared with greater care and rigour. The SEC received more than 14,000 comments on its proposal - after evaluating the feedback, the Commission will decide whether to adopt final rules.
The presentations were followed by a panel discussion chaired by ISSB Vice-Chair Sue Lloyd with panel members from the Australian Accounting Standards Board (AASB), the UK Financial Reporting Council (FRC), the Korean Accounting Standards Board (KASB), the Pan-African Federation of Accountants (PAFA), and the Sustainability Standards Board of Japan (SSBJ). The panel members expressed full support for the global baseline approach of the ISSB, which they described as much needed. Other comments included:
- Global baseline does not mean that the standards are basic; they will provide a full set of information for investors.
- The fact that the standards are based on the TCFD recommendations is greeted in the UK where mandatory TCFD-reporting is currently being phased in.
- There is some anxiety in African countries about what sustainability reporting will mean in practice.
- Australia will use the ISSB standards as starting point and then, if necessary, add Australia-specific requirements (same approach as with IFRSs).
- It was noted that the ISSB standards will need to allow for enough flexibility to actually build on them (e.g. regarding double materiality).
- There were concerns from several jurisdictions regarding the industry specific part of the climate standard, which were perceived as not being international enough and in some cases divided rather arbitrarily between the two standards proposed by the ISSB.
- The standards should be inclusive and scalable. This should not only refer to more advance and less advanced jurisdictions, but also to entity size.
- It would be good if the standards could also be applied across different sectors.
- The tension between investors calling for industry-specific requirements for reasons of comparability and the fact that industries and companies falling into these industries differ across jurisdictions was pointed out.
- The amount of quantitative information required might be difficult to obtain. Might qualitative information work as an interim replacement?
- The level of preparedness and knowledge between jurisdictions and between companies differs greatly. In some jurisdictions companies have other pertinent problems.
- Jurisdictions are willing to support adoption of ISSB standards and capacity building, however, the ISSB will also have to provide support and supporting material.
- The link between financial reporting and sustainability reporting was considered problematical, especially in jurisdictions where there is a great litigation risk (Korea, Australia).
- The different time horizon between financial reporting and sustainability reporting was seen as difficult as the same issue might be assessed differently when looked at with a time horizon of one year or several years.
- It was also noted, that some information that would be included in sustainability reporting simply could not be reflected in financial reporting.