ISSB exposure draft of general requirements of sustainability reporting

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31 Mar 2022

The Chair and Vice-Chair of the International Sustainability Standards Board (ISSB) have published the exposure draft 'General Requirements for Disclosure of Sustainability-related Financial Information' that builds on the TRWG prototype of the same name. The deadline for submitting comments is 29 July 2022.

 

Background

In November 2021, the IFRS Foundation announced the creation of its new International Sustainability Standards Board (ISSB) tasked with developing a comprehensive global baseline of high-quality sustainability disclosure standards to meet investors’ information needs.

In order to facilitate a running start of the ISSB, a Technical Readiness Working Group (TRWG) had been created in March 2021. Concomitantly with the announcement of the formation of the ISSB, the TRWG published a General requirements for disclosure of sustainability-related financial information prototype.

In an additional meeting in March 2022, the Due Process Oversight Committee (DPOC) confirmed that it does not object to the ISSB Chair and Vice-Chair publishing the exposure draft General Requirements for Disclosure of Sustainability-Related Financial Information that builds on the TRWG prototype before the ISSB is quorate.

The proposed standard on general requirements for sustainability-related disclosures published today is accompanied by an exposure draft of the ISSB's first thematic standard on climate related disclosures.

 

Key proposals

The main proposals in ED/2022/S1 General Requirements for Disclosure of Sustainability-Related Financial Information generally reflect the proposals in the prototype with some changed titles and strengthened definitions and some changes to the order of proposals. They cover the following aspects of sustainability reporting: 

  • Objective: The objective of sustainability-related financial disclosures is providing information about the significant sustainability-related risks and opportunities to which the reporting entity is exposed that is useful to primary users of general purpose financial reporting in deciding whether to provide resources to the entity. A reporting entity discloses material information about all of the significant sustainability-related risks and opportunities to which it is exposed. Materiality is assessed in the context of the information necessary for users of general purpose financial reporting to assess enterprise value.
  • Scope: A reporting entity would apply the proposed standard in preparing and disclosing sustainability-related financial information in accordance with IFRS Sustainability Disclosure Standards. The application of the standard is not restricted to entities applying IFRSs.
  • Core content: An entity would provide disclosures about governance, strategy, risk management, and metrics and targets unless another IFRS Sustainability Disclosure Standard permits or requires otherwise.
  • General features: Applying the proposed general requirements standard, an entity would disclose information that is relevant and faithfully represents what it purports to represent. Usefulness of the information provided is enhanced if the information is comparable, verifiable, timely and understandable.
  • Reporting entity: The exposure draft proposes that the reporting entity's boundary for its general purpose financial reporting is the same for its financial statements and sustainability-related financial disclosures. When currency is specified as the unit of measure, the reporting entity would use the presentation currency of its financial statements. The financial statements to which the sustainability-related financial disclosures relate must be disclosed.
  • Connected information: The disclosures provided must enable users of general purpose financial reporting to understand the connections between the different sustainability-related risks and opportunities and how these are linked to general purpose financial reporting information.
  • Fair presentation: A complete set of sustainability-related financial disclosures would present fairly the sustainability-related risks and opportunities to which the entity is exposed. A fair presentation requires the faithful representation of sustainability-related risks and opportunities in accordance with the principles set out in the proposed standard and would include additional disclosures when necessary.
  • Materiality: An entity would disclose all information on sustainability matters that is material for investors and other providers of capital in respect of a reporting entity. Sustainability-related financial information is considered material if omitting, misstating or obscuring that information could reasonably be expected to influence decisions that the primary users of general purpose financial reports make on the basis of those reports.
  • Comparative information: An entity would present comparative information regarding the previous period for all metrics reported in the current period. This might include comparative information for narrative and descriptive sustainability-related financial disclosures if relevant to an understanding of the current period’s sustainability-related financial disclosures.
  • Frequency of reporting: An entity would report its sustainability-related financial disclosures at the same time as its related financial statements and the sustainability-related financial disclosures would be for the same reporting period as the financial statements.
  • Location of information: An entity would disclose information required by IFRS Sustainability Disclosure Standards as part of its general purpose financial reporting. This can include an entity’s management commentary when management commentary forms part of an entity’s general purpose financial reporting or cross-referencing if the cross-referenced information is available to users of general purpose financial reporting on the same terms and at the same time as the general purpose financial reporting.
  • Sources of estimation and outcome uncertainty: When sustainability-related financial disclosures cannot be directly quantified and can only be estimated, the use of reasonable estimates is an essential part of preparing sustainability-related financial disclosure and does not undermine the usefulness of the information if the estimates are clearly and accurately described and explained. When sustainability-related financial disclosures incorporate financial data and assumptions, such financial data and assumptions would be consistent with the corresponding financial data and assumptions incorporated in the entity’s financial statements (to the extent possible).
  • Errors: Prior period errors are omissions from, and misstatements in, the entity’s sustainability-related financial disclosures for one or more prior periods. Unless impracticable, an entity would correct material prior period errors retrospectively in the first general purpose financial reporting authorised for issue after their discovery.
  • Statement of compliance: An entity whose sustainability-related financial disclosures comply with all of the relevant requirements of IFRS Sustainability Disclosure Standards would include an explicit and unqualified statement of compliance.

The deadline for submitting comments on these proposals is 29 July 2022.

The ISSB has also developed a survey to support stakeholders in responding to the proposals in the exposure draft as an alternative or in addition to a comment letter.

 

Transition and effective date

The standard would be applied prospectively. Comparative information would not be required to be disclosed in the first period in which an entity applies the proposed standard.

The Board intends to decide on the effective date after exposure. Earlier application would be permitted.

 

Additional information

The following additional information is available on the IFRS Foundation website and on IAS Plus:

The press release also notes that the ISSB's proposals will be presented in two live webinars on 28 April at 9am and 5pm BST.

In addition to publishing its first two exposure draft, the ISSB has also published a statement on its plans for building upon the SASB standards and for embedding SASB’s industry-based standards development approach into the ISSB’s standards development process. The statement discusses the industry-based approach to standards development, the inclusion of SASB standards in the exposure drafts published today, the commitment to improving the international applicability of SASB standards, the starting point for ISSB industry-based requirements, and current SASB projects. The statement also notes that the ISSB actively encourages preparers and investors to continue to provide full support for and to use the SASB Standards in this transition phase. Please click to access the full statement on the IFRS Foundation website.

In a statement on the IOSCO website, the Monitoring Board of the IFRS Foundation welcomes the publication of the two exposure drafts and notes that the Monitoring Board remains focused on supporting the development of a comprehensive global baseline of sustainability disclosure standards that can used across jurisdictions in accordance with their own legal framework, while making sure the actions of both IFRS Foundation standard-setting boards are coordinated, aligned and in the public interest.

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