Feedback summary—Cover paper and overview (Agenda Paper 2)

The ISSB’s Request for Information (RFI) Consultation on Agenda Priorities that was published to inform its work plan for the next two-year period, was issued in May 2023 with the comment period ending on 1 September 2023. The ISSB received 411 unique respondents which included a variety of stakeholders from all geographic regions, the majority coming from Europe (44%) and North America (29%). The staff created a high-level summary of the feedback received from respondents that ISSB members discussion during the meeting.

The agenda papers in this session were discussed together (see discussion summary under Agenda Paper 2D).

Feedback summary—Strategic direction and balance of the ISSB’s activities (Agenda Paper 2A)

Respondents were asked to prioritise the following activities within the scope of the ISSB’s work:

• Beginning new research and standard-setting projects
• Supporting the implementation of IFRS S1 and IFRS S2
• Researching targeted enhancements to the ISSB Standards
• Enhancing the Sustainability Accounting Standards Board (SASB) Standards

Respondents were mostly supportive of the activities. The majority ranked ‘supporting the implementation of IFRS S1 and IFRS S2’ as the highest priority as it is essential to the successful establishment of a global baseline. Respondents suggested additional capacity building, new educational materials, and a continued emphasis on interoperability with other sustainability standards as types of work to be pursued within this activity. Views were mixed on the relative priority of other activities, although ‘beginning new research and standard-setting projects’ was considered the next highest priority overall. 

Respondents were also asked to comment on the addition of other activities to the ISSB’s scope of work. Responses were evenly split between including additional activities and continuing with the ISSB’s current scope. Devoting resources to clearly articulate and define a longer-term strategic vision for the ISSB was one proposed scope addition.

Feedback summary—Criteria for assessing sustainability matters that could be added to the ISSB’s work plan (Agenda Paper 2B)

The RFI asked respondents to provide feedback on the ISSB’s proposed criteria used to evaluate potential new research or standard-setting projects for its work plan. Almost all respondents agreed with the proposed criteria, with some suggesting amendments or additions. Suggested amendments included adding a formal criterion on interoperability with other standards and frameworks and adding a criterion that considers other stakeholder views in accordance with ‘double’ or ‘impact’ materiality.

Feedback summary—Priority of proposed projects (Agenda Paper 2C)

Within the RFI, four research projects were proposed for inclusion in the ISSB’s two-year work plan:

• Research projects on sustainability-related risks and opportunities associated with one of the following:
  • Biodiversity, ecosystems, and ecosystem services (BEES)
  • Human capital
  • Human rights
• One research project to explore how to integrate financial and sustainability reporting, beyond the requirements within the ISSB’s existing Standards

Given the ISSB’s limited capacity, respondents were asked whether the ISSB should concentrate efforts on a single project or make incremental progress on more than one.

Responses lacked a clear consensus on the number and mix of research projects to be included in the work plan. Some respondents emphasised the need to quickly advance multiple projects to establish a global baseline for a range of sustainability topics, while others cited the need for the ISSB to work slowly given its limited capacity and to allow for sufficient implementation and maturity of IFRS S1 and IFRS S2. Therefore, the staff will perform a detailed analysis of this feedback and create recommendations to be presented to the ISSB members at a future meeting.

Feedback summary—Proposed projects on sustainability-related risks and opportunities (Agenda Paper 2D)

The RFI requested feedback to inform the scope and structure of the proposed research projects (BEES, human capital and human rights). Note, feedback received on the fourth proposed research project (focusing on integration with financial reporting) will be evaluated in conjunction with the International Accounting Standards Board (IASB) at a future meeting.

Respondents suggested that the ISSB should approach each of the topics holistically, rather than prioritising subtopics. Further, they highlighted the importance of considering the implications of industry and geography on the risks and opportunities for each topic. Respondents encouraged the ISSB to build on materials and works from other organisations to advance the projects more quickly, including the Taskforce on Nature-related Financial Disclosures (TNFD), the Global Reporting Initiative (GRI), the European Sustainability Reporting Standard (ESRS) and SASB as possible sources.

Respondents also provided more specific feedback, encouraging the ISSB to consider the intrinsic interrelation of human capital and human rights, and if these topics should be combined into a single project. They also suggested replacing BEES with the term ‘Nature’ to reduce confusion and better depict the broader scope of potential risks and opportunities.

ISSB discussion

Agenda Papers 2-2D were discussed together. Multiple ISSB members emphasised the significance of understanding respondents’ characteristics and reasoning to better incorporate feedback into the ISSB’s work plan. 

Related to the strategic direction and balance of the ISSB’s activities (Agenda Paper 2A) ISSB members requested that the staff explore the interrelation between providing implementation guidance for IFRS S1 and IFRS S2 with other agenda priorities laid out within the RFI. Further, the Chair underscored the importance of considering industry-based standards and how they may be a cross-cutting solution to multiple respondent requests.

Several ISSB members highlighted the feedback to create a long-term strategic direction for the ISSB and its significance in determining a work plan. ISSB members agreed that strategic direction should be a topic analysed during future meetings.

On the topic of criteria for assessing sustainability matters that could be added to the ISSB’s work plan (Agenda Paper 2B), ISSB members concurred that although the IASB’s criteria were a strong starting point, the ISSB needs to evolve its criteria to consider the nuances between the two standard-setters.

ISSB members agreed that it was difficult to draw conclusions from the feedback related to the priority of proposed projects (Agenda Paper 2C) and proposed projects on sustainability-related risks and opportunities (Agenda Paper 2D). Again, ISSB members highlighted the importance of understanding the different views of stakeholders to draw better conclusions from responses.

ISSB members were not asked to make any decisions at this meeting. The staff will continue to evaluate the responses received in response to the RFI for discussion and analysis by ISSB members in future meetings.