In its response to the proposed rule, Accountancy Europe welcomes the SEC's efforts and notes that there it fully supports mainstreaming environmental, social and governance (ESG) topics in corporate reporting. However, as Accountancy Europe points out, there are other parallel initiatives aiming to streamline sustainability reporting standards, in particular those of:

• the International Sustainability Standards Board (ISSB) with its initial exposure drafts on sustainability-related financial information and climate-related disclosures, and
• the European Union (EU), via the European Financial Reporting Advisory Group (EFRAG), with its European Sustainability Reporting Standards (ESRS) exposure drafts.

Accountancy Europe stresses that there needs to be a high degree of coordination and alignment, including of language and definitions, for all of these initiatives to be meaningful and fit-for-purpose for global markets.

Also, Accountancy Europe especially responds to a specific SEC question regarding whether alternative reporting requirements (for example ISSB requirements) should be permitted for use in the US and whether such a provision should be limited to foreign private issuers or available to all registrants. Accountancy Europe clearly supports an alternative reporting provision for foreign private issuers and advocates extending it to all registrants. The comment letter notes that this would entail a significant step towards achieving a global reporting framework on sustainability and climate-related information.

Please click to access the full letter on the Accountancy Europe website.