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Deloitte comment letter on SEC's requests for input on climate-related and other ESG disclosures

Published on: 22 Jun 2021

We have commented on the US Securities and Exchange Commission's (SEC) statement requesting input from investors, registrants, and other market participants on whether current disclosures related to climate change adequately inform investors.

In our comment letter, we discuss:

  • Observation from our participation in the capital markets;
  • the value of standards in driving consistent, comparable, and reliable disclosure; and
  • the benefits of global consistency.

We note that we support the efforts of the IFRS Foundation to establish an International Sustainability Standards Board (ISSB) that will focus on globally accepted sustainability standards (for climate initially, but eventually on a range of ESG topics). And we stress that we believe that the IFRS Foundation is well-positioned to lead the efforts to rationalize existing disclosure standards and frameworks, given its proven track record of independent global standard setting.

We also comment on the SEC efforts and developments. Our comment latter states:

We were pleased to see the SEC express support for the statement by the International Organization of Securities Commissions (IOSCO) in support of convergence efforts — specifically that of the IFRS Foundation — and that the SEC will co-chair the IOSCO Technical Expert Group to advise on standing up the ISSB. We encourage the SEC to remain active in these discussions to help shape global standards in this area so that the Commission does not lose an important opportunity to align with global standards at the outset.

Please click to download our full comment letter below.

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