Consultation: Malaysia's National Sustainability Reporting Framework

ACCA commends the Advisory Committee on Sustainability Reporting (ACSR) on the development of the Proposed National Sustainability Reporting Framework (NSRF) involving the adoption of International Financial Reporting Standards (IFRS) Sustainability Disclosure Standards – specifically IFRS S1 and S2. We further commend ACSR on inviting public feedback on the proposed framework through a formal consultation process. This is critical towards fostering trust and transparency in the framework and positively shaping the journey of sustainability reporting in Malaysia.

ACCA welcomes the opportunity to respond to this consultation. In forming our responses, it is useful to note that roundtables were carried out involving participants from two critical components of the reporting ecosystem – namely:

  • preparers of sustainability-related disclosures (namely Chief Financial Officers, Chief Sustainability Officers and other finance leaders); and
  • audit partners who will be critical in providing assurance in respect of such disclosures in time to come.

These roundtables were conducted on Chatham House rules and were instrumental in providing validation and feedback on a number of key issues raised in the consultation paper. Where there were mixed views by the participants, we have endeavoured to capture such perspectives in this our responses in order that ACSR will have the benefit of appreciating alternate view points on what will likely be a challenging yet exciting development in the corporate reporting landscape.

In addition to the specific questions which were raised in the consultation, for which we provide our responses in the accompanying document, we set out in this comments letter detailed views on a number of significant issues for your overall consideration. It is important to highlight that both this comments letter and the responses to the consultation questions should be read together.

To read the response in full, please download the consultation response document on this page.