ACCA welcomes the opportunity to provide views in response to the ISSB’s Exposure Draft ISSB/ED/2023/1 Methodology for Enhancing the International Applicability of the SASB Standards and SASB Standards Taxonomy Updates. We hope that our comments, which reflect feedback from our ACCA Global Forum for Corporate Reporting and Global Forum for Sustainability, are a helpful contribution to this process.
ACCA has consistently advocated for a global approach to the development of sustainability disclosure standards, and we fully support the role of ISSB in setting a consistent and comparable global baseline to sustainability reporting around the world.
Overall, we also support the ISSB’s phased approach with this Exposure Draft focusing specifically on the first phase of narrow-scope work to amend the SASB Standards metrics in accordance with the proposed methodology to enhance their international applicability when they contain jurisdiction-specific references, with further enhancements to be considered in subsequent phases to improve decision-usefulness, balance cost-effectiveness for preparers and ensure international relevance.
However, we are still mindful that developed as the SASB Standards have been in the US, the disclosure topics and metrics for each given industry have also been identified in relation to US-based entities. Given that entities will be required to refer to the SASB Standards not only in making disclosures, but also in identifying sustainability-related risks and opportunities (SRRO), this could be challenging for entities outside of the US, especially in the Global South, to apply.
In relation to this, we are further of the view that the SASB Standards should evolve to eventually be subsumed and fully integrated into the ISSB Standards following the appropriate IFRS Foundation standard-setting due process. This will help address concerns around international applicability as well as encourage adoption in the longer run. However, the SASB Standards should continue to support implementation in the form of non-mandatory guidance, with updates introduced as the respective markets and sustainability-related topics mature and relevant metrics become available.
In the meantime, as sustainability-related standard-setting progresses, it is important to ensure that the reporting catalyses the necessary systemic change: that operational changes take place in the entities making these disclosures; and that investors use these disclosures to allocate capital more efficiently and responsibly. For this to happen, we reiterate our view[1] that widespread application of integrated thinking is necessary.
To read the response in full, please download the response document.