ACCA welcomes the opportunity to provide views in response to the ISSB’s Request for Information Consultation on Agenda Priorities. We hope that our comments, which include 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. We fully support the role of ISSB in setting a consistent and comparable global baseline to sustainability reporting around the world. We welcome and commend the issuance of IFRS S1 and IFRS S2 as its first step in this direction.
However, while we appreciate the need for urgency and speed in evolving the sustainability reporting space, balancing these with coherence and connectivity is paramount to reduce the risk of disconnect and further regulatory fragmentation. As such, our focus centres around getting the foundation right during this critical implementation stage of the ISSB Standards which will, in turn, form the base for future reporting, standard-setting, policy development and, ultimately, progress in combatting climate change.
ISSB is best placed to lead development of supplementary educational materials centrally to ensure greater interoperability and consistent application across jurisdictions. We recognise that this will be resource-intensive, and so it is important that the ISSB leverage the IFRS Foundation Partnership Framework (Partnership Framework) as much as possible. ACCA is a partner of this Partnership Framework, and stands ready to support the IFRS Foundation. Thus far, we have produced a series of explainer videos with the ISSB, available on our Sustainability Hub, to help understanding and application of the ISSB Standards. We are also currently developing a series of guides – the first of which will be published later this year – to help entities get ready for preparing sustainability disclosures using the ISSB Standards.
We strongly believe that the proposed ‘Integration in Reporting’ project will complement efforts to support implementation of the ISSB Standards, and as such, should be placed first in priority of the new research and standard-setting projects identified in the Request for Information as well as alongside activities to support implementation of the ISSB Standards. In particular, we envisage that this project can effectively demonstrate connectivity as an overriding priority, while bringing clarity to the application of IFRS S1. This will help lay the foundations for an integrated, coherent and comprehensive system of corporate reporting which can provide a holistic and transparent view of how an entity creates value over time.
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; better quality of information becomes available to investors, who will then use these disclosures to allocate capital more efficiently and responsibly. For this to happen, widespread application of integrated thinking by entities as well as integrative thinking by finance professionals are necessary.
To read the response in full, please download the response document.