Exposure Draft - Amendments to Climate Change and Energy Standards

Reflecting the IFRS Sustainability Disclosure Standards as the baseline.

We appreciate the conscious effort to consider the requirements of other sustainability reporting regimes in the Climate Change ED, in particular the IFRS Sustainability Disclosure Standards as a global baseline for sustainability reporting. 

There are, unsurprisingly, proposals in the Climate Change ED that go beyond the requirements of IFRS S1 and IFRS S2. In aiding the adoption of amendments to the two GRI standards, greater reflection could be made on how the proposed requirements can be overlaid with the IFRS Sustainability Disclosure Standards. For example:

• there is considerable opportunity to enhance disclosures required by IFRS S1 on approach to governance, setting strategy, and risk management relative to the actual details of the ‘what’ is in the transition or adaption plan (see disclosure CC-1). 
• complementing the requirements of IFRS S2, in particular disclosure of social and biodiversity impacts arising from climate adaptation plans, carbon removals and the use of carbon credits.  
• it would be good to understand the relationship between upstream and downstream relative to an organisation’s boundary for reporting and its value chain. 

GRI has a memorandum of understanding (MOU) with the IFRS Foundation to coordinate work programmes and standard-setting activities in order to help reduce the reporting burden for organisations and to further harmonise the sustainability reporting landscape at an international level1. It would also be helpful to understand how the GRI might seek to work closely with the International Sustainability Standards Board (ISSB) and the potential role that the Sustainability Innovation Lab could play to enhance and align both the IFRS Sustainability Disclosure Standards and the GRI Standards, such that reporting organisations will eventually only need to prepare one set of climate-related disclosures. 

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