ACCA welcomes the opportunity to provide views in response to the ISSB’s exposure draft (ED) on proposed amendments to IFRS S2 in relation to greenhouse gas emissions disclosures. 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 principles-based reporting standards which provide a high-quality comprehensive baseline for corporate reporting. We fully support the role of the ISSB in setting a consistent and comparable global baseline to sustainability reporting around the world. To this end, we also appreciate and commend the ISSB’s efforts and commitment in supporting IFRS S1 and IFRS S2 implementation as its highest priority.
We believe that the proposed targeted amendments will provide better clarity and timely practical relief to many entities and jurisdictions which are already in the process of implementing, adopting or otherwise using IFRS S2. By reducing the risk of duplication in effort and reporting, these proposed amendments will help entities to focus on relevant, material information, leading to improved decision-making and a reduced reporting burden. Permitting early adoption will further support and facilitate their sustainability reporting journeys, as this would enable entities and jurisdictions to better plan their resources, processes and systems for the longer term.
In the meantime, as industries and markets continue to mature in the sustainability reporting space, we recommend that the ISSB/IFRS Foundation takes the opportunity to work closely across jurisdictional authorities or exchanges availing the optional reliefs and other relevant stakeholders to maximise alignment and minimise divergence in practice, while focusing on the provision of decision-useful information. Alongside such efforts, The ISSB/IFRS Foundation should also leverage implementation and capacity building insights from outreach with stakeholders through professional accountancy organisations and the IFRS Foundation Partnership Framework, of which ACCA is a partner. For example, our ongoing research on ‘Sustainability reporting: Track your progress’ to be published in November will evaluate and provide insights about organisations’ progress in sustainability reporting, incorporating global feedback from circa 1,000 survey respondents as well as reflections, real implementation experiences and examples through a series of global roundtables.
Ultimately, as 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. We believe that for this to happen, widespread application of integrated thinking by entities as well as integrative thinking by finance professionals are necessary, where information connections lead to quality decision-making and sustainable value creation.
To read the response in full, please download the response document found on this page.
