ACCA welcomes the opportunity to provide views in response to the ISSB’s exposure drafts (ED) on proposed amendments to the SASB Standards (SASB/ED/2025/1) and the Industry-based Guidance on Implementing IFRS S2 (ISSB/ED/2025/2), which should be read together. We appreciate the efforts that have gone into these projects, and provide our comments on areas which we consider most important or where we have perspectives to add.
Our responses have been shaped by input from ACCA members and stakeholders across a diverse range of jurisdictions, including Bangladesh, the Netherlands, Sri Lanka, the UAE and the UK, gathered during a virtual roundtable in October. We hope that our comments, which include feedback from our ACCA Global Forum for Corporate Reporting, 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 and commend the ISSB’s role and continued efforts in setting a consistent and comparable global baseline to sustainability reporting around the world.
ACCA also supports the stated objectives of the amendments to the SASB Standards – namely, to enhance international applicability, improve interoperability with other frameworks, align language and concepts, and promote clarity, conciseness, and cost-effectiveness for preparers. In this regard, we reiterate our view that the SASB Standards should evolve to eventually be subsumed and fully integrated into the IFRS Sustainability Disclosure Standards following the appropriate IFRS Foundation standard-setting due process. In the meantime, 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.
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.
