ACCA welcomes the opportunity to respond to the ISSB’s exposure draft (ED) on proposed amendments to the SASB Standards and IFRS S2 Industry-based Guidance (IBG). We appreciate the efforts that have gone into these projects, and provide our comments below on areas which we consider most important or where we have perspectives to add.
Our response has been shaped by input from ACCA members and stakeholders across a diverse range of jurisdictions, including Australia, Bangladesh, Hungary, Malaysia, Singapore, and Sri Lanka, gathered during a virtual roundtable in May. 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 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. However, more clarity is needed on the ISSB’s intended standard-setting architecture and long-term strategy with respect to the SASB Standards.
We reiterate our concerns with the current approach and our view that priority should be to first amend the ISSB’s IBG in supporting implementation of IFRS S2 – followed by consequential amendments to the SASB Standards for the express purpose of maintaining alignment with the IBG as the respective markets and sustainability-related topics mature and relevant metrics become available. Further, the ISSB may wish to consider a ’thinking small first’ approach in developing proportionality mechanisms.
We also think 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 interim, the current approach should continue – where the SASB Standards support implementation in the form of non-mandatory guidance.
As standard-setting progresses, it is important to ensure that the reporting continues to catalyse 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.
