UNEP FI Response to the IFRS/ISSB General Requirements Exposure Draft

26 July 2022

UNEP FI commends the work of the ISSB in developing the General Requirements Exposure Draft (‘GRED’). The standard being developed by the ISSB provides a unique opportunity to equip primary users of general purpose financial reporting with the full breadth of information that is useful to assess enterprise value as a basis for investment choices and decision-making.

In particular, we welcome:

  • The ISSB’s efforts to build upon a number of globally recognised market standards, namely the TCFD and SASB standards.
  • The alignment sought between financial and sustainability disclosures, namely as regards scope and timing.
  • The acknowledgment that enterprises need to consider all significant sustainability-related topics, including the interlinkages between these.
  • The consideration of both cross-cutting and sector-specific sustainability issues.
  • The recognition of both risk and opportunity factors.

We see scope for enhancement and seek to draw attention to:

  • The currently ambiguous and potentially narrow definition of enterprise value and what might affect it (positively and negatively).
  • The limited requirements and guidance on how to appropriately undertake some of the actions underlying the information that needs to be disclosed, in particular the identification of material issues, and the existence of increasingly consensual norms which could be drawn on to this end.
  • The existence of a ‘risk bias’, with less attention devoted to the treatment of opportunities, which are equally important.
  • The long and complex construction of the document, including repetition between the four sections, which as a result makes it difficult to identify exactly what entities should report.

In the consultation document, we expand further on these concerns and set out our recommendations in relation to them, responding to a selection of consultation questions posed by ISSB. This includes specific text suggestions; these are offered by way of illustration, for clarification purposes.

Read full consultation document here.

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