In June 2023, the International Sustainability Standards Board (the ISSB) published its first set of global sustainability and climate-related disclosure standards for investors. The ISSB was established in November 2021 at the UN Climate Change Conference (COP26) as a sister board to the International Accounting Standards Board (IASB) and is responsible for developing IFRS sustainability standards to better inform investment decisions and meet the needs of the capital markets.
Although IFRS is not used in the US, the standards are likely to influence the Securities and Exchange Commission’s (SEC) sustainability reporting requirements that are currently being developed. IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) and IFRS S2 Climate-related Disclosures (IFRS S2) have been drafted in response to users of financial reports calling for information to be presented in a comparable, verifiable and consistent way.
IFRS S1 is a set of sustainability-related financial disclosures that prescribe how companies should report information about their sustainability-related risks and opportunities in a way that is useful to users of financial reports in making investment decisions. The standards require companies to disclose and report on sustainability-related risks and opportunities over the short, medium and long term to investors. IFRS S1 requires companies to disclosure information regarding sustainability targets, governance, strategy and risk management.
IFRS S2 is a set of climate-related disclosures that have been developed to provide information to investors about a company’s climate-related risks and opportunities. IFRS S2 incorporates recommendations provided by the Task Force on Climate-related Financial Disclosures (TCFD). IFRS S2 requires a company to disclose its Scope 1, Scope 2 and Scope 3 greenhouse gas emissions.
IFRS S1 and IFRS S2 are effective for annual reporting periods beginning on or after 1 January 2024. The standards are not mandatory and it is up to individual countries to decide whether listed companies are required to apply them. It is expected that the standards will be voluntarily adopted as non-financial reporting on sustainability becomes market standard. The UK has indicated its intent to incorporate the ISSB standards, however the EU and US plan to introduce their own separate disclosure requirements. European companies are subject to disclosure requirements with the European Sustainability Reporting Standards (ESRS) and the SEC’s climate-related disclosure rules were proposed in 2022 and are due to be issued later this year. It remains to be seen how the different reporting obligations will work together to avoid duplication and inconsistency. The ISSB has been working with EFRAG (European Financial Reporting Advisory Group) on the specific reporting requirements of the CSRD to ensure there is a level of consistency between the standards. Guidance is expected to be issued by the ISSB in order to avoid duplication between the different standards in the EU. The ISSB has also established the Transition Implementation Group to work with stakeholders to facilitate implementation of the standards and address concerns. The International Organization of Securities Commissions (IOSCO) also intends to independently review the ISSB standards.
Duane Morris has an active ESG and Sustainability Team to help organizations and individuals plan, respond to, and execute on your Sustainability and ESG planning and initiatives. For more information, please contact Brad A. Molotsky, David Amerikaner, Sheila Rafferty-Wiggins, Alice Shanahan, Jeff Hamera, Nanette Heide, Joel Ephross, Jolie-Anne Ansley, Robert Montejo, Seth Cooley, or the attorney in the firm with whom you are regularly in contact.