New ISSB standards: Appeasement or a new era of accountability?

The International Sustainability Standards Board (ISSB) released its final published standards this week. The launch, aimed at "ushering a new era for sustainable reporting standards" was marked with much fanfare at a number of events hosted globally, including at the London Stock Exchange. But what do investors make of it?

Initially formed following the COP26 climate conference in Glasgow in 2021, the ISSB aims to develop standards for a global baseline of sustainability disclosures, and to enable companies to provide comprehensive sustainability information to global capital markets.

IFRS S1 provides a set of disclosure requirements to enable companies to disclose ESG risks and opportunities they face to their investors. IFRS S2 sets out specific climate-related disclosures and looks to fully incorporate the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD).

Emily Pierce, chief global policy officer at carbon accounting platform Persefoni is confident that the new standards could bring about a new focus for greater uniformity. “What's been presented builds on existing market practices and sustainability reporting that was developed in the voluntary space, in particular the TCFD.

“Ultimately, global investors needed more reliable, consistent, comparable information on sustainability risks and opportunities that are financially material to a company. The ISSB brings a core focus to meeting that objective.”

The ISSB has acknowledged, that collaboration between different bodies tackling reporting challenges remains vital. IISB stated that it will continue to work with jurisdictions wishing to require disclosures beyond the global baseline and is working with coordinating partner the Global Reporting Initiative (GRI) to support effective reporting when the ISSB standards are applied in combination with other reporting standards such as the TCFD.

Questions of materiality

The ISSB’s approach focuses solely on single materiality, or how sustainable factors relate to the financial value of a business,  as Frédéric Ducoulombier, director at the EDHEC-Risk Climate Impact Institute explains: “We remain solidly in the realm of single materiality - the progress achieved is thus in the standardisation of the metrics.

“It remains incumbent on society as a whole to change what reporting entities consider financially material by way of political action where possible.”

The ISSB’s approach also differs from European standards bodies such as the European Financial Reporting Advisory Group (EFRAG), which take a double materiality approach, namely incorporating considerations of both financial risks and how a company’s operations more widely impact the world around them.

Pierce adds that the focus on single materiality is based on meeting the needs of investors as understood in the current market environment. "The ISSB standard can also evolve as market demands evolve, but it will always be driven by stakeholder feedback” she stresses. 

At an October 2022 meeting, the ISSB voted unanimously to require company disclosures on Scope 3 (value chain) greenhouse gas emissions, applying the current version of the GHG Protocol Corporate Standard. The ISSB has also developed relief provisions to help companies apply the Scope 3 requirements.

However, the current form of the ISSB does not confront Scope 4, actual emissions reductions as a result of the product, which is seen as an indicator of increasing importance and is currently lacking in reliable data collection.

Of Scope 3 versus 4, Pierce says: ”The ISSB clearly determined based on feedback that Scope 3 is part of a comprehensive climate risk; it explains where your risks lie in your value chain, in terms of exposure to emissions. Right now, I'm not sure Scope 4 has that same understanding and investor demand in the marketplace.”

An act of appeasement?

Many of the responses to the ISSB standards have been positive, backed by the optimism of the architects themselves. Emmanuel Faber, ISSB chair, said: “[the standards] represent the outcome of more than 18 months of intense work to deliver an inaugural set of sustainability disclosure standards for the global capital markets.

“The ISSB standards have been designed to help companies tell their sustainability story in a robust, comparable and verifiable manner. We have consulted closely with the market to ensure the standards are proportionate and will result in disclosures that are relevant for investment decision-making.”

There has however, also been scepticism. Ralph Thurm, managing director of Dutch sustainability firm Ahead, said: “I just realise once more what a great diversionary tactic the release of the ISSB’s standards for sustainability reporting will be. [It is] totally irrelevant in addressing the pace of decline we’re in as humanity. Just one of so many examples of valuable time spent for nonsensical entertainment of those that want to sell services to corporates for pure Enterprise Value Creation.”

Zsolt Lengyel, former secretary at the Institute for European Energy and Climate Policy Foundation, even claimed that those who considered the ISSB’s standards as “sufficient” were comparable to those who had appeased Nazi Germany prior to the breakout of the Second World War.

With a less enraged assessment of the advantages and potential drawbacks of the ISSB, Pierce says: “Capacity building is needed. There are many companies around the globe who have been doing TCFD reporting and have a running start, but the market needs more metrics, and new technology to evolve to support that.

“There's also some risk related to of breadth of regulatory adoption. I think it will be important that regulators who do adopt the standards, adopt them as a whole package and don't carve out individual elements of it.”