To keep European Union capital markets open and integrated, new international standards should be reflected in future European law and accounting practice to provide further incentives for a reallocation of capital, reflecting in particular climate risks.
The publication in late March of proposals
by the International Sustainability Standards Board (ISSB) put the
European Union’s own agenda on corporate disclosures under the spotlight
once again. The ISSB is part of the international accounting body IFRS
(International Financial Reporting Standards), which has already defined
a global standard for financial statements. The ISSB sustainability
disclosure standards could similarly become a global benchmark. This
could address financial stability risks, given that the impact of the
climate emergency may not have been properly reflected in asset values.
A new EU model for corporate
sustainability disclosures was published last year and will also be
finalised in the coming months. The EU has promoted what seems a more
ambitious concept of ‘double materiality’ which captures a firm’s impact
on people and the planet, in addition to the risks to enterprise value.
In order for EU capital markets to remain open, the just-announced
international standards should be a building block of European standards
to the greatest extent possible.
What gets measured gets managed
IFRS 9, the latest version of the global accounting standard, has been applied by in the EU since 2018. This seeks to provide a “true and fair”
picture of a company’s finances. Yet, a company’s accounts are rarely
sufficient to reflect risks from climate change and other sustainability
risks. Comprehensive disclosure of such risks is needed alongside the
published accounts. Numerous surveys
have underlined that institutional investors, such as pension funds,
still don’t have access to sufficiently clear and consistent information
on such risks. Serious long-term investors are keen to understand how
such risks are managed and what targets are set, in particular to reduce
risks resulting from the low-carbon energy transition.
The IFRS 9 accounting standard introduced
major changes in the form of forward-looking provisions, as firms need
to anticipate losses. In reality, this is insufficient to capture
sustainability risks companies face from the low-carbon energy
transition, and companies and financial firms have had too much leeway.
Three types of sustainability risk illustrate why financial accounts and
disclosures do not capture climate risks well:
- Firms should in principle explain future liabilities, even though
the scale and timing of these liabilities are unclear. Decommissioning a
coal plant ahead of its project lifetime or climate litigation could be
significant expenses which will increasingly materialise over the
coming years. IFRS guidance
already requires such expenses to be shown if liabilities are more
likely than not, while United States accounting rules only reflects such
expenses if they are highly likely. In practice, there are few
incentives to recognise provisions until liabilities are about to
crystallise.
- A related problem is the write down of assets that are exposed to the low-carbon transition. Stranded assets
could emerge, for instance where proven oil reserves turn out to be
un-burnable, or where residential property is exposed to floods or
coastal erosion. Such ‘material’ information should in principle be
disclosed in financial statements, though interpretations of this
requirement vary widely. As a result, markets may be overvaluing assets
significantly.
- Finally, investors increasingly demand information on companies’
carbon exposures that arise in their upstream or downstream value
chains, in particular in the emissions financed by banks or asset
managers. Such indirect emissions could expose the reporting company or
bank to risks arising in the climate transition. Computing these
so-called ‘scope-3’ emissions is complicated by both lack of data and
unclear methodologies.
Greater transparency through good
disclosures and reporting should reveal material issues for a company’s
future financial performance and hold boards to account in managing
these future liabilities. In this way, markets may be spared abrupt
re-pricing once the scale of the climate transition is revealed. Capital
could be mobilised for those firms least exposed to risks, or for
investment opportunities in which low-carbon technologies are deployed.
Together with a company’s accounts there
should be a full disclosure of sustainability risks. Firms’
sustainability risk reports should be standardised...
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