Open response to the open letter from COP, Climate Disclosure Standards Board (CDSB), Global Reporting Initiative (GRI), International Integrated Reporting Council (IIRC) and Sustainability Accounting Standards Board (SASB) proposing avenues for Working together to meet the needs of the capital markets
Regulators and market participants increasingly recognise that climate-related and
other sustainability impacts are material to companies' businesses and their future value
creation. A growing number of companies and investors are adapting their business and
investment strategies to align with a path towards net-zero carbon emissions. And it is
now almost universally accepted that failure to integrate environmenta l, social and
governance (ESG) factors into investment decisions constitutes a failure to meet the fiduciary
duty to clients and beneficiaries. A good flow of decision-useful information on
sustainability factors from the corporate sector is therefore essential.
Securities regulators share the core objectives of protecting in vestors , maintammg
fair , efficient, and transparent markets , and reducing systemic risk.
Sustainability issues in genera l, and climate-related issues in particular , raise
important challenges in meeting these core objectives.
The IOSCO Sustainable Finance Network (SFN) report , published in April this
year, underscored IOSCO' s readiness to play a driving role in this area. Our report
highlighted three main areas of concern:
• multiple and diverse sustainability frameworks and standards
• lack of common definitions of sustainable activities
• greenwashing and other investor protection cha llenges .
Our findings therefore align with the concerns you raise around the relia bili ty,
comparability and quality of issuer s' sustainability disclosures at the global level.
The proliferation of - typically voluntary - frameworks and standards for
sustainability reporting presents a challenge to both the preparers and users of corporate
reports.
Issuers face confusion as to which standard they should adopt. And for investors and
other us ers, the fragmented reporting landscape leads to i ncomplete, inconsistent
information that cannot easily be compared across companies - potentially undermining the efficiency of asset
pricing , risk management and capital allocation.
Further to publication of the report, IOSCO established a Board-level Task
Force on Sustainable Finance (STF) to address the areas for improvement identified in
the report. A dedicated workstream of the Taskforce has a specific focus on improving
securities is suers' sustainability -relat ed disclosures. This work has been underway
since June. Reflecting IOSCO' s core objectives, the group is committed to promoting
transparency in markets by identifying the most decision-useful categories of disclosures for
investors and other market participants; and by considering how IOSCO can influence the
direction of ongoing . industry initiatives in this area.
In our work, we are considering the scope for improvement m
sustainability-related disclosures on two main dimensions:
• Content. Here, the focus is on the provision of information that meets the needs
of global capital markets and supports business , risk and investment
decisions. Sustainability is a global challenge. Capital markets need a flow of
reliable , in ternationally-c onsis tent, comparable and decision-useful information to
support asset pricing and capital allocation across their portfolios; and to help design and
develop the sustainable finance product s that end-investors increasingly need.
• Governance, due process and the public interest. To uphold the integrity of capital
markets , the system for corporate reporting must be transparent, independent and serve the
public interest. Our recent report notes that the success of IFRS and ISA standards reflects
certain key attributes including: (i) public accountability and the independence of its
respective standard setting bodies; (ii) rigorous, transparent and participatory due process;
(iii) a clear mission statement and a defined targeted audience; (iv) assurance standards
applying to the information publis hed; and (v) a robust process for selecting topics for new
standard setting that focus on specific accounting issues where enhanced comparability would be
meaningful.
We are delighted to see the progress that is being made on both dimensions....
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