Comment letter from 2° Investing Initiative & the Ecological Accounting Chair (Exposure Draft IFRS S1 General Requirements for Disclosure of Sustainability- related Financial Information and Exposure Draft IFRS S2 Climate-related Disclosures)
Thursday 13 July 2023
Comment letter from 2° Investing Initiative & the Ecological Accounting Chair (Exposure Draft IFRS S1 General Requirements for Disclosure of Sustainability- related Financial Information and Exposure Draft IFRS S2 Climate-related Disclosures)
Authors : Soline Ralite, pour la Chaire Comptabilité écologique & 2° investing Initiative
Summary : In June 2022, The Ecological Accounting Chair (Chaire Comptabilité Écologique) and the 2° Investing Initiative have joined forces to submit a response to the International Sustainability Standards Board’s consultation on their proposed extra-financial standard.
Our response raises two issues with the ISSB proposal…
- Issue 1: Scientific research tends to show that a single materiality approach, or even a dynamic materiality approach, is not relevant to natural resource management. The ISSB proposal yet is based on this approach.
- Issue 2: The ISSB’s approach to materiality is opposed to the EU vision, which may pose applicability problems for companies subject to both frameworks.
…and highlights three propositions:
- Proposition 1: The ISSB must provide further clarification of the concept of materiality in the Exposure Drafts.
- Proposition 2: Were a double materiality perspective to be adopted, the disclosure requirements would need to be amended. A further consultation would be required to define these requirements.
- Proposition 3: Given the specific nature of ecological issues, the ISSB should systematically rely on multidisciplinary scientific expertise (specialists in scientific ecology, IPCC climate scientists and bio economists) and provide scientifically sound arguments to design its standards moving forward.
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