Accountancy Europe has responded to the International Sustainability Standards Board’s (ISSB) Request for Information: Consultation on Agenda Priorities (RfI). The ISSB will develop and pursue its first two-year work plan following the feedback received from stakeholders in this RfI.

ISSB activities & Selection Criteria

Accountancy Europe suggests the ISSB equally prioritises activities to:

• support the implementation of ISSB standards (IFRS S1 and IFRS S2)
• begin new research and standard-setting projects

It is important for the ISSB to complete its suite of standards to develop the global baseline, as well as provide implementation support to help the standards’ uptake. From a European perspective, these activities are paramount to ensure interoperability with the 12 European Sustainability Reporting Standards (ESRS) and the upcoming guidance.

New research and standard-setting projects

Accountancy Europe strongly supports working in parallel on multiple projects. The ISSB should first determine the list and scope of sustainability matters it plans to work on.

We suggest prioritising developing both environmental and social topical standards. The ISSB should leverage its own resources and the work of existing initiatives such as the Taskforce on Nature-related Financial Disclosures (TNFD), ESRS and Global Reporting Initiative (GRI).

We continue to support a “conceptual framework for connected reporting” to provide the principles that underpin the work of the ISSB and the International Accounting Standards Board (IASB). Nonetheless, we have not prioritised the “integration in reporting” project because we believe it is a broad and resource intensive project, likely to take over two years to finalise.

In this first two-year workplan, the ISSB can focus on finalising as many new topical standards. In the long term, this will serve the output of the “integration in reporting” project as the ISSB has a more complete suite of standards, similarly to the IASB’s suite of IFRS accounting standards.

Other comments

Accountancy Europe invites the ISSB to explore replicating the process followed for IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures to develop standard for relatively mature sustainability topics such as environmental ones. For these, the ISSB may decide to immediately issue the project as Exposure Drafts for consultation.

Finally, we suggest the IFRS Foundation considers as a long-term ambition to develop sustainability standards that address investors and broader stakeholders’ needs.