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One global baseline? The ISSB outlines its proposed sustainability disclosure standards


The International Sustainability Standards Board (ISSB) joined IIGCC members, industry spokespeople and policy experts to outline its hotly anticipated sustainability disclosure standards, discussing the ‘General Requirements’ and ‘Climate Exposure’ drafts.

One global baseline to rule them all – it’s the clarity investors have been hoping for since the ISSB was first established by the International Financial Reporting Standards (IFRS) Foundation after COP26 Glasgow, November 2021.

And in the opening words of Stephanie Pfeifer, CEO of the IIGCC, “the stakes are high.”

IIGCC MEMBERS: Access the slides and webinar.

Currently under consultation until 29 July, the proposed disclosure standards build on the momentum of the 2021 Global Investor Statement which urged governments to implement recommendations from the Taskforce for Climate-related Financial Disclosures (TCFD).

For investors, whose portfolios span sectors and geographies, it’s vital that the ‘alphabet soup’ of reporting initiatives and frameworks is consolidated, and the IFRS Foundation has the influence to help. Its accounting standards are recognised and adopted in more than 140 jurisdictions worldwide.

“That clarity is just as important for companies reporting on the risks and opportunities associated with sustainability to the global capital markets,” explained Caroline Clark-Maxwell, a technical staff member at the IFRS Foundation, working on the ISSB.

Together with IFRS Foundation colleague, Cameron Hindal, she explained that the standards require a company to report information about its exposure to sustainability-related risks and opportunities. This, along with other data provided as part of a company’s general purpose financial reporting, will help investors to assess the company’s enterprise value.

And with regards to the IFRS Accounting Standards:



Proposed requirements

Collaboration was a key theme of the ISSB methodology. Cameron described their thinking as a “building blocks approach,” designed to encourage interoperability with existing and emerging regional reporting frameworks.

The thread guiding these requirements are the four TCFD core recommendations with which many investors will be familiar:


  • Governance
  • Strategy
  • Risk management
  • Metrics and targets

The team explained that this cross-sector architecture is complemented by existing industry-based reporting requirements, leveraging the Sustainability Accounting Standards Board (SASB) Standards. Their ambition is that building on existing guidance will lower the costs for preparers already familiar with those guidelines.

For greenhouse gas emissions (GHG), the ISSB highlighted that Scope 1-3 emissions are measured as gross GHG emissions, in accordance with the Greenhouse Gas Protocol.

Investor reactions

The investor community was quick to acknowledge that creating one set of globally recognised standards was no small challenge and thanked the team for their work so far.

Will Martindale, Co-Head of Sustainability at Cardano, welcomed the focus on climate-linked executive remuneration and mandatory target setting, but felt that the standards didn’t yet reflect best practice in the industry.



A double materiality approach to reporting requires companies to disclose the impact of their activities on the climate, as well as the climate’s impact on them.

Will also recommended that targets should be science based, aligned with the Paris Agreement, and that more guidance was needed around offsetting. While offsets may have a role to play in addressing residual emissions, many investors feel that companies rely too heavily on them and that they should be used only as a last resort.

Julia Kaczynska, Director of Responsible Investing at IFM Investors, agreed that the standards should make it clear that climate mitigation follows a clear hierarchy of action:



Echoing Wills’ recommendation, Julia pointed out that to reach a sustainable 1.5 degree world “is not just about mitigation, but also adaption and resilience.”

Raising the concept of just transition, Julia said that the companies operating in high emissions industries should disclose in their transition plans long-term strategies for a just transition, for the employees whose skillsets may be less relevant in the future.

A ‘just transition’ considers the livelihood and rights of workers and their communities during the shift to a carbon-neutral world.

The lack of detail on adaption and resilience was also highlighted in many of the IIGCC member questions, along with the need for more detail in assessing carbon offsets.

IIGCC recommendations

IIGCC, which represents more than 350 members and €51trn of assets, is drafting a response to the Climate Exposure proposal with support from its Policy Steering Group.

Leo Donnachie, Sustainable Finance Lead for the IIGCC, outlined to members that it would be structured under three headline recommendations:

  1. Enhancements to, and development of, the high-level TCFD framework
  2. Supporting a holistic view of climate-related exposures
  3. Ensuring disclosures are implemented effectively

If you’d like to discuss IIGCC’s response ahead of the 29 July deadline, please contact The ISSB team will then analyse this feedback and aim to finalise the standards by the end of 2022.

If you’d like to become and IIGCC member, get in touch with us today.