The IIF submitted a comment letter to the IFRS Foundation’s Consultation Paper on Sustainability Reporting.

In the letter, the IIF in consultation with its member firms commends the Trustees of the IFRS Foundation for exploring its possible role in sustainability reporting and endorse the Foundation’s plan to create a ‘Sustainability Standards Board’ (SSB) as a global standard setter for sustainability reporting. 
 
However, we also provide a number of comments pertaining to the establishment of the SSB. For instance, while the IIF understands that the Foundation’s plan is to start with a limited scope focusing on climate-related information and financial materiality, we think that a broader scope will be key to achieve the greatest possible impact. This will ensure alignment with existing market practices, evolving supervisory expectations, and private-sector initiatives. It will also provide a path to address issues arising from the intersection of sustainability reporting and financial accounting.
 
Furthermore, the IIF strongly believes that existing initiatives in the ESG disclosure space—and the principles, frameworks, and standards that have helped advance the ESG disclosure agenda—should form the basis for the development of a common international standard. Also, it will be very important to work with national, regional, and international authorities that have established, or are in the process of developing, legislative, regulatory, and prudential frameworks for disclosure of sustainability-related information. It would be useful for the Foundation to consider the work and outputs of such initiatives and identify options that can help reduce the risk of fragmentation emerging from different approaches taken by authorities in different jurisdictions.