The IIF submitted a comment letter in response to the U.S. Securities and Exchange Commission’s (SEC) call for public input on climate change disclosures.
We welcome the SEC initiative to evaluate its disclosure rules and support its goal of facilitating the disclosure of consistent, comparable, and reliable information on climate change. As an over-arching recommendation, we emphasize the need for a principles-based, non-prescriptive, dynamic framework that is aligned with existing jurisdictional as well as voluntary climate-related initiatives, towards the shared objective of convergence on an international standard for climate-related disclosures.
We encourage the SEC—as well as other U.S. authorities—to actively contribute to current international efforts to develop standardized approaches to the disclosure and reporting of climate and other ESG-related issues. This is key to ensure a robust global framework that reflects U.S. perspectives and considerations and that builds on the pillars of the existing U.S. disclosure framework within the SEC’s original mandate, while seeking to draw upon best practices and innovative approaches in other jurisdictions where appropriate.
In this letter, the IIF lays out four key messages: the need for global standards; the importance of leveraging existing initiatives, like the Taskforce on Climate-related Financial Disclosures framework; the need for appropriate sequencing; and outstanding issues and questions related to compliance. Answers to selected consultation questions can be found in the annex to this letter.