IIF Submits Response to ISSB Consultation on Agenda Priorities

The Institute of International Finance (IIF) has submitted a response to the International Sustainability Standards Board’s (ISSB) Consultation on Agenda Priorities.

The IIF and its members believe that the ISSB should take a nimble approach to standard-setting, targeting the areas where risk of fragmentation is highest. it is critical that the ISSB’s efforts to deliver a global baseline have the desired impact – and that efforts to deliver additional guidance and resolve interoperability issues are maintained. IIF members strongly agree that the ISSB should prioritize support for widespread implementation of ISSB Standards IFRS S1 and IFRS S2 with a particular focus on improving practices in less developed markets. To this end, the ISSB should prioritize guidance to and coordination with national authorities to identify and address interoperability challenges, evaluate inter-jurisdictional reciprocity and equivalency, and reduce complexity for global entities subject to multiple regulatory regimes. As part of IFRS S2 implementation efforts, we would strongly encourage the ISSB to provide additional support for implementation of provisions related to transition plans. To support effective implementation, IIF members propose that the ISSB undertake a post-implementation evaluation of ISSB Standards IFRS S1 and IFRS S2 to identify any unintended consequences and assess whether adjustments or refinements to the standards may be necessary.

IIF members strongly agree that the ISSB should also prioritize efforts to conduct new research and standard-setting projects. If the ISSB is to serve as the global baseline for sustainability reporting, action should be taken to address globally relevant sustainability topics where approaches and frameworks are developing rapidly, and/or where significant divergences exist between different market-based and official-sector frameworks. Efforts to initiate new research and standard-setting projects should thus focus on critical emerging areas – specifically, biodiversity, ecosystems, and ecosystem services – while also addressing areas where fragmentation is already clear, including human capital and human rights.