CORPORATE DISCLOSURE OF INFORMATION ON CLIMATE-RELATED MATTERS: RESEARCH INTO THE NEW PROPOSALS OF SEC, EFRAG, AND ISSB (PART I)
Keywords:
Environmental Degradation, Sustainability, Climate ChangeAbstract
The contemporary problems that occur due to climate change are unique. The change climate process
observed for decades causes an existential threat to both humankind and other living beings. Another interrelated
risk arises from environmental degradation and biodiversity deterioration. The multiple complicated, compound and
simultaneous impacts of both factors and processes on people, biodiversity, and economic entities and sectors pose
challenges to humankind.
Current circumstances and effects of climate change require adequate governmental, institutional, managerial, and
administrative strategies, policies, and activities both at national, regional, and international levels, for achieving
sustainable (ecological), fair, and resilient growth alongside combating climate change. Moreover, natural
phenomena and processes, unknown to the local indigenous inhabitants of certain geographical regions, are vast
evidence of climate change. All these processes, more and more give rise to highlighting and justifying the need for
meaningful climate-related disclosures through the opportunities of corporate reporting.
The societal necessity of trustworthy, transparent, and reliable disclosures on climate-related matters and inherent
potential risks and opportunities focused on climate change mitigation and adaptation is the problem of crucial
importance to the present article. The relevance of climate-related disclosures as a significant part of present-day
corporate reporting proves to be of great importance to achieving disclosure efficiency. The author aims to highlight,
discuss and justify the necessity of a responsible approach to implementing and conducting an adequate disclosure
policy and providing meaningful and consistent disclosures concerning matters, risks, and opportunities related to
climate and its visible change. This is considered a substantial part of contemporary corporate reporting and
substantiates why probable benefits for a sustainable future can be expected, not only for the company. Concerning
the specified issues and objectives, the paper discusses and essentially presents the three most significant proposals
for climate-related disclosures recently made – the U.S. Securities and Exchange Commission’s proposal, the
proposal made by the European Financial Reporting Advisory Group, and the International Sustainability Standards
Board’s proposal. The author has set out to present the just essential core values of each of the proposals, thus
comparing them with each other as well as with the foundation they follow – the recommendations of the TFCD
framework.
The terminology is in the field of both financial and non-financial reporting and the respective regulatory
frameworks, which are not fully aligned, although the long-lasting efforts of many global and international
authoritative organizations and institutions. Heuristic methods like analysis and synthesis, methods of induction and
deduction, descriptive approach, and techniques and methods such as observation, analogy, comparison, and others
were applied in the research process that is important to achieving the author’s objective.
References
Azzouz, M., & Brisson-Félix, A. (2022). NATIXIS CORPORATE & INVESTMENT BANKING. “Navigating the sea of proposed climate-related disclosures: A deep dive into the SEC’s, ISSB’s and EFRAG’s proposals”, 3 June 2022.
Ceres joins investors in supporting SEC’s climate disclosure proposal EFRAG, June 17, 2022, Boston, available at https://www.ceres.org/news-center/press-releases/ceres-joins-investors-supporting-secs-climate-disclosure-proposal.
Ceres, ERM, and Persefoni Webinar “Understanding the cost implications of the SEC’s proposed climate-related disclosure rule: Webinar representatives from Ceres, ERM, and Persefoni focused on the cost of climate change related disclosure”, 2022.
EU Council, New rules on corporate sustainability reporting: [the] provisional political agreement between the Council and the European Parliament, 21 June 2022.
European Commission, Corporate disclosure of climate-related information Guidance for companies on how to report on the impacts of their business on the climate and on the impacts of climate change on their business, January 2019.
European Commission, Corporate sustainability reporting, available at https://ec.europa.eu/info/business-economy-euro/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting.
European Commission, Impact assessment accompanying the CSRD proposal, SWD(2021) 150.
European Commission, Non-financial reporting by large companies (update rules), website.
European Commission, Proposal for a directive amending Directive 2013/34/EU, Directive 2004/109/EC, Directive 2006/43/EC and Regulation (EU) No 537/2014, as regards corporate sustainability reporting, COM (2021) 189.
European Financial Reporting Advisory Group, European Sustainability Reporting Standards, April 2022, available at https://www.efrag.org/.
European Financial Reporting Advisory Group, Final Report: Proposals for a relevant and dynamic EU sustainability reporting standard-setting, February 2021.
European Financial Reporting Advisory Group, Report: Proposals for a relevant and dynamic EU sustainability reporting standard-setting, 8 March 2021.
European Parliament, EU responses to climate change, created on 07.08.2018 and updated on 17.06.2022, available at https://www.europarl.europa.eu/news/en/headlines/society/20180703STO07129/eu-responses-to-climate-change.
European Parliament, Legislative Observatory. Procedure file on Corporate Sustainability Reporting Directive, 2021/0104(COD).
European Parliament, New social and environmental reporting rules for large companies, 21 June 2022.
Herdman, R. K. (2002). Testimony Concerning The Roles of the SEC and the FASB in Establishing GAAP, Chief Accountant at the U.S. Securities & Exchange Commission, May 14, 2002.
IFRS Foundation 2022. “Exposure Draft and comment letters: Climate-related Disclosures Consultation”, London, available at https://www.ifrs.org/projects/work-plan/climate-related-disclosures/exposure-draft-and-comment-letters, accessed July 2022.
IFRS Foundation Exposure Draft Sustainability Disclosure Standard [Draft] IFRS S2 Climate-related Disclosures, March 2022.
IFRS Foundation International Sustainability Standards Board Disclosure Exposure Drafts ISSB IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and IFRS S2 Climate-related Disclosures, 2022.
IFRS Foundation Basis for Conclusions on [draft] IFRS S2 Climate-related Disclosures, March 2022.
Ravindirane, J., and Girard T., (2020). NATIXIS CORPORATE & INVESTMENT BANKING. “The UK about to impose mandatory TCFD climate disclosure and to issue a sovereign Green Bond”, 30 November 2020.
Matt Haddon, ERM, Robert LaCount, ERM, Justin Nelson, ERM, Kevin Stephen, Persefoni, Anissa Vasquez, Persefoni, and Kristina Wyatt, Persefoni, 2022.
Moody’s Analytics IOSCO Publishes Report on Sustainability-Related Issuer Disclosures by Regulatory News
OICU-IOSCO. The International Organization of Securities Commissions, 21 June 2021, www.iosco.org.
Oreshkova, H. (2013). The crisis and the future of financial reporting. Global financial reporting standards - reality or utopia, Economic Alternatives, 2013(2), 55-74.
Oreshkova, H. (2018). The Future of Corporate Reporting Reflections on the Critical Question of the Necessity of Forward-thinking philosophy and culture of Reporting Worldwide. Knowledge International Journal, 28(5), 1455–1466, available at https://doi.org/10.35120/kij28051455H.
Régis Gourdel, Irene Monasterolo, Nepomuk Dunz, Andrea Mazzocchetti, Laura Parisi (2022). The double materiality of climate physical and transition risks in the euro area, Working Paper Series, The European Central Bank (ECB). EUROSYSTEM, May 2022.
SEC Proposes Expansive Climate-Related Disclosure Rules Would Require Public Companies to Disclose Detailed Greenhouse Gas Emissions, Climate Transition Plans, Targets and Progress Against Targets, Long-Term Climate Risks and Business Impacts, and Climate-Related Corporate Governance, Including New Information in Notes to Audited Financial Statements, Webinar, March 29, 2022.
Segal, M. (2022). Study Reveals Convergence, Remaining Differences among Emerging Climate Disclosure Frameworks, ESG Today Finance with Purpose ESG Reporting, Reports Studies, June 14, 2022, available at https://www.esgtoday.com/study-reveals-convergence-remaining-differences-among-emerging-climate-disclosure-frameworks.
Sullivan & Cromwell, LLP, 2022. SEC Proposes Expansive Climate-Related Disclosure Rules. Online posting March 28, 2022, accessed on 30 July 2022, at https://www.sullcrom.com/files/upload/sc-publication-sec-proposes-expansiveclimate-related-disclosure-rules.pdf.
Sullivan, & Cromwell, LLP, 2022. SEC Proposes Expansive Climate-Related Disclosure Rules. Online posting March 28, 2022, accessed on 30 July 2022 at https://www.sullcrom.com/files/upload/sc-publication-sec-proposes-expansiveclimate-related-disclosure-rules.pdf.
TCFD 2017. Task Force on Climate-related Financial Disclosures Recommendations of the Task Force on Climate-related Financial Disclosures Final Report, June 15, 2017.
TCFD Recommendations, available at https://www.fsb-tcfd.org/recommendations.
The Greenhouse Gas Protocol Corporate and Reporting Standard, World Resources Institute (WRI). The World Business Council for Sustainable Development (WBCSD). The GHG Protocol FAQ, further details are available at https://ghgprotocol.org.
The Project Task Force to operate the project on preparatory work for the elaboration of possible EU non-financial reporting standards, mandated to EFRAG by the European Commission, 4 September 2020.
The SEC’s Enhancement and Standardization of Climate-Related Disclosures for Investors, 2022 https://www.sec.gov/rules/proposed/2022/33-11042.pdf.
The Securities and Exchange Commission’s Press Release, SEC Proposes Rules to Enhance and Standardize Climate-Related Disclosures for Investors, March 21, 2022, Washington.
The SustainAbility Institute by ERM and Persefoni AI “The Evolution of Sustainability Disclosure Comparing the 2022 SEC, ESRS, and ISSB Proposals”, 2022.
Understanding the cost implications of the SEC’s proposed climate-related disclosure rule: Webinar featuring representatives from Ceres, ERM, and Persefoni, on the cost of climate change-relate disclosure, May 11, 2022.
United Nations (UN) Environment Programme, available at https://www.unep.org/explore-topics/sustainable-development-goals/why-do-sustainable-development-goals-matter/goal-13.
United Nations Conference on Environment and Development, Rio de Janeiro, Brazil, June 1992.
https://www.unglobalcompact.org/what-is-gc/our-work/environment/climate.
https://www.epa.gov/climateleadership/scope-3-inventory-guidance.
