2485

Executive summary

ISSB’S publication of the Exposure Draft (ED) recognises the increasing importance of
sustainability reporting from entities whereby alignment of financial and sustainability
reporting ensures that long-term value is generated for entities and relevant stakeholders
(IFRS Foundation 20222, p.5). This report will discuss submissions from the selected
comment letter (CL) sample which are favourable and unfavourable of ED IFRS S2 Climate-
related disclosures. Summation of key findings highlight common submission themes such
as linguistic concerns, notions of materiality and commentary surrounding Scope 3
Emissions. Furthermore, analysis of accounting regulations in various countries reveal the
interrelated relationship between reporting standard enforcement and CL submission.
Finally, theoretical frameworks are applied to analyse decisions motivating lobbyist’s
submissions.

Comment letter samples

Category Asia Australi Europ North Undisclo Multi- No. of

a e Ameri sed national submissio
ca ns
Professional 1 2 3
accounting
bodies
Professional 1 1 2
accounting firms

National 1 1 2
standard setters
Sub-total – 4 3 7
accounting
interests
Individuals 4 4
Banks 2 2
Investment firms 3 3
Non-profit 1 4 2 1 8
organisations
Other business 2 7 7 16
Actuaries 1 1
Academics 1 1 2
Unions & 1 1 3 2 7
Societies
Total comment 9 2 15 16 5 3 50
letters
Overall response to the Exposure Draft

CLs submitted in response to the ED of IFRS S2 serve as a public

record of the diverse perspectives shared with the board, with
the intention of shaping the resulting standard. While majority
of CLs in the sample express a favourable attitude towards the
ED (figure 1), all submitters emphasise that further revisions are
required to ensure that reporting is of high-quality and
comparable across industries.

Four submitters from distinct geographical locations

establish that they are unfavourable towards the ED
whereby they critique the inherent complexities of
reporting and tracking activities that create emissions.
Submissions from individuals have the most variance in
stance followed by ‘unions & societies’ and ‘other
businesses’ (figure 2). Our sample reveals that all other
submitter classifications demonstrate a favourable stance
towards the ED. Unfavourable submitters establish that
the ED is not feasible due to a multitude of challenges
whereby favourable submitters offer suggestions which
will improve the execution and reporting of climate
related disclosures.
Key findings

Identification of the pain points in IFRS S2 reveals themes pertaining to structural integrity,
overarching materiality and Scope 3 emissions reporting whereby submitters express their
concern in adapting such standards if no further corrections are enacted. Observing the CLs
from various countries in our sample reveals the complex relationship between
enforcement and engagement. Analysis of IFRS S2 submissions reveals valuable insights
toward how such standards can promote long-term value generation.

A) Structural integrity of IFRS S2

Majority of submissions in the sample revealed that IFRS S2 lack linguistic and structural
integrity whereby if such notions are not adequately addressed, collective impact of the
future standard will be hindered. CLs that identify this paint point arise from minor semantic
issues and critique the limited use of supporting examples to establish the case. Our sample
showcases a trend amongst submitters who were ‘individuals’ whereby they identify that
minor modification in semantics generates greater overall clarity. In CL 26, Robert Kercheval
identifies how rewording S2 para 23 significantly improves overall strategy by clarifying the
subject matter (IFRS Foundation 2022). Similarly, all ‘professional accounting bodies’ in our
sample highlight the importance of clarifying the links between risks and opportunities
through semantic review.

Whilst submissions from ‘individuals’ suggest minor rewording, ‘professional accounting

bodies’ urge IFRS work to revise the thematic structure of S2 standards. Japanese Institute
of Certified Public Accountants, a professional accounting body, submitted CL 23 to
emphasise the underlying repetitiveness and lack of clarity within the ED whereby concepts
should be structurally reorganised according to policies to promote coherence of reporting
requirements. Association of Charted Certified Accountants affirms such recommendation
whereby their response to question three in CL 371 (IFRS Foundation 2022) identifies
inconsistencies in phrasing which convolute whether standards be implemented as guidance
for reporting or compulsory requirements. Thus, revision of semantic choice and conceptual
structure will grant greater clarity in interpreting IFRS S2 ultimately allowing shared
understanding of requirements from entities.
 B) Overarching materiality

Materiality, which encompasses aspects such as financial impact, relevance, time horizon,
and qualitative factors, is a prominent concern within CLs. Addressing and refining these
aspects is crucial for enabling stakeholders to make informed decisions based on relevant
and reliable information. Multiple professional accounting bodies and firms such as ACCA,
EY, and Deloitte (CL 371, 374 and 56 respectively), note the concept of materiality in the ED
lacks clarity, in terms such as 'significant,' 'material,' and 'relevant' (EY 2022). These
organizations suggest that the proposed standard could be improved through guidance of
application by incorporating illustrative examples to help distinguish whether a matter is
material, significant, or both. In addition, submitters propose that more information be
included about the potential unreliability of estimates for medium to long-term horizons. As
these projections become increasingly uncertain over time, notions of accuracy and
information usefulness are negatively impacted.

Numerous companies, especially within the natural resources sector, have expressed
concerns regarding the mandatory disclosure of scenario analysis (question 7). In CL 431
(IFRS Foundation 2022) Glencore argues that implementing such disclosure is challenging for
select industries due to the incremental learning process and uncertainties when separating
climate-related information from other factors to evaluate short and long-term effects. This
reduces the disclosure's value and hinders meaningful comparisons across sectors.
Furthermore, CL 446 submitted by Enterprise Rent-A-Car UK (IFRS Foundation 2022) notes
that using quantitative metrics might unintentionally provoke unwarranted competition and
introduce anti-trust law risks within its industry. The hindrance on value creation prompts
firms to contend against disclosure of scenario analysis, ultimately ensuring ease of
compliance when IFRS S2 is enforced.

Moreover, organisations such as Amazon Watch and First Philippine Holdings (IFRS
Foundation 2022, CL116 & CL326) highlight ED's shortcomings in addressing the
environmental impacts of business activities, as evidenced by the objectives outlined in
paragraph one. Consequently, they propose adopting the double materiality approach. This
approach not only facilitates a clear distinction between outside-in and inside-out
materiality perspectives, empowering users of financial information to holistically assess and
report climate-related risks and opportunities, but also promotes greater alignment with
global standards. By addressing these concerns and refining the materiality concept,
stakeholders will be better equipped to make well-informed decisions based on
comprehensive and reliable information.

C) Reporting of scope 3 emissions

The disclosure of Scope 3 emissions within the ED has been raised as a concern by most of
our sample whereby submitters recognise notions of usefulness however disagree that it
should be disclosed. Question 9 of the ED (IFRS Foundations 2022) mandates the recording
and disclosure of emissions from activities throughout an enterprise's value chain, a notably
complex task. The lack of consistent methodology for identifying, collecting, and estimating
data may result in discrepancies, while disclosing that information might lead to diminished
comparability between companies, consequently imposing financial burdens on both the
reporting company and the market. As such, regulatory agencies like the Financial Services
Commission and the Korea Accounting Institute (2022) have requested additional
information regarding what to incorporate within Scope 3 data as well as increased targets
to improve the reliability of this information.

European countries show significant interest in this theme, with organisations such as
Glasgow Financial Alliance for Net Zero recommending the disclosure of emission reduction
targets in CL 266 (IFRS Foundations 2022). This inclusion promotes effective alignment with
the goals of the Paris agreement, reflecting the value of climate-related disclosures for
stakeholders of European Firms. CL 236 from European based organisation The Ellen
Macarthur, further affirms the importance of aligning with Paris Agreement when disclosing
climate-related issues and opportunities.

CL 371 and 491 submitted from ACCA and Dimensional Fund Advisors respectively (IFRS
Foundation 2022) express the burdens and unintended consequences that disclosing Scope
3 emissions may impose on smaller businesses, particularly those not subject to the
commission's regulations. Smaller companies are exempt from such requirements may be
required to estimate emissions for larger partners. This concern creates barriers to entry
and requires financial support to meet data requirements ultimately affecting notions of
profitability and future collaboration with larger companies. To address these concerns,
majority of CLs in our sample advocate a phased approach to develop and implement
suitable reporting frameworks for Scope 3 emissions. By adopting this gradual approach, it
will allow methodologies to mature, resulting in enhanced consistency, reliability, and
meaningful comparisons between organisations. Hence, this approach also supports global
efforts in reducing greenhouse gas emissions in line with Paris Agreement objectives.

D) Relationship between IFRS enforceability and number of comment letters

Countries adopt the IFRS framework with varying extent thereby enforcement of such
standard differs from region to region. Geographical analysis of our sample reveals the
complex relationship between adopted reporting standards and number of submissions.
Submissions from Canada constitute a majority of our sample (figure 3) whereby they
recognise the importance of sustainability reporting and offer suggestions to improve pain
points of the draft. IFRS reporting standards are required for public companies in Canada,
the high number of submissions affirms that entities operating under strong accounting
regulations wish to express their stance on proposed enforcements. This analysis holds true
for countries in our sample such as the UK who are highly regulated by IFRS application
thereby hypothesising the positive correlation between accounting standard enforcement
and number of CL submissions.
In contrast, countries which generally align with overarching principles of IFRS but adopt the
national standards of reporting have fewer CLs. For example, reporting in China is enforced
by national standards whereby such standards overlap with IFRS application. Sample
breakdown of CLs by country reveal that China constitutes two of 50 submissions which
reveals a lower number compared to countries that are enforced by IFRS standards.
Nonetheless, both CLs showcase high levels of commitment towards improving IFRS S2. For
example, China Securities Regulatory Commission in CL 221 (IFRS Foundation 2022)
showcases engagement by expressing concerns regarding key metrics to ensure that climate
related disclosures are applicable to all markets. CL 506 (IFRS Foundation 2022) from Beijing
Institute of Finance and Sustainability offer suggestions about sector specific reporting of
GHG emissions. Such analysis reveals that countries conforming to national standards still
consider wider frameworks such as IFRS regulations to promote collaboration and value
creation amongst standard setters.

However, the relationship between the CLs and a country's adoption of the IFRS framework
is not always straightforward. In the United Sates (US), adoption of IFRS accounting
standards is not required for domestic public companies as they conform to national
standards, however are permitted for foreign listed companies (IFRS Foundation 2022). The
hybrid enforcement of US GAAP and IFRS application demonstrates a reduced power of the
latter in governing US reporting. Our sample has more submissions from the US compared
to Canada (figure 3), undermining the hypothesis that enforcement and CL submissions
have a positive correlation. Therefore, it is not sufficient to observe the number of CLs by
exclusively analysing a country’s adoption of IFRS or national standards, there are a
multitude of additional factors such as industry and motivation of submitters that will grant
more valuable insight.
 E) Further discussion

It is important to examine the potential impact of the proposed climate-related disclosures

on different industries and companies, particularly to identify if certain sectors or
organisations would be disproportionately affected. CL 356 (IFRS Foundation 2022)
highlights the potential limitations of the current draft of the standard, including inadequate
coverage of some industry issues. One of the significant concerns raised by Compassion in
World Farming (CIWF) includes lack of attention to emissions from feed production, which
significantly contributes to the carbon footprint of meat, poultry, and dairy industries.
Additionally, CIWF emphasizes the need to shift toward plant-based alternatives and
sustainable agricultural practices, citing the current unsustainability of these industries. The
letter also highlights that the IFRS Exposure Draft S2 may not offer sufficient incentives for
companies to adopt a more sustainable model. These observations indicate that some
stakeholders perceive the proposed standard as inadequate in achieving sustainability goals,
resulting in unfavourable views of the IFRS S2.

Application of positive accounting theory and legitimacy theory

As a legitimate act of political participation, lobbying in all its forms has become more
widespread, allowing stakeholders to participate in the development and implementation of
policies. This section will explain how positive accounting theory and legitimacy theory
influence a lobbyist’s decision to establish their stance regarding IFS S2 in CLs.

According to the Positive Accounting Theory (PAT) as suggested by Watts and Zimmermann
(1990), all rational individuals act to maximise their self-interests. Sutton (1984) states that
accounting standard setting is a political process and as such offers several opportunities
and means for interested parties to influence its outcomes. Aligning with PAT, Sutton (1984)
suggests lobbyists will only allocate resources to lobbying if the expected benefits from
doing so exceed its costs. Such critiques are affirmed by analysing the CLs within our sample
whereby all professional accounting firms establish a favourable stance toward IFRS S2
however lobby against measures which create complexities for overall business activities.
Our sample contains CLs 56 and 311 received from Deloitte and KAI respectively (IFRS
Foundation 2022) whereby both professional accounting firms against the cross-sector
metric categories incite complexities when combined with industry-specific metrics. As
professional accounting firms have clients in a multitude of industries, employment of cross-
sector metric categories will greatly impact the relationship with select clients as the firm
will need to revise reporting processes which will be timely and costly. Monsen (2022)
explores how large accounting firms' lobbying positions reflect profit motives through
support for standards that will benefit their clients. Hence, by lobbying against metrics
proposed in IFRS S2, professional accounting firms maximise self-interest through
suggesting alternative methods of reporting, and thus ensuring value is generated by
retaining clients and effectively utilising firm resources.

Furthermore, Gina and Arce (2012) explain how submitting CLs are seen as visibility-
enhancing, ultimately assisting a corporation in establishing their legitimacy. Companies
with large carbon emissions in our sample such as Electricity Canada, Glencore and Secure
Energy affirm their favourability of IFRS S2 in CLs 401, 431 and 416 respectively. By engaging
in policy setting of sustainability accounting, corporations demonstrate their concern
toward the wider environment as well as the overall wellbeing of stakeholders. As corporate
legitimacy is assessed by social contract, demonstrating resistance against sustainability
disclosures compromises their ability to operate and ultimately affects self-maximisation as
brand image is undermined. Therefore, such analysis affirms that lobbying is a strategy used
by corporations to enhance their public image and gain legitimacy (Deegan 2020).

Hence, motivations for lobbyists to submit IFRS S2 comment letters can be explained
through notions of self-maximisation and enhancing brand legitimacy. Lobbying against
select paragraphs in the draft is an approach for firms to maximise economic gain through
retaining clientele. By offering suggestions to improve the draft, lobbyists showcase their
capability in providing legitimate solutions.
Conclusion

To conclude, discussion and analysis of 50 CLs reveals that majority of submitters are in
favour of IFRS S2, however, the draft requires significant revision to promote overall clarity
and consistency of strategy. The pain points identified by comment letters illustrate the
shared concern amongst submitters regarding conceptualisations and materiality. Perceiving
such notions through a theoretic lens yields greater understanding towards the underlying
motivations of climate-related disclosure submissions.

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