A Canadian Response To The Pursuit of Global Sustainability Reporting Standards

A Canadian Response to the Pursuit of Global
Sustainability Reporting Standards*

HAMILTON ELKINS, Edwards School of Business, University of Saskatchewan
GARY ENTWISTLE, Edwards School of Business, University of Saskatchewan†
ABSTRACT
As business, government, and society continue to emphasize the importance of
sustainability—both of individual organizations and of the natural world—accounting
standard-setting bodies want to be part of the process. In September 2020, in response to
“urgent and growing demand” for more “consistent and comparable” sustainability
reporting, the IFRS Foundation (the Foundation) released for comment a Consultation
Paper on Sustainability Reporting. In the paper, the Foundation proposed the creation of
a Sustainability Standards Board (SSB), which it would oversee alongside the IASB. The
SSB would become, de facto, the global sustainability reporting standard setter. The
Foundation received 577 responses to its proposal. These responses came from around
the world and from a wide range of stakeholders. Thirty-eight of the responses came
from Canada. This study profiles the Canadian responses, contrasting them with the
wider set of worldwide responses. Some uniquely Canadian features include user
responses from a large number of pension funds and preparer responses solely from the
energy sector. There was also a significant response from the Canadian accounting com-
munity, including from the full set of Canadian standard-setting organizations. Five audi-
tors general also responded. Overall, Canadian respondents supported both globalized
sustainability reporting standards and the Foundation’s creation of the SSB. This support
aligns Canada’s response with the worldwide response.
Keywords: sustainability reporting, comment letters, standard setting, international,
Canada, lobbying
RÉPONSE CANADIENNE À LA CRÉATION DE NORMES MONDIALES SUR

L’INFORMATION RELATIVE À LA DURABILITÉ

RESUM
E
Alors que les entreprises, les gouvernements et la société continuent de mettre l’accent
sur l’importance de la durabilité, à la fois des organisations individuelles et du milieu
naturel, les organismes de normalisation comptable souhaitent participer au processus. En
septembre 2020, en réponse à la « demande urgente et croissante » d’information relative
* Accepted by Bruce McConomy and Leslie Berger. The authors would like to thank Bruce McConomy (asso-
ciate editor) and two anonymous reviewers for their helpful comments. We also wish to recognize the excel-
lent research assistance of Tanner Gerwing, Caleb Haight, and Mekelty Wisse. Gary Entwistle acknowledges
the financial support of the Sutherland Scholar in International Business.
† Corresponding author. entwistle@edwards.usask.ca
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022) pages 00–00 © CAAA/ACPC

doi:10.1111/1911-3838.12297
2 ACCOUNTING PERSPECTIVES / PERSPECTIVES COMPTABLES
à la durabilité plus « uniforme et comparable », l’IFRS Foundation (la Fondation) a

publié aux fins de commentaires un document de consultation sur le sujet. Dans ce docu-
ment, la Fondation propose la création d’un conseil des normes sur la durabilité, qu’elle
chapeauterait parallèlement à l’IASB. Ce conseil deviendrait par le fait même l’organisme
de normalisation de l’information relative à la durabilité à l’échelle mondiale. La
Fondation a reçu 577 réponses à sa proposition, formulées par un vaste éventail de parties
prenantes de partout dans le monde, dont 38 du Canada. La présente étude dresse un por-
trait des réponses canadiennes, en les comparant à l’ensemble des réponses reçues
d’ailleurs. Parmi les caractéristiques propres aux réponses canadiennes, mentionnons le
grand nombre de réponses fournies par des régimes de retraite du côté des utilisateurs et
le fait que celles fournies par des préparateurs provenaient exclusivement du secteur
énergétique. La communauté comptable du Canada a aussi répondu en grand nombre, y
compris tous les organismes d’établissement de normes canadiens. Cinq vérificateurs
généraux ont également fait parvenir leurs commentaires. Dans l’ensemble, à l’image du
reste du monde, les répondants canadiens appuyaient l’établissement de normes
mondiales sur l’information relative à la durabilité ainsi que la création d’un conseil des
normes par la Fondation.
Mots-clés : information relative à la durabilité, lettres de commentaires, établissement de
normes, international, Canada, lobbying
1. INTRODUCTION
Global Concerns with Sustainability Reporting

In 2015, the UN released Transforming Our World: The 2030 Agenda for Sustainable Devel-
opment. The report contained 17 sustainable development goals (SDGs) and 169 associated
targets designed to stimulate action “in areas of critical importance for humanity and the
planet” (UN 2015). These include ending poverty and hunger; protecting the planet from
degradation; and fostering peaceful, just, and inclusive societies. In 2017, more than
140 CEOs and global business leaders committed to align their corporations’ values and
strategies with these SDGs. Similarly, sustainability-oriented investing—which began as early
as 1758 when the Religious Society of Friends (the Quakers) banned their members from
participating in the slave trade—is now prevalent in financial markets. In Canada, 41 new
sustainability-oriented exchange-traded funds (ETFs) were launched in 2020, more than dou-
ble the 2019 number (Nash 2021). Sustainability reporting could indicate whether corporate
alignment with SDGs is being achieved and whether sustainable ETFs are investing in sus-
tainable companies. How do Canadian views on the need for sustainability reporting
requirements—and on who should set these requirements—compare to the rest of the world?
Convoluted Sustainability Reporting Environment

A recent white paper from the World Economic Forum (WEF 2020), prepared in con-
junction with the Big 4 accounting firms, proffers a set of “stakeholder capitalism
metrics,” consisting of 21 core metrics and 34 expanded metrics. The paper suggests the
use of these metrics would serve to increase consistency among environmental, social,
and governance (ESG) disclosures, enabling users to more accurately assess alignment
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

GLOBAL SUSTAINABILITY REPORTING STANDARDS 3
with SDGs or whether organizations are operating sustainably. However, these metrics
are being introduced into an already crowded field of sustainability reporting frameworks
and measures and may only serve to further complicate the sustainability reporting envi-
ronment. As of September 2020, there were six major sustainability reporting framework
and standard setters, each with their own set of standards and/or guidelines.1 These six
were the Global Reporting Initiative (GRI), the Sustainability Accounting Standards
Board (SASB), the International Integrated Reporting Council (IIRC), the Task Force on
Climate-Related Financial Disclosures (TCFD), the Climate Disclosure Standards Board
(CDSB), and the Carbon Disclosure Project (CDP).
From a reporting perspective, the presence of multiple standard setters with different
reporting frameworks and disclosure guidelines makes it difficult for preparers to know
which standards to use or how to combine multiple frameworks into a single coherent
approach. This diversity also impacts the ability of stakeholders to evaluate the sustain-
ability practices of reporting entities.
A good example of diversity in sustainability reporting practice and assessment can be
found in the 2020 ESG report of Nutrien Ltd., a large, publicly traded Canadian company
in the environmentally sensitive industry of fertilizer mining operations.2 In an extensive
index found at the back of its 68-page report, Nutrien shows how its reported information is
connected to guidance from three different sustainability frameworks: SASB, TCFD, and
GRI. The 2020 report also provides a link to a limited assurance report from KPMG attes-
ting to Nutrien’s Scope 1 and 2 emissions disclosures.3 No other information in the ESG
report has any form of external assurance. Nutrien also presents its ESG ratings profile,
showing five different ratings agencies’ scores. Although scoring low risk on governance
(a good thing), Nutrien was rated poorly on climate. Three broader ESG ratings showed
Nutrien as having a mid-range sustainability profile. Nutrien also reminds readers that the
ratings only reflect the extent of disclosure, and not its quality, nor its actual ESG
performance.
Nutrien, as with other such reporters, reports sustainability information drawing upon
a diverse set of existing frameworks. Furthermore, only a very narrow subset of this
information is subject to formal assurance. Rating agencies, using their own proprietary
assessment tools, then use this information to inform their assessment of the disclosing
firm’s sustainability practices. Whether their assessments can be done consistently from
period to period, and are comparable across organizations using different reporting frame-
works, is open to significant debate.
The IFRS Foundation (the Foundation) views such debate as an important motivation
for their recent sustainability reporting initiative. According to the Foundation, what is
needed to cut through this complexity is a global sustainability reporting standard setter.
1. An update of recent developments is provided in the sustainability reporting environment in section 2.

2. https://nutrien-prod-asset.s3.us-east-2.amazonaws.com/s3fs-public/uploads/2020-04/Nutrien%202020%
20ESG%20Report_0.pdf
3. https://nutrien-prod-asset.s3.us-east-2.amazonaws.com/s3fs-public/uploads/2021-04/Nutrien%20-%
202020%20Assurance%20Report.pdf
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

Consequently, in September 2020, the Foundation, in a Consultation Paper (IFRS 2020),

proposed the creation of the SSB, which it, along with the IASB, would oversee. The
SSB would be tasked with setting global sustainability reporting standards. This would
serve to enhance both comparability and consistency in sustainability reporting and, ulti-
mately, a more sustainable environment. Five hundred seventy-seven respondents submit-
ted letters to the Foundation,4 including 38 from Canada, and from each of the existing
sustainability reporting standard-setting organizations. This paper profiles these respon-
dents. It also presents their responses to the need for globalized sustainability reporting
standards and for a global standard setter overseen by the Foundation.
Canada’s Response Positioning

With 38 separate responses to the Consultation Paper, Canada ranks second in total
responses for an individual nation and second in most responses per person for individual
nations.5 This level of response activity by Canadians shows a high level of interest in
the area of sustainability reporting and sustainability reporting standards. This level of
interest raises the joint research questions examined in this study: (i) Are Canadian
respondents, and their responses to the need for global sustainability standards and a
standard setter overseen by the Foundation, representative of the overall response? and
(ii) What differentiates the Canadian respondents, or responses, from the rest of the
world? With the Deputy Prime Minister and Finance Minister inviting the IFRS board of
trustees to headquarter the proposed SSB in Canada (Freeland 2021), Canada’s pitch to
host the Foundation’s sustainability standard-setting board would be bolstered if the
responses from Canada are representative of the global responses.
The Deputy Prime Minister and Finance Minister’s letter to the IFRS board of
trustees claims that Canada has a multicultural society (Freeland 2021). The 2016 census
supports this assertion.6 The 2016 census indicates that approximately 40% of Canada’s
population is either foreign born or has at least one foreign-born parent, with almost half
of the foreign born being from Asia (Statistics Canada 2017a, 2017b). The recent immi-
grants to Canada hail from all over the world, with at least 10% coming from each of
Asia, Africa, the Americas, and Europe (Statistics Canada 2017b). The 2016 census also
reported over 250 ethnic origins among the Canadian population and almost 5% of the
population as Indigenous (Statistics Canada 2017b, 2017c).
Although Canada’s population makeup suggests the country’s attitudes may be a fair
representation of the world’s attitudes on sustainability, aspects of the Canadian economy
may not align with the rest of the world. Canada is a member of the G7, placing it in the
upper echelon of democracies in terms of GDP. While being the smallest of the G7 in
4. The full set of responses is available at https://www.ifrs.org/projects/work-plan/sustainability-reporting/

exposure-draft-and-comment-letters/#view-the-comment-letters.
5. There are chain letters that do not represent separate responses to the consultation paper. See section 4
for a discussion of the chain letter responses and Appendix 3 for an example of a chain letter. The
United Kingdom has the most separate responses, and Hong Kong has the most responses per person.
6. The results of the 2021 Census were not available at the time of this writing.
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

terms of total GDP, Canada ranks third among G7 nations in GDP per person. In addi-
tion, a significant portion of the Canadian economy (20%) is in environmentally sensitive
industries (Statistics Canada 2021).7 Canada also has the third largest proven oil reserves
in the world and is the fourth largest producer and third largest exporter of oil
(Government of Canada 2021). Recent research reports that Canadian-listed companies
provide sustainability information at lower rates than other countries (Cho et al. 2020).
Furthermore, the governmental focus on carbon pricing suggests that Canadians are more
interested in only the environmental aspect of sustainability reporting than other coun-
tries.8 The 2021 record heat, wildfires, and flooding definitely have brought Canada’s
direct impact of climate change front and center to the populace.
There are competing reasons for why Canadian respondents and responses may or
may not be representative of all the respondents and responses to the Consultation
Paper. Analysis of the comment letters to the Consultation Paper offers a unique situa-
tion in the study of lobbying of accounting standard setters. In contrast to other com-
ment letter studies (Francis 1987; McLeay et al. 2000; Georgiou 2004), what is
proposed in the Consultation Paper will not have a direct impact on firms’ financial
statements. In addition, it is uncertain what, if any, assurance sustainability reporting
will require. With preparers and the accounting profession—two of the most prevalent
comment letter writers—not directly impacted, what interest groups are responding, and
are there differences depending on where the respondents are from? The comment let-
ters to the Consultation Paper also offer an opportunity to examine lobbying behavior at
a very early stage in the standard-setting process. Sutton (1984) proposes that the proba-
bility of influencing the outcome is higher earlier in the standard-setting process. Dis-
cussion of the formation of the standard-setting body can be interpreted as very early in
the standard-setting process. With this early entry into the process, traditionally under-
represented interest groups may find more incentive to engage in lobbying. By investi-
gating a novel occurrence in Canadian and global standard setting, we follow prior
research into lobbying of standard setters (Bujaki and McConomy 2007). Furthermore,
comparing Canadian lobbying with global lobbying can lend more credence to the gen-
eralizability of prior studies of lobbying behavior in Canada (Durocher et al. 2007;
Durocher and Fortin 2011).
The paper is structured as follows. Section 2 profiles the existing major sustainabil-
ity reporting organizations, including their responses to the need for global sustainabil-
ity standards and to the creation of the SSB. This section also presents in greater detail
the Foundation’s sustainability reporting initiative as documented in the formal Consul-
tation Paper and describes the Foundation’s overall assessment of the feedback it
received from the respondents. Also included in this section are recent developments in
7. These include agriculture, forestry, fishing, hunting, mining, quarrying, oil and gas extraction, and
manufacturing.
8. British Columbia enacted North America’s first wide-scale carbon tax (Government of British Colum-
bia 2021), and Canada has one of the more robust carbon pricing schemes in the world (Plumber and
Popovich 2019).
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

the sustainability reporting environment, including the formal creation of the Interna-
tional Sustainability Standards Board (ISSB).9 Section 3 provides additional back-
ground information on due process within standard setting, the role of comment letters,
and the lobbying of accounting standard setters. It also provides the contrasting views
which currently exist on the role of sustainability reporting standards. Section 4, our
research design section, describes the protocols we followed to categorize the respon-
dents and to capture selected elements of their responses. Sections 5 and 6 present our
data analysis. Section 5 profiles the full respondent set and then places the Canadian
respondents in context. Section 6 shows the extent to which the respondents favored
global sustainability reporting standards and the Foundation’s proposed role as the
global standard setter. We conclude in section 7 by highlighting our major findings.
We also comment on how our research contributes to both the limited Canadian litera-
ture on standard setting and the literature on comment letters more broadly. Limitations
of the study and areas for future research are also identified. The section concludes with
some commentary regarding the Foundation’s initiative.
2. CURRENT SUSTAINABILITY FRAMEWORK AND STANDARD SETTERS AND THE

IFRS FOUNDATION SUSTAINABILITY INITIATIVE
Current Sustainability Framework and Standard Setters

As mentioned in section 1, when the Consultation Paper was issued, there were six major
sustainability reporting framework and standard setters: GRI, SASB, IIRC, TCFD, CDSB,
and CDP. A description of each of these standard setters is presented next, along with their
responses to the need for global sustainability standards and the creation of the SSB.10
GRI
The GRI, with a secretariat located in Amsterdam, is an international organization
founded in 1997 following the Exxon Valdez oil spill. It serves as an advocate for greater
corporate transparency.11 The GRI standards, first published in 2000 as guidelines, con-
stituted the first global framework for sustainability reporting. The standards, set by the
Global Sustainability Standards Board, currently consist of three universal reporting prin-
ciples (foundation, general disclosures, and management approach) supplemented by
34 topic-specific standards encompassing economic, environmental, and social issues.
The standards are aligned with international expectations for responsible business con-
duct and hence are consistent with a public interest perspective. The standards extend
beyond a pure market or investor focus to be multi-stakeholder in orientation. They are
also closely attuned to the information needs of the jurisdictions in which they operate.
The GRI claims that its standards are the sustainability reporting standards most widely
referenced by governments, financial market regulators, and stock exchanges around the
world. The 2020 KPMG Survey of Sustainability Reporting states that 73% of the
9. In a formal exposure draft, the Foundation changed the name of the board to ISSB (IFRS 2021d).
10. The specific wording in the Consultation Paper of these two questions can be found in Appendix 1.
11. https://www.globalreporting.org/
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

world’s largest companies (the G250), along with 67% of the largest 100 companies
across each of 52 countries (the N100), use GRI standards (KPMG 2020).
The GRI’s comment letter sees the Foundation as playing a “purposeful” role in
advancing global standards, albeit a role restricted to reporting the impact of sustainabil-
ity issues on the firm.12 This “outside in” perspective, for example, would report how cli-
mate change affects firm assets. The GRI, however, also sees a great need for firms to
report the “inside out” view—for example, the firm’s impact on the environment. Given
that the GRI’s existing standards align with this inside out perspective and that its stan-
dards have been widely adopted by preparers worldwide, their response directly ques-
tions the need for an SSB, especially if such a board should try to replicate the GRI’s
existing work. The response states, “Given our recommendation to focus the standard-
setting efforts of the IFRS Foundation on sustainability-related financial reporting, we
believe it will be key for the IFRS to assess whether the creation of a new standards
board is warranted. It would need to be evaluated whether the mandate of the new board
is sufficiently distinct from the mandate of the IASB.”
SASB
Founded in 2011 and headquartered in San Francisco, the SASB has identified a subset
of ESG issues deemed most relevant to investors in assessing financial performance
within each of 77 different industries.13 These industry-specific standards, first issued in
2018, were developed “based on extensive feedback from companies, investors and other
market participants as part of a transparent, publicly-documented process.” The SASB
claims their standards are used by asset managers and owners representing over $60 tril-
lion in assets. Corporate use of these standards increased 325% from 2019, and they are
now used by companies in 67 industries in 37 countries. The SASB suggests that its stan-
dards, along with those of the TCFD (see below), are becoming the preferred sustainabil-
ity reporting choice of the investment community.
The comment letter from the SASB favors, in principle, both the need for global sus-
tainability reporting standards and the creation of the SSB.14 A proviso, however, is that
the standards focus on investor needs and have an industry-specific mandate. The
response notes that broader sustainability reporting needs—for example, a firm’s impact
on the planet—are currently being served through GRI-based reporting.
IIRC
The IIRC, with a registered office in London, is a global coalition of regulators, inves-
tors, companies, standard setters, the accounting profession, academia, and non-
governmental organizations (NGOs).15 The IIRC supports organizations globally to
12. Response #41. The numbering follows the IFRS website. A lower number denotes an earlier-received
response.
13. https://www.sasb.org/
14. Response #44
15. https://integratedreporting.org/
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

improve their communication about value creation, contributing to both financial stability
and sustainable development. Originally published in 2013 and recently updated in
January 2021, the Integrated Reporting Framework (<IR> Framework) is comprised of
seven guiding principles (e.g., strategic focus, connectivity), eight content elements
(e.g., governance, risks, and opportunities), and six capitals (e.g., intellectual, social and
relationship, natural). The concept of integrated reporting brings together these principles,
elements, and capitals to show how they create, preserve, or erode value over time. As of
October 2020, over 2,500 businesses in more than 70 countries report using the <IR>
Framework guidance.
In its response, the IIRC states a clear need for a global set of internationally recog-
nized sustainability reporting standards. They also advocate for a value creation lens as a
vital starting point in the development of the standards. The IIRC views the Foundation
as the appropriate body within which to house an international SSB, making special note
of its credibility, legitimacy, and international reach.16
TFCD
In April 2015, the Financial Stability Board (FSB), at the behest of the G20 group of
countries, was tasked with reviewing how the financial sector can better take account of
climate-related risks when making investment, lending, and insurance underwriting deci-
sions. To undertake the review, the FSB established an industry-led task force, the
TCFD.17 The TCFD released its final recommendations in 2017. The recommendations
suggest 11 types of disclosures of climate-related risks and opportunities, including infor-
mation on governance, strategy, and risk management, as well as certain metrics and tar-
gets. In its 2020 status report, the TCFD reported significant growth in the number of
organizations expressing support for the TCFD. The current reach was stated to be 1,500
organizations globally, including over 1,340 companies with a total market capitalization
of $12.6 trillion, as well as financial institutions responsible for $150 trillion in assets.
Investor demand for companies to report information in line with the TCFD recommen-
dations has also grown dramatically. There are currently 110 regulators and governmental
entities from around the world which support the TCFD, including the governments of
Belgium, Canada, Chile, France, Japan, New Zealand, Sweden, and the United Kingdom.
In a recent article (Jones 2021), the Canadian government stated that “it plans to ‘engage’
with the provinces and territories to make TCFD part of regular disclosure practices. It is
also mandating use of TCFD by Crown corporations, though there is no regulation mak-
ing adopting in the private sector mandatory.”18 In its response, the FSB recognizes the
importance to market participants and financial authorities of having globally consistent
and comparable disclosures of their climate-related financial risks.19 The FSB also
strongly recommends the TCFD recommendations as the basis for such standards. They
16. Response #110

17. https://www.fsb.org/
18. Crown Corporations are government organizations with a mix of commercial and public policy
objective.
19. Response #210. The response was from the FSB.
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

also encourage the Foundation to capture these climate-related financial risks within exis-
ting financial reporting, either by strengthening existing IFRS standards or through the
management commentary guidance currently in development.20 As such, the FSB states
that if a new board (the SSB) were to be created, it needs to work closely with the IASB.
CDSB
The CDSB, headquartered in the United Kingdom, is an international consortium of busi-
ness and environmental NGOs.21 It was founded in 2007 due to the absence of an inter-
nationally recognized, mainstream reporting standard for climate-related issues. It
subsequently expanded its remit to incorporate natural capital. The CDSB offers the mar-
ket a framework for reporting climate and environmental information with the same rigor
as financial information. The CDSB’s reporting framework has 12 requirements. These
requirements are divided into five categories ranging from an organization’s ESG policies
to its future environmental performance to how specific environmental information is to
be reported. The framework is used by large-listed companies throughout the world. It is
also referenced for use in the UK Companies Act 2006 and in stock exchange guidance
worldwide. The CDSB sees its framework as being foundational to the recommendations
of the TCFD.
The CDSB’s response acknowledges the importance of developing global sustain-
ability reporting standards.22 It notes the importance of ensuring the standards cover all
sustainability matters, in a connected and comprehensive manner, highlighting the impor-
tance of ensuring strong coordination—or the building of bridges—with GRI and CDP.
The CDSB also supports the formation of the SSB under the auspices of the IFRS Foun-
dation, stating that “the IFRS Foundation is the ideal means of governing an SSB,” help-
ing to ensure “that climate-related and wider sustainability standards are produced to be
harmonious and complementary with financial standards, and vice-versa, ensuring trans-
parency, accountability and efficiency.”
CDP
The CDP is a global environmental not-for-profit located in London.23 The CDP offers a
disclosure mechanism, or platform, to enable the reporting of sustainability information
created using the various sustainability frameworks currently in existence. While not an
official sustainability standard setter, the CDP collaborates with a number of standard set-
ters, including the CDSB, GRI, SASB, IIRC, and TCFD. This collaboration better
enables investors, companies, and cities to measure, understand, and address their envi-
ronmental impact. In 2020, over 9,600 companies worldwide disclosed on the CDP plat-
form—an increase of more than 70% since 2015. These 9,600 companies represent over
50% of total global market capitalization.
20. https://www.ifrs.org/projects/work-plan/management-commentary/
21. https://www.cdsb.net/
22. Response #42
23. https://www.cdp.net/en
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

The comment letter from the CDP agrees with the need to create a global set of inter-
nationally accepted, sustainability-related financial disclosures.24 It suggests that such dis-
closures be modeled on value-reporting frameworks of the CDSB, IIRC, and SASB. The
CDP also recognizes the growing demand for information on the impacts of companies
on people and planet, most notably exemplified in GRI standards. The CDP cautions that
the creation of an SSB under the Foundation would best serve as a transitory measure to
catalyze developing sustainability-related standards, with further development being sub-
sumed under the IASB.
Progressing to a Single Set of Standards

In September 2020, a Statement of Intent to Work Together (the Statement) was signed
between five (“the Five”) sustainability framework and standard-setting institutions: the
GRI, SASB, IIRC, CDSB, and CDP (CDP et al. 2020a). In the Statement, note was made
of the confusion that exists for both preparers and users of sustainability information
owing to the existing plethora of frameworks and standards. It was argued that a pivotal
moment had been reached “that could usher in progress towards a more comprehensive
solution for corporate reporting; one that is urgently needed to improve enterprises’ con-
tribution to sustainable development, to help address climate change and to enable more
resilient, efficient financial markets” (CDP et al. 2020a, 3). The Five agreed that this pro-
gress could be aided through a joint commitment toward a comprehensive corporate
reporting system. In the Statement, the system is predicated on a building-blocks
approach.25 The first block focuses on disclosure linked to enterprise value creation and
is directed toward investors and financial market regulators. It utilizes an integrated
annual report (IIRC) and encompasses information found in existing financial statements
(IASB or FASB standards) as well as sustainability information relevant to economic
decision-making (SASB and CDSB). The second building block goes beyond enterprise
value creation to reporting on a wider set of economic, environmental, and social impacts
caused by the organization (GRI). The second block is directed toward a diverse set of
stakeholders, including government and civil society. Fundamental to understanding the
comprehensive reporting system is the concept of “dynamic materiality,” whereby sus-
tainability topics can move between the two blocks, either gradually or very quickly. In
December 2020, a prototype of a climate-related financial disclosure standard based
around enterprise value was released in a partnership between the Five and the TCFD
(CDP et al. 2020b). The prototype demonstrated “how certain components of our current
frameworks and standards, along with the recommendations set out by the Task Force on
Climate-Related Financial Disclosures (TCFD), can be used together to provide a starting
point for the development of global standards for sustainability-related financial disclo-
sure” (CDP et al. 2020b, 4). The prototype represents an important step toward recogniz-
ing the vision of the Five.
Subsequent to the Statement, in November 2020 (SASB 2020), the IIRC and SASB
announced they were merging to create the Value Reporting Foundation (VRF). The
24. Response #226

25. See figure 6 of CDP et al. (2020a, 13).
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

merger became official on June 9, 2021 (VRF 2021). The merger was seen as creating a
credible international organization that maintains the <IR> Framework, advocates inte-
grated thinking, and sets sustainability disclosure standards for enterprise value creation.
The <IR> Framework and the SASB standards would both remain integral in enabling
organizations globally to communicate how sustainability issues are connected to long-
term enterprise value, with the merger seen as enabling further linkages to be developed.
In its submission to the Foundation, the VRF noted it would also be entering exploratory
merger talks with the CDSB. The VRF also reiterated support, in principle, of merging
organizations for the creation of the SSB. The VRF also specifically stated that it would
not “compete” with the IFRS Foundation, but rather that its initiatives are
“complementary.”
The IFRS Foundation Sustainability Initiative

According to its website, “The IFRS Foundation is a not-for-profit, public interest organi-
zation established to develop a single set of high-quality, understandable, enforceable
and globally accepted accounting standards—IFRS standards—and to promote and facili-
tate adoption of the standards.” These accounting standards are set by the IASB, which is
in turn overseen by the Foundation. IFRS standards are currently required for use in more
than 140 jurisdictions and are permitted in many more. In its 2020 Annual Report, Erkki
Likanen, the Foundation’s chair, made mention of the extensive effort in 2020 spent pre-
paring for the Foundation’s five-year strategy review (IFRS 2021a). Notably, he men-
tioned how discussions with key stakeholders highlighted the need to accelerate progress
in the area of sustainability reporting. This progress culminated during the year with the
release in September 2020 of the Consultation Paper on Sustainability Reporting.
Responses to the Consultation Paper were due by December 31, 2020.
The Consultation Paper (IFRS 2020) noted the increasing importance of sustainabil-
ity reporting to a broad range of stakeholders, including investors, preparers, central
banks, regulators, public policy makers, and auditing firms. It also highlighted the grow-
ing and urgent need to improve the consistency and comparability in sustainability
reporting. The Consultation Paper also referenced the many organizations which cur-
rently provide sustainability reporting guidance. Noting that while some of this work
overlaps, each standard setter was seen as producing products for its own stakeholders,
ranging from investors to broader society. As a result, preparers are faced with using
multiple standards, frameworks, and metrics. This can result in limited effectiveness and
impact, high complexity, and increasing costs. The paper spoke of a “supply side in
transition,” including efforts of standard setters to coordinate their work to build a shared
vision. Some countries and regions, such as the European Union (EU), were noted as
undertaking initiatives that complement the private sector initiatives. Overall, however,
concern was expressed that diverse approaches and objectives pose the threat of
increased global fragmentation in sustainability reporting.
To reduce this fragmentation and hence advance toward greater reporting consistency
and comparability, the Foundation proposed the creation of the SSB, which would set
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

global sustainability reporting standards.26 The Foundation would oversee the SSB in the
same way it presently oversees the work of the IASB in setting accounting standards.
The Foundation would use its existing standard-setting expertise and due process proce-
dures to help legitimate global sustainability standards by ensuring broad consultation
and accountability. It would also use a similar three-tier governance structure to that used
in developing its accounting standards, consisting of an independent standard-setting
board of experts, governed and overseen by a global set of trustees and accountable to a
monitoring board consisting of public authorities. The paper also alluded to the synergies
that could be achieved by having both boards—sustainability and financial—operate
within a single organization.
In the paper, the Foundation acknowledged that its success as the global sustainability
standard setter would require working with existing sustainability standard setters and
regional initiatives, achieving support from global regulators, ensuring appropriate technical
expertise of the Trustees, SSB members, and staff, and obtaining the necessary financial
support such that the current mission and resources of the Foundation are not com-
promised. Specifically, the paper sought responses to 11 questions, the first two arguably
of greatest import: (i) Is there a need for a global set of internationally recognized sustain-
ability reporting standards? and (ii) Is the development of an SSB by the Foundation an
appropriate approach to further consistency and global comparability in sustainability
reporting? Additional questions explored whether a “climate first” approach should be
adopted, a remit to be later extended to capture broader sustainability issues, such as social
and other related matters. Responses were also sought whether to initially adopt a single
materiality (outside in) focus, followed later by double materiality (inside out) as well as
the need for sustainability information to be subject to external assurance, such as an audit.
The Foundation received 577 responses to its Consultation Paper. These are analyzed
in significant detail in sections 5 and 6. In a press release and feedback statement from
the IFRS Foundation trustees, the following conclusions were drawn based on the
responses: there is an urgent need for global sustainability reporting standards; the Foun-
dation should play a significant role in the development of the global standards; the stan-
dards should be aimed at investors and should utilize an enterprise value lens; the
standards should prioritize climate while working to incorporate other ESG matters; the
standards should build on existing frameworks—notably, the TCFD, SASB, and IIRC;
and the standards should use a building-block approach, consisting of a base set of stan-
dards with flexibility to adapt to local circumstances (IFRS 2021b, 2021c).
Recent Developments
To move forward on its sustainability reporting mandate, in April 2021 the Foundation
published a 42-page exposure draft (ED) that outlined proposed targeted amendments to
the IFRS Foundation Constitution to accommodate the ISSB, which would set global
26. The Consultation Paper mentioned three high-level options the Foundation could consider:
maintaining the status quo of no formal involvement, working to facilitate existing market initiatives,
or creating the SSB as the standard setter (identified as the best option within the paper) (IFRS 2020).
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

sustainability standards (IFRS 2021d). The proposed amendments were exposed for com-
ment until July 29, 2021. As of August 31, 2021, there were 175 responses.27 Although
neither these respondents nor their specific comments on the IFRS Foundation constitu-
tional changes are the focus of this research, a review of the responses showed significant
overall support for the technical changes required to create the ISSB.28 Subsequently,
and as part of the 2021 UN COP26 conference on climate change held in Glasgow from
October 31 to November 12, 2021,29 the IFRS Foundation formally announced the for-
mation of the ISSB.30 The Foundation’s announcement also noted the commitment of the
VRF and CDSB to consolidate with the ISSB, and of the publications of prototype cli-
mate and general disclosure requirements. The Foundation also released in November
2021 its revised Constitution formally incorporating the ISSB as part of its operations
(IFRS 2021e).
3. ADDITIONAL BACKGROUND INFORMATION
Standard-Setting Due Process

The Foundation’s release and request for comments on their Consultation Paper on Sus-
tainability Reporting follows a well-established consultative due process system used by
accounting standard setters (Tandy and Wilburn 1996; Larson 2007; Durocher
et al. 2007; Rey et al. 2020). Jorissen et al. (2013) stress that nongovernmental standard
setters require “input legitimacy.” This input legitimacy can only be achieved if all rele-
vant stakeholders have a say in the standard-setting process (Jorissen et al. 2013). The
requirement of broad stakeholder input in the accounting standard-setting process is
long-standing and prevalent in academic literature (Johnson and Solomons 1984;
Dyckman 1988; Wallace 1990; Tandy and Wilburn 1992; Larson 2007; Richardson and
Eberlein 2011; Jorissen et al. 2013). Richardson and Eberlein (2011) contend interna-
tional standard setters face even greater hurdles to legitimacy than single-nation entities.
Single-nation standard setters, such as the FASB in the United States, are ultimately
under the purview of the domestic government (Richardson and Eberlein 2011).31 An
international standard setter such as the IASB does not have this final arbiter and there-
fore is entirely subject to voluntary participation at the nation-state level (Richardson and
Eberlein 2011). The Foundation, as overseers of the IASB, would be fully aware of the
need for participatory input legitimacy in the establishment of an SSB and the develop-
ment of a set of global sustainability standards.
27. Two of these responses were received subsequent to the due date but are included in the list of respon-
dents at the IFRS website.
28. Of the responses, 14 of 175 (8%) were from Canada. This proportion is similar to the Consultation
Paper (see Table 1). Of the 14 responses, 12 had responded to the Consultation Paper. There was no
notable opposition to the constitutional changes in any of the 14 responses.
29. The conference website is https://ukcop26.org/.
30. https://www.ifrs.org/news-and-events/news/2021/11/ifrs-foundation-announces-issb-consolidation-
with-cdsb-vrf-publication-of-prototypes/
31. While currently independent, the FASB could be rendered no longer the official standard setter for US
GAAP by an act of Congress, similar to the establishment of the PCAOB by the Sarbanes-Oxley Act.
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

One method to legitimize a private standard-setting body is to focus on the entity’s

independence, experience, and technical expertise, which the Foundation arguably does
in the Consultation Paper. This method, however, only goes so far and falls short of the
input legitimacy stressed as a requirement in Jorissen et al. (2013). Accounting standard
setters have consequently adopted a system of proposal (discussion or consultation papers
followed by exposure or proposal drafts) and feedback from stakeholders in the form of
comment letters.
Comment Letters in Due Process

While comment letters are only one piece of the due process system used by accounting
standard setters (Kwok and Sharp 2005; Durocher et al. 2007; Larson 2007), the partici-
patory feedback provided by the comment letters is viewed as an important step in earn-
ing legitimacy (Larson 2007; Orens et al. 2011; Richardson and Eberlein 2011; Jorissen
et al. 2013; Larson and Herz 2013).
Much of the research into comment letters as a sign of standard-setting due process
focuses on the participants in the comment letter process. Through a setting of standards
lens, the diversity of the categories of respondents is viewed as a more inclusive form of
due process. Research in this area finds financial statement preparers are the most com-
mon participants (Tandy and Wilburn 1996; Durocher et al. 2007; Durocher and For-
tin 2011; Jorissen et al. 2012).
Many of these studies focus on the motivations of respondents in choosing to write a
comment letter. From a preparer perspective, Schalow (1995) finds that preparers are
more likely to write a comment letter if they represent a larger firm, if the proposed stan-
dard will have a greater impact on their company’s financial statements, and if they
oppose the proposed standard. Orens et al. (2011) find that in an international setting,
preparers with a tradition of private versus governmental standard setting are more likely
to write comment letters. The preparers from the governmental standard-setting tradition
are more likely to express their opinions to their auditors rather than the standard-setting
body. Jorissen et al. (2012) find preparers write more letters when the proposed standards
will have a greater impact on their financial statements and are more likely to write letters
later in the process during the ED phase. Tandy and Wilburn (1996) investigate academic
participation, finding that academics are more likely to write a comment letter if they are
interested in the topic or have conducted research in the area of the proposed standard.
Additionally, academics are more likely to write a comment letter if the proposed stan-
dard is in a substantial rather than narrow area and they feel they have valuable infor-
mation or opinions to influence the standard setter’s process (Tandy and Wilburn
1996). User participation in the comment letter process is documented as low in prior
research (Weetman et al. 1996; Durocher et al. 2007). However, users are more likely
to write comment letters when the proposed standards are related to disclosure (Jorissen
et al. 2012). Durocher and Fortin (2011) study the motivations behind accounting prac-
titioners participating in the comment letter system. They find that practitioners are
more likely to write comment letters if they possess a strong personal interest to
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

participate in the standard-setting process along with a belief of being able to partici-
pate adequately.
Through a legitimacy of an international standard setter lens, prior research focuses
on the geographic diversity of comment letters in addition to the diversity of the
respondent classifications. Larson (2007) finds a preponderance of the comment letters
written to the IASB in connection with the International Financial Reporting Interpreta-
tions Committee were written by entities with IFRS reporting requirements. In a pair of
interrelated studies, Jorissen et al. (2012, 2013) investigate the diversity of respondents
by both classification and geography. Jorissen et al. (2012) focus on respondents by
classification, finding that preparers are the largest respondent group, with accounting
practitioners and other standard-setting bodies making up the next two largest groups.
Jorissen et al. (2013) focus on the geographical diversity of comment letter participants
over a 12-year period. They find an increase in geographic diversity of comment letters
over time, indicating more widespread participation in the standard-setting process.
However, this participation is influenced by institutional differences within the respon-
dents’ home nations. Nations with strong enforcement of investor protection laws have
higher rates of participation through the comment letter system. In addition, countries
with a tradition of nongovernmental accounting standard-setting processes, use and
knowledge of the English language, and knowledge and use of the traditional account-
ing values of transparency and professional judgment are also associated with more par-
ticipation in the comment letter system.
Lobbying Accounting Standard Setters

The comment letter system is intended to provide stakeholders with an ability to influ-
ence the development of accounting standards (Tandy and Wilburn 1996). These com-
ment letters expressing the respondents’ point of view are a form of lobbying intended to
influence the resultant standard (Larson 1997; Georgiou 2004). Therefore, comment let-
ters are a way to measure not only the legitimacy of a standard setter but also the lobby-
ing activity of the respondents.
Much of the research into lobbying of accounting standard setters stems from an
observation by Zeff (1978) of the financial ramifications of accounting standards and
Sutton’s (1984) definition of lobbying as the efforts of stakeholders to impact standard
setters’ decision-making (Rey et al. 2020). The accounting lobbying literature can be
classified into two separate streams: (i) What are lobbying activities, and why do partic-
ipants engage in lobbying of standard setters? and (ii) What impact on standard setting
do lobbying efforts have (Stenka and Ta 2010; Rey et al. 2020)? Much of the first cate-
gory stems from the findings of Watts and Zimmerman (1978, 1979, 1990). These stud-
ies find that entities engage in lobbying accounting standard setters because they
believe there are financial gains from influencing the standard-setting process (Rey
et al. 2020). Kwok and Sharp (2005), Hansen (2011), and Rey et al. (2020) examine
characteristics of the successful lobbyist. Kwok and Sharp (2005) find that changes
made to proposed standards seem to be most influenced by the comment letters and
desires of preparers. Hansen (2011) finds that higher-quality comment letters and the
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)
apparent credibility of the information provided in the letters have some influence on
the standard-setting process. Hansen (2011) also finds that the size of a lobbyist’s finan-
cial contribution to the standard setter and the relative size of the financial market in
the home nation of the lobbyist provide influence in the standard-setting process. Rey
et al. (2020) find that successful lobbyists come from countries with a standard-setting
board member. They also find, in line with the findings from Hansen (2011), that finan-
cial contribution to the standard setter provides influence over the standard-setting pro-
cess and that stricter enforcement of investor protections also provides some influence
over the standard-setting process.
Sustainability Reporting Standards

There are contrasting views on the extent of required disclosure in sustainability reporting
standards. This contrast focuses on whether a firm should disclose only sustainability
issues that have a financial impact on its own net assets or whether it should also be
required to report the firm’s greater impact on overall global sustainability. Christensen
et al. (2021) refer to these as the “narrow” and “broad” approaches; the extant sustain-
ability vernacular uses the terms “single” and “double” materiality.
Proponents of single materiality appear to view sustainability reporting standards as
equivalent to financial reporting standards in terms of intended audience and general pur-
pose. Focusing sustainability reporting standards on the sustainability issues that have
direct financial impacts on the firm provides useful information to investors and potential
investors. Limiting sustainability reporting standards to the financial impacts on the firm
can result in a situation where the sustainability reporting standards actually do not
require any disclosure beyond what is already included in financial reporting standards
(Christensen et al. 2021).
On the other hand, proponents of double materiality appear to view sustainability
reporting standards as relevant and important to a range of stakeholders well beyond the
scope of investor-based financial reporting standards. Requiring firms to disclose their
impacts on the sustainability of the planet provides useful information to all impacted
stakeholders, including investors. Under this view, sustainability reporting is not an
extension of or supplemental to financial reporting, but rather is a completely different
form of reporting with different users and objectives (CDP et al. 2020a). If sustainability
reporting is a different form of reporting from financial reporting, there is little to no
chance that sustainability reporting standards would not require disclosure beyond what
is already included in financial reporting standards.
In their “Statement of Intent to Work Together Towards Comprehensive Corporate
Reporting” (CDP et al. 2020a), the Five clearly define their perspective on single and
double materiality and how these concepts relate to sustainability reporting and sustain-
ability reporting standards. Single materiality disclosure is intended for the set of
reporting users whose main purpose is making investment decisions (CDP et al. 2020a),
whereas double materiality disclosure is intended for the full spectrum of potential stake-
holder users and is a defining characteristic of sustainability reporting (CDP
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

et al. 2020a). These five organizations view the reporting environment as a nested model.
Current and future “financial” reporting is the innermost set of reporting requirements.
Single materiality sustainability reporting of information “material for the enterprise
value creation” of the firm, and not required by financial reporting standards, is the next
set of reporting. Finally, double materiality sustainability reporting of information on the
firm’s “significant impacts on the economy, environment, and people” is the outer layer
of reporting (CDP et al. 2020a). Under the nested reporting model proposed by the Five,
any set of sustainability reporting standards would require double materiality disclosure.
The European Commission (EC) is moving toward developing a set of sustainability
reporting standards similar in concept to those proposed by the Five (EC 2021). In 2014,
the EC adopted the Non-Financial Reporting Directive (NFRD), requiring large public-
interest companies to disclose some sustainability reporting on certain topics
(EC 2021).32 In 2021, the EC amended the NFRD and renamed it the Corporate Sustain-
ability Reporting Directive (CSRD), extending the requirements to all large companies
and all companies listed on regulated stock exchanges (EC 2021). The CSRD requires
the development of a set of EU sustainability reporting standards by the European Finan-
cial Reporting Advisory Group (EFRAG) (EC 2021). It will also require that the dis-
closed information be audited. In February 2021, the European Reporting Lab of
EFRAG released a set of proposals for EU sustainability reporting standard setting
(EFRAG 2021). This proposal clearly states that EU sustainability reporting standards
should require double materiality and be founded on a reporting nesting concept similar
to the one outlined by the Five (EFRAG 2021). Required disclosure should include sus-
tainability information impactful to the firm’s value creation and the firm’s sustainability
impacts on a broad set of stakeholders (EFRAG 2021).
Contrasting with the Five and the EC, the IFRS Foundation is proposing to create a
sustainability standard-setting board whose focus will be on serving investor information
needs based upon single materiality. In addition, the Foundation’s proposal will initially
focus on environmental and climate-related disclosures. Combined, this will lead to sig-
nificantly narrower information than a requirement using double materiality and incorpo-
rating such measures as social and governance.
4. RESEARCH DESIGN
The IFRS Foundation received 577 responses to their Consultation Paper. These
responses are archived on the IFRS website.33 The responses ranged from a curt “polluter
pays”34 through to detailed responses from all the major sustainability reporting standard
setters. In our study each response was profiled in terms of the respondent and the
response. The respondent profile was divided into geographic location and interest group.
32. The initial topics included environmental matters, social matters and treatment of employees, respect
for human rights, anticorruption and bribery, and diversity on company boards of directors (EC 2021).
33. https://www.ifrs.org/projects/work-plan/sustainability-reporting/consultation-paper-and-comment-
letters/#view-the-comment-letters
34. Response #566
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

The response profile focused on answers to the first two questions proposed in the Con-
sultation Paper. This question concentration follows prior research on comment letter
content analysis (Rey et al. 2020). To ensure the reliability of the profiling, each response
letter was independently read by at least three individuals, including at least one author
and two research assistants. Any differences were resolved through debate, discussion,
and reanalysis.
To assign a geographic location, we searched the response for locational clues such
as letterhead addresses and respondent titles. Website information searches were also
commonly used. Although most location categorizations were reasonably objective, a
few judgment calls were made. For example, the response from KPMG,35 while con-
taining a UK address on the letterhead, was assigned as International as the response was
judged to reflect the worldwide views of the firm.36 The response from BlackRock,37
while from an investment manager claiming to have a “worldwide” client base, was
assigned to the United States due to BlackRock’s decision-making being highly central-
ized in its New York Office. The response from a group of academics at the Nyenrode
Business Universiteit,38 a university located in the Netherlands, was assigned as Europe
and not the Netherlands, based on the following comment: “Worthwhile mentioning is,
that we take a European (EU) perspective” (p. 1). Where a geographic location could not
be clearly determined, the response was categorized as unassigned. There were 77 of
these. The unassigned responses were all from individuals who provided no additional
identifying information beyond their name.
Appendix 2 presents, in alphabetical order, the 10 interest group categories used in
the study. Some overlap exists with interest groups identified in other comment letter
studies. For example, in their study on comment letters to IFRS 16, Rey et al. (2020)
identified 8 categories, similar to ours, including the accounting profession, individuals,
preparers, and users. Giner and Arce (2012) in their comment letter study on share-based
payments had 6 categories, again similar to ours, including academics, preparers, and
users. Unique to our sustainability initiative comment letter study are the categories “sus-
tainability advocacy and consulting” and “sustainability reporting standard setters.”
Appendix 2 shows, for each interest group, the categorization guidance we used. It also
provides the names of example respondents within that interest group. Canadian exam-
ples are in bold type.
We concentrate our analysis of the responses on the two main questions being asked
in the Consultation Paper: about the need for globalized sustainability reporting standards
and the creation of the SSB under the IFRS Foundation. We focus on these questions
because the remaining nine questions are of less usefulness to the Foundation if there is
no need for a single set of standards and if the standard setter is not overseen by the
Foundation. Furthermore, alignment of the entire response set with Canadians on these
35. Response #152

36. This is consistent with the classification by Hansen (2011) and Jorissen et al. (2013).
37. Response #390
38. Response #497
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

two questions would provide support for Canada as the proposed SSB host, especially if
the Canadian set of respondents includes influential supportive institutional representa-
tives. For each question, the response was categorized as either in favor, opposed, or
unclear. The unclear responses included situations where the narrative included commen-
tary both supportive of and opposed to globalized standards or to the creation of the SSB
and provided no clear conclusion. It also included responses where the respondent did
not address the specific question.39
Unique to our study was the existence of a chain letter submitted by 102 of the
577 respondents. While the wording in the chain letters was often slightly different, the
basic structure and messaging across all the letters remained consistent. Appendix 3 pro-
vides an example of a chain letter. This particular response was submitted by two British
Members of Parliament, Caroline Lucas (Green Party) and Clive Lewis (Labour Party),
who are also the joint chairs of the All-Party Parliamentary Group on the Green New
Deal.40 Consistent across the chain letters, concerns are expressed that sustainability
reporting is being produced solely for the financial community and not for all stake-
holders. A call is also made in the letters for integrating sustainability reporting into
mainstream financial reporting. This integration, it is believed, would help ensure that
sustainability reporting is not seen as “peripheral” and would reduce the possibility of
“greenwashing.” The chain letters oppose a separate SSB. The letters also implore the
Foundation to “seize the opportunity to make this the biggest issue in accounting for
decades to come.” Overall, the chain letters constitute 17.7% (102/577) of the responses
received by the Foundation. The seriousness with which they were taken by the Founda-
tion is unclear.41 Of the chain letters, 35 were traceable to the United Kingdom, likely
the letter’s point of origin. Single letters were also traced to Australia, Colombia,
Germany, and New Zealand. The remaining 63 letters could not be traced to a specific
location. All but 2 of the 102 letters were submitted by individuals, with the 2 others
being submitted by academics.
5. PROFILING THE RESPONDENTS
The Respondents: Full Set

Table 1 presents the geographic classification of the responses to the Consultation Paper.
The presentation is made in two ways: first, the 500 responses for which a respondent
location was clearly determinable, and second, the 461 responses for which a respondent
location was clearly determinable, excluding all the chain letters. It is this second group
of comment letters which serves as the basis of the commentary below.
39. As an example, response #160, from the CPAB, restricts its discussion to Consultation Paper Ques-
tions 1 and 10.
40. According to www.parliament.uk, the purpose of the group is to provide a cross-party platform for the
development of a transformative Green New Deal for the United Kingdom.
41. No mention was made of the chain letters in the April 2021 IFRS Foundation Feedback Statement.
Only a small number of the chain letters were submitted by recognizable (and confidently traceable)
individuals, such as the British MPs.
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

TABLE 1
Responses by geographic location
Clearly traceable and

Clearly traceable (n = 500)a remove chain (n = 461)b
Location Number % of total Number % of total
United Kingdom 100 20.0 65 14.1
International 73 14.6 73 15.8
Canada 38 7.6 38 8.2
United States 35 7.0 35 7.6
Europe 25 5.0 25 5.4
Australia 23 4.6 22 4.8
Brazil 18 3.6 18 3.9
Germany 18 3.6 17 3.7
South Africa 15 3.0 15 3.3
Netherlands 14 2.8 14 3.0
France 12 2.4 12 2.6
Hong Kong 11 2.2 11 2.4
New Zealand 9 1.8 8 1.7
Italy 8 1.6 8 1.7
Japan 8 1.6 8 1.7
Malaysia 6 1.2 6 1.3
Spain 6 1.2 6 1.3
Switzerland 6 1.2 6 1.3
Colombia 5 1.0 4 0.9
Nigeria 5 1.0 5 1.1
Sweden 5 1.0 5 1.1
Asia 4 0.8 4 0.9
Ireland 4 0.8 4 0.9
South Korea 4 0.8 4 0.9
China 3 0.6 3 0.7
India 3 0.6 3 0.7
Turkey 3 0.6 3 0.7
Africa 2 0.4 2 0.4
Argentina 2 0.4 2 0.4
Austria 2 0.4 2 0.4
Chile 2 0.4 2 0.4
Finland 2 0.4 2 0.4
Norway 2 0.4 2 0.4
Poland 2 0.4 2 0.4
Romania 2 0.4 2 0.4
Russia 2 0.4 2 0.4
Singapore 2 0.4 2 0.4
Uganda 2 0.4 2 0.4
Belgium 1 0.2 1 0.2
Botswana 1 0.2 1 0.2
(The table is continued on the next page.)
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

TABLE 1 (continued)
Clearly traceable and

Clearly traceable (n = 500)a remove chain (n = 461)b
Location Number % of total Number % of total
Denmark 1 0.2 1 0.2
France and Spain 1 0.2 1 0.2
Indonesia 1 0.2 1 0.2
Iran 1 0.2 1 0.2
Kenya 1 0.2 1 0.2
Latin America 1 0.2 1 0.2
Mexico 1 0.2 1 0.2
New Zealand and 1 0.2 1 0.2
Australia
Norway, Sweden, 1 0.2 1 0.2
Iceland,
Denmark, and
Finland
Portugal 1 0.2 1 0.2
Saudi Arabia 1 0.2 1 0.2
Taiwan 1 0.2 1 0.2
Tanzania 1 0.2 1 0.2
United Kingdom 1 0.2 1 0.2
and Australia
United Arab 1 0.2 1 0.2
Emirates
Total 500 100 461 100
Notes: aOf the 577 total responses, 77 were not clearly traceable to a specific geographic location: n =
(577 – 77) = 500. bThere were 102 chain letters. Of these, 63 were not clearly traceable: n = (577 – 77 –
102 + 63) = 461.
The highest percentage of responses was categorized as International, accounting

for 15.8% (73 of 461). In terms of individual countries, the highest number of
responses came from the United Kingdom at 14.1% of responses (65 of 461). The next
highest was Canada at 8.2% (38). Other countries having at least 10 respondents
included the United States at 7.6% (35), Australia at 4.8% (22), Brazil at 3.9% (18),
Germany at 3.7% (17), South Africa at 3.3% (15), the Netherlands at 3.0% (14), France
at 2.6% (12), and Hong Kong at 2.4% (11). At least 1 response was received from
46 different countries.
These geographic response rates are generally comparable to the comment letter
study on lease accounting standard changes by Rey et al. (2020), although there are
some notable differences.42 Of the 734 responses received directly by the IASB on
42. The lease accounting changes, envisaged by both the IASB and FASB, were going to have a global
reporting impact—hence the relevance of the comparison to the sustainability initiative.
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

its proposed changes,43 at least 1 response was received from 44 different countries,
similar to 46 on the IFRS’s sustainability initiative. Also, similar to our findings, the
largest percentage of responses came from the United Kingdom at 21.4%, followed
by the United States, Australia, and Canada. In contrast to our findings, Rey
et al. (2020) classify 3.4% of responses as International, whereas International is the
highest response rate (15.8%) for the comment letters to the Consultation Paper.
This significantly higher international rate in our study is attributable to the large
number of global organizations (e.g., World Business Council for Sustainable
Development, UN Principles for Responsible Investment, International Corporate
Governance Network) concerned with global sustainability issues such as climate
change.44
We categorize some responses by geographic region. The most common are clas-
sified as European45 at 5.41% of all responses. A smaller number of regional
responses were also received from Asia (4, 0.87%), Africa (2, 0.43%), Latin America
(1, 0.22%), and the Nordic region (1, 0.22%). We are able to further classify the
responses geographically into International and six areas of the world.46 The greatest
number of responses come from Europe (38.7%), followed by International (15.8%),
North America (15.8%), Asia (11.47%), Australia and New Zealand (6.82%), Latin
America (6.06%), and Africa (5.85%).
Table 2 shows the respondents by interest group. This table is also presented in two
ways. The first shows all 577 responses. The second set removes the geographically
unassigned and chain letter responses. Of the full set of 577 responses, the highest per-
centage came from individuals (25.48%), at just over one-quarter of total responses. After
excluding the geographically unassigned and chain letters, the percentage of individual
responses decreases drastically to 7.16%. The second set of 461 responses is the basis of
the commentary below.
The user community submitted the highest number of responses at 24.5% (113 of
461), nearly 1 out of 4. The sustainability advocacy and consulting group (14.1%, 65)
and the accounting profession (13.2%, 61) interest groups submitted the next highest
number of responses, followed by academia (12.2%, 56) and the preparer community
(8.5%, 39). The remainder of the responses came from individuals (7.2%, 33), financial
reporting standard setters (6.3%, 29), government (5.9%, 27), sustainability reporting
standard setters (5.0%, 23), and exchanges and financial market regulators (3.3%, 15).
43. Rey et al. (2020) analyzed the total responses received on the original discussion paper and two subse-
quent EDs. Responses were made either directly to the IASB or FASB or jointly to the IASB
and FASB.
44. Responses #69, 116, and 187
45. Rey et al. (2020) find a similar number (28) of European responses, categorized as Pan-European
Organizations. There are no other regional categorized responses in their study.
46. We follow the same world areas used in Rey et al. (2020): Europe; Australia and New Zealand; North
America (Bermuda, Canada, and the United States); Asia; Latin America (South America, Mexico,
and Jamaica); and Africa.
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

TABLE 2
Responses by interest group
Remove chain letter and

Total responses (n = 577) unassigned (n = 461)
Interest group Number % of total Number % of total

IND 147 25.5 33 7.2
USER 113 19.6 113 24.5
SAC 65 11.3 65 14.1
AP 61 10.6 61 13.2
ACAD 58 10.1 56 12.2
PREP 39 6.8 39 8.5
FRSS 29 5.0 29 6.3
GOVT 27 4.7 27 5.9
SRSS 23 4.0 23 5.0
EFMR 15 2.6 15 3.3
Total 577 100 461 100
Notes: In this table, the column totals do not equal exactly 100% due to rounding. The abbreviations for each
interest group are used in subsequent tables: IND = individuals, USER = users, SAC = sustainability advo-
cacy and consulting, AP = accounting profession, ACAD = academia, PREP = preparers, FRSS = financial
reporting standard setters, GOVT = government, SRSS = sustainability reporting standard setters, and
EFMR = exchanges and financial market regulators. See Appendix 2 for definitions of interest groups.
In comparison to the interest group response rates from prior research on comment letters,
a number of differences stand out. First is the high response rate from the user community to
the Consultation Paper. Prior research finds low user participation in the comment letter pro-
cess (Weetman et al. 1996; Durocher et al. 2007; Rey et al. 2020), which is very different
from the 24.5% of responses coming from users to the Consultation Paper. This significantly
higher rate is likely attributable to the challenge users currently experience in coping with mul-
tiple sustainability reporting frameworks and their desire for a global set of sustainability
reporting standards.47 A second difference is the relatively low preparer response rate. Prior
research finds preparers to be the most numerous respondents (Tandy and Wilburn 1996;
Durocher et al. 2007; Durocher and Fortin 2011; Jorissen et al. 2012; Rey et al. 2020). Prior
comment letter studies mostly focus on accounting standard changes that would directly
impact the financial statements. The Consultation Paper does not propose any changes to the
financial statements, and hence preparers may be less inclined to respond. Another contrast of
note is the 12.2% response rate from academia, which is higher than what is documented in
other studies (Tandy and Wilburn 1996; Rey et al. 2020). This result is likely driven by the
large number of professors and students engaged in sustainability research having the expertise
and interest sufficient to respond, which is consistent with prior findings for why academics
are more likely to write comment letters (Tandy and Wilburn 1996).
47. However, a higher participation rate on issues related to disclosure is consistent with prior research
(Jorissen et al. 2012). Even with an expected higher rate of user participation, the almost one-quarter
of responses coming from users is significantly different from prior research on comment letters.
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

Our next two analyses combine geographic location and interest group using the
461 responses remaining after removing the chain letters and the geographically
unassigned responses. Table 3 presents the percentage of responses in each geographic
region from each interest group (e.g., number of international user responses/total number
of international responses). Table 4 presents the percentage of responses from each inter-
est group for each geographic region (e.g., number of international user responses/total
number of user responses).
Our commentary on Table 3 primarily focuses on individual countries providing
more than 10 total responses. The highest within-country proportional response is from
French users at 41.7%. US and Canadian users also account for a high proportion of their
country’s responses: 40% and 36.8%, respectively, compared to the overall 24.3% user
response rate. Within the preparer group, Germany has the highest response rate at
29.4%, followed closely by the Netherlands at 28.6%. Canada’s preparer response rate is
7.9%, comparable to the overall rate of 8.5%. The lowest preparer response rate (2.9%)
is in the United States. Hong Kong has the highest percentage of responses from the sus-
tainability advocacy and consulting group (27.3%), followed by the United Kingdom
(26.2%) and the United States (25.7%). Canada’s sustainability advocacy and consulting
response rate of 5.3% is lower than the overall rate of 14.1%, while no French responses
were received from this group. The highest academia response rate was seen in Brazil, at
27.8%, with Australia a close second, at 27.3%. Compared to the overall rate of 12.1%,
Canada’s academia response rate of 7.9% is low. Canada has the highest response rate
from government at 18.4%, compared to an overall rate of 6.1%.48 It is also notable
(refer to the final row in the table) that responses from the accounting profession were
received from 35 of the 55 geographical locations. This is the highest total number of
geographic locations for any interest group. Conversely, only 9 of the 55 geographical
locations provided responses from sustainability reporting standard setters or exchanges
and financial market regulators. No responses were received from financial reporting
standard setters from 35 geographic locations, including the United States, Brazil,
Germany, and Japan.49 Financial reporting standard setters comprise 10.5% of Canadian
responses.
Table 4 shows the largest proportion of the user responses (19.5%) come from
International users. Over half (57.6%) of all user responses to the Consultation Paper
are International, UK, Canada, and US based. The United Kingdom provided the larg-
est proportion (26.2%) of the responses from the sustainability advocacy and consult-
ing interest group. The United Kingdom, International, and the United States account
for over half (56.9%) of responses from sustainability advocacy and consulting. In
contrast, Canada provides only 3.1% of sustainability advocacy and consulting
responses. The International classification provides 23.0% of the responses from the
accounting profession, far exceeding the next highest, from the United Kingdom, at
8.2%. Canada’s accounting profession provided 3.3% of the responses. Over one-
48. As noted later in the analysis, this Canadian rate was largely attributable to responses from a number
of auditors general.
49. Japan’s results are included with “Other.”
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

TABLE 3
Within each geographic location, which interest group responded? (n = 461)
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11)
Location Total USER (%) SAC (%) AP (%) ACAD (%) PREP (%) IND (%) FRSS (%) GOVT (%) SRSS (%) EFMR (%)
International 73 28.8 15.1 19.2 4.1 4.1 0 0 6.8 17.8 4.1
United Kingdom 65 24.6 26.2 7.7 23.1 6.2 7.7 0 1.5 0 3.1
Canada 38 36.8 5.3 5.3 7.9 7.9 5.3 10.5 18.4 0 2.6
United States 35 40.0 25.7 5.7 14.3 2.9 11.4 0 0 0 0
Europe 25 32.0 16.0 8.0 4.0 16.0 0 4.0 8.0 0 12.0
Australia 22 9.1 22.7 4.5 27.3 4.5 18.2 4.5 4.5 4.5 0
Brazil 18 11.1 11.1 0 27.8 11.1 5.6 16.7 0 11.1 5.6
Germany 17 29.4 5.9 5.9 5.9 29.4 5.9 11.8 0 5.9 0
South Africa 15 6.7 13.3 20.0 0 6.7 20.0 6.7 6.7 13.3 6.7
Netherlands 14 21.4 14.3 7.1 0 28.6 0 7.1 14.3 0 7.1
France 12 41.7 0 0 16.7 16.7 8.3 0 16.7 0 0
Hong Kong 11 18.2 27.3 9.1 18.2 18.2 0 0 9.1 0 0
Other 116 17.2 6.0 25.0 11.2 6.0 10.3 13.8 4.3 3.4 2.6
Total 461 24.3 14.1 13.2 12.1 8.5 7.2 6.1 6.1 5.0 3.5
Row count 55 24 17 35 21 18 17 21 13 9 9
Notes: Column (1) is total responses from that geographic location. Columns (2) to (11) are the percentage of total responses from that geographic location
received from that interest group. The total row amounts are based on the 461 total responses (e.g., 36.8% of all Canadian responses were from users). The
highest percentage for each interest group is in bold type, based on a minimum of 11 responses (e.g., of countries providing at least 11 responses, the highest
proportion of user responses (41.7%) came from France). Amounts for Canada are in italics. The “Other” row contains the results from 43 additional geographic
locations. The bottom row provides a count of how many of the 55 geographic locations provided a response from that interest group. The row totals may not
equal exactly 100% due to rounding. See Appendix 2 for definitions of interest groups.
GLOBAL SUSTAINABILITY REPORTING STANDARDS
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

25
TABLE 4
26
For each interest group, which geographic location did the responses come from? (n = 461)
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)
USER SAC AP ACAD PREP IND FRSS GOVT SRSS EFMR
(n = 113) (n = 65) (n = 61) (n = 56) (n = 39) (n = 33) (n = 29) (n = 27) (n = 23) (n = 15)
Location (%) (%) (%) (%) (%) (%) (%) (%) (%) (%)
International 19.5 16.9 23.0 5.4 7.7 0 0 18.5 56.5 20.0
United Kingdom 13.3 26.2 8.2 26.8 10.3 15.2 0 3.7 0 13.3
Canada 12.4 3.1 3.3 5.4 7.7 6.1 13.8 25.9 0 6.7
United States 12.4 13.8 3.3 8.9 2.6 12.1 0 0 0 0
Europe 7.1 6.2 3.3 1.8 10.3 0 3.4 7.4 0 20.0
Australia 1.8 7.7 1.6 10.7 2.6 12.1 3.4 3.7 4.3 0
Brazil 1.8 3.1 0 8.9 5.1 3.0 10.3 0 8.7 6.7
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

Germany 4.4 1.5 1.6 1.8 12.8 3.0 6.9 0 4.3 0
South Africa 0.9 3.1 4.9 0 2.6 9.1 3.4 3.7 8.7 6.7
Netherlands 2.7 3.1 1.6 0 10.3 0 3.4 7.4 0 6.7
France 4.4 0 0 3.6 5.1 3.0 0 7.4 0 0
ACCOUNTING PERSPECTIVES / PERSPECTIVES COMPTABLES
Hong Kong 1.8 4.6 1.6 3.6 5.1 0 0 3.7 0 0

Other 17.5 10.7 47.6 33.1 17.8 36.4 55.4 18.6 17.5 19.9
Total 100 100 100 100 100 100 100 100 100 100
Notes: The column headings show the total number of responses from each interest group in the full set of 461 responses. Columns (1) to (10) are the percent-
age of the total responses in each interest group received from that geographic location (e.g., 19.5% of all user responses were categorized as International).
The highest percentage for each interest group is in bold type, based on a minimum of 11 responses (e.g., of countries providing at least 11 responses, the
highest proportion of user responses (19.5%) were International). Amounts for Canada are in italics. The “Other” row contains the results from 43 additional
geographic locations. The column totals may not equal exactly 100% due to rounding. See Appendix 2 for definitions of interest groups.
quarter of all responses from academia (26.8%) came from the United Kingdom,
followed by Australia at 10.7%. Canadian responses made up 5.4% of all academia
responses. Other percentages of note include that 43.7% of all preparer responses
came from four locations: Germany, the United Kingdom, the Netherlands, and
Europe; 41.2% of the individual responses come from either the United Kingdom, the
United States, or Australia; the largest proportion of responses from the financial
reporting standard-setting community (13.8%) and government (25.9%) are from
Canada; over half (56.5%, 13 of 23) of responses from the sustainability reporting
standard setter interest group are International, although a large percentage (43.5%, 10
of 23) come from 8 other geographic locations; and over half (53.3%) of responses
from exchanges and other financial market participants come from three geographic
locations: International, the United Kingdom, and Europe.
To summarize at this point, there is significant global response to the Consultation
Paper, with comment letters received from 46 different countries and five regions. A
large proportion of the responses come from the United Kingdom, Canada, the
United States, and Australia. There was also a significant number received from Interna-
tional and European respondents. Users make up a much larger proportion of respondents
compared with prior research into comment letters, while preparers account for a lower
proportion. Not surprisingly, there are a large number of respondents from the sustain-
ability community, including sustainability advocates and businesses, sustainability stan-
dard setters, and academics with an interest in this topic. Canadian respondents account
for the highest proportion of overall government respondents. This study now turns its
attention toward the 38 Canadian respondents.
The Respondents: Canada in Context

Table 5 presents the full list of Canadian respondents, showing the interest group,
response number, and respondent name. The largest number of responses comes from
users: 14 out of 38 (36.8%), more than one-third. The next most common respondent is
government: 7 of the 38 responses (18.42%). Of the remaining 17 respondents, 4 come
from the financial reporting standard-setting community, 3 each from academia and the
preparer community, 2 each from the accounting profession, individuals, and sustain-
ability advocacy and consulting, and 1 from the financial regulatory community. There
are no Canadian respondents in the sustainability reporting standard-setting interest
group.
We next discuss the Canadian respondents in comparison to the full set of respon-
dents. We begin our analysis with users, preparers, and the accounting profession, which
are the main interest groups directly impacted by financial reporting. Analysis of the
remaining interest groups is then presented. To enhance the analysis, each interest group
is further divided into various categories.50
50. Detailed information on which respondents were placed into each interest group and each category is
available upon request from the authors.
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

TABLE 5
Responses from Canada (n = 38)
Interest group
(number of responses) Response # Name of respondent
USER (14) 377 1832 Asset Management
137 Addenda Capital
136 Alberta Investment Management Corporation
266 Beutel, Goodman & Company
420 British Columbia Investment Management Corporation
108 Caisse de dépôt et placement du Québec
208 Canada Pension Plan Investment Board
133 Canadian Bankers Association
544 CIBC Asset Management
336 Jarislowsky Fraser Global Investment Management
375 NEI Investments
328 OMERS
219 Ontario Teachers’ Pension Plan
94 Public Sector Pension Investment Board
GOVT (7) 139 Auditor General of Québec
494 City of Montréal, City of Vancouver, and City of Toronto
574 Government of Ontario Staff
340 Office of the Auditor General of Alberta
192 Office of the Auditor General of British Columbia
413 Office of the Auditor General of Canada
572 Office of the Auditor General of Ontario
FRSS (4) 131 Accounting Standards Board
95 Auditing and Assurance Standards Oversight Council & Accounting
Standards Oversight Council
88 Auditing and Assurance Standards Board
159 Public Sector Accounting Board
ACAD (3) 510 Kathryn Bewley
453 Charles Cho
387 David Cooper
PREP (3) 107 Canadian Association of Petroleum Producers
215 Cenovus Energy Inc.
466 Suncor Energy
AP (2) 160 Canadian Public Accountability Board
161 Chartered Professional Accountants of Canada
IND (2) 509 Alan Willis
267 Barb Zvan
SAC (2) 46 Canadian Coalition for Good Governance
78 Global Risk Institute
EFMR (1) 158 Canadian Securities Administrators
SRSS (0) — —
Notes: See Appendix 2 for definitions of interest groups.
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

Users
The 113 users were separated into six categories.51 For the full set of responses, the most
common user respondent is associations whose role is to represent or advocate for vari-
ous user groups. These associations provided 45 of the 113 user responses (39.8%). The
next most common respondent is investment firms (31 of 113, 27.4%). Lower numbers
of respondents are pension funds (12), market analysis providers (10), banks (9), and
insurance companies (6).
The largest number of Canadian user respondents is pension funds (7 of 14). Of note
is that these 7 Canadian respondents exceeded the 5 pension fund respondents from the
rest of the world combined.52 Public pension funds represent a major cornerstone of
Canada’s financial system and economy. Combined, the 7 Canadian pension fund respon-
dents, including the Canada Pension Plan Investment Board, represent approximately
$Cdn 1.5 trillion in assets under management. On November 25, 2020, in a joint state-
ment, the CEOs of the eight leading Canadian pension plan investment managers called
on companies to provide consistent and complete ESG information to strengthen invest-
ment decision-making and to better assess and manage their collective ESG risk expo-
sures (BCI 2020). Specifically, the statement called on companies to measure and
disclose their performance on material, industry-relevant ESG factors by adopting the
SASB standards and the TCFD framework. All 7 of the Canadian pension fund respon-
dents were signatories to this joint statement.53
Six of the 14 Canadian user respondents are investment firms, equaling the highest
number in this category with the United Kingdom and United States. The Canadian
respondents include privately owned firms such as Addenda Capital and Beutel Good-
man, along with the bank-owned firms 1832 Asset Management and CIBC Asset Man-
agement (both CIBC) and Jarislowsky Fraser Investment Management (Scotiabank).
With $US 8.7 trillion of assets under management54 a notable US respondent is
BlackRock, whose CEO, Larry Fink, has been a vocal proponent of sustainable investing,
including a recent requirement of its investees to disclose how their business model will
be compatible with a net zero economy. Of note is that BlackRock aligns its sustainabil-
ity reporting with SASB standards and the TCFD framework.
Globally, there are 9 bank respondents (8 different countries and the World Bank
Group), and 6 insurance company respondents (5 different countries and 1 from Asia).
No individual Canadian bank or insurance company responded directly. However, a
Canadian respondent is the Canadian Bankers Association (CBA). The CBA describes
itself as “the voice for more than 60 domestic and foreign banks operating in Canada.”55
51. As with the categorization into interest groups and geographic location, the reliability of the category
coding was enhanced through the use of multiple independent coders.
52. The other pension fund respondents are from the United States (2), the United Kingdom (2), and
New Zealand (1).
53. The only nonrespondent was “HOOPP.”
54. https://www.blackrock.com/corporate/literature/annual-report/blackrock-2020-annual-report.pdf
55. https://cba.ca/cba-today
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

The CBA represents a large group of users (lenders) which is critical to the Canadian
economy, and as a group it is likely the largest employer in the country. The CBA
response is one of 45 association respondents. As a subgroup, associations provide nearly
1 out of every 10 responses (45 of 461; 9.8%) to the Consultation Paper. Association
respondents are from throughout the world, including Asia (1), Europe (6), and Interna-
tional (11), as well as 25 domestic associations from 11 different countries. Associations
representing the banking and insurance industries are common responders, as are repre-
sentatives of the investment industry. Investment industry respondents range from the
Hong Kong Green Finance Association to the Chartered Financial Analysts Institute.
The final user category is market analysis providers, with 9 of the 10 classified as
International due to their global focus. These respondents include well-known global
credit rating agencies such as Moody’s Investor Services, S&P Global, and Fitch Ratings.
Refinitiv, one of the world’s largest providers of financial market data and infrastructure,
and a leading provider of ESG data, analytics, and expertise for investors and corpora-
tions globally, is also a respondent. Other globally recognized providers of ESG research,
ratings, and data respondents include MSCI ESG Research LLC, Moody’s ESG Solu-
tions Group, ISS ESG, and Morningstar Sustainalytics. A notable absence from this mar-
ket analysis subgroup is Bloomberg, especially given that the Bloomberg ESG
Disclosure Score is a prominently used gauge of ESG performance by investment profes-
sionals and is available through the Bloomberg Terminal.56
Preparers
The 39 preparer respondents were separated into four categories. Similar to the full user
set, most respondents from the preparer group are representative associations. There are
respondent associations from 11 different countries, 2 European groups, and 3 Interna-
tional. Overall these associations provide nearly half (19 of 39, 48.7%) of the preparer
responses (40.2%). The next most common respondents are energy firms (9 of
39, 23.1%). Of the 39 responses, durables firms provide 6, while consumable firms pro-
vide 5. The Netherlands and Hong Kong are the only countries with preparer responses
from more than one industry category; both have respondents from energy and durables.
All 5 respondents in the consumables industry are European companies, including 2 from
the United Kingdom—Unilever and Burberry.
Not surprisingly, given the sustainability spotlight under which they operate, all of
the Canadian preparer respondents are from the energy industry. One is the Canadian
Association of Petroleum Producers (CAPP), an energy industry lobby group,57 while 2
others are Cenovus Energy and Suncor Energy, which are both large oil and gas
56. Two Canadian organizations which provide proprietary ESG ratings, but which did not provide a
response, include Corporate Knights (https://www.corporateknights.com/reports/2021-global-100) and
FUNDATA (https://www.fundata.com/ProductsServices/FundataESG.aspx).
57. According to its website (https://www.capp.ca/), CAPP’s member companies produce about 80% of
Canada’s natural gas and oil, contributed $110 billion to Canada’s GDP in 2019, and supported
almost 550,000 jobs across the country.
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

companies. The Netherlands also has 2 energy firm respondents, SBM Offshore and
Shell. There are also 2 European energy firm respondents, RWE and Vattenfall. France,
Hong Kong, and Italy each have 1 energy firm respondent. Oil and Gas UK responds on
behalf of the UK industry. International respondents of note include the Partnership for
Carbon Accounting Financials, a consortium of banks and investors focused on measur-
ing and reporting greenhouse gas emissions, and the International Petroleum Industry
Environmental Conservation Association (IPIECA). The IPIECA develops, shares, and
promotes good practice and knowledge to help the oil and gas industry improve environ-
mental and social performance. Overall, the energy industry makes up a significant num-
ber of preparer respondents from Canada and worldwide. Similar to the Canadian energy
sector, the German chemical industry is represented by both an industry group and an
individual company, BASF.
Accounting Profession
The 61 respondents from the accounting profession were divided into two groups:
(i) accounting providers and (ii) regulatory bodies and representative organizations. The
far larger group of respondents is organizations, which license, regulate, or represent the
interests of professional accountants: 51 of the 61 (83.6%). These include respondents
from 27 individual countries, including Canada. There is 1 joint respondent (Australia
and New Zealand); regional respondents from Africa, Europe, and the Nordic region; and
7 International organization respondents. The largest number of individual country
respondents came from South Africa and the United Kingdom, with 3 each. Countries
with 2 respondents included Canada, Ireland, Malaysia, Nigeria, and Romania. The
European region also has 2 respondents. Notable international organization respondents
include the International Federation of Accountants, which describes itself as the “global
voice of the accountancy profession”; the Chartered Institute of Public Finance and
Accountancy, which identifies itself as “the only such body globally dedicated to public
financial management”; and the Institute of Internal Auditors, which is “the internal audit
profession’s global voice.” The Center for Audit Quality (CAQ) in the United States is a
country-level respondent. The CAQ is a well-known public policy organization that is
affiliated with the American Institute of CPAs and is dedicated to enhancing investor
confidence and public trust in global capital markets. The remaining 10 respondents are
accounting or auditing firms. Seven large international firms responded, including the
Big 4 of Deloitte, KPMG, EY, and PricewaterhouseCoopers. There are also 3 national
firm respondents from Italy, Kenya, and the United Kingdom. No other national firms
responded.
As noted above, both Canadian respondents are from the category of regulatory or
representative organizations. One respondent is the Canadian Public Accountability
Board (CPAB). CPAB provides regulatory oversight of public accounting firms that audit
Canadian reporting issuers. This oversight is primarily achieved by completing assess-
ments of actual firm audits. Given its overall vision to reinforce public confidence in
Canada’s capital markets, the growing interest it was seeing in sustainability reporting
within such markets prompted its response. The other respondent is CPA Canada, which
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

represents more than 220,000 Chartered Professional Accountants. According to its

response, “CPA Canada has long recognized sustainability as a key business issue. Our
activities in this area extend over 25 years and we have a significant portfolio of
resources that encourage a more holistic view of performance.” CPA Canada also over-
sees accounting and auditing standard setting in Canada; these standard-setting organiza-
tions are discussed below as part of the financial reporting standard setters interest group.
Academia
There were 56 respondents from academia. The largest number of respondents, 19 of
56 (33.9%), are either formal sustainability reporting research units or named university
departments. These include responses from European, Asian, and International research
units, as well as respondents from eight different countries; the largest number (5) is from
the United Kingdom. An almost equal number of respondents, 18 of 56 (32.1%), are
individual professors. The largest number, 5 of 18, is from the United Kingdom. Three
well-known Canadian academics (Kathryn Bewley, Charles Cho, and David Cooper)
responded. There are also 8 student respondents, half of whom are from the
United States. Students from France, Poland, and the United Kingdom are also respon-
dents to the Consultation Paper.
Sustainability Advocacy and Consultants

A large number of respondents, and second only to users, are from sustainability advo-
cacy and consulting. The majority of these, 42 of 65, are organizations whose role is to
advocate for increased awareness of sustainability issues, including ESG, in society.
These respondents come from 13 different countries, as well as European and Interna-
tional organizations. Two respondents are from Canada. One is the Canadian Coalition of
Good Governance (CCGG). CCGG represents the interests of Canadian institutional
investors and has as its stated goal to promote good governance practices in Canadian
companies. These practices include responding to the increasing worldwide focus on sus-
tainability. The other is the Global Risk Institute in Financial Services. This advocacy
group for both financial statement preparers and users wrote in response to its stated rec-
ognition of the high demand for ESG and sustainability-related financial risk information
for decision-making. There are also 23 respondents whose role is to provide formal con-
sulting services to businesses on becoming more sustainable. Sustainability consulting
respondents are from nine different countries and International. No respondents in this
category are from Canada.
Financial Reporting Standard Setters

The Consultation Paper, not surprisingly, elicited a number of responses from the “tradi-
tional” financial accounting, reporting, and auditing standard-setting communities. In
total, there are 29 respondents from this interest group. The majority (22 of 29, 76%) are
formal standard setters, while 7 are organizations serving an advocacy role in standard
setting. The formal body respondents are from 15 different countries, with the largest
number from any one country being 4, from Canada. These include the Auditing and
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

Assurance Standards Board, the Accounting Standards Board, and the Public Sector
Accounting Board. There is also a joint submission from the two councils which provide
oversight for these three standard-setting bodies. These 4 Canadian responses are indica-
tive of the importance with which the sustainability reporting issue is viewed in the
Canadian standard-setting community, both in the private and public sectors, along with
the auditing and assurance communities. There are also multiple respondents from the
Brazilian standard-setting community, as well as a joint response from the Australian
accounting, auditing, and oversight bodies. A regional joint respondent is a consortium
of Latin American standard-setting bodies (GLASS), in combination with the academic
accounting community (Inter-American Accounting Association). The South African
respondent, similar to the Canadian PSAB, is an organization responsible for setting
accounting standards in the public sector. Of note is that the FASB, one of the world’s
most high-profile accounting standard-setting bodies, did not respond to the Consultation
Paper. Finally, within this interest group, respondents from six different countries and
Europe are bodies tasked with providing input into new standards, including, for exam-
ple, the Danish EFRAG mandate.
Government
Of the respondents, 27 are formal bodies operating in the public sector. Of these, 6 are
auditors’ general offices, including 5 from Canada, and 1 from New Zealand. The 5
Canadian respondents include 1 each from Canada’s four largest provinces (Alberta, Brit-
ish Columbia, Ontario, and Québec) and the Office of the Auditor General of Canada.
These latter responses highlight how sustainability reporting in Canada has significant
import beyond the private sector and into the broader realm of public accountability.
There are also 10 respondents whose organizations play a broader role in the economy.
These roles could include managing monetary policy, protecting a country’s financial
systems, or contributing to the development of industrial policy. Notable examples
include the Bank of France and the Bank of England. Finally, 11 respondents within this
interest group constitute a varied group of government entities. Two of these are from
Canada. One is a joint submission from Canada’s three largest cities: Montréal, Vancou-
ver, and Toronto; the other is from various staff members working for the Government
of Ontario. These 2 responses again highlight the focus on sustainability reporting in
Canada’s public sector. This final sub-grouping includes 5 International responses. Nota-
ble high-profile respondents included the OECD, the IMF, and the Office of the Special
Envoy for Climate Action and Finance at the UN. This latter response was authored by
Mark Carney, a former governor of the Bank of Canada and Bank of England and a
major voice in advocating for the consideration of climate change on financial market
risk. The Swedish Environment Protection Agency also responded.
Exchanges and Financial Market Regulators

Respondents within this interest group include 15 organizations which play a direct role
in ensuring strong capital markets, either nationally, regionally, or globally; 5 of these
are stock or commodity exchanges located in five different countries, and 6 are formal
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

regulatory bodies which either oversee or facilitate various financial market exchanges.
These include responses from both European authorities and 3 at the individual country
level. Notably, the SEC, the regulator of the world’s largest financial market, did not
respond to the Consultation Paper.58 The Canadian respondent is the Canadian Securities
Administrators (CSA). The CSA is an umbrella body of Canada’s provincial and territo-
rial securities regulators whose objective is to improve, coordinate, and harmonize regu-
lation in the Canadian capital markets. There are also 4 respondent organizations which
work to represent the interests of financial markets and exchanges throughout the world.
One of these respondents is the International Organization of Securities Commissions
(IOSCO).59 According to its website, IOSCO is the international body that brings
together the world’s securities regulators.60
Sustainability Reporting Standard Setters

The 23 sustainability reporting standard setters are divided into three groups. The first
group consists of global developers or global promoters of sustainability reporting stan-
dards. The global developers are profiled earlier in the paper and include the GRI, CDSB,
SASB, IIRC, VRF, and FSB (TCFD). There is also a response from the International
Organization for Standardization (ISO). According to its submission, the ISO has publi-
shed 23,500 international standards covering technical and management standards rele-
vant to all sectors of the economy. Specific reference is made in their submission to the
environmental management standard ISO 14001, which has over 300,000 certificated
users in 197 countries, including the finance sector.
There are 10 respondents from a varied set of regional- or country-level developers
or promoters of sustainability reporting standards. These include a regional respondent,
the Africa Integrated Reporting Council, and 9 respondents from seven different coun-
tries. Notably, 2 of the respondents are from South Africa, a jurisdiction considered a
leader in integrated reporting. Mervyn King, a recognizable name worldwide in inte-
grated reporting, leads one of the respondents. There are also 3 respondent organizations
whose role is providing a data platform to host corporate reporting information. One of
these is the CDP, an organization profiled earlier in the paper. Another is XBRL Interna-
tional, a major player worldwide whose purpose is to provide open data exchange stan-
dards for business reporting. There are no Canadian respondents among the sustainability
reporting standard setters.
58. The SEC did, however, respond to the subsequent IFRS Foundation ED. This ED recommended
changes to the Foundation’s structure to formally enable creation of an ISSB (the new name for the
proposed SSB). In their response (response #13), the SEC voiced significant opposition to this new
Board’s creation. This opposition specifically cited the potential negative impact this new Board
would have on the important work of the IASB in setting IFRS.
59. IOSCO is viewed by the IFRS Foundation as playing a crucial role in advancing the cause of global
sustainability reporting in much the same way that it did for the cause of global financial reporting.
IOSCO’s response was supportive overall of the Foundation’s initiative (IFRS 2021b).
60. See https://www.iosco.org/about/?subsection=about_iosco.
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

Individuals
There were 33 individual respondents to the Consultation Paper. These respondents are
from 17 different countries, with 5 from the United States and 4 each from Australia and
the United Kingdom. Two of the individual respondents are from Canada. One is Allan
Willis, an independent professional accountant. The other is Barb Zvan, the current presi-
dent and CEO of the University Pension Plan Ontario. Both Canadian respondents noted
their extensive experience and involvement in sustainability reporting. There are also
14 individual respondents which, due to lack of identifying information, could not be
assigned to a specific geographic location.
6. PROFILING THE RESPONSES
Questions of Concern
As noted earlier, in profiling the responses (i.e., the narrative), we focus on the support
expressed for a single set of sustainability reporting standards and for the Foundation’s
creation of a global SSB.
Responses to Question 1: Do you Support a Single Set of Sustainability

Reporting Standards?
Table 6 presents the classification of responses to the first question. The vast majority,
463 of 475 responses,61 express clear support for a single set of sustainability reporting
standards. These responses included all the members of the preparer, financial reporting
standard setter, government, sustainability reporting standard setter, and exchanges and
financial market regulator interest groups and the vast majority of the members of the
other identified interest groups. At least 1 respondent from every geographic location
expressed support for a single set of sustainability standards. The supportive responses
stress the need for a set of consistent and comparable sustainability standards.
Contrary to the opinion of the overwhelming majority, we find 5 responses, including
1 from Canada, which clearly oppose a single set of sustainability reporting standards.
Four of the 5 argue that sustainability is too big and broad a concept to be covered by a
single set of reporting standards, which cannot cover all desired disclosures from
reporting companies. Three of the 5 also desire that the current process of convergence
happening among the current sustainability standard setters continue without interference
from another standard-setting body. There are 7 responses where the respondent’s opin-
ion is unclear, providing reasons both in support and opposition to global sustainability
standards.
Responses to Question 2: Do you Support the Creation of the SSB?

Table 7 presents the classification of responses to the second question. While support is
not quite as overwhelming as for the first question, the vast majority, 424 out of
61. For the analysis of the responses, we removed the 102 chain letters.
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

TABLE 6
Response to need for global sustainability standards (n = 475)
Support (463) Opposition (5) Unclear (7)
Interest group Location Interest group Location Interest group Location

USER 111 International 73 ACAD 3 United Kingdom 2 ACAD 2 United States 2
SAC 62 United Kingdom 63 SAC 1 Australia 1 SAC 2 Brazil 1
AP 60 Canada 37 USER 1 Canada 1 AP 1 Hong Kong 1
ACAD 51 United States 32 United States 1 IND 1 Malaysia 1
IND 46 Europe 25 USER 1 Romania 1
PREP 39 Australia 21 Unassigned 1
FRSS 29 Brazil 17
GOVT 27 Germany 17
SRSS 23 South Africa 15
EFMR 15 Netherlands 14
Unassigned 14
France 12
Hong Kong 10
New Zealand 8
Italy 8
Japan 8
Spain 6
Switzerland 6
Malaysia 5
Nigeria 5
Sweden 5
Asia 4
Colombia 4
Ireland 4
South Korea 4
China 3
India 3
Turkey 3
Africa 2
Argentina 2
Austria 2
Chile 2
Finland 2
Norway 2
Poland 2
Russia 2
Singapore 2
Uganda 2
Australia and 1
New Zealand
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

TABLE 6 (continued)

Australia and 1
United Kingdom
Belgium 1
Botswana 1
Denmark 1
Denmark, Finland, 1
Iceland, Norway,
and Sweden
France and Spain 1
Indonesia 1
Iran 1
Kenya 1
Latin America 1
Mexico 1
Portugal 1
Romania 1
Saudi Arabia 1
Taiwan 1
Tanzania 1
United Arab 1
Emirates
475, provide support for the creation of an SSB by the Foundation. These responses cite
the Foundation’s current status related to financial standard setting and the credibility that
an SSB under the Foundation would bring to the sustainability reporting standards cre-
ated by such an entity. This credibility and influence are also noted when considering
potential global adoption of the reporting standards. The respondents also note that the
Foundation has connections, influence, and a proven track record of bringing individual
country regulators together under a single set of reporting standards. Supporters addition-
ally note that there are potential benefits to having international financial and sustainabil-
ity standard-setting boards under a single governing body.
Compared to the response to global standards, there is significantly more opposition
to the Foundation taking the lead in establishing a sustainability standard-setting board.
There are 47 clear “no” responses to the Foundation creating an SSB, including 4 from
Canada. Just under 75% (35 of 47) cite that there are already sustainability standard-
setting bodies at work and that the addition of an SSB created by the Foundation is
unnecessary, at best, or harmful, at worst. About 60% (28 of 47) express the opinion that
sustainability reporting standards designed just for a traditional financial statement
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

TABLE 7
Response to creation of an SSB (n = 475)

USER 99 International 70 ACAD 23 United 11 ACAD 1 Asia 1
Kingdom
AP 59 United 53 USER 13 France 5 AP 1 Romania 1
Kingdom
SAC 58 Canada 34 SAC 6 Australia 4 USER 1 Russia 1
IND 46 United States 31 SRSS 2 Canada 4 SAC 1 United 1
Kingdom
PREP 39 Europe 22 AP 1 United States 4
ACAD 32 Australia 18 GOVT 1 Europe 3
FRSS 29 Brazil 17 IND 1 International 3
GOVT 26 Germany 17 Italy 2
SRSS 21 South Africa 15 Asia 1
EFMR 15 Netherlands 14 Australia and 1
United
Kingdom
Unassigned 14 Botswana 1
Hong Kong 10 Brazil 1
Japan 8 Colombia 1
France 7 Hong Kong 1
New Zealand 7 India 1
Italy 6 Malaysia 1
Spain 6 New Zealand 1
Switzerland 6 Sweden 1
Malaysia 5 Unassigned 1
Nigeria 5
Ireland 4
South Korea 4
Sweden 4
Asia 3
China 3
Colombia 3
Turkey 3
Africa 2
Argentina 2
Austria 2
Chile 2
Finland 2
India 2
Norway 2
Poland 2
Singapore 2
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

TABLE 7 (continued)

Uganda 2
Australia and 1
New Zealand
Belgium 1
Denmark 1
Denmark, 1
Finland,
Iceland,
Norway, and
Sweden
France and 1
Spain
Indonesia 1
Iran 1
Kenya 1
Latin America 1
Mexico 1
Portugal 1
Romania 1
Russia 1
Saudi Arabia 1
Taiwan 1
Tanzania 1
United Arab 1
Emirates
audience are insufficient, and the same percentage believe that financial materiality and/or
single materiality is insufficient when creating sustainability reporting standards. A sig-
nificant number of the dissenters (27 of 47) believe that the Foundation does not have
either the skills or personnel required to create an appropriate SSB. Ten of these negative
responses cite that the EC is already crafting a set of sustainability reporting standards
and that the Foundation’s SSB is not needed. Eleven of the rejecters of a Foundation
SSB suggest that the proposals from the Consultation Paper be included in the financial
statements (i.e., incorporated as part of IFRS), which are already under the governance of
the Foundation. There are 4 responses where the opinion is unclear, with respondents
stating they are opposed to a Foundation-created SSB, yet also providing reasoning that
supports an SSB under the Foundation.
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

7. CONCLUSION
Interest in and demand for sustainability-oriented investment continues to grow, spurred
on by concerns about climate change and the idea that businesses are accountable to a
larger group of stakeholders than just their shareholders. Motivated by the increased
focus on sustainable business practices, many global business leaders pledged to align
their corporations with the 17 SDGs from the UN’s Transforming our World: The 2030
Agenda for Sustainable Development. Within this developing new landscape, a crucial
question remains: How can firms provide sufficient and informative evidence of sustain-
able business practice? There are currently multiple sustainability reporting frameworks
and sustainability standard setters, each offering a set of disclosure guidelines. This con-
voluted reporting environment makes it difficult for preparers to develop a single coher-
ent approach to sustainability reporting and for stakeholders to confidently compare
sustainability performance across firms.
With the release of its 2020 Consultation Paper in September 2020, the IFRS Foun-
dation entered the crowded area of sustainability reporting. Using the consultative due
process system to gain legitimacy for its entry, the IFRS Foundation sought comments
from interested parties throughout the world on its proposal to create a global SSB. In
total, the Foundation received 577 responses. These responses came from respondents in
46 different countries as well as regional and international respondents. We focus in this
study on the respondents, providing a detailed analysis of both the interest groups they
represent and their geographic location. We also place within this larger analysis the set
of 38 Canadian respondents. Our study also explores the comment letter responses to the
Foundation’s call for global sustainability reporting standards and for its role as the
global standard setter.
In our study, we find both similarities to and differences from prior research analyz-
ing comment letters. The broad geographical dispersion of respondents we identified is
consistent with the prior research, although we did identify a larger set of regional and
international respondents. Our set of interest groups was also similar to prior research,
although we did identify two additional sustainability-focused interest groups: (i) sustain-
ability reporting standard setters (ii) and sustainability advocacy and consulting. In con-
trast to prior research, we found that a large proportion of the respondents to the
Consultation Paper are users, which is likely reflective of the current challenges in
assessing organizations’ sustainability efforts. We also found a large response from the
academic community, reflective of its active engagement and interest in sustainability.
Notably, and in contrast with prior research, we found a low number of respondents from
the preparer community. A final notable difference is in the volume of responses the
Foundation received on the Consultation Paper. Prior comment letter research finds high
numbers of responses to later parts of the process and not to the initial consultation or
discussion paper stage.
In analyzing the responses, we find overwhelming support for the need for a global
set of sustainability standards, with such support normally citing the need to provide con-
sistent and comparable sustainability information. The limited number of dissenters,
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

primarily academics, highlighted the inherent vastness and complexity of sustainability

reporting that would make a singular set of standards unattainable. We also find that the
vast majority of respondents support the creation of an SSB under the aegis of the IFRS
Foundation. These supporters tend to cite the Foundation’s past success in financial
reporting, which is built upon its worldwide connections in the financial reporting and
regulatory communities and is crucial to enabling the ultimate adoption of a set of global
sustainability standards. Supporters also identify the potential synergies of having both
financial and sustainability reporting boards governed by a singular body. Opponents to
the Foundation’s creation of a global sustainability board cite the current existence of
credible sustainability standard-setting bodies as well as the need for double materiality
disclosure requirements, a position currently not favored by the IFRS Foundation. This
opposition again came largely from academics, although there were also a substantial
number of dissenting users and sustainability advocates.
In terms of the Canadian setting, the 38 total respondents from Canada placed third-
highest, behind only the United Kingdom and International respondents. Consistent with
the overall set, users are the largest group of respondents from Canada. The next largest
interest group from Canada is government, with 7 respondents, 5 of whom are auditors
general. This group of 7 is the highest individual total from any geographic location.
Canada also has a significant number of responses from the financial reporting standard-
setting community, with respondents from the accounting, auditing, public sector, and
oversight boards. Preparer respondents from Canada, while similar in overall percentage
to the global set of respondents, were concentrated in a single industry: oil and gas. The
Canadian respondents, at a similar rate to all respondents, expressed strong support for a
global set of sustainability reporting standards and for the creation of an SSB under the
Foundation.
It is important to note that our study focuses on actual respondents to the Consulta-
tion Paper. Future research might contrast actual respondents with potential respondents,
thereby providing a fuller understanding of the representativeness of the respondent
group. Our study also restricts the response analysis to 2 of the 11 questions posed in the
Consultation Paper. Future research can examine responses to the other questions. We
also found that a significant number of dissenters (concentrated in Europe) to an SSB
governed by the Foundation cited the EC’s own development of sustainability reporting
standards. Future research can contrast European attitudes to sustainability reporting stan-
dards with attitudes in the rest of the world.
Our study primarily contributes to the literature on comment letters while also
adding to the literatures on lobbying and standard setting. The Foundation’s Consulta-
tion Paper offers a novel set of circumstances within the study of comment letters.
There are no direct financial statement impacts from what is proposed, and it is an
extremely early stage of the standard-setting process. This study documents that there
are differences in respondents, under these unusual circumstances, from prior comment
letter studies: greater participation from users and lesser participation from preparers.
The study is particularly unique in its microlevel presentation of the respondent set.
This presentation involved the creation of various interest subgroupings as well as the
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

identification within the subgroupings of actual respondents. The study also extends
existing comment letter research by identifying the specific reasons behind support or
opposition to a standard-setting proposal. With its focus on the Canadian respondents,
the study also contributes to the existing dearth of research on standard setting in a
Canadian context. By highlighting the Canadian entities concerned enough with sus-
tainability reporting to respond to the Foundation’s proposal, our study complements
the recent Cho et al. (2020) study on the sustainability disclosure practices of Canadian
companies.
Canada’s respondents and responses to the first and second questions in the
Consultation Paper appear representative of the global response, with a notable differ-
ence. The relatively large number of respondents from government and the financial
reporting standard-setting communities in Canada highlights a country with institu-
tional concern for sustainability disclosure. General representativeness of the global
response, coupled with notable institutional interest, enhances the case for Canada to
be the headquarters of the ISSB. Despite the strong case for Canada, the Foundation
ultimately chose Frankfurt, Germany, as “the seat of the board and office of the
Chair” (IFRS 2021f). However, Montréal, Québec, was selected as the ISSB’s host
location for the Americas in what the Foundation calls a “global and multi-location
presence,” with either Beijing or Tokyo as the host location for Asia-Oceania
(IFRS 2021f). Canada seems primed to be a prominent voice in the development of
the ISSB’s standards to come. More importantly, can a set of global sustainability
reporting standards be agreed upon, and will such reporting become mandatory
throughout the world?
APPENDIX 1: CONSULTATION QUESTIONS 1 AND 2 (IFRS 2020)

Question 1
Is there a need for a global set of internationally recognized sustainability reporting
standards?
a. If yes, should the IFRS Foundation play a role in setting these standards and
expand its standard-setting activities into this area?
b. If not, what approach should be adopted?
Question 2
Is the development of a sustainability standards board (SSB) to operate under the gover-
nance structure of the IFRS Foundation an appropriate approach to achieving further con-
sistency and global comparability in sustainability reporting?
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

APPENDIX 2: INTEREST GROUPS—CODING PROTOCOL AND EXAMPLE

RESPONDENTS
Interest group Abbrev. Coding protocol Example respondentsa

Academia ACAD Respondents writing in their role as Carol Adams, Charles Cho,
university professors or students, Richard Barker and Bob Eccles,
and either as an individual or part professors of accounting
of a group conducting research in the field of
sustainability accounting and
reporting and editors of
accounting journals which publish
this research
Accounting profession AP Organizations which provide Deloitte, Mazars, CPA Canada,
accounting and auditing services, Nordic Federation of Public
or which represent or regulate the Accountants, International
members working in such Federation of Accountants, New
organizations York Society of CPAs
Exchanges and EFMR Stock exchanges, commodity Canadian Securities
financial market exchanges, and other Administrators, Johannesburg
regulators organizations that either regulate Stock Exchange, International
or advance the interests of Organization of Securities
financial markets worldwide Commissions
Financial reporting FRSS Organizations which set formal Dutch Accounting Standards Board,
standard setters accounting and auditing Austrian Financial Reporting and
standards, either for the private or Auditing Committee, IFRS
public sector, or which provide Experts Forum Nigeria, Auditing
advice to, or oversee, such and Assurance Oversight
organizations Council
Government GOVT Organizations operating within the International Monetary Fund, Office
public sector of the Auditor General of
Alberta, OECD
Individuals IND Individuals writing solely as private Ian Mackintosh, Mervin King,
citizens and not on behalf of any Caroline Lucas, and Clive Lewis
other interest group (chain letter), Barb Zvan
Preparers PREP Organizations concerned with Suncor Energy, Unilever,
having to report externally in Confederation of Swedish
accordance with sustainability Enterprises, Japan Business
reporting standards, or which Federation
represent these organizations’
interests
Sustainability SAC Organizations which provide advice Arge Consulting, Canadian
advocacy and or guidance to organizations on Coalition for Good Governance,
consulting becoming more sustainable or Carbon Tracker Initiative,
which advocate for increased Shinergise Consulting, Tobacco
sustainability awareness Free Portfolios
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

(continued)
Interest group Abbrev. Coding protocol Example respondentsa
Sustainability SRSS Organizations which set or develop Climate Disclosure Standards Board,
reporting standard sustainability or nonfinancial Global Reporting Initiative,
setters reporting standards, or which Integrated Reporting Committee of
enable or promote these standards South Africa, Sustainability
Accounting Standards Board,
World Benchmarking Alliance,
XBRL International
Users USER Organizations which use externally Addenda Capital, BlackRock, Fitch
reported sustainability information Ratings, Moody’s ESG Solutions
in making asset allocation Group, Hong Kong Green Finance
decisions or which provide advice Association, OMERS, Spanish
on such decisions Institute of Financial Analysts
Notes: aCanadian respondents are in bold type.
APPENDIX 3: EXAMPLE OF CHAIN LETTER—RESPONSE #524
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

REFERENCES
BCI (British Columbia Investment Management Corporation). 2020. CEOs of eight leading Cana-
dian pension plan investment managers call on companies and investors to help drive sustain-
able and inclusive economic growth. Newswire, November 25, https://www.newswire.ca/news-
releases/ceos-of-eight-leading-canadian-pension-plan-investment-managers-call-on-companies-and-
investors-to-help-drive-sustainable-and-inclusive-economic-growth-844608554.html
Bujaki, M. L., and B. J. McConomy. 2007. Income tax accounting policy choice: Exposure draft
responses and the early adoption decision by Canadian companies. Accounting Perspectives 6
(1): 21–53.
CDP, CDSB, GRI, IIRC, and SASB (Carbon Disclosure Project, Climate Disclosure Standards
Board, Global Reporting Initiative, International Integrated Reporting Council, Sustainability
Accounting Standards Board). 2020a. Statement of intent to work together towards compre-
hensive corporate reporting, https://29kjwb3armds2g3gi4lq2sx1-wpengine.netdna-ssl.com/
wp-content/uploads/Statement-of-Intent-to-Work-Together-Towards-Comprehensive-
Corporate-Reporting.pdf
CDP, CDSB, GRI, IIRC, and SASB (Carbon Disclosure Project, Climate Disclosure Standards
Board, Global Reporting Initiative, International Integrated Reporting Council, Sustainability
Accounting Standards Board). 2020b. Reporting on enterprise value Illustrated with a proto-
type climate-related financial disclosure standard, https://29kjwb3armds2g3gi4lq2sx1-
wpengine.netdna-ssl.com/wp-content/uploads/Reporting-on-enterprise-value_climate-
prototype_Dec20.pdf
Cho, C. H., K. Bohr, T. J. Choi, K. Partridge, J. M. Shah, and A. Swierszcz. 2020. Advancing
sustainability reporting in Canada: 2019 report on progress. Accounting Perspectives 19 (3):
181–204.
Christensen, H. B., L. Hail, and C. Leuz. 2021. Mandatory CSR and sustainability reporting: Eco-
nomic analysis and literature review. Working paper, National Bureau of Economic Research,
https://care-mendoza.nd.edu/assets/443735/christensen_leuz_mandatory_csr_and_
sustainability_reporting_economic_analysis_and_literature_review.pdf
Durocher, S., and A. Fortin. 2011. Practitioners’ participation in the accounting standard-setting
process. Accounting and Business Research 41 (1): 29–50.
Durocher, S., A. Fortin, and L. Côté. 2007. Users’ participation in the accounting standard-setting
process: A theory-building study. Accounting, Organizations and Society 32 (1–2): 29–59.
Dyckman, T. R. 1988. Credibility and the formulation of accounting standards under the Financial
Accounting Standards Board. Journal of Accounting Literature 7 (1): 1–30.
EC (European Commission). 2021. Corporate sustainability reporting, https://ec.europa.eu/
info/business-economy-euro/company-reporting-and-auditing/company-reporting/
corporate-sustainability-reporting_en
EFRAG (European Financial Reporting Advisory Group). 2021. Final report proposals for a rele-
vant and dynamic EU sustainability reporting standard-setting, https://ec.europa.eu/info/sites/
default/files/business_economy_euro/banking_and_finance/documents/210308-report-efrag-
sustainability-reporting-standard-setting_en.pdf
Francis, J. R. 1987. Lobbying against proposed accounting standards: The case of employers’ pen-
sion accounting. Journal of Accounting and Public Policy 6 (1): 35–57.
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

Freeland, C. 2021. Letter from the Deputy Prime Minister to the Chair of the Board of Trustees of
the IFRS Foundation, https://www.canada.ca/en/department-finance/programs/financial-
sector-policy/letter-from-deputy-prime-minister-chair-board-trustees-ifrs-foundation.html
Georgiou, G. 2004. Corporate lobbying on accounting standards: Methods, timing and perceived
effectiveness. Abacus 40 (2): 219–37.
Giner, B., and M. Arce. 2012. Lobbying on accounting standards: Evidence from IFRS2 on share-
based payments. European Accounting Review 21 (4): 655–91.
Government of British Columbia. 2021. British Columbia’s carbon tax. https://www2.gov.bc.ca/
gov/content/environment/climate-change/clean-economy/carbon-tax
Government of Canada. 2021. Crude oil facts, https://www.nrcan.gc.ca/science-and-data/data-and-
analysis/energy-data-and-analysis/energy-facts/crude-oil-facts/20064
Hansen, T. B. 2011. Lobbying of the IASB: An empirical investigation. Journal of International
Accounting Research 10 (2): 57–75.
IFRS. 2020. Consultation Paper on sustainability reporting, https://www.ifrs.org/content/dam/ifrs/
project/sustainability-reporting/consultation-paper-on-sustainability-reporting.pdf
IFRS. 2021a. IFRS Foundation annual report 2020, https://www.ifrs.org/content/dam/ifrs/about-
us/funding/2020/IFRS-Annual-Report-2020.pdf
IFRS. 2021b. IFRS Foundation Trustees announce strategic direction and further steps based on
feedback to sustainability reporting consultation. March 8, https://www.ifrs.org/news-and-
events/news/2021/03/trustees-announce-strategic-direction-based-on-feedback-to-
sustainability-reporting-consultation/
IFRS. 2021c. IFRS Foundation trustees’ feedback statement on the consultation paper on sustain-
ability reporting, https://www.ifrs.org/content/dam/ifrs/project/sustainability-reporting/sustainability-
consultation-paper-feedback-statement.pdf
IFRS. 2021d. Exposure Draft: Proposed targeted amendments to the IFRS Foundation Constitu-
tion to accommodate an international sustainability standards board to set IFRS sustainability
standards, https://www.ifrs.org/content/dam/ifrs/project/sustainability-reporting/ed-2021-5-proposed-
constitution-amendments-to-accommodate-sustainability-board.pdf
IFRS. 2021e. Constitution, https://www.ifrs.org/content/dam/ifrs/about-us/legal-and-governance/
constitution-docs/ifrs-foundation-constitution-2021.pdf
IFRS. 2021f. ISSB: Frequently asked questions, https://www.ifrs.org/groups/international-
sustainability-standards-board/issb-frequently-asked-questions/
Johnson, S. B., and D. Solomons. 1984. Institutional legitimacy and the FASB. Journal of
Accounting and Public Policy 3 (3): 165–83.
Jones, J. 2021. Bank of Canada warns carbon-intense assets mispriced. Globe and Mail, May 20.
Jorissen, A., N. Lybaert, R. Orens, and L. Van Der Tas. 2012. Formal participation in the IASB’s
due process of standard setting: A multi-issue/multi-period analysis. European Accounting
Review 21 (4): 693–729.
Jorissen, A., N. Lybaert, R. Orens, and L. Van der Tas. 2013. A geographic analysis of con-
stituents’ formal participation in the process of international accounting standard setting:
Do we have a level playing field? Journal of Accounting and Public Policy 32 (4):
237–70.
KPMG. 2020. The time has come: KPMG survey of sustainability reporting 2020, https://assets.
kpmg/content/dam/kpmg/xx/pdf/2020/11/the-time-has-come.pdf
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

Kwok, W. C. C., and D. Sharp. 2005. Power and international accounting standard setting: Evi-
dence from segment reporting and intangible assets projects. Accounting, Auditing &
Accountability Journal 18 (1): 74–99.
Larson, R. K. 1997. Corporate lobbying of the international accounting standards committee.
Journal of International Financial Management & Accounting 8 (3): 175–203.
Larson, R. K. 2007. Constituent participation and the IASB’s international financial reporting
interpretations committee. Accounting in Europe 4 (2): 207–54.
Larson, R. K., and P. J. Herz. 2013. A multi-issue/multi-period analysis of the geographic diver-
sity of IASB comment letter participation. Accounting in Europe 10 (1): 99–151.
McLeay, S., D. Ordelheide, and S. Young. 2000. Constituent lobbying and its impact on the
development of financial reporting regulations: Evidence from Germany. Accounting, Organi-
zations and Society 25 (1): 79–98.
Nash, T. 2021. Eco-fund guide: The ultimate guide to responsible investing. Corporate Knights,
April 21, https://www.corporateknights.com/responsible-investing/2021-eco-fund-guide-the-
ultimate-guide-to-responsible-investing/
Orens, R., A. Jorissen, N. Lybaert, and L. Van Der Tas. 2011. Corporate lobbying in private
accounting standard setting: Does the IASB have to reckon with national differences?
Accounting in Europe 8 (2): 211–34.
Plumber, B., and N. Popovich. 2019. These countries have prices on carbon. Are they working?
New York Times, April 2, https://www.nytimes.com/interactive/2019/04/02/climate/pricing-
carbon-emisssions.html
Rey, A., R. Maglio, and V. Rapone. 2020. Lobbying during IASB and FASB convergence due
processes: Evidence from the IFRS 16 project on leases. Journal of International Accounting,
Auditing and Taxation 41 (December): 1–23.
Richardson, A. J., and B. Eberlein. 2011. Legitimating transnational standard-setting: The case of
the International Accounting Standards Board. Journal of Business Ethics 98 (2): 217–45.
SASB (Sustainability Accounting Standards Board). 2020. IIRC and SASB announce intent to
merge in major step towards simplifying the corporate reporting system. PRNewswire,
November 25, https://www.prnewswire.com/news-releases/iirc-and-sasb-announce-intent-
to-merge-in-major-step-towards-simplifying-the-corporate-reporting-system-301180179.
html
Schalow, C. M. 1995. Participation choice: The exposure draft for postretirement. Accounting
Horizons 9 (1): 27–41.
Statistics Canada. 2017a. Immigration and ethnocultural diversity statistics, https://www.statcan.
gc.ca/en/subjects-start/immigration_and_ethnocultural_diversity
Statistics Canada. 2017b. Immigration and ethnocultural diversity: Key results from the 2016 Cen-
sus, https://www150.statcan.gc.ca/n1/daily-quotidien/171025/dq171025b-eng.htm?indid=
14428-1&indgeo=0
Statistics Canada. 2017c. Aboriginal peoples in Canada: Key results from the 2016 Census,
https://www150.statcan.gc.ca/n1/daily-quotidien/171025/dq171025a-eng.htm
Statistics Canada. 2021. Gross domestic product (GDP) at basic prices, by industry, monthly,
growth rates ( 1,000,000), https://www150.statcan.gc.ca/t1/tbl1/en/tv.action?pid=3610043402
Stenka, R., and P. Taylor. 2010. Setting UK standards on the concept of control: An analysis of
lobbying behaviour. Accounting and Business Research 40 (2): 109–30.
AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

Sutton, T. G. 1984. Lobbying of accounting standard-setting bodies in the UK and the USA: A
Downsian analysis. Accounting, Organizations and Society 9 (1): 81–95.
Tandy, P. R., and N. L. Wilburn. 1992. Constituent participation in standard-setting: The FASB’s
first 100 statements. Accounting Horizons 6 (2): 47–58.
Tandy, P. R., and N. L. Wilburn. 1996. The academic community’s participation in standard set-
ting: Submission of comment letters on SFAS Nos. 1-117. Accounting Horizons 10 (3):
92–111.
UN. 2015. Transforming our world: The 2030 agenda for sustainable development, https://
sustainabledevelopment.un.org/content/documents/21252030%20Agenda%20for%
20Sustainable%20Development%20web.pdf
VRF (Value Reporting Foundation). 2021. IIRC and SASB form the Value Reporting Foundation,
providing comprehensive suite of tools to assess, manage and communicate value. June 9,
https://www.valuereportingfoundation.org/news/iirc-and-sasb-form-the-value-
reportingfoundation-providing-comprehensive-suite-oftools-to-assess-manage-and-
communicate-value/
Wallace, R. O. 1990. Survival strategies of a global organization: The case of the International
Accounting Standards Committee. Accounting Horizons 4 (2): 1–22.
Watts, R. L., and J. L. Zimmerman. 1978. Towards a positive theory of the determination of
accounting standards. The Accounting Review 53 (1): 112–34.
Watts, R. L., and J. L. Zimmerman. 1979. The demand for and supply of accounting theories:
The market for excuses. The Accounting Review 54 (2): 273–305.
Watts, R. L., and J. L. Zimmerman. 1990. Positive accounting theory: A ten year perspective. The
Accounting Review 65 (1): 131–56.
Weetman, P., E. S. Davie, and W. Collins. 1996. Lobbying on accounting issues: Preparer/user
imbalance in the case of the operating and financial review. Accounting, Auditing & Account-
ability Journal 9 (1): 59–76.
WEF (World Economic Forum). 2020. Measuring stakeholder capitalism towards common met-
rics and consistent reporting of sustainable value creation, https://www3.weforum.org/docs/
WEF_IBC_Measuring_Stakeholder_Capitalism_Report_2020.pdf
Zeff, S. A. 1978. The rise of “economic consequences.” Journal of Accountancy 146 (6): 56–63.
AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

A Canadian Response To The Pursuit of Global Sustainability Reporting Standards

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

A Canadian Response To The Pursuit of Global Sustainability Reporting Standards

Uploaded by

Copyright:

Available Formats

A Canadian Response to the Pursuit of Global

Sustainability Reporting Standards*

RÉPONSE CANADIENNE À LA CRÉATION DE NORMES MONDIALES SUR

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022) pages 00–00 © CAAA/ACPC

à la durabilité plus « uniforme et comparable », l’IFRS Foundation (la Fondation) a

Global Concerns with Sustainability Reporting

Convoluted Sustainability Reporting Environment

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

1. An update of recent developments is provided in the sustainability reporting environment in section 2.

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

Consequently, in September 2020, the Foundation, in a Consultation Paper (IFRS 2020),

Canada’s Response Positioning

4. The full set of responses is available at https://www.ifrs.org/projects/work-plan/sustainability-reporting/

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

2. CURRENT SUSTAINABILITY FRAMEWORK AND STANDARD SETTERS AND THE

Current Sustainability Framework and Standard Setters

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

16. Response #110

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

Progressing to a Single Set of Standards

24. Response #226

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

The IFRS Foundation Sustainability Initiative

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

3. ADDITIONAL BACKGROUND INFORMATION

Standard-Setting Due Process

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

One method to legitimize a private standard-setting body is to focus on the entity’s

Comment Letters in Due Process

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

Lobbying Accounting Standard Setters

Sustainability Reporting Standards

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

35. Response #152

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

5. PROFILING THE RESPONDENTS

The Respondents: Full Set

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

Clearly traceable and

(The table is continued on the next page.)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

Clearly traceable and

The highest percentage of responses was categorized as International, accounting

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

Remove chain letter and

Interest group Number % of total Number % of total

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

Hong Kong 1.8 4.6 1.6 3.6 5.1 0 0 3.7 0 0

The Respondents: Canada in Context

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

Notes: See Appendix 2 for deﬁnitions of interest groups.

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022) pages 00–00 © CAAA/ACPC

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 00 No. 00 — PC vol. 00, n 00 (2022)

AP Vol. 9999 No. 00 — PC vol. 00, n 00 (2022)