CONSISTENCY BETWEEN ISSB STANDARDS AND EFRAG  ESRSs
WSBI-ESBG  believe that it is crucial to achieve consistency of 
sustainability reporting at global level and especially a full alignment
 of reporting requirements between ISSB standards and EFRAG  European 
Sustainability Reporting Standards (ESRSs) to ensure a global playing 
field in terms of sustainability reporting. This convergence between 
both standards will address the risk of additional disclosures.
DOUBLE MATERIALITY
WSBI-ESBG  highlight that the IFRS  sustainability standards are based on 
an ‘enterprise value creation’ or financial materiality approach, in 
which sustainability impacts are measured in terms of impacts on the 
financial position and prospects of the company itself. On the other 
hand, the EFRAG  ESRSs are being developed based on the ‘double 
materiality’ principle, where disclosure is required both from the point
 of view of financial impact on the company and on the impact of the 
company on society and the environment.
TRANSITION PLANS
WSBI-ESBG  notes that the EFRAG  ESRSs make a clearer reference to 
alignment with limiting global warming to 1.5°C in line with the Paris 
Agreement. On the other hand, IFRS  sustainability standards allow the 
entity to choose its own target. By way of consequence, WSBI  – ESBG  
requests that the ISSB takes into consideration including a clear 
reference to the 1.5°C target of the Paris Agreement in order to ensure 
comparability between the two standards.
BOUNDARIES AND VALUE CHAIN
Although, WSBI  – ESBG  considers it essential that sustainability 
reporting should capture the entire value chain, we ask for clearer and 
more defined boundaries as it is considered difficult and complicated to
 obtain information from companies that are not under the control of a 
financial institution, especially regarding scope 3 GHG emissions.