EBF consultation response on the International Sustainability Standards Board (ISSB) Exposure Drafts

01 August 2022

The EBF welcomes the International Sustainability Standards Board’s (ISSB) efforts to develop a commonly accepted global baseline for sustainability disclosures.

To the end of fostering consistency, comparability, understandability, and an overall harmonised and efficient framework, the EBF supports:

• The intention of providing structure to achieve comparability across jurisdictions and firms worldwide
• The ISSB’s continuous cooperation with existing international initiatives and practices and with due regard to existing or new standards, including the EFRAG’s European Sustainability Reporting Standards (ESRS)
• A single set of comprehensive disclosure standards — applying to both financial and non-financial firms — which is key to facilitating better investment and financing decisions by all stakeholders
• The concept of double materiality, which although not addressed by the ISSB, is an essential concept of sustainability as the impact of a company on the environment and society at large is a crucial piece of information for investors and lenders that wish to align their portfolios to the Paris Agreement. We would, therefore, encourage further guidance from the ISSB regarding materiality and enterprise value, as well as on the interoperability between the ISSB and the EFRAG standards (the latter having incorporated the double-materiality concept)

EBF

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