We believe that the ISSB standards are a helpful global baseline, and we recognize the implementation progress that has been made across various jurisdictions. We also propose a few amendments on some of the measures proposed by the ISSB. For example, when they would not provide decision-useful information while being operationally burdensome and costly to implement, including potential new systems implementation, potentially undermining the objective of the relief. Finally, we express concerns about the current proposal’s complexity and recommend simplifications. We encourage the ISSB to consider adding guidance or implementation support that recommends jurisdictions clearly explain how alternative methodologies align with the objectives and principles of IFRS S2.
IBFed letter to the ISSB on Greenhouse Gas Emissions Disclosures – 27 June 2025