The EACB appreciates the fact that the International Sustainability Standards Board’s Exposure Draft IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and Exposure Draft IFRS S2 Climate-related Disclosures set out requirements that are understandable and principle based. As a general comment, we would like to highlight that the ISSB Exposure Drafts – with the focus on the enterprise value and the risks affecting the enterprise value - lack the definition of double materiality.
In reference to the paragraph 60 of the General Requirements Exposure Draft, we appreciate a clear statement that if a specific standard is not relevant for the undertaking, then a company may not deem necessary to provide a specific disclosure. In addition, when it comes to the issue of cross-referencing of the material information, EACB members suggest that a provision should be included to the effect that referencing is only permissible if local law does not prohibit it.
Regarding the Climate Exposure Draft, we are convinced that the requirements to disclose resources used in the transformation plans and how a company expects its financial position to change over time should be optional, as they may contain confidential information. We are concerned that ISSB proposed requirements will lead entities to disclose sensitive information that will disadvantage them against their international competitors not subjected to such requirements. We would therefore welcome if the ISSB Exposure Drafts introduced an option allowing not to disclose the information that is deemed sensitive by the reporting entity.