Response to the IFRS consultation paper on Sustainability Reporting

The IFRS working to promote convergence of existing standards for sustainability reporting would be welcomed, rather than proposing a new set of standards. In particular, IFRS could leverage progress already made by the TCFD.

The TCFD framework provides the foundations for reporting of climate-related financial information and is a globally recognised standard. It will be important for IFRS to build on this to avoid first-movers having to make significant adaptations to any new framework on climate data.

In addition, any proposal for a new standard should also consider and build upon the work conducted by GRI, SBAS, EU Taxonomy/EFRAG and monitor the developments under the review of the NFRD and its guidelines. Further global consistency would be best achieved by the IFRS working together with existing stakeholders.