International Sustainability Standards Board – Exposure Drafts

 

 

The Property Council of Australia and the Green Building Council of Australia (GBCA) welcome the opportunity to provide comments on the International Sustainability Standards Board (ISSB)’s Exposure Drafts on [Draft] IFRS S1 and [Draft] IFRS S2 on sustainability-related financial reporting.

The Property Council and GBCA support the Peak Australian bodies submission, dated 18 July 2022, made by a coalition of Australian industry representative bodies and offer the following comments from a property specific perspective.

We support a global approach to the development of sustainability disclosure standards, and we are supportive of the ISSB being the global body to issue these standards.

The overarching goal should be a globally consistent, comparable, reliable, and assurable corporate reporting system to provide all stakeholders with a clear and accurate picture of an organisation’s ability to create sustainable value over time. We consider it critical that the ISSB and other jurisdictions developing sustainability standards take a coordinated approach by aligning key concepts, terminologies, and metrics on which disclosure requirements are built.

The current fragmentation of regulation and standard-setting is adding confusion, complexity and costs for both respondents and users of sustainability reporting – detracting attention from the important actions that need to be taken to meet ESG commitments.

We note there are challenges in establishing a global baseline and provide comments below on suggested approaches or changes within the draft exposure drafts.

In our December 2022 submission to the initial consultation paper, we recommended engaging with existing sustainability frameworks and welcome the collaborative work of the ISSB to date.