Authors – Vanessa Boudreau-Sannier and Jessica Di Bartolomeo
2022 is set to mark several important developments in the sustainability reporting landscape, especially in North America, where the move towards mandatory climate and sustainability disclosures has begun.
The demand for high-quality sustainability information on par with financial data is continuing to increase, driven in great part by investors who want to understand how the sustainability risks and opportunities faced by organizations impact their value. While investor-focused mandatory climate disclosure is already well-established in some countries (for instance our UK offices have been supporting customer reporting to UK Financial Conduct Authority’s Listing Rules Handbook for climate disclosures and Companies Act 2006 for Greenhouse Gas emissions reporting for many years), North America has been slower in imposing such practices.
Many of the new regulations and standards are based around the requirements of the Task Force on Climate-Related Financial Disclosures (TCFD).
In Canada, the Prime Minister has recently directed its Minister of Finance and its Minister of Environment and Climate Change to move toward mandatory climate-related financial disclosures and to require federally regulated institutions including financial institutions, pension funds and government agencies, to issue climate-related disclosures and net-zero plans.
The Ontario Securities Commission (OSC) was the first to recommend mandatory climate and ESG disclosure for public companies in their 2021-2022 Statement of priorities in alignment with TCFD guidance.
The Canadian Securities Administrators (CSA) followed with consultation documents on mandatory climate disclosure requirements for issuers in Canada in October 2021. Based on the TCFD recommendations, the financial disclosures will follow four themes: Governance, Strategy, Risk management, and Metrics and targets, including Greenhouse Gas emissions.
According to the draft national instrument, public companies listed on Canadian stock exchanges can expect new sustainability related disclosure requirements as of the 2023 reporting year. Venture issuers would have until 2025 to be phased in. The regulations would implicate approximately 3,400 reporting issuers, including 2,972 companies that are listed, for example, on the Toronto Stock Exchange.
The CSA has also published guidance on Environmental, Social, and Governance (ESG)-related investment fund disclosure in January 2022.
To help meet the new requirements, an understanding of the following standards will be useful: The GHG Protocol, noted as the basis of emissions reporting standards; TCFD, which provides the overarching framework for the mandatory disclosures; and the Carbon Disclosure Project (CDP), Global Reporting Initiative (GRI), and Sustainability Accounting Standards Board (SASB), which the CSA references as the most commonly used voluntary sustainability and ESG frameworks by Canadian companies.
The CSA also supports the creation of a consolidated set of sustainability standards by the International Financial Reporting Standards (IFRS) Foundation (see “ISSB” section) and believes that the proposed regulatory requirements in Canada would align with the upcoming IFRS standards.
In response to the creation of an international board, the Independent Review Committee on Standard Setting in Canada has launched consultations on the creation of a Canadian Sustainability Standards Board, which ends on March 31.
The United States is similarly expected to develop mandatory climate risk reporting in 2022. The Securities and Exchange Commission (SEC) created the Climate and ESG Task Force in 2021 to spearhead these efforts. SEC Chair Gary Gensler has indicated that the regulations would apply to public companies, with specific guidance for industries such as banking, insurance, and transportation, as well as sustainable investment funds.
To help meet the upcoming requirements, the TCFD framework will be most useful, as it will form the basis of the new regulations.
Another important signal that sustainability performance and metrics are taking the center stage in corporate disclosure and strategy is the creation by the IFRS, an organization that is behind one of the two main sets of standards of accounting rules for the financial statements of public companies, of the International Sustainability Standards Board (ISSB), which was announced last November at COP26. The ISSB aims to develop, by the end of 2022, a global baseline of sustainability disclosure standards to help meet investors’ needs for high-quality information.
The ISSB will consolidate existing leading investor-focused sustainability disclosure organizations, including the Climate Disclosures Standard Board (CDSB)- an initiative of the CDP – and the Value Reporting Foundation, which houses the Integrated Reporting Framework and the SASB Standards.
The intention is to build those Sustainability Disclosure Standards in a way that will facilitate their integration in jurisdiction-specific mandatory disclosure requirements and that will help meet the needs of investors. This focus on investors’ needs and the fact that the ISSB was set up by the main body covering financial reporting standards, the IFRS, signals that the new set of standards may help bring enhanced comparability, coherence and transparency to the world of sustainability reporting.
Prototype standards have already been published and cover climate-related information and general requirements for sustainability disclosures. They are based on existing standards, including TCFD. The ISSB aims to hold a public consultation on the proposed guidance in 2022.
Climate change metrics, because they are measurements of impacts, are ruled by specific accounting and reporting methodologies. The climate-related disclosure prototype supplemental technical protocols make explicit reference to the GHG Protocol Corporate Accounting and Reporting Standard’s methodologies – using the financial control approach – as well as sector-specific and other guidance documents that conform and build on it (for instance, ISO 14064-1; GHG Reporting Guidance for the Aerospace Industry provided by International Aerospace Environmental Group (IAEG); Greenhouse Gas Inventory Guidance: Direct Emissions from Stationary Combustion Sources provided by the U.S. Environmental Protection Agency (EPA); and the Intergovernmental Panel on Climate Change (IPCC) Fifth Assessment Report for preferred Global Warming Potential values).
Whether the US and Canada will specifically use or reference the ISSB’s standards and whether those mandatory reporting requirements will favor coherence and comparability remains to be seen. However, it is clear that most important sustainability reporting updates mentioned here are investor-focused and TCFD-aligned. The future of sustainability reporting in North America is therefore lined up to focus on climate-related risk assessment and to provide useful forward-looking information in disclosures.
How Ecometrica can help
Sustainability and climate change reporting requires robust metrics and transparency in order to be credible, and this has been at the core of Ecometrica’s offering for nearly 15 years. Our software tool is built on best practices from the GHG Protocol and integrates other best practice solutions based on existing standards, including CDP and TCFD.
Ecometrica’s Platform features are designed by a team of expert practitioners who are also on-hand to guide our clients throughout their reporting process by answering their questions, reviewing their data and helping them set science-based targets and improve on their reporting so they can be confident in their disclosures.
In addition to having unrivalled experience in voluntary disclosure, we have built a strong track record in mandatory reporting, helping UK companies meet regulatory carbon disclosures requirements and TCFD-aligned reporting. We are well-placed to offer you software solutions and services to help obtain robust, transparent and auditable metrics.
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