了解全球报告框架
投资者对从事可持续商业活动的公司越来越感兴趣。投资者希望了解公司如何解决气候变化、性别多样性或供应链风险等可能对其业务产生重大影响的问题。
证券交易所和监管机构制定了可持续发展和气候披露法规。目前,全球有 71 家--超过半数的证券交易所制定了 ESG 披露指南;而在 2015 年,只有 13 家。根据联合国可持续发展证券交易所数据库,有27个市场制定了强制性规则,其中16个是新兴市场。
统一可持续发展信息披露标准将创建可靠、可比的ESG数据和信息披露,这对于吸引资本和投资者、防止 "洗绿 "越来越重要。
国际财务报告准则基金会(IFRS Foundation)和欧洲可持续发展报告准则(European Sustainability Reporting Standards)制定了新的可持续发展和气候报告准则,为不同准则和框架的融合迈出了可喜的一步。
国际财务报告准则》可持续发展信息披露标准于 2023 年 6 月 26 日发布,自 2024 年 1 月起 "生效";《欧洲可持续发展报告标准》于 2023 年 7 月 31 日发布,自 2024 年 1 月起生效。
下图展示了过去 20 年中可持续发展信息披露成为主流的重要里程碑。
资料来源:国际金融公司,2023 年:资料来源:国际金融公司,2023 年。
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IFRS Sustainability Disclosure Standards
The IFRS Sustainability Disclosure Standards are developed by the International Sustainability Standards Board (ISSB). The ISSB is an independent, private-sector body that develops – in the public interest – standards that will result in a high-quality, comprehensive global baseline of sustainability disclosures focused on the needs of investors and the financial markets.
The ISSB's standards focus on sustainability-relayed risks and opportunities that are material for investors and are largely build on the Task Force for Climate-related Financial Information (TCFD) Recommendations (see below). As such, implementing the IFRS Sustainability Disclosure Standards also fulfills means that a company has implemented the TCFD Recommendations. The standards cover four core content areas
- Governance: the governance processes, controls and procedures the entity uses to monitor and manage sustainability-related risks and opportunities
- Strategy: the approach the entity uses to manage sustainability-related risks and opportunities
- Risk Management: the processes the entity uses to identify, assess, prioritize and monitor sustainability-related risks and opportunities
- Metrics and Targets: the entity’s performance in relation to sustainability-related risks and opportunities, including progress towards any targets the entity has set or is required to meet by law or regulation
IFRS S1 General Requirements for Disclosure of Sustainability-Related Financial Information provides the conceptual foundations and disclosure content for reporting all sustainability-related financial information, while IFRS S2 Climate-Related Disclosures provides more detailed requirements focusing on climate-related risks and opportunities, within the foundations of IFRS S1. Companies must consider the applicability of the industry-based Sustainability Accounting Standards Board (SASB) Standards (see below) when applying the IFRS Sustainability Disclosure Standards. The standards are to be applied as of January 1, 2024.
Given that IFRS S2 requires information on transition plans to be disclosed (where an entity has such a plan) and that transition plans are a growing component of corporate climate-related disclosures, the ISSB announced that it will assume responsibility for the disclosure-specific materials developed by the Transition Plan Taskforce. Potentially building on pre-existing initiatives, including the SASB standards, CDSB guidance, and the work of the Task Force on Nature-related Financial Disclosures, the ISSB also decided to look into risks and opportunities associated with biodiversity and human capital in the coming two years.
Designed for mandatory adoption by regulators, the IFRS Sustainability Disclosure Standards are being gradually implemented into reporting requirements around the world.
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Global Reporting Initiative (GRI) Standards
The GRI Standards represent global best practice for reporting publicly on a range of economic, environmental and social impacts. Sustainability reporting based on the Standards provides information about an organization’s positive or negative contributions to sustainable development.
The GRI Standards is a modular system of interconnected standards, delivering an inclusive picture of an organization's material topics, their related impacts, and how they are managed. Three series of Standards support the reporting process:
- the GRI Universal Standards, which apply to all organizations;
- the GRI Sector Standards, applicable to specific sectors;
- the GRI Topic Standards, each listing disclosures relevant to a particular topic.
Using these Standards helps organizations to determine what topics are most to achieve sustainable development.
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European Sustainability Reporting Standards
The EU Corporate Sustainability Reporting Directive (CSRD) modernizes and strengthens the rules concerning the social and environmental information that companies headquartered in the EU, or those with significant operations in the EU, have to report. A broader set of large companies, as well as listed SMEs, will now be required to report on sustainability.
Certain European companies have to apply the new rules from the 2024 financial year, for reports published in 2025, with others being phased in over 2026 and 2027. Finally, non-EU companies with significant operations in Europe will have to start reporting from 2029, based on FY 2028 data, using a simplified set of standards.
Companies subject to the CSRD will have to report according to European Sustainability Reporting Standards (ESRS).
The ESRS set general requirements for to guide the disclosure of all sustainability information and require all organizations to report on four areas of general disclosures:
- Governance
- Strategy
- Impacts, risks, and opportunities
- Metrics and targets
Depending on their materiality to the organization, it may also disclose using a number of topical standards:
Environmental
- Climate Change
- Pollution
- Water and marine resources
- Biodiversity and ecosystems
- Resource use and circular economy
Social
Governance
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Integrated Reporting Framework (part of the IFRS Foundation)
The Integrated Reporting Framework is a principles-based framework used by organizations to communicate clearly and concisely about how its strategy, governance, performance and prospects – in the context of its external environment – lead to the creation, preservation or erosion of value over time. The Integrated Reporting Framework categorizes the inputs and outcomes of accompany into six capitals: Financial, Manufactured, Intellectual, Human, Social and relationship, and Natural.
As of August 2022, the International Sustainability Standards Board (ISSB) of the IFRS Foundation assumed responsibility for the Integrated Reporting Framework.
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SASB Standards (part of the IFRS Foundation)
The SASB Standards help companies disclose material, industry-specific sustainability information to their investors in the context of the IFRS Sustainability Disclosure Standards (see above).
Available for 77 industries, the SASB Standards identify the sustainability-related risks and opportunities most likely to affect an entity’s cash flows, access to finance and cost of capital over the short, medium or long term and the disclosure topics and metrics that are most likely to be useful to investors.
As of August 2022, the International Sustainability Standards Board (ISSB) of the IFRS Foundation assumed responsibility for the SASB Standards. The ISSB has committed to maintain, enhance and evolve the SASB Standards and encourage their use, and in 2023 updated the standards to ensure their international applicability.
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US SEC Climate Disclosure Rules
The US Securities and Exchange Commission has adopted new rules on climate-related disclosures in March 2024. These rules apply to all companies that have an existing requirement to report to the SEC, including, non-US companies that trade shares on a US exchange.
Built on the TCFD Recommendations (see below), the disclosure rules will require SEC registrants to disclose information on:
- Material climate-related risks
- Material impacts of climate-related risks on the organization’s strategy, business model and outlook
- Any climate risk mitigation or adaptation activities undertaken by the registrant, if applicable
- A description of the registrant’s climate transition plan, if applicable
- The material climate-related outcomes of a scenario analysis, if applicable
- The use of an internal carbon price by the registrant, if material
- Oversight of climate-related risks by the registrant’s board of directors and management
- Climate risk management processes, if applicable
- Climate related targets and goals, if applicable and material
- Material Scope 1 and/or Scope 2 emissions metrics, if the company is not exempted
- Certain financial maters related to materialized climate risk
The phased implementation, with a subset of registrants required to report a subset of the rules starting for their fiscal year beginning in 2025, until full implementation for reports covering fiscal year beginning 2027
A summary of the requirements is available here.
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Task Force on Climate-related Financial Disclosures (TCFD) Recommendations (part of the IFRS Foundation)
The recommendations of the Task Force for Climate-Related Financial Disclosure (TCFD) were launched in 2017 “to help identify the information needed by investors, lenders, and insurance underwriters to appropriately assess and price climate-related risks and opportunities.” The TCFD Recommendations comprise of four core elements:
- Governance
- Strategy
- Risk Management
- Metrics and Targets
The recommendations were intended for voluntary implementation, but they are increasingly becoming mandatory in markets such as Brazil, Japan, Singapore, Switzerland, the United Kingdom, and others. More than 4,900 companies provided TCFD reports as of October 2023.
The climate-related and general sustainability-related disclosure standard of the International Sustainability Standards Board (ISSB) ) marked the culmination of the TCFD and the ISSB has now taken over responsibility for monitoring progress of companies’ climate-related disclosures from the TCFD.
For additional resources on TCFD, visit the TCFD Knowledge Hub, see the TCFD’s final status report and the TCFD publications web page.
下表提供了主要可持续发展框架和标准的简要比较,包括
- 全球报告倡议组织(GRI)标准;
- 欧洲可持续发展报告标准;
- 综合报告框架 - 现为《国际财务报告准则》基金会的一部分;
- 可持续发展会计准则委员会 (SASB)- SASB 准则 - 现为《国际财务报告准则》基金会的一部分;
- 气候相关财务披露特别工作组 (TCFD)建议 - 现为《国际财务报告准则》基金会的一部分;
- 国际可持续发展准则委员会 (ISSB)- 《国际财务报告准则》S1 披露可持续发展相关财务信息的一般要求和《国际财务报告准则》S2 气候相关披露。
- 国际财务报告准则》可持续性披露准则的辅助材料
- WBCSD CFO 网络: 国际可持续发展标准委员会 (ISSB) 标准和欧洲可持续发展报告标准 (ESRS) 实施指南
比较的重点是工具的类型、是自愿性还是强制性、其地理覆盖范围、涉及的主题以及重要性的定义。
比较美国证券交易委员会 (SEC)、欧洲可持续发展报告标准 (ESRS) 和国际可持续发展标准委员会 (ISSB) 的气候披露。
注: CSRD= 企业可持续发展报告指令;EFRAG= 欧洲财务报告咨询小组;ESG= 环境、社会和治理;ESRS= 欧洲可持续发展报告标准;EU= 欧洲联盟;FY= 财政年度;ISSB= 国际可持续发展标准委员会;SEC= 美国证券交易委员会。
用于气候披露比较表的比较研究:
- 可持续发展信息披露的演变:比较 2022 年 SEC、ESRS 和 ISSB 提案;
- 欧洲可持续发展报告准则草案》,附录 V:《国际财务报告准则》可持续发展准则与《欧洲财务报告准则》调节表(《欧洲财务报告准则》E1 与《国际财务报告准则》S2 对比,第 54-73 页);
- ISSB IFRS S2 气候相关披露与 TCFD 建议的比较;
- 全球报告倡议组织和欧洲可持续发展报告准则 (ESRS):问答;