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Previously, we discussed ISSB Chair Emmanuel Faber’s comments on double materiality and his rejection of it for the ISSB. Faber’s comments drew criticism from those that believe he maligned the concept. Recently, IPE ran a comment piece arguing that Faber’s position is untenable. The commentary addresses each of the three major points Faber raised and addresses flaws and assumptions in his arguments. The article states that:

“Proponents of impact materiality have heard these calls to put an end to divisive narratives before and many have concluded that they were simply uttered to avoid an honest debate about material differences of views in relation to the responsibility of businesses and the integration of ESG concerns into accounting and reporting systems.”

The article goes on to argue that we cannot rely on profit-seeking behaviors alone to correct for the harms caused by climate change. Because financial materiality focuses only on business impacts this could potentially leave other important issues unaddressed when profit motives do not align with good climate policy.

This counterpoint makes some compelling arguments. Perhaps we shouldn’t view financial materiality as the endpoint. However, it is a starting point that industry is historically familiar with. I stated previously that the world may be big enough for both financial materiality and double materiality. To me, the IPE piece makes a good argument. However, most jurisdictions still struggle to implement even basic GHG reporting frameworks. That, combined with a lack of accounting standards and a consensus approach to impact determination, we aren’t quite ready to dive into the deep end of double materiality reporting. Companies are certainly free to produce voluntary disclosures as they wish – and may even want to look towards a future that includes double materiality. But for now, it might be best to walk before you start sprinting towards the finish line.

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The Editor

Zachary Barlow is a licensed attorney. He earned his JD from the University of Mississippi and has a bachelor’s in Public Policy Leadership. He practiced law at a mid-size firm and handled a wide variety of cases. During this time he assisted in overseeing compliance of a public entity and litigated contract disputes, gaining experience both in and outside of the courtroom. Zachary currently assists the editorial team by providing research and creating content on a spectrum of ESG… View Profile