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There is much momentum behind the ISSB sustainability disclosure standards, but that doesn’t guarantee governments are falling over each other to adopt the framework. In the US, the SEC’s final climate disclosure rules bluntly addressed ISSB standards in footnote 147:

“While we acknowledge that there are similarities between the ISSB’s climate-related disclosure standards and the final rules, and that registrants may operate or be listed in jurisdictions that will adopt or apply the ISSB standards in whole or in part, those jurisdictions have not yet integrated the ISSB standards into their climate-related disclosure rules. Accordingly, at this time we decline to recognize the use of the ISSB standards as an alternative reporting regime.”

To some, that may be a bitter pill to swallow but it could be prescient. In an article from Responsible Investor, Norges Bank Investment Management (NBIM) Chief Governance and Compliance Officer Carine Smith Ihenacho suggested that

“jurisdictions adopting the ISSB standards should aim for ‘relief rather than carving out anything’… if jurisdictions are not ‘totally ready’ to implement the ISSB standards they should avoid carve-outs ‘in order to really go for that global baseline.'”

She brings forward a critical point – there is no guarantee that national bodies will (or are ready to) adopt the ISSB standards whole-hog. Relief rather than carve-outs is a preferable approach, but the political nature of policymaking means it is inherently unpredictable – and sometimes free of the burden of common sense. Individual jurisdictions can choose their own paths that diverge from the ISSB standards and from each other. Transitioning voluntary standards to governmental mandates means reopening debates and decisions that were concluded in the voluntary standard context. There is no certainty here, so give the SEC some credit for trying to avoid additional uncertainty – at least for the time being.

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The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile