SBAI Response - ISSB Exposure Draft on Climate Related Disclosures
The Key Points:
- Clairity that the intended scope of the disclosure requirements are corporate entities (including asset managers) and not investment funds,
- Requesting a later effective date for asset managers reliant on issuer disclosures to complete their own disclosures,
- The potential difficulty of determining the exact contribution of climate-related risks and opportuntities,
- Recommendation to expand the asset list to show assets that are not linked to corporate entities and therefore may not be able to produce climate-related metrics,
- That the requirement for these disclosures to be audited may increase barriers to entry for smaller firms, and
- An offer to assist the ISSB with their guidance and requirements if they choose to extend this disclosure regime to investment funds.