EFAMA shares the urgent need to improve the consistency and comparability of sustainability reporting at a global level. Therefore, we welcome the opportunity to respond to the ISSB consultation on the Exposure Drafts on “General Requirements for Disclosure of Sustainability Related Financial Information” (IFRS S1) and on “Climate-Related Disclosures” (IFRS S2). EFAMA appreciates the work done by the ISSB, which will represent a progress in fostering the vision of comparable investor-relevant sustainability-related information.

Our recommendations include the following:

• Interoperability between standards and double materiality as criteria
• Including some mandatory indicators to allow alignment with SFDR PAIs
• Reaching common ground in the disclosure requirements for information on material risks and opportunities from the perspective of enterprise value creation
• Providing clarity on the use of the terms “significant” and “material”