SBAI Response - ISSB Exposure Draft on Climate Related Disclosures

We respond to the International Sustainability Standards Board's (ISSB) consultation on Climate Related Disclosures. Key points raised include clarity of scope and a later effective date for asset managers reliant on issuer 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.