SBAI Response - ISSB Exposure Draft on General Sustainability Disclosures

We respond to the International Sustainability Standards Board's (ISSB) consultation on general sustainability disclosures in financial statements. Key points raised include clarity of scope and additional guidance recommendations for asset managers.

The key points that we raise in this response include:

• A request to clarify that this reporting is intended for corporate entities (including asset managers) and not for investment funds,
• Highlighting that the requirement for audited information may create increased barriers to entry for smaller firms,
• Asset managers may look to our Responsible Investment Policy Framework for additional guidance on disclosures, and
• If this disclosure regime is to be extended to investment funds that we would be happy to assist the ISSB with understanding the requirements and nuances involved.