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Industrial Sustainability Reporting Guide For 2024 and Beyond

Meeting today’s mandatory regulations requires the right data-driven digital tools

While calls for transparent industrial sustainability reporting have been growing louder in recent years, 2024 is the year they move from a voluntary nice-to-have to a mission-critical mandatory activity with significant real-world consequences.

Not only are global regulators mandating accurate sustainability reporting across the supply chain, but customers, partners and staff are demanding tangible action on emissions reductions, particularly from energy-intensive industries.

To maintain operations in many major markets, and stay competitive over time, new standards will require industrial organisations to disclose sustainability indicators such as greenhouse gas (GHG) emissions across Scopes 1, 2 and 3, water, energy, air quality, waste, hazardous materials, pollutants, nature-related risk factors, product carbon footprint (PCF), life cycle assessment (LCA) and Taskforce on Nature-related Financial Disclosures (TNFD) impacts.

Siloed legacy systems, manual processes and lack of data analytics are the biggest barriers for traditional industries. However, if industrial leaders don’t understand their obligations and catch up fast, they face major risks to their compliance, reputation and revenue.

This guide outlines the essentials of industrial sustainability reporting, compares the three primary global frameworks and explains how digital tools can ensure a smooth transition to the new era of legislated accountability.   


What is sustainability reporting?

Sustainability reporting is a catch-all term that is often misunderstood. In truth, it can mean different things in different contexts.

Broadly speaking, sustainability reporting involves disclosing an organisation’s economic, environmental and social impacts, risks, opportunities, targets, progress and performance to various stakeholders. It serves as a tool for accountability, allowing stakeholders to assess an organisation’s commitment to sustainable practices and its overall impact on society and the environment.

For example, when organisations pledge initiatives towards net zero, they need to quantify and report on the progress towards these targets using quantitative metrics.

Sustainability reporting definitions

In recent times, sustainability reporting has often focused on greenhouse gas emissions and climate change, and has been used interchangeably with terms like climate reporting or carbon accounting. While they are all closely related and overlap, there are important differences.

This section defines some of the common sustainability reporting definitions, including how they fit under the broader umbrella.


Sustainability is described in the International Sustainability Standards Board’s (ISSB) General Sustainability-related Disclosures Standard (S1) as:

“The ability for a company to sustainably maintain resources and relationships with and manage its dependencies and impacts within its whole business ecosystem over the short, medium and long term. Sustainability is a condition for a company to access over time the resources and relationships needed (such as financial, human, and natural), ensuring their proper preservation, development and regeneration, to achieve its goals.”

ESG Reporting

This covers the disclosure of an organisation’s environmental, social and governance (ESG) performance to stakeholders. This is a key component of sustainability reporting, which takes in a broader range of economic, environmental and social impacts.

Done well, ESG reporting provides transparent and standardised information on how a company manages its impact on the planet, society and its governance structures, allowing investors, suppliers, staff and customers to assess its sustainability practices and make informed decisions.

Carbon Accounting

Carbon accounting involves quantifying and tracking the greenhouse gas emissions produced directly or indirectly by an organisation. Another crucial aspect of sustainability reporting is that it provides a view of a company’s environmental impact, particularly its contribution to climate change.

By measuring and reporting these emissions, companies can identify opportunities to reduce their carbon footprint, set emission reduction targets and demonstrate their commitment to mitigating climate change.

Emissions Accounting

Emissions accounting quantifies all emissions produced by an organisation, encompassing not only greenhouse gases but also pollutants and other harmful substances released into the environment.

A vital component of sustainability reporting is that it allows companies to identify areas for improvement, implement strategies to reduce emissions and transparently communicate their environmental impact to stakeholders as part of their sustainability initiatives.

Climate Reporting

Another broader term, climate reporting refers to disclosing an organisation’s impact on and response to climate change, encompassing greenhouse gas emissions, climate-related risks and opportunities, strategies for mitigating environmental impact, adaptation measures and alignment with global climate goals.

It helps stakeholders understand a company’s contribution to climate change, its resilience to climate-related risks and its commitment to addressing these challenges.

Nature Reporting

Nature reporting refers to the evaluation and disclosure of an organisation’s relationship with and impacts on biodiversity loss, ecosystems and natural resources, including strategies for conservation, sustainable resource management and enhancing natural capital.

Nature reporting aims to demonstrate an organisation’s commitment to biodiversity conservation and foster a deeper understanding of its environmental stewardship beyond just climate-related concerns.

Three primary Sustainability Reporting Frameworks

Over the years global jurisdictions have responded independently to the emerging era of accountable sustainability, creating a tangled patchwork of inconsistent rules, regulations and guidelines. EY estimates that there are over 600 ESG frameworks across the globe1, with many having differing interpretations of sustainability.

In response to an increasingly urgent need for simpler and consistent rules to manage global markets, the majority of these are rolling up under three main frameworks that industry leaders will need to understand:

  • ISSB: International Sustainability Standards Board
  • CSRD: EU Corporate Sustainability Reporting Directive
  • SEC: Securities and Exchange Commission

The key reason for the focus on these three umbrella frameworks is their broad geographic reach that covers many global markets and, therefore, their potential to reach and direct high volumes of organisations.

Large industrial enterprises are likely to be impacted by one, two or all three of these frameworks. For example, a large multinational that is registered with the SEC and has a subsidiary operating in the EU and in an ISSB-adopted jurisdiction, may need to report in accordance with all three frameworks.

The shift from voluntary to mandatory reporting is here

While specific rules and regulations will vary in local jurisdictions, the sustainability reporting landscape is rapidly moving from voluntary to mandatory reporting rules in many regions.

Referencing relevant government standards like International Financial Reporting Standards (IFRS), European Sustainability Reporting Standards (ESRS) and US SEC2, and drawing on sources including KPMG’s Comparing sustainability reporting requirements3 and Survey of Sustainability Reporting9, this table summarises the key changes that are on the radar in 2024 and beyond for each of the three primary frameworks:

Voluntary reportingMandatory reporting

Frameworks (voluntary standards used internationally by N100* companies)

Note – companies can report across many frameworks.

GRI is the most dominant standard used internationally by N100 companies – Singapore, Taiwan, Chile, Brazil, Spain, Italy, Austria, Finland, Japan and Argentina. Since 1997, GRI has remained the most incumbent standard for non-financial reporting.

SASB is the leading reporting standard among companies in the USA, Canada, Brazil, Mexico, UK, Chile, Uruguay, Hungary, Argentina and Taiwan.

33% of N100 companies report against the SASB, primarily driven by the USA and Canada. There has been increasing uptake among Europe’s N100 companies with 35% adoption in 2022.

The SASB standards were developed in 2011 to guide companies on investor-focused sustainability disclosures. In 2022, the SASB was consolidated into the IFRS foundation and now forms part of the ISSB standards released in 2023.

Stock exchange – country stock exchange guidelines dominate where GRI and SASB usage is lower in South Africa, Malaysia, India, Singapore, Taiwan, Thailand, China, UAE and Mexico. Close to 25% of N100 companies use their domestic stock exchange guidelines or standards.

TCFD – 34% of the N100 reported using the TCFD recommendations and 61% of G250** observed the TCFD in 2022. This reflects the change to mandatory TCFD-aligned climate reporting. The TCFD was established in 2015 to respond to the threat of climate change to the stability of the global financial system.

New Zealand was the first country in the world to mandate TCFD climate-related financial disclosures. From 1 January 2023, listed entities and some financial services businesses are to report to the TCFD for their first accounting period after this date.

Top 10 N100 countries reporting towards TCFD in 2022 were Japan, UK, Taiwan, US, France, South Africa, Canada, Thailand, The Netherlands and Sweden.

UN Sustainable Development Goals (SDG)

71% of N100 report to the SDG. 17 UN SDGs launched in 2015, introduced by the United Nations (UN) to achieve a more sustainable future addressing global challenges including poverty, inequality, climate change, environmental degradation, peace and justice.

Biodiversity reporting

New standards have been introduced to report on risks that companies face from the loss of nature and biodiversity. 40% of N100 companies reported on biodiversity in 2022 – Top four reporters are the UK, Thailand, South Africa and Japan.

Reporting standards such as the TNFD, ISSB topic specific standards and the CSRD will drive improvements in disclosure.

*N100 refers to a worldwide sample of 4,900 companies comprising the top 100 companies by revenue in each of the 49 countries used in the sample.

** G250 are the top 250 companies globally by revenue.

Reference: KPMG, Big shifts, small steps, Survey of Sustainability Reporting 20229

Frameworks (EU mandatory standards, SEC mandatory standards and ISSB standards to be determined and adopted into law by individual jurisdictions) 

New legislation, guidelines and proposals for sustainability reporting for 2024 and beyond are:

ISSB standards/ IFRS Sustainability Disclosure Standards

  • Investor focused, single materiality/ financial materiality
  • 2 standards:
    • ISSB S1 – General principles to report across all sustainability-related risks and opportunities
    • ISSB S2 – Topic specific on climate reporting with industry specific disclosures
  • Companies need to consider the SASB standards for other topics, based on the 77 industry specific SASB standards
  • Future topic specific standards to be released
  • ISSB will consider the work of the TNFD and other existing nature-related standards where they relate to the information needs of investors.

During COP28, ISSB announced 400 organisations from 64 jurisdictions signed a statement committing to advancing the global adoption of its climate related standard. More than 20 regulators and standard setters issued statements of support including policy makers from ASEAN, Brazil, Brunei, Canada, the European Union, Germany, Ghana, Hong Kong, Japan, Kenya, Mauritius, Mexico, Myanmar, Nigeria, the Philippines, Singapore, Turkey, the United Kingdom, Uruguay and Vietnam.

ISSB effective date is 1 January 2024

CSRD, ESRS from the EU

  • Double materiality – Investor focused as well as environmental impact and multi stakeholder focused.
  •  12 EU standards

ESRS1, ESRS2 core principle for disclosure. Other 10 standards and topic-specific standards require granular disclosures.

  • Industry specific requirements will be released in the future.

This applies to a broad range of EU companies (large EU companies and all companies listed in the EU) and some non-EU companies with significant operations in the EU.

50,000 large companies across EU member states will be required to disclose data on the impact of their business operations across ESG themes.

In 2023, the ESRS delegated act was watered down, moving away from originally proposed disclosure indicators that were to be mandatory and now allowing companies to report relevant information determined through a materiality assessment. Sector specific standards that were to be developed are likely to be delayed until 2026.

Effective date is 1 January 2024.

US SEC climate rule, proposed requirements from the US

  • Investor focused
  • Requirements to report on climate risks and opportunities only
  • No industry specific disclosures other than industry appropriate GHG emissions intensity metric

Set to formally announce climate rules in 2024.

These rules apply to nearly all US SEC registrants, including some foreign private issuers.

Effective date is open until adoption of the final rules.

The TCFD forms a shared input amongst these, however there are areas where they are not aligned. This presents challenges to multinationals operating across many jurisdictions that will therefore need to apply multiple frameworks.

Reference: KPMG, Comparing sustainability reporting requirements, Updated Nov 20233

ISSB: International Sustainability Standards Board

What are the ISSB sustainability reporting standards?

Now one of the primary global frameworks, the ISSB was established as part of the International Financial Reporting Standards (IFRS) Foundation in 2021 and builds on, consolidates and manages the work of market-led, investor-focused reporting initiatives including the:

  • Climate Disclosure Standards Board (CDSB), the
  • Task Force for Climate-related Financial Disclosures (TCFD), the
  • Value Reporting Foundation’s Integrated Reporting Framework and industry-based Sustainability Accounting Standards Board (SASB) Standards.

On 26 June 2023, the ISSB issued two international standards for investor-focused sustainability reporting. IFRS S1 – being General Requirements for the Disclosure of Sustainability-related Financial Information, and IFRS S2 – covering climate related disclosures. Their intention is to create a global baseline for sustainability-related financial disclosures.

Both standards are based on the four pillars used in the TCFD framework; governance, strategy, risk management and sustainability-related metrics and targets – referred to in the standards as the ‘core content’.

These standards, which will set a global baseline in sustainability-related financial disclosures, have been developed in response to calls from primary users of general-purpose financial reports for more information about the entity’s sustainability-related risks and opportunities that materially impact an entity’s future cash flows, financial position and performance.

It is now for jurisdictions to decide if and how they will incorporate these standards into national law or for companies to adopt the ISSB standards voluntarily.

Recent ISSB updates

Australia, and several other jurisdictions, are either planning or have introduced mandatory disclosure requirements for large businesses. Countries that have indicated that they will adopt these standards are the UK, Australia, Canada, Japan, Singapore, Nigeria, Chile, Malaysia, Brazil, Egypt, Kenya and South Africa. Notably, the US is NOT one of the jurisdictions.

IFRS created the ISSB. IFRS financial accounting standards are used in 168 jurisdictions (132 countries), however the IFRS climate disclosure standards must be adopted by the individual jurisdictions.

A groundswell of global support

At COP28 in December 2023, close to 400 organisations from 64 jurisdictions, including associations gathering over 10,000 member companies and investors, joined multilateral and market authorities to commit to advancing the adoption or use of the ISSB.4

This demonstrates a groundswell of global support for action on climate change risks and clear standards that create comprehensive and comparative sustainability disclosures and information about organisations’ climate resilience strategies.

The IFRS also reported5 that many influential groups have signaled their support including:

  • 25 stock exchanges, as well the African Securities Exchanges Association which represents 27 securities exchanges and the Arab Federation of Capital Markets (representing 17 stock exchanges).
  • Regulators and standard setters from ASEAN, Brazil, Brunei, Canada, the European Union, Germany, Ghana, Hong Kong, Japan, Kenya, Mauritius, Mexico, Myanmar, Nigeria, the Philippines, Singapore, Turkey, the United Kingdom, Uruguay and Vietnam.
  • IOSCO and the Financial Stability Board of G20, joined by the International Monetary Fund (IMF), Organisation for Economic Co-operation and Development (OECD), United Nations entities, the World Bank and the Asian Development Bank, and echoed by Network for Greening the Financial System (NGFS).
  • The ISSB’s key partners in the sustainability disclosure landscape including the Global Reporting Initiative (GRI), CDP and the Taskforce on Nature-related Financial Disclosures (TNFD) also reaffirmed their support for the work of the ISSB.

What is the status of ISSB?

Although there is a high demand for a single global standard, the United States and the European Union are separately developing climate reporting systems.

To establish compatibility, the ISSB has collaborated with officials from the US, Europe, Japan and China, as well as the International Organisation of Securities Commissions (IOSCO). The IOSCO is an international organisation of securities and/or futures regulators with 239 members from 132 jurisdictions. Those members regulate 95% of the world’s securities markets. Following its comprehensive review, in July 2023 the IOSCO announced its endorsement of the ISSB standards, and rapid adoption is expected in a number of jurisdictions.6

Both New Zealand and the UK recently passed legislation that made climate-related disclosures mandatory for a subset of businesses. Brazil has announced that ISSB’s7 IFRS Sustainability Disclosure Standards will be incorporated into their regulatory framework, setting out a roadmap to move from voluntary use starting in 2024 to mandatory use on 1 January 2026.

Why is ISSB important?

Currently, efforts are being made to establish a universal standard for ensuring sustainability-related disclosures, with ongoing work by the International Accounting and Assurance Standards Board to create ISSA 5000 as the worldwide benchmark for providing assurance on sustainability disclosures. Their intention is to create a global baseline for sustainability-related financial disclosures.8

The two standards are designed to disclose decision-useful information to capital markets and securities regulators and require information about all material sustainability-related and climate-related risks and opportunities that could reasonably affect the cash flow of an entity, access to finance and the cost of capital.

What is declared as material aligns with the International Accounting Standards Board (IASB) definition stating: “Information is material if omitting, misstating or obscuring it could reasonably be expected to influence the decisions that the primary users of general-purpose financial statements, which provide financial information about a specific reporting entity.”

Who does ISSB impact?

Potentially large listed, heavy emitters and financial institutions in the first instance, but it may become broader. It is now for jurisdictions to decide if and how they will incorporate these standards into national law or for companies to adopt the ISSB standards voluntarily.

What are the ISSB reporting requirements?

The ISSB reporting requirements are investor focused and go above and beyond the TCFD in that they provide a detailed reporting framework and are far more prescriptive than the TCFD’s higher level guidelines, including a step up in the number of quantitative disclosures that are expected.8

This is in relation to:

  1. Disclosure of quantitative impacts on strategy for addressing climate-related risks and opportunities
  2. Increased disclosure on industry-based metrics and greenhouse gases, including Scope 3 emissions
  3. Relevance of targets used by the organisation.

Detailed qualitative and quantitative disclosure extends to other sustainability risks and opportunities including biodiversity, fresh water and human capital. The proposed ISSB climate standards require the disclosure of a significant amount of inherently uncertain forward-looking information to the market, and granular detail around transition plans.8

When is ISSB in effect?

It is now for jurisdictions to decide if and how they will incorporate these standards into national law or for companies to adopt the ISSB standards voluntarily.

CSRD: EU Corporate Sustainability Reporting Directive

What is the CSRD?

The CSRD requires companies to report on their sustainability information to provide investors and stakeholders with information to assess investment risks related to climate change and other sustainability factors, and to report on the company’s impact to people and the environment.

The CSRD was adopted by the European Parliament and the European Council in November 2022, and entered into force on 5 January 2023. Member states of the EU must incorporate the CSRD into their local law by July 2024.

The European Commission has mandated the European Financial Reporting Advisory Group (EFRAG) to develop standards detailing what is to be reported under the CSRD. These standards are called European Sustainability Reporting Standards (ESRS), covering a set of 12 reporting factors, including climate change, pollution and other aspects of corporate sustainability.

What are the CSRD sustainability reporting standards?

In November 2022 the European Commission adopted the CSRD proposal, requiring large companies and all companies listed on regulated markets to report on social and environmental impacts. It has been described as an inside-out view of the company’s impact on the environment and society.9

The provisions of the CSRD are broad in scope and apply to many companies operating in the EU, estimated to be nearly 50,000 in total.10

Recent CSRD updates

EU CSRD and Global Reporting Initiative (GRI) have worked together with a big focus on interoperability between the frameworks and double materiality (financial impact and impact to climate, environment and society). It includes reporting on risks they face from the loss of nature and biodiversity – disclosures around these aspects are likely to grow over time.9

Limited assurance is mandatory from the onset, moving to reasonable assurance requirements in the near future.10 New enhanced standards are ESRS that cover a set of 12 sustainability reporting standards.

What is the status of CSRD?

The CSRD is active as of 5 January 2023, requiring a broader set of large companies, as well as listed SMEs, to report on sustainability. The first companies will have to apply the new rules for the first time in the 2024 financial year, for reports published in 2025.11

Why is CSRD important?

Despite the entry into force of the Non-Financial Reporting Directive (NFRD) in 2017, reporting far too often still fails to offer investors a clear understanding of a companies’ development, performance, position and impact, as it lacks the necessary quality, consistency, comparability and coherence. The intention of this latest framework is to increase the consistency and comparability of sustainability reporting.

To achieve a comprehensive corporate reporting system based on existing reporting standards and frameworks, the CSRD plans for the adoption of ESRS. The ongoing international standardisation process offers an opportunity to standardise reporting on enterprise value and set a global baseline, on which Europe can build on and innovate beyond reflecting its own policy priorities.11

As part of the CSRD, companies shall disclose information in line with the targets of limiting global warming to 1.5°C and with climate neutrality by 2050.10

Who does CSRD impact?

The CSRD is expected to increase the number of firms subject to EU sustainability reporting requirements to approximately 49,000.10

What are the CSRD reporting requirements?

The double materiality assessment requires companies to identify both their impact on people and environment (impact materiality) as well as the sustainability matters that financially impact the undertaking (financial materiality).

Organisations will have to set targets, select a baseline and report progress towards these targets in line with the EU taxonomy. All reporting will need to be in one report, so they’ll need to reshape their existing reporting structure to accommodate new information and different types of information required.10

The CSRD standards include a range of calculations across Scopes 1, 2 and 3 (Scope 3 component categories only need to be disclosed if it is material).

When is CSRD in effect?

From Q1 2024 companies will have to start publishing their first reports following the CSRD requirements. From 1 January 2026 reporting against CSRD requirements will be enforced for SMEs.11

SEC: Securities and Exchange Commission

While stock exchange guidelines and standards are used around the world, this report singles out the proposed SEC guidelines as the US is a major superpower economy with direct impact across many nations.

What are the SEC sustainability reporting standards?

In March 2022, the U.S. Securities and Exchange Commission proposed rule changes requiring companies to disclose certain climate-related information, ranging from greenhouse gas emissions and expected climate risks to transition plans.

Drawing from the TCFD framework, the proposals would provide investors with consistent, comparable, and decision-useful information for making investment decisions, and consistent and clear reporting obligations for issuers.12

Recent SEC updates

For registrants that already conduct scenario analysis, have developed transition plans or publicly set climate-related targets or goals, the proposed amendments would require certain disclosures to enable investors to understand those aspects of the registrants’ climate risk management.13

What is the status of SEC?

The proposed disclosures are similar to those that many companies already provide based on broadly accepted disclosure frameworks, such as the Task Force on Climate-Related Financial Disclosures and the Greenhouse Gas Protocol.13 It is important to note that SEC is still a proposed framework, and as such is not yet mandatory.

Why is SEC important?

It would provide consistent and clear reporting obligations for issuers, and provide investors with consistent, comparable, and decision-useful information for making their investment decisions. This means that investors get to decide which risks to take, as long as public companies provide full and fair disclosure and are truthful in those disclosures.13

Who does SEC impact?

The newly proposed rule would require SEC-registered domestic or foreign public companies to include climate-related information in registration statements and periodic reports.

What are the SEC reporting requirements?

As outlined by S&P Global12, SEC disclosures include:

  • Climate-related risks and their actual or likely material impacts on business, strategy and outlook.
  • Details about governance practices on climate-related risks and relevant risk management processes.
  • Scope 1 and Scope 2 greenhouse gas emissions, which would require attestation reports for accelerated filers.
  • Scope 3 emissions if either of two conditions are present: 1) If Scope 3 emissions are material to the company or 2) if the company has set an emissions target or goal that includes Scope 3 emissions.
  • Certain climate-related financial statement metrics and related disclosures in a note to audited financial statements.
  • Information about climate-related targets and goals, and transition plans, if any.

When is SEC in effect?

For large companies, the SEC’s climate disclosure requirements will likely begin in 2024. Smaller companies have until 2025 to comply.

Feature comparisons of the 3 primary sustainability proposals

Drawing from relevant government sources and standards, including IFRS, ESRS and US SEC with reference to the PWC report Navigating the ESG landscape,14 this table compares the key features of the three primary frameworks, followed by a comparison of the key disclosures required by each framework.

Name of the standardsIFRS: IFRS S1, IFRS S2, more to comeESRS: ESRS 1, ESRS 2, ESRS E1 – E5, ESRS S1 – S4, ESRS G1Proposed rule: The enhancement and standardisation of climate-related disclosures for investors, amendments to its rules under the Securities Act of 1933
Focus/ Materiality

Investor focused, single materiality (financial materiality).

Materiality is assessed on factors that could reasonably be expected to influence decisions that the primary users make based on the information provided. Materiality is the same as the IFRS definition, commonly referred to as Financial Materiality. Information is deemed material if omitting, misstating or obscuring it could reasonably be expected to influence the user’s decision.

Multi-stakeholder focused, double materiality (financial, environmental and social impact).

Double materiality consists of financial materiality (an outside in perspective) and impact materiality (an inside out perspective).

Investor focused.

Materiality would be assessed based on the definition of materiality in the existing SEC laws. A matter is material if there is a substantial likelihood that a reasonable investor would consider it important when determining whether to buy or sell securities or how to vote.

Also, a 1% aggregate absolute bright-line materiality threshold would be applied for financial statement footnote quantitative disclosures. Companies to disclose the impact of climate-related events that affect financial impact or expenditure metrics by more than 1%.

ScopeVoluntarily adopted and determined by individual jurisdictions.

Mandatory within the EU

ESRS and apply to large companies (defined as meeting two of the following criteria: >250 employees; >€40M revenue;

>€20M total assets)

Also including large subsidiaries of non-EU parents:

>€150M aggregated revenue within the EU

> all companies listed in the EU (other than micro-companies).

Proposed to be mandatory to accelerated, large accelerated and non-accelerated filers, smaller reporting companies (with some relief), emerging growth companies, foreign private issuers and companies filing registration statements, including IPOs.
Disclosure where and when

Not required in audited financial statements, required in the annual report and at the same time as financial statements.

No financial statement footnote disclosure would be required.

Not required in audited financial statements, required in the management report at the same time as the financial statements.

No financial statement footnote disclosure would be required.

Required in audited financial statements, required in the annual report in a separate section or by reference from another section, and at the same time as the financial statements.

A financial statement footnote would include disclosure of the impact of severe weather events and transition-related activities.

TCFD alignmentMostly aligned, builds on the TCFD with more granular transition plans, scenario analysis and industry specific metrics and targets.Aligned, however also include double materiality/ impact reporting and granular metrics and targets including alignment with the Paris agreement addressing EU policy objectives.Mostly aligned, disclosures only required if the company uses them in their goals and targets (such as scenario analysis), optional reporting for climate-related opportunities, more granular disclosure on the financial impacts.
Industry specific disclosures

Climate standards IFRS S2 contains industry specific disclosures and companies will need to consider SASB standards for other topics.

ISSB uses the SICS® industry classification systems.

No industry specific requirements yet, however this will be released in time.

The EU intends to use the NACE CODES for industry classification.

No industry-specific disclosures, however industry appropriate GHG emissions intensity metric.
Scope 1 and 2YesYesYes
Scope 3YesYesYes, if material or included in goals/targets
Basis for organisational boundaries (for GHG calculations)Scope boundaries to follow the GHG Protocol Standard – operational or financial control, or equity share.Scope boundaries based on operational control.Scope boundaries are consistent with the financial statements – based on control and share of equity method investees.
Intensity MetricsNot required.Yes, based on net revenue for the total of Scopes 1, 2 and 3 emissions.Yes, based on revenue and a unit of production for the total of Scope 1 and 2, and Scope 3 is to be included separately if it has been included.
Effective dateDepending on adoption and timing of the jurisdiction.1 January 2024.Waiting on adoption of final rules, expected sometime in 2024.
AssuranceLocal jurisdiction will decide on level of assurance and timelines.Initially, limited assurance moving to reasonable assurance over time.

Assurance only on Scope 1 and Scope 2 GHG emissions.

Footnote disclosure subject to assurance through the financial statement and internal controls audit.

Time horizons – short, medium and long term definitions

Disclosures need to provide information on the impact of sustainability-related risks and opportunities on the company’s strategy, business model and financial statements over the short, medium and long term.

The short, medium and long term time horizons are to be defined by the company. They can vary and depend on many factors, including industry-specific characteristics, such as cash flow and business cycles, the expected duration of capital investments, the time horizons over which the users of general-purpose financial reporting conduct their assessments and the planning horizons typically used in an entity’s industry for strategic decision-making.

When preparing its sustainability report, the undertaking shall adopt the following time intervals as of the end of the reporting period:

(a) the same period adopted by the undertaking in its financial statements for short-term

(b) two to five years for medium-term and

(c) more than five years for long-term.

Time horizons for the disclosure of climate-related risks over the short, medium and long term are not defined by the SEC proposal, however companies are required to describe how they define these to allow them to select the time horizons that are most appropriate to them.
Digital Taxonomy

IFRS Sustainability Disclosure Taxonomy is set to be formally released in Q2 2024.

It is designed to use the XBRL (eXtensible business reporting language) taxonomy, which will provide the digital framework to enable machine-readable and easily comparable disclosures under the ISSB sustainability standards.

Companies subject to the directive will be required to submit their management report in accordance with the electronic reporting format specified in the Delegated Regulation and to mark up their sustainability report including disclosures in accordance with the electronic format specified in the delegated regulation.

The European Single Electronic Format (ESEF) will be used, which is based on Inline XBRL.

The SEC proposal requires registrants to report on certain climate-related disclosures in XBRL format.

Registrants are required to electronically tag both narrative and quantitative climate-related disclosures in Inline XBRL.

Key disclosures comparison across the 3 primary frameworks

Targets and transition planningDisclosure is required for the sustainability related targets and goals set by the company, and how these targets were informed by the latest international agreement on climate change. Targets also include those that have been set in response to regulatory requirements or climate-related treaty law.

Disclosure of transition plans compatibility with the most recent international agreement on climate change.

Disclosure on GHG emissions reduction targets in five-year rolling periods, including targets set for 2030 and 2050 if available.

Disclosure required for any climate-related targets set by the company. Targets include those set-in response to regulatory requirements or climate-related treaties or laws.
Scenario analysisScenario analysis is to be used to assess climate resilience. Disclosure of whether the scenario used aligns with the latest international agreement on climate change.Scenario analysis is to be used to assess climate resilience. Explanation is to be included on whether and how the scenario analysis is consistent with the Paris agreement and limiting climate change to 1.5°C.

Any analysis is accepted to assess climate-related resilience.

SEC proposal does not define specific scenarios.

GHG ProtocolUse of the GHG Protocol is required unless a different method is required to be used as set by a jurisdictional authority or exchange.Use of the GHG Protocol is required.GHG Protocol would not be required, however the proposed requirements are based on the GHGP concepts.
GHG emissions organisational boundariesConsistent with what is described in the GHGP –Emissions are to be reported using either a control or equity share approach.Emissions of the parent and emissions of the consolidated subsidiaries are to be reported following the organisational boundaries of the consolidated financial statements.Emissions are to be reported following the organisational boundaries of the consolidated financial statements.
Scope 1 and Scope 2 GHG emissions

Gross Scope 1 and Scope 2 GHG emissions for the consolidated group and separately for the investees excluded from consolidation.

Scope 2 emissions disclosed using the location-based method.

No need to disaggregate emissions by type of GHG.

Gross Scope 1 and Scope 2 emissions for the parent and consolidated subsidiaries as well as entities over which it has control.

The Scope 1 percentage of emissions under regulated emissions trading schemes are to be separately disclosed.

The location-based method and market-based methods are both to be separately disclosed when reporting Scope 2 emissions.

No need to disaggregate emissions by type of GHG.

Gross Scope 1 and Scope 2 GHG emissions for the consolidated group, including equity method investments.

Scope 2 emissions are to be disclosed using either the location-based or market-based method, or a combination of both.

GHG emissions by type are required.

Scope 3 emissionsTotal Scope 3 emissions to be disclosed by component categories.Total Scope 3 emissions for parent and consolidated subsidiaries as well as entities over which it has operational control, including significant Scope 3 component categories.Total Scope 3 emissions disclosed by component categories if they are material and/or if the company has set a target or goal that includes Scope 3 emissions.
GHG emissions intensityGHG emissions intensity not required to be disclosed.Total GHG emissions per net revenue is to be disclosed.

For Scope 1 and Scope 2 GHG emissions per unit of total revenue and per unit of production are to be disclosed.

For Scope 3 disclosures that are required, GHG emissions per unit of total revenue and per unit of production.

Common themes across the three primary frameworks

While they are aligned in many ways, the specific disclosures and rules differ across the three primary reporting frameworks. So, meeting the requirements of one may not satisfy the requirements of another. However, there are many common themes that already do, or soon will, need to be addressed by industrial organisations regardless of which framework impacts them.

Drawing from hands-on industrial client experience and insights from the PWC report Navigating the ESG landscape,14 this section explores the key considerations moving forward for business leaders.

Why is data important for sustainability reporting?

The first step in meeting any sustainability reporting obligation is having access to the right information. Data collection, data validation, data contextualisation and data management are key to transparent, accurate, auditable sustainability reporting across all these frameworks, however they may evolve. This requires digital tools and sustainability reporting software beyond traditional spreadsheets.

What is in scope for sustainability reporting?

Current frameworks don’t cover all businesses, sectors or reporting indicators, however the overall trend is towards widening scope and deeper disclosures. In particular, the growing global adoption of the CSRD will quickly result in more companies being included with more granular reporting.

What is the approach to materiality across ISSB, CSRD and SEC?

Across the primary frameworks, disclosures are guided by an evaluation of materiality, which is a fundamental distinction between them. IFRS Sustainability disclosure standards cover the impact of sustainability on the company and its potential effects on financial performance, with a specific focus on the investor perspective. CSRD adopts a broader perspective on materiality, including both financial impact and how the company will affect individuals and the environment. The SEC applies an investor lens, emphasising the financial impact of sustainability on the organisation.

Are sustainability reporting frameworks sector-specific?

The European Commission has announced ten sector-specific standards. However, they are prioritising the implementation of an ESRS support function over the development of sector standards. In October 2023, it published a proposal15 stating that streamlining reporting and reducing administrative burdens is a priority and will therefore delay the adoption of some sector specific standards as well as dedicated standards for non-EU companies.

The ISSB standards (incorporating IFRS S1) require companies to refer to and consider the disclosure topics and related metrics in the industry-based standards set out by the SASB. More thematic standards will be developed in time. The IOSCO called on its member jurisdictions, that regulate more than 95% of the world’s financial markets, to consider ways to adopt or to be informed by the ISSB standards16 in their jurisdictions. Unlike the ISSB and the CSRD, the SEC has not indicated that they will draft sector specific standards.

Transition planning and climate-related targets

All three frameworks require targets and goals to be disclosed, including information about target setting, offsets and mitigation strategies. The CSRD requires companies to set target values with prescribed dates aiming to limit global warming to 1.5°C, whereas the SEC and ISSB do not prescribe dates or targets and leave this to be defined by the company.

Is scenario analysis needed for ISSB, CSRD and SEC?

Each of the primary frameworks will require assessments that cover information including climate resilience and the identification and management of risk and opportunities, often requiring scenario analysis. The ISSB requires disclosure about whether the company conducted a scenario analysis aligning with the latest international agreement on climate change. The CSRD asks for and explanation of how the scenario analysis aligns with the Paris Agreement’s goal of limiting climate change to 1.5 °C. The SEC asks for additional disclosures if scenario analysis is used, without specifying the consideration of any particular scenario.

What GHG disclosures are required for ISSB, CSRD and SEC?

All frameworks require GHG emissions disclosures and reference the GHG Protocol, however the Greenhouse Gas Protocol (GHGP) is not required by the SEC. The ISSB will allow for other methods to be used when disclosing GHG if required by an exchange or jurisdiction regulation.

The scope of entities included in the GHG disclosure differs among the three frameworks. SEC requires alignment with the financial statements, the ISSB follows the GHGP where the emissions are reported using control or equity share approach and the ESRS require the parent to use organisational boundaries consistent with the financial statements, but for associates/joint ventures and other arrangements it depends on the operational control of the company.

All require Scope 1, and 2 in carbon dioxide equivalent (CO2e) tons

All three frameworks require disclosure of scope 1 and scope 2 GHG emissions in carbon dioxide equivalent tons. ESRS and SEC require one or more intensity metrics (a ratio of emissions specific to a measure in the financial statements), excluding the impact of offsets (purchased or generated). All seven gases are required in the disclosure; however, the SEC requires disaggregation of each gas for each scope. The ISSB does not require disclosure of intensity metrics.

Scope 3 disclosure requirements for ISSB, CSRD and SEC

All three disclosure frameworks include various specific requirements to disclose scope 3 GHG emissions. ISSB requires Scope 3 emissions in total, including all 15 Scope 3 component categories. CSRD requires Scope 3 to be disclosed in total, and in a specific format. The SEC requires Scope 3 disclosures if they are material or if the company has set an emissions reduction target or goals that include Scope 3 emissions.

Does sustainability reporting require assurance?

CSRD and the SEC have a phased approach to give organisations time to develop the required levels of assurance over time, beginning with limited assurance and increasing to reasonable assurance. CSRD sustainability information and GHG emissions would be subject to assurance, and ISSB sustainability and emissions disclosures would be subject to assurance based on the rules of the jurisdiction. SEC assurance will apply to footnote disclosures in the financial statements and Scopes 1 and 2 emissions transitioning to reasonable assurance in time.

Building on the TCFD increases the data and reporting demands

The ISSB, CSRD and SEC all align with TCFD principles and integrate many elements of TCFD with the aim to provide a more comprehensive, transparent, standardised and comparable framework for sustainability reporting. As a result, this prioritises quantitative data-driven analysis over qualitative reports to a level not found in reporting practices to date. This will require upskilling in data capture and reporting by those preparing reports and directors responsible for signing them off.

Prepare for machine-readable digital taxonomy

The need for periodic reporting in a machine-readable digital taxonomy, scenario analysis, resilience assessments and forward-looking statements means that data-driven sustainability software is the only way to reduce complexity and meet evolving compliance standards.

Digital taxonomy is essential because it enables investors and other stakeholders to efficiently run large-scale extraction, analysis and comparison of disclosures across organisations, sectors and time periods.

Regulators are, or will soon be, requiring sustainability disclosures to be submitted digitally and tagged subject to Inline XBRL (eXtensible business reporting language) requirements similar to other stock exchange filings.

While all three primary frameworks will require machine-readable format for sustainability disclosures – narrative (qualitative disclosures) and metrics and targets (quantitative disclosures) – the details will differ between each.

ISSB digital taxonomy

  • The ISSB published their proposed digital taxonomy for consultation in July 2023 and plans to publish the IFRS Sustainability Disclosure Taxonomy in Q2 2024.
  • It is designed to help market users, organisations and regulators by enabling efficient tagging, reporting, analysing and comparing of sustainability-related financial information.
  • It uses eXtensible business reporting language (XBRL), the open international standard for digital business reporting which is also used for the IFRS Accounting Taxonomy.
  • The approach to tagging narrative information to reflect the relationships between IFRS S1 and IFRS S2 and tagging metrics and targets are all included in the prospective taxonomy.
  • The SASB Taxonomy alongside the ISSB Taxonomy will be required for some metrics.

CSRD digital taxonomy

  • Impacted companies will be required to submit their management report and markup their sustainability report in accordance with the electronic reporting format specified in the Delegated Regulation.
  • CSRD uses the European Single Electronic Format (ESEF), which is based on Inline XBRL.
  • Required companies will have to tag their disclosures with a digital XBRL taxonomy, with unique definitions for 100+ wide-ranging data points.
  • The Inline XBRL report is human-readable and machine-readable at the same time, allowing stakeholders to identify individual disclosures and extract data points for analysis.
  • Final Sustainability Reporting ESRS XBRL Taxonomy is to be handed over to EC and European Securities and Markets Authority (ESMA) in 2024.

SEC digital taxonomy

  • In March 2022 the SEC published a rule proposing that public companies be required to report on certain climate-related disclosures in XBRL format.
  • Registrants are required to electronically tag both narrative and quantitative climate-related disclosures in Inline XBRL.
  • Inline XBRL is both machine-readable and human-readable, to reduce the time and effort associated with preparing XBRL filings and improve data quality and usability.
  • Inline XBRL tagging climate-related disclosures makes them easy to access, aggregate, compare, filter and analyse for investors and other market participants.

Spotlight on the TNFD Framework

While not yet legislated, the new TNFD Framework is widely expected to be incorporated into global regulatory frameworks in coming years, impacting many organisations across the world. So, it is important to understand and prepare for its potential impact.

TNFD: Taskforce on Nature-related Financial Disclosures

What are the TNFD sustainability reporting standards?

The TNFD is a global initiative established to develop a framework for organisations to assess and disclose their dependencies and impacts on nature.

Similar to its counterpart, the Task Force on Climate-related Financial Disclosures (TCFD), the TNFD aims to provide businesses and financial institutions with a standardised approach to integrating nature-related considerations into their financial disclosures.

This framework assists in better understanding and managing the risks and opportunities associated with nature, biodiversity, and ecosystem services, ultimately promoting a more sustainable and resilient global economy.

The TNFD was launched on 4 June 2022 and has been given international political support through endorsement by G7 Finance Ministers.17 It is a market-led, open innovation approach that encourages market participants to support the development of a risk management and disclosure framework for organisations to report and act on evolving nature-related risk.9

The TNFD aligns with the emerging global baseline for sustainability reporting in development by the ISSB. The ISSB will refer to the TNFD recommendations in its operations, “The TNFD supports the delivery of a global baseline of sustainability-related financial disclosures under the ISSB. As such, the TNFD developed the recommendations to be compatible with the ISSB Standards and has similarly grounded its work in the four content areas set out by the TCFD which has been embedded into the ISSB Standards.”18

The TNFD framework is structured around the four pillars of: governance, strategy, risk management, and metrics and targets. This draws from, and is consistent with, the approach of TCFD and the ISSB.

The TNFD Framework19 also includes new disclosures focused on: stakeholder rights and engagement; priority locations to accommodate specific considerations arising from regional differences; and upstream and downstream value-chain risk and impact management.

Recent TNFD updates

On 16 January 2024, the TNFD announced that 320 organisations from over 46 countries have committed to start making nature-related disclosures based on the TNFD recommendations published as part of their annual corporate reporting for FY2023, FY2024 or FY2025. These early adopters include leading publicly listed companies across geographies and industry sectors representing US$4 trillion in market capitalisation.

What is the status of TNFD?

Many global governments have signaled their intention to consider adoption of the TNFD through regulation. For example, in September 2023, the UK Parliament 20 welcomed the final publication of the TNFD framework indicating the UK Government “should consider making these latest rules mandatory for companies” and will be looking further into the recommendations in the upcoming inquiry on the role of natural capital in the green economy. The EU has also integrated aspects of the TNFD guidance into its regulatory reporting regime, the CSRD. Until it becomes mandatory, the TNFF has committed to tracking and annually reporting voluntary market adoption from 2024.

Why is TNFD important?

The World Economic Forum (WEF) 2021 Global Risk Report identifies biodiversity loss, ecosystem collapse and human-made environmental damage, as top risks. Biodiversity loss is highlighted as an existential global threat.13

The TNFD will broadly align itself with the goals of no net-loss of biodiversity by 2030 and net gains by 2050 (nature positive). The TNFD mission is to provide a framework for how organisations can address environmental risks and opportunities with the goal of channeling capital flows into positive action.17

The availability of accurate, comparable and decision-useful nature-related data is an essential pre-requisite to address the global challenge of accelerating nature loss, to help organisations become more resilient in the face of nature-related risks, to deliver sustainable development for local communities and to facilitate the flow of capital to nature positive outcomes.22

Who does TNFD impact?

Global financial services firms and organisations – all sizes, sectors and value chains.

What are the TNFD reporting requirements?

Companies are required to understand the implications of biodiversity loss for their business, that is risk and opportunities to economic activities and financial assets that depend on biodiversity. The TNFD has developed guidance for organisations when assessing nature-related risks and opportunities using a ‘LEAP’ framework.

  • Locate the interface with nature
  • Evaluate dependencies and impacts
  • Assess risks and opportunities
  • Prepare to respond to nature-related risks and opportunities and report.

When is TNFD in effect?

The TNFD framework is expected to be incorporated into regulatory frameworks in the years ahead.  It is voluntary for the moment, however, until mandatory reporting in regulated, the TNFD has committed to tracking market adoption annually, and will publish this status update at the beginning of 2024. As outlined above, their first update in January 2024 detailed commitments by 320 companies across 46 countries to start reporting based on the TNFD.

Secondary Sustainability Reporting Frameworks

While the focus going forward will be on the three primary frameworks detailed above, there are a number of secondary frameworks that remain commonly used and/or are important to understand as they are embedded in or inform these frameworks.

TCFD: Task Force on Climate-Related Financial Disclosures

The TCFD has now become an integral part of the ISSB with a more harmonised approach towards disclosing climate-related financial information, aligning with the ISSB’s broader goal of establishing consistent and transparent sustainability reporting standards for businesses.

As communicated on its home page, concurrent with the release of its 2023 status report in October 2023, the TCFD has fulfilled its remit and disbanded. The Financial Stability Board (FSB) has asked the IFRS Foundation23 to take over the monitoring of the progress of companies’ climate-related disclosures.

From 2024, as the ISSB Standards start being applied around the world, the IFRS Foundation will take over these responsibilities from the TCFD. Companies that have been reporting according to the SASB and TCFD frameworks can now report to the ISSB instead.

What are the TCFD sustainability reporting standards?

The TCFD was established in 2015 by the Financial Stability Board to respond to the threat of climate change to the stability of the global financial system. In 2017, the TCFD released climate-related financial disclosure recommendations designed to help companies provide better information to support informed capital allocation.24

Through widespread adoption, financial risks and opportunities related to climate change will become a natural part of a companies’ risk management and strategic planning processes. As this occurs, companies’ and investors’ understanding of the potential financial implications associated with transitioning to a lower-carbon economy and climate-related physical risks will grow, information will become more decision-useful and risks and opportunities will be more accurately priced, allowing for the more efficient allocation of capital.24

KPMG’s Survey of Sustainability Reporting9 found that since TCFD’s establishment, more than half of all companies in the N100* and the G250** have disclosed their climate targets – a figure growing rapidly in recent years.

Recent TCFD updates

As outlined on its website, the success of the TCFD’s recommendations can be demonstrated by the 19 jurisdictions, accounting for close to 60% of global 2022 GDP, with final or proposed TCFD-aligned disclosure requirements. Additionally, the Task Force has seen over 4,800 organisations indicate their support for the TCFD’s recommendations, ranging from companies and civil society to governments. However, more needs to be done. As this report describes, although companies continue to make progress in their disclosures, significant gaps in data remain.

In particular, reporting the impact of climate change on companies’ businesses, strategies and financial planning is still lagging behind. Several governments, regulators and standard setters have incorporated or drawn from the TCFD recommendations in developing climate related reporting requirements and standards, including the U.S. Securities and Exchange Commission, the U.K. Parliament, the European Commission and the ISSB.24

What is the status of TCFD?

While a voluntary framework, within 2 years of the establishment of the TCFD, more than half of all companies in the N100* and the G250** have disclosed their climate targets. On a country basis, the strongest carbon target reporters were the United Kingdom (96%), Japan (95%) and Germany (94%).9

Why is TCFD important?

The Task Force aims to improve corporate reporting on climate-related risks and enable financial stakeholders – investors, lenders, and insurers – to factor climate-related risks into their decisions.9 Without the right information, investors and others may incorrectly price or value assets, leading to a misallocation of capital. The Task Force believes its recommendations, which provide a singular, accessible framework for climate-related financial disclosure, have helped existing disclosure regimes come into closer alignment over time.24

Who does TCFD impact?

TCFD supporters span 101 countries and jurisdictions, covering nearly all sectors of the economy, with a combined market capitalisation of $26 trillion. The TCFD has also garnered support from the world’s largest public companies. Of the 100 largest public companies, 92 either support the TCFD, report in line with the TCFD recommendations, or both – as of 2022.24

What are the TCFD reporting requirements?

Its disclosure recommendations are structured around four thematic areas that represent core elements of how companies operate: governance, strategy, risk management, and metrics and targets. The four recommendations are interrelated and supported by 11 recommended disclosures that build out the framework with information that should help investors and others understand how reporting organisations think about and assess climate-related risks and opportunities.24 TCFD covers a range of Scope 1, 2 and 3 disclosures.

SASB: Sustainability Accounting Standards Board

As of August 2022, the ISSB of the IFRS Foundation assumed responsibility for the SASB Standards.

What are the SASB sustainability reporting standards?

In 2011, the SASB standards were developed to guide investor-focused sustainability disclosure. The ISSB is committed to maintaining, enhancing and evolving the SASB Standards and encourages preparers and investors to continue to use the SASB Standards.

The SASB Standards play an important role in the first two IFRS Sustainability Disclosure Standards, IFRS S1 General Requirements for Sustainability-related Disclosures and IFRS S2 Climate-related Disclosures.25

Recent SASB updates

The ISSB is building on the SASB Standards, TCFD recommendations, Climate Disclosure Standards Board guidance, and Integrated Reporting Framework to create a comprehensive global baseline of sustainability disclosure standards for the financial markets. Because sustainability issues that drive enterprise value are different from industry to industry, the ISSB is also leveraging the SASB Standards’ industry-based standards development process.9

What is the status of SASB?

According to KPMG’s Survey of Sustainability Reporting9, SASB is the leading reporting standard among companies in the US, Canada and Brazil. Currently one-third of N100* companies and nearly half of the G250** report against SASB. There is an increasing uptake of the standards outside of the Americas, with 35% adoption among Europe’s N100*.

Why is SASB important?

The new ISSB under the IFRS Foundation, which now houses the SASB Standards and Integrated Reporting Framework, is working to enable more consistency and comparability amongst frameworks and standards by harmonising and simplifying the landscape.9

SASB Standards enable organisations to provide industry-based disclosures about sustainability-related risks and opportunities that could reasonably be expected to affect the entity’s cash flows, access to finance or cost of capital over the short, medium or long term. SASB Standards identify the sustainability-related issues most relevant to investor decision-making in 77 industries. Global investors recognise SASB Standards as essential requirements for companies seeking to make consistent and comparable sustainability disclosures.25

Who does SASB impact?

Companies that already use the SASB Standards should continue to do so and those that are not using them yet should consider adoption. Report preparers that are new to sustainability disclosure should prepare for the future application of the IFRS Sustainability Disclosure Standards.26

What are the SASB reporting guidelines?

The SASB Standards provide disclosures across a range of sustainability matters and, over time, will inform the industry-based requirements in the IFRS Sustainability Disclosure Standards. According to the SASB, leading companies are using SASB standards to:

  1. Evaluate internal systems and processes for collecting, aggregating and validating sustainability-related information across the organisation and its value chain.
  2. Consider the sustainability-related risks and opportunities that affect the business.
  3. Establishing technical protocol for compiling data

When is SASB in effect?

Report preparers will benefit from starting now, using the SASB Standards to meet the immediate needs of investors while laying the groundwork for adoption of IFRS Sustainability Disclosure Standards in the coming years. 26

GRI: Global Reporting Initiative

What are the GRI sustainability standards?

The GRI Standards enable any organisation – large or small, private or public – to understand and report on their impacts on the economy, environment and people in a comparable and credible way, thereby increasing transparency on their contribution to sustainable development. In addition to companies, the Standards are highly relevant to many stakeholders – including investors, policymakers, capital markets and civil society.27

The world has changed since the GRI Standards was first published in 2016, and traditional metrics for measuring an organisation’s economic impact – GDP growth, profitability, shareholder returns – are increasingly seen as inadequate. The new GRI standards will take a more holistic approach and include economic, social, and environmental factors.27

Recent GRI updates

GRI and the EU CSRD have worked together to grow interoperability between the frameworks and their shared focus on double materiality (financial impact and impact to climate, environment and society).

Since March 2022 the GRI and the IFRS Foundation have operated under a collaboration agreement28 to coordinate their sustainability-related work programs and standard-setting activities.

In January 2024, the GRI release educational resources, mapping tools and support services to help existing GRI reporters comply with the new standards of the ESRS and the ISSB.

What is the status of GRI?

GRI remains the most commonly used reporting standard globally, with increased adoption across both the N100* and G250**. It has longevity and reputation on its side: since 1997, GRI has remained the incumbent standard for non-financial reporting.9 GRI includes Scope 1, 2 and 3 disclosures and is currently a voluntary framework.29

KPMG’s Survey of Sustainability Reporting found that the GRI remains the most dominant standard used globally, led by Singapore, Taiwan and Chile. GRI has been the incumbent standard for non-financial reporting used by 68% of N100* companies.9

Why is GRI important?

Standards allow organisations to publicly report the impacts of their activities in a structured way that is transparent to stakeholders and other interested parties.30

Who does GRI impact?

Any organisation, large or small, public or private, from any sector or location, can use the GRI Standards. Reporters, stakeholders and other information users draw on the standards. Reporters within an organisation use the standards to report on the organisation’s impacts in a credible way that is comparable over time and in relation to other organisations. The standards also help stakeholders and other information users understand what is expected from an organisation to report on and use the information published by organisations in various ways.11 Standards will be developed for 40 sectors, starting with those with the highest impact, such as oil and gas, agriculture, aquaculture and fishing.

What are the GRI reporting requirements?

The GRI Standards30 consist of the following:

  • GRI 1 Foundational 2021: lists baseline requirements and has specific principles around reporting such as accuracy, balance and verifiability – fundamental to good quality reporting
  • GRI 2 General Disclosures 2021: contains disclosures relating to details about an organisation’s specific principles around reporting such as accuracy, balance and verifiability – fundamental to good quality reporting. 11GRI 2 General Disclosures 2021: contains disclosures relating to details about an organisation’s structure and reporting practices, activities and workers, governance, strategy, policies, practices and stakeholder engagement. These give insight into the organisation’s profile and scale and help provide a context for understanding an organisation’s impacts.
  • GRI 3: Material Topics 2021: explains the steps describing how the Sector Standards are used in this process. It also contains disclosures for reporting its list of material topics, the process by which the organisation has determined its material topics and how it manages each topic.

When is the GRI in effect?

Revised GRI standards came into effect from 1 January 2023 – the previous version (2016) which companies were using has now been withdrawn.

The GRI Sector Program31 is developing standards for 40 sectors, starting with those that have the highest impact. The Sector Standards for Oil and Gas (GRI 11), Coal (GRI 12) and Agriculture, Aquaculture and Fishing (GRI 13) have now been released and are available for public use. Standards focused on the mining sector are set to be published in February 2024.

CDP: Carbon Disclosure Project

What are the CDP sustainability reporting standards?

CDP was established as the ‘Carbon Disclosure Project’ in 2000, asking companies to disclose their climate impact. CDP has since broadened this scope to incorporate deforestation and water security.

In 2021 it launched a new strategy that expanded to cover all planetary boundaries, and new areas such as biodiversity, plastics and oceans, and recognising the interconnectedness of nature and earth’s systems.

What is the current status of CDP?

CDP and IFRS are working together32 to explore how they can collaborate to drive adoption of the ISSB Standards. CDP reported in 202333 that from 2024 all companies disclosing through CDP (18,700 in 2022, worth half of global market capitalisation) will be asked to disclose against the ISSB climate standard to enable streamlined reporting processes and clear data for stakeholders.

The sustainability reporting challenge: A lack of data and digital tools

One of the biggest concerns for industrial organisations lies in the confidence they have in the quality of their data. Many operations don’t have the right digital tools and sustainability reporting software in place to support effective, efficient and detailed GHG emissions, water and energy consumption accounting.

Today’s largely manual and disconnected processes are not working. In fact, a global survey of industry executives found that 91% fail to measure emissions comprehensively.34

While some organisations are making great progress, others still rely on the same legacy systems and processes they have used for many years. For these organisations, accurate emissions reporting is going to become increasingly challenging.

Without the right data-driven sustainability platform, it’s impossible to meet evolving reporting requirements, let alone implement effective decarbonisation strategies.

If there are gaps in an organisation’s in-house digital platforms or analytics expertise, engaging a specialist consultant to assist with advice on technology, data, compliance or reporting early can accelerate the process.

Introducing Sustainability Tracker (ST)

Based on a decade of experience, Industrial Sustainability Solutions (ISS) has developed comprehensive data-driven sustainability reporting software solutions across industrial assets and the entire industrial value chain, as well as measuring and reporting on other sustainability indicators for climate and nature.

Designed for complex industrial processes, Sustainability Tracker (ST) is an established SaaS platform that captures, analyses and reports on sustainability indicators such as GHG emissions across Scopes 1, 2 and 3, water, energy, air quality, waste, hazardous materials and nature-related risk factors.

Integrating seamlessly with your existing systems – and customisable to your industrial process – ST automatically centralises huge volumes of data from multiple sources across your operation and supply chain and uses machine learning to validate and organise the measured and collected data.

Road-tested since 2010 in complex industrial sites across 9 countries and in 4 languages, ST is your proven fast-track solution to sustainability compliance and accurate reporting.

Learn more about ISS’s Sustainability Software Solutions

Take control of your industrial sustainability reporting

To learn how Sustainability Tracker (ST) can help you report across your sustainability indicators and minimise emissions, energy, water and waste across your supply chain, contact our expert team on +61 2 7229 5662 or

About Industrial Sustainability Solutions (ISS)

Industrial Sustainability Solutions (ISS) is the world-leading Australian technology company behind Sustainability Tracker (ST), a proven industrial sustainability analytics and reporting platform designed for complex industrial processes

ISS is founded and run by the established team behind Metallurgical Systems. Since 2010, Metallurgical Systems has enabled accurate and transparent production reporting and finance grade sustainability reporting for minerals and mining plants globally.

Our award-winning digital twin technology is built on a decade of experience streamlining industrial plants worldwide. Proven in 9 countries and in 4 languages, this gold standard approach to sustainability tracking and reporting is now available for all complex industrial operations and it’s ready to deploy today.

About the Authors

This article has been collaboratively authored by the Industrial Sustainability Solutions team and fact-checked and authorised by Managing Director and industry specialist John Vagenas.


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  2. Federal Register / Vol. 87, No. 69 / 11.04.2022 / Proposed Rules
  3. KPMG, Comparing sustainability reporting requirements, Updated Nov 2023
  1. IFRS, COP28 Declaration of Support, 2023
  2. ISSB, COP28: close to 400 organisations commit to advance the ISSB climate global baseline, 2023
  3. Forbes, IOSCO Endorses ISSB Climate/ ESG Reporting Standards For Business, July 2023
  4. IFRS, Brazil adopts ISSB global baseline, October 2023
  5. AICD, Gearing up for mandatory climate reporting, 2023
  6. KPMG, Big shifts, small steps – Survey of Sustainability Reporting 2022
  7. KPMG, Corporate Sustainability Reporting Directive
  8. EU Commission, EU Corporate Sustainability Reporting Directive (CSRD), 2032
  9. S&P Global, Getting ready for the SEC Climate Disclosure Rule
  10. SEC, SEC Proposes Rules to Enhance and Standardise Climate-Related Disclosures for Investors, March 2022
  11. PWC, Viewpoint: Navigating the ESG landscape, January 2024
  12. EU Commission, European sustainability reporting standards (ESRS) – postponement of deadlines under the Accounting Directive, October 2023
  13. IOSCO, IOSCO endorses the ISSB’s Sustainability-related Financial Disclosures Standards, July 2023
  14. Deloitte, TNFD and nature-related financial disclosures, 2023
  15. IFRS, ISSB congratulates Task Force on Nature-related Financial Disclosures on finalised recommendations, September 2023
  16. TNFD, ISSB congratulates TNFD on finalised recommendations , November 2023
  17. UK Parliament, Comment: Taskforce on Nature-related Financial Disclosures (TNFD) framework, September 2023
  18. TNFD, TNFD publishes scoping study exploring global nature-related public data facility, 2023
  19. IFRS, ISSB and TCFD
  20. TCFD, About the TCFB – important message, October 2023
  21. SASB, SASB Standards Overview
  22. SASB, Future of the SASB Standards: What you need to know for 2023 disclosure, January 2023
  23. GRI, GRI Standards – The global standards for sustainability impacts
  24. IFRS, IFRS Foundation and GRI to align, March 2022
  25. IBM, What are Scope 3 emissions?
  26. GRI, A short introduction to the GRI Standards
  27. GRI, GRI Sector Program – Reporting with the Sector Standards
  28. IFRS, IFRS Foundation completes consolidation of CDSB from CDP, January 2022
  29. CDP, CDP comment on ISSB standards launch, June 2023
  30. BCG, Carbon Measurement Report Survey 2021

*(N100 refers to a worldwide sample of 4,900 companies comprising the top 100 companies by revenue in each of the 49 countries used in the sample)

** G250 are the top 250 companies globally by revenue