Comment Letter: Submission to AASB on Sustainability

The EDO disagrees with the AASB’s proposal to remove the requirement for an entity to refer to and consider the applicability of the SASB Standards and references to Industry-based Guidance on Implementing IFRS S2. [...] The IFRS S1 provision requires preparers to “refer to and consider the applicability of the disclosure topics in the SASB Standards”. [...] The more entities apply the same disclosure topics and metrics, the more decision-useful the disclosures become and the greater the potential for reporting to drive better performance. [...] The EDO considers that the availability of this transitional relief – when considered alongside the provisions referred to above - are sufficient to address the challenges arising from the collection of data for the calculation of Scope 3 emissions and there is no basis for the AASB to offer an additional relief. [...] The invitation in paragraph AusB33.1 for an entity to consider the 15 GHG Protocol Categories is likely to raise questions over whether the entity should disclose the reasons why it has determined not to use the 15 GHG Protocol Categories and the extent to which its chosen categories differ from the 15 GHG Protocol Categories.