Comparing ESG reporting proposals

• There is commonality between the proposals – including that the Task Force for Climate-related Financial Disclosures (TCFD) framework forms a shared input.
• However, there are also areas where they are not aligned, which may create practical challenges for companies trying to design coherent and consistent reporting that meets the needs of both global investors and jurisdictional requirements. In addition to points of detail, this includes the greater scope and scale of the EFRAG proposals with their wider stakeholder focus.

• The proposals are ambitious and would have a significant impact on companies. 
• For multinationals and others needing to apply multiple frameworks, the challenges will be magnified if the requirements are not compatible. A key practical consideration is aligning calculation methodologies – minimizing the different data requirements.
• Achieving a global baseline would support companies in applying the standards, as well as drive consistent reporting across jurisdictions – reporting that is internationally comparable, but also meets local (including US) needs.

• Understand where similarities and differences exist between the proposals that may affect you.
• Identify what you will be required to report versus what you may choose to adopt.
• Prepare for fast adoption of all requirements that may affect your company.

See our responses to the consultations from the ISSB, SEC and EFRAG on their respective proposals.

We answer these questions about the three sets of proposals:

1. At a glance, how do they compare?
2. Who would be in scope?
3. What materiality lens would apply?
4. Where and when would information be disclosed?
5. How do the proposals align with the TCFD?
6. What industry-specific disclosures would be required?
7. What GHG emissions reporting would be required?
8. When would they be effective?
9. What assurance would be required?
10. What do you need to do now?