ISSB Standards | Disclosure checklist
Our disclosure checklist will help entities prepare and present sustainability-related financial information under the currently effective IFRS Sustainability Disclosure Standards. The checklist identifies the specific disclosure requirements for climate and other topics (in a simple sequence), and the available transition reliefs for first-time adopters.
Banks | 2024 sustainability-related disclosure benchmarking
Our 2024 sustainability-related disclosure benchmarking analysis covers 33 major banks. We’ve found that, as banks expand their sustainability-related disclosures, it is becoming increasingly important to deliver a connected and focused narrative. With many disclosure frameworks applied, comparing and understanding ESG performance can be a challenge.
Other key findings from our analysis include:
- Although all banks disclose sustainability-related considerations in their credit risk assessment process, the quantified impact of climate risk on expected credit losses (ECL) remains relatively limited.
- Disclosures of portfolio coverage for financed emissions are gaining traction, and risk and dependency disclosures are expanding as interim target dates approach.
- Despite ample narrative on financial inclusion and customer protection, a lack of standardized metrics and targets makes it difficult to assess their effectiveness.
- Banks have begun disclosing their risk management approaches to artificial intelligence (AI) ethics and algorithmic bias.
Read our analysis for further insight.
Insurers | 2024 sustainability-related disclosure benchmarking
Our 2024 sustainability-related disclosure benchmarking analysis covers 45 major insurers. We’ve found that as sustainability mandates evolve and diverge, comparability in insurers’ disclosures remains challenging.
Insurers have an opportunity to provide clearer, more focused sustainability narratives with insurance-specific data that is better connected to the financial statements.
Other key findings from our analysis include the following:
- More insurers are publishing transition plans, but still not the majority, while many focus on extreme weather risk assessments.
- There is notable progress on financed emissions, but calculations remain challenging for insurers.
- Few still disclose insurance-associated emissions, reflecting data and methodology challenges.
- Business conduct disclosures are mostly qualitative; more can be done to provide quantitative information, such as metrics and targets.
Read our analysis for further insight.
Clarifications on IFRS S2 Climate-related Disclosures
Targeted amendments to IFRS S2 could change the way companies disclose emissions.
Feedback on IFRS S2 from stakeholders – including regulators, preparers and investors – has focused on areas where clarification may help them apply the standard. In response, the International Sustainability Standards Board (ISSB) is proposing amendments in the following areas:
- Scope 3 Category 15 greenhouse gas (GHG) emissions
- Global warming potential values
- The Global Industry Classification Standard
- Jurisdiction relief
The proposals will interest companies that are currently planning their implementation or have already conducted a gap assessment.
Read our article to find out more.
We have submitted our comment letter to the ISSB on the proposed amendments. Overall, we support the ISSB’s efforts to clarify the requirements in IFRS S2 on disclosing greenhouse gas emissions.
Enhancing the SASB Standards | Significant proposals to improve industry-based disclosures
Many companies use the SASB Standards to provide useful information to investors. These industry-based standards are set to change.
The ISSB has proposed significant amendments to the SASB Standards to support the high-quality implementation of IFRS S1 and IFRS S2, which require industry-based disclosures.
The proposals would influence how companies determine what to disclose and set the tone for the ISSB's approach to industry guidance. Therefore, companies operating both within and outside the nine industries specifically covered by these proposals need to consider how they could affect them.
Read our article to find out more.
Omnibus proposals | Update on developments
The European Commission has been progressing its Omnibus package of proposals to reduce sustainability reporting and due diligence requirements.
First Omnibus proposals approved
A two-year delay in mandatory reporting under the European Sustainability Reporting Standards (ESRS) and EU Taxonomy for second- and third-wave companies has been agreed upon under the proposed ‘Stop the Clock’ directive. Member states have until 31 December 2025 to transpose the directive into national law.
Refer to our article, which explains the key proposals and highlights potential impacts and next steps.
Simplifying ESRS
Additionally, the Commission has mandated EFRAG, the advisory body to the EU on corporate reporting, to provide advice on how to simplify ESRS by 31 October 2025. Find out more in our article.
In response, EFRAG has been seeking views from stakeholders. KPMG has provided input on EFRAG’s call for feedback. Check out the article for more details.
Quick fix amendments to ESRS
First-wave companies reporting under ESRS will be relieved from additional reporting requirements by the European Commission’s ‘quick fix’ amendments.
While the Omnibus process and ESRS simplification are ongoing, the amendments allow first-wave companies to continue applying phase-in reliefs until FY27 and delay the application of the four standards: biodiversity and three social standards. The amendments will apply for 2025 reporting periods.
Read our article for more details.
New digital hub
We’ve created a new EU Omnibus digital hub tracking the work underway to reduce sustainability reporting and due diligence requirements. Under the latest proposals, only the largest companies would report under ESRS, with a subset of those companies continuing to report under EU Taxonomy.
Bookmark the digital hub to track new developments.
The first wave of ESRS reporting | Webcast
Key lessons are emerging for companies navigating the initial phase of ESRS reporting. These include the value of engaging stakeholders effectively and the importance of having a clear strategic narrative in a complex landscape.
KPMG professionals have shared practical takeaways from the first wave of ESRS reporting and dived into thought-provoking questions around how impact ties into financial materiality.
Check out this webcast replay to find out more.