What’s the issue?

Forward-looking information is fundamental to sustainability-related financial reporting. Therefore, the International Sustainability Standards Board (ISSB) is keen to help companies understand what is expected of them when identifying relevant forward-looking information to support their disclosures.

Feedback on the ISSBTM proposals1 included calls for guidance on providing information that is subject to high outcome and measurement uncertainty – e.g. forward-looking information.

Disclosing forward-looking information can be challenging for companies because of the high level of uncertainty involved. The ISSB has agreed a practical solution, leveraging IFRS Accounting Standards, to help companies identify the type of information to use for disclosures in a scalable way.

Jonathan Ko
Partner, ESG Advisory
KPMG China

Jonathan Ko
Partner, ESG Advisory
KPMG China

Connect with us

What was proposed?

The proposals include many areas where significant outcome or measurement uncertainty can make it challenging to provide disclosures – e.g:

Read our guide for further details on the proposed disclosure requirements. 

What’s the ISSB’s latest thinking?

To support companies in providing disclosures in these areas, the ISSB agreed to introduce the concept of ‘reasonable and supportable information that is available at the reporting date without undue cost or effort’.

Some companies use the same concept when estimating expected credit losses under IFRS 9 Financial Instruments and future cash flows under IFRS 17 Insurance Contracts.

Concept What did the ISSB discuss?
Reasonable and supportable information

Companies would need to have a reasonable basis for using the information and it would need to be relevant to what is being reported.

Appropriate governance and controls would need to be in place to ensure that the information can be supported.

Available without ‘undue cost or effort’

Companies would need to consider all information that is ‘reasonably available’ to them. This also means that they could not disregard any information they already have or know about.

However, they would not need to undertake an exhaustive search for information. ‘Undue cost or effort’ would weigh the costs and benefits of information and would be proportional to the company, considering both:

  • the degree of the company’s exposure to risks and opportunities; and
  • the skills, capabilities and resources available to it.
At the reporting date

Companies would consider information about past events, current conditions and forecasts of future conditions, as at the reporting date.

The information available, particularly forward-looking information, will change over time.

For example, information from existing systems or information that is otherwise available for financial reporting purposes would be considered to be available without ‘undue cost or effort’. In some instances, companies will need to source additional information reasonably available to them for their sustainability reporting.

What’s the impact?

The concept of ‘reasonable and supportable’ would support all types of company to report information with a high degree of outcome or measurement uncertainty because it is scalable based on an individual company’s circumstances. However, it would not give companies an exemption from providing the required disclosures.

Each company would need to assess what reasonable and supportable information it has and can reasonably obtain to support its disclosures, but it would not need to perform an exhaustive search.

To ensure information is supportable, companies would need to ensure they have the appropriate processes, systems and controls in place. This is likely to require additional cost and effort, in terms of management time and/or direct spend, but would be proportional.

This is not a one-time assessment. The ISSB expects that over time the quality of reasonable and supportable information will improve as companies gain experience of reporting and data becomes more readily available.

Actions for management

  • Familiarise yourself with the requirements that involve disclosures with high outcome or measurement uncertainty. See our detailed guide.
  • Understand the information required to support these disclosures, including what is reasonably available to you.
  • Assess whether any existing systems, processes and controls are sufficient to support these disclosures.
  • Develop a roadmap to improve information for disclosures over time.

How did we get here?


Document version Reference
Proposed IFRS S1 ED/2022/S1 Published 31 March 2022
Proposed IFRS S2 ED/2022/S2 Published 31 March 2022
ISSB Board meeting: 20–23 September 2022; Frankfurt

AP3C and AP4C: Scalability

Meeting summary

The ISSB agreed on the factors that they will use to consider further which scalability mechanisms are appropriate to help companies apply the proposals
ISSB Board meeting: 17-19 January 2023; Frankfurt 

AP4C and AP4D: Reasonable and supportable information that is available at the reporting date without undue cost or effort

Meeting summary

The ISSB agreed to introduce the concept of ‘reasonable and supportable information that is available at the reporting date without undue cost or effort’ in selected areas

1 Proposed IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information and proposed IFRS S2 Climate-related Disclosures.


© 2024 KPMG Huazhen LLP, a People's Republic of China partnership, KPMG Advisory (China) Limited, a limited liability company in Chinese Mainland, KPMG, a Macau (SAR) partnership, and KPMG, a Hong Kong (SAR) partnership, are member firms of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

The KPMG name and logo are trademarks used under license by the
independent member firms of the KPMG global organisation.

For more detail about the structure of the KPMG global organisation please visit https://kpmg.com/governance.