We believe that further guidance is needed on the measurement and disclosure of information from associates, joint ventures and other non-consolidated investments. Initially, we suggest requiring disclosure of the approach(es) taken to incorporate information relating to material investments, followed by a separate project to provide further guidance. This should include working together with the Greenhouse Gas (GHG) Protocol to update those requirements and drive consistency and comparability in the reporting of GHG emissions.
As drafted, certain requirements may encourage companies to make inconsistent attributions of impacts as climate- or sustainability-related, and may lead to companies disclosing management’s forecasts of future performance without sufficient explanation that these are hypothetical and inherently uncertain. We suggest clarifications and drafting changes to resolve this.
By requiring retrospective changes in estimates, we believe the proposals place an undue burden on preparers to potentially restate all comparative information each year. We have made recommendations to resolve this – including a near-term solution and longer-term project.