EBF CONSULTATION RESPONSE
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EBF consultation response on the International Sustainability Standards Board (ISSB) Exposure Drafts

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BRUSSELS, 1^st August 2022  – The EBF welcomes the International Sustainability Standards Board’s (ISSB) efforts to develop a commonly accepted global baseline for sustainability disclosures. To the end of fostering consistency, comparability, understandability, and an overall harmonised and efficient framework, the EBF supports:

• The intention of providing structure to achieve comparability across jurisdictions and firms worldwide
• The ISSB’s continuous cooperation with existing international initiatives and practices and with due regard to existing or new standards, including the EFRAG’s European Sustainability Reporting Standards (ESRS)
• A single set of comprehensive disclosure standards — applying to both financial and non-financial firms — which is key to facilitating better investment and financing decisions by all stakeholders
• The concept of double materiality, which although not addressed by the ISSB, is an essential concept of sustainability as the impact of a company on the environment and society at large is a crucial piece of information for investors and lenders that wish to align their portfolios to the Paris Agreement. We would, therefore, encourage further guidance from the ISSB regarding materiality and enterprise value, as well as on the interoperability between the ISSB and the EFRAG standards (the latter having incorporated the double-materiality concept)

For more information please contact:

Denisa Avermaete
Senior Policy Adviser – Sustainable Finance, d.avermaete@ebf.eu

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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together 32 national banking associations in Europe that together represent a significant majority of all banking assets in Europe, with 3,500 banks – large and small, wholesale and retail, local and international – while employing approximately two million people. EBF members represent banks that make available loans to the European economy in excess of €20 trillion and that reliably handle more than 400 million payment transactions per day. Launched in 1960, the EBF is committed to a single market for financial services in the European Union and to supporting policies that foster economic growth.