IFRS Comparativo - Samantha García

March 2022
Exposure Draft
IFRS®
June 2023
IFRS S1
IFRS ® Sustainability Disclosure Standard
[Draft] IFRS S1 General Requirements for

Disclosure of Sustainability-related Financial
Information
Comments to be received by 29 July 2022
International Sustainability Standards Board
ED/2022/
I
F
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S
S
1
Exposure Draft
General Requirements for Disclosure of

Sustainability-related Financial Information
Comments to be received by 29 July 2022

Exposure Draft ED/2022/
IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information is
publishedtogether with its accompanying documents is issued by the International Sustainability
Standards Board (ISSB) for comment only. Comments need to be received by 29 July 2022 and should
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ISBN for this part: 978-1-914113-62-8
ISBN for complete publication (three parts): 978-1-914113-61-1
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GENERAL REQUIREMENTS
IFRS SUSTAINABILITY
FOR DISCLOSURE OF
DISCLOSURE
SUSTAINABILITY-RELATED FINANCIAL INFORMATION
STANDARDS
CONTENTS
from pageparagraph
INTRODUCTION 5
INVITATION TO COMMENT 8
[DRAFT] IFRS S1 GENERAL REQUIREMENTS FOR
DISCLOSURE OF SUSTAINABILITY-RELATED FINANCIAL
INFORMATION 22
OBJECTIVE 22
SCOPE 23
CORE CONTENT 23
Governance 24
Strategy 25
Risk management 28
Metrics and targets 29
GENERAL FEATURES 30
Reporting entity 30
Connected information 31
Fair presentation 32
Materiality 33
Comparative information 34
Frequency of reporting 35
Location of information 36
Sources of estimation and outcome uncertainty 37
Errors 38
Statement of compliance 39
APPENDICES 40
A Defined terms 40
B Effective date 42
C Qualitative characteristics of useful sustainability-related financial
information 43
APPROVAL BY THE ISSB CHAIR AND VICE-CHAIR OF
EXPOSURE DRAFT IFRS S1 GENERAL REQUIREMENTS
FOR DISCLOSURE OF SUSTAINABILITY-RELATED
FINANCIAL INFORMATION PUBLISHED IN
MARCH 2022 49
IFRS SUSTAINABILITY DISCLOSURE STANDARD

S1 GENERAL REQUIREMENTS FOR DISCLOSURE OF
SUSTAINABILITY-RELATED FINANCIAL
INFORMATION
OBJECTIVE 1
SCOPE 5
CONCEPTUAL FOUNDATIONS 10
Fair presentation 11
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Materiality 2023 17
Reporting entity 20
Connected information 21
CORE CONTENT 25
Governance 26
Strategy 28
Risk management 43
Metrics and targets 45
GENERAL REQUIREMENTS 54
Sources of guidance 54
Location of disclosures 60
Timing of reporting 64
Comparative information 70
Statement of compliance 72
JUDGEMENTS, UNCERTAINTIES AND ERRORS 74
Judgements 74
Measurement uncertainty 77
Errors 83
APPENDICES
A Defined terms
B Application guidance
C Sources of guidance
D Qualitative characteristics of useful sustainability-related
financial information
E Effective date and transition
APPROVAL BY THE ISSB OF IFRS S1 ISSUED IN JUNE 2023
FOR THE ACCOMPANYING GUIDANCE LISTED BELOW, SEE PART B OF THIS EDITION
ILLUSTRATIVE GUIDANCE
(see separate booklet)
ILLUSTRATIVE EXAMPLES
continued...
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...continued
FOR THE BASIS FOR CONCLUSIONS, SEE PART C OF THIS EDITION
BASIS FOR CONCLUSIONS (see separate booklet)
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[Draft] IFRS S1 General Requirements for Disclosure of Sustainability-related Financial

Information is set out in paragraphs 1–92 and Appendices A–C. All the paragraphs have
equal authority. Paragraphs in bold type state the main principles. Terms defined in
Appendix A are in italics the first time they appear in the [draft] Standard. Definitions of
other terms are given in other IFRS Sustainability Disclosure Standards. The [draft]
Standard should be read in the context of its objective and the Basis for Conclusions.
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Introduction
Why is the ISSB publishing the Exposure Draft?

These proposals respond to calls from primary users (investors, lenders and other
creditors) of general purpose financial reporting for more consistent, complete,
comparable and verifiable sustainability-related financial information to help them
assess an entity’s enterprise value. An entity’s ability to remain resilient will rely on a
range of resources and relationships. Such resources and relationships include its
workforce, any specialised knowledge it has developed and its relationships with local
communities and natural resources. Investors, lenders and other creditors, therefore,
seek information about the significant sustainability-related risks and opportunities
facing an entity to inform their decisions about providing resources to the entity. Such
information supplements and complements the information contained in the entity’s
financial statements.
Sustainability-related risks and opportunities arise from an entity’s dependencies on

resources and its impacts on resources, and the relationships the entity maintains that
may be positively or negatively affected by those impacts and dependencies. When an
entity’s business model depends, for example, on a natural resource—like water—it is
likely to be affected by changes in the quality, availability and pricing of that resource.
When an entity’s activities result in adverse, external impacts—on, for example, local
communities—it could be subjected to stricter government regulation and consequences
of reputational effects—for example, negative effects on the entity’s brand and higher
recruitment costs. Furthermore, when an entity’s business partners face significant
sustainability-related risks and opportunities, the entity could be exposed to related
consequences of its own. When such impacts, dependencies and relationships create
risks or opportunities, they can create or erode the value of the enterprise, the
financial returns to providers of financial capital, and the assessment of enterprise value
by primary users.
Enterprise value reflects expectations of the amount, timing and certainty of future cash
flows over the short, medium and long term and the value of those cash flows in the
light of the entity’s risk profile, and its access to finance and cost of capital. The
information contained in its financial statements and the information included in an
entity’s sustainability-related financial disclosures are essential inputs to a primary
user’s assessment of an entity’s enterprise value. The proposals would require an entity
to disclose material information about all of the significant sustainability-related risks
and opportunities to which it is exposed.
A summary of the proposals in the Exposure Draft

The proposals set out the overall requirements for disclosing sustainability-related
financial information in order to provide primary users with a complete set of
sustainability-related financial disclosures. The Exposure Draft is based on the general
requirements for disclosure of sustainability-related financial information prototype
published on the IFRS Foundation website in November 2021, developed by the Technical
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Readiness Working Group (TRWG). 1 The prototype and the Exposure
Draft include the recommendations by the Financial Stability Board's Task
Force on Climate-related Financial Disclosures (TCFD) and components of
the frameworks and standards of international sustainability bodies, as
published in a prototype of a sustainability-related financial disclosure
presentation standard in December 2020.2
The Exposure Draft includes proposals for definitions and requirements

that are consistent with the IASB’s Conceptual Framework for Financial Reporting,
IAS 1 Presentation of Financial Statements and IAS 8 Accounting Policies, Changes
in Accounting Estimates and Errors.
Proposals in the Exposure Draft would require an entity to disclose material

information about all of the significant sustainability-related risks and
opportunities to which it is exposed. The proposals include requirements
and guidance to support the disclosure of material information about
significant sustainability-related risks and opportunities not specifically
addressed by an IFRS Sustainability Disclosure Standard. In such cases, to
identify sustainability-related risks and opportunities and to disclose
information about them, entities are directed to consider sources that
include the disclosure topics in the industry-based Sustainability
Accounting Standards Board (SASB) Standards, the International
Sustainability Standards Board's (ISSB) non-mandatory guidance (such as
the CDSB Framework application guidance for water- and biodiversity-
related disclosures), the most recent pronouncements of other standard-
setting bodies whose requirements are designed to meet the needs of users
of general purpose financial reporting, and the sustainability-related risks
and opportunities identified by entities that operate in the same industries
or geographies.
The information requirements are designed to enable primary users to assess

enterprise value. The information required reflects the way in which an entity
operates, covering governance, strategy, risk management and metrics and
targets. This approach responds to feedback on key requirements for success
in the IFRS Foundation Trustees’ (Trustees) 2020 consultation on
sustainability reporting by building upon the well-established work of the
TCFD.
The proposals would require an entity to explain the connections between

different pieces of information, including between various sustainability-
related risks and opportunities and information in the entity’s financial
statements.
The sustainability-related financial information must be for the same

reporting entity as the financial statements and published as part of its
general purpose financial reporting. This means the information must be
disclosed at the same time as the financial statements.
To be able to assert compliance with
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IFRS S1 General Requirements for Disclosure of Sustainability-related Financial
Information is set out in paragraphs 1–86 and Appendices A–E. All paragraphs have equal
authority. Paragraphs in bold type state the main principles. Terms defined in Appendix A
are in italics the first time they appear in the Standard. Definitions of other terms are given
in other IFRS Sustainability Disclosure Standards. The Standard should be read in the
context of its objective and the Basis for Conclusions.
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IFRS S1 General Requirements for Disclosure of

Sustainability-related Financial Information
Objective
1
The objective of IFRS S1 General Requirements for Disclosure of Sustainability- related
Financial Information is to require an entity to disclose information about its sustainability-
related risks and opportunities that is useful to primary users of general purpose financial
reports in making decisions relating to providing resources to the entity.1
2
Information about sustainability-related risks and opportunities is useful to primary users
because an entity’s ability to generate cash flows over the short, medium and long term is
inextricably linked to the interactions between the entity and its stakeholders, society, the
economy and the natural environment throughout the entity’s value chain. Together, the
entity and the resources and relationships throughout its value chain form an
interdependent system in which the entity operates. The entity’s dependencies on those
resources and relationships and its impacts on those resources and relationships give rise
to sustainability-related risks and opportunities for the entity.
3
This Standard requires an entity to disclose information about all sustainability-related
risks and opportunities that could reasonably be expected to affect the entity’s cash
flows, its access to finance or cost of capital over the short, medium or long term. For
the purposes of this Standard, these risks and opportunities are collectively referred to
as ‘sustainability-related risks and opportunities that could reasonably be expected to
affect the entity’s prospects’.
4
This Standard also prescribes how an entity prepares and reports its sustainability-related
financial disclosures. It sets out general requirements for the content and presentation of those
disclosures so that the information disclosed is useful to primary users in making
decisions relating to providing resources to the entity.
Scope
5
An entity shall apply this Standard in preparing and reporting sustainability-related
financial disclosures in accordance with IFRS Sustainability Disclosure Standards.
6
Sustainability-related risks and opportunities that could not reasonably be expected to
affect an entity’s prospects are outside the scope of this Standard.
Other IFRS Sustainability Disclosure Standards, an entity must meet all of the
requirements of these Standards.
1 The TRWG included the International Accounting Standards Board (IASB), the Climate Disclosure
Standards Board (CDSB), the Financial Stability Board’s Task Force on Climate-related Financial
Disclosures (TCFD), the Value Reporting Foundation (previously the SASB Foundation and the
International Integrated Reporting Council) and the World Economic Forum and its Measuring
Stakeholder Capitalism Initiative.
2 https://29kjwb3armds2g3gi4lq2sx1-wpengine.netdna-ssl.com/wp-content/uploads/Reporting-on-
enterprise-value_climate-prototype_Dec20.pdf
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Due process provisions applicable to the Exposure Draft
The urgent need for the ISSB to deliver its initial Standards has been repeatedly
highlighted, including in feedback to the September 2020 consultation on sustainability
reporting held by the Trustees and to the April 2021 Exposure Draft of proposed
amendments to the IFRS Foundation Constitution. The International Organization of
Securities Commissions has also emphasised the urgent need for disclosure standards on
climate change. Such urgency can pose significant challenges to standard-setting, which
aims to achieve effective outcomes by balancing timely responsiveness to market needs
with the rigour of formal due process.
The Trustees recognised the opportunity to use and build upon existing sustainability
standards and frameworks, including those developed in accordance with prior due
process by the organisations that developed them and that enjoy broad user and preparer
support. The main components of the Exposure Draft are based on work that has been
subject to extensive public consultation and redeliberation and have since garnered
significant market uptake. The Trustees viewed this as a signal that these foundational
standards and frameworks help to address the information needs of investors and other
capital market participants.
The Trustees noted the need for prompt action and the background to the content of the
Exposure Draft. However, they also noted that this does not negate the need for formal
due process and exposure by the ISSB. It is important that the ISSB’s stakeholders are
given the opportunity to provide feedback on the proposals consistent with the IFRS
Foundation’s inclusive and thorough due process.
To balance the need to advance the work of the ISSB on a timely basis while obtaining
input from interested parties, the Trustees decided to grant special powers to the Chair
and Vice-Chair of the ISSB to enable timely publication of initial exposure drafts for
stakeholder input. The Trustees agreed it would be appropriate that as the ISSB is being
established (that is, as a transitional measure) the ISSB Chair and Vice-Chair be
provided with the ability to publish exposure drafts of a climate-related disclosure
standard and/or a general requirements disclosure standard. This decision is reflected in
paragraph 56 of the IFRS Foundation’s Constitution published in November 2021.
The effect of this provision in the Constitution is only to enable the exposure drafts to
be published prior to the ISSB being quorate. The exposure drafts are subject to public
consultation and will be redeliberated by a quorate ISSB. The ISSB Chair and Vice-Chair’s
right was made subject to oversight by the Due Process Oversight Committee of the
Trustees who were consulted at a meeting convened on 21 March 2022 during which
they confirmed they did not object to the ISSB Chair and Vice-Chair publishing these
exposure drafts.
Next steps
The Chair and Vice-Chair anticipate significant interest from stakeholders on the
Exposure Draft and on [draft] IFRS S2 Climate-related Disclosures which has been published
at the same time as the Exposure Draft. The ISSB will analyse and consider the
comments and feedback it receives and will decide how to proceed.
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The ISSB intends to redeliberate the Exposure Draft in the second half of 2022 based on
feedback from stakeholders and seeks to issue the resulting IFRS Sustainability Disclosure
Standard based on these proposals expeditiously.
Invitation to comment
The Chair and Vice-Chair invite comments on the proposals in the Exposure Draft,
particularly on the questions set out below. Comments are most helpful if they:
(a) address the questions as stated;
(b) specify the paragraph(s) to which they relate;
(c) contain a clear rationale;
(d) identify any wording in the proposals that is difficult to translate; and
(e) include any alternative the ISSB should consider, if applicable.
The Chair and Vice-Chair are requesting comments only on matters addressed in the
Exposure Draft.
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Questions for respondents
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Question 4—Core content (paragraphs 11–35)

The Exposure Draft includes proposals that entities disclose information that enables
primary users to assess enterprise value. The information required would represent
core aspects of the way in which an entity operates.
This approach reflects stakeholder feedback on key requirements for success in the
Trustees’ 2020 consultation on sustainability reporting, and builds upon the well-
established work of the TCFD.
Governance
The Exposure Draft proposes that the objective of sustainability-related financial
disclosures on governance would be:
to enable the primary users of general purpose financial reporting to understand the
governance processes, controls and procedures used to monitor and manage
significant sustainability-related risks and opportunities.
Strategy
disclosures on strategy would be:
to enable users of general purpose financial reporting to understand an entity’s strategy
for addressing significant sustainability-related risks and opportunities.
Risk management
disclosures on risk management would be:
to enable the users of general purpose financial reporting to understand the process, or
processes, by which sustainability-related risks and opportunities are identified, assessed
and managed. These disclosures shall also enable users to assess whether those
processes are integrated into the entity’s overall risk management processes and to
evaluate the entity’s overall risk profile and risk management processes.
Metrics and targets

disclosures on metrics and targets would be:
to enable users of general purpose financial reporting to understand how an entity
measures, monitors and manages its significant sustainability-related risks and
opportunities. These disclosures shall enable users to understand how the entity assesses
its performance, including progress towards the targets it has set.
(a) Are the disclosure objectives for governance, strategy, risk management
and metrics and targets clear and appropriately defined? Why or why not?
(b) Are the disclosure requirements for governance, strategy, risk management and
metrics and targets appropriate to their stated disclosure objective? Why or
why not?
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Question 7—Fair presentation (paragraphs 45–55)

The Exposure Draft proposes that a complete set of sustainability-related financial
disclosures would be required to present fairly the sustainability-related risks and
opportunities to which an entity is exposed. Fair presentation would require the
faithful representation of sustainability-related risks and opportunities in accordance
with the proposed principles set out in the Exposure Draft. Applying IFRS Sustainability
Disclosure Standards, with additional disclosure when necessary, is presumed to
result in sustainability-related financial disclosures that achieve a fair presentation.
To identify significant sustainability-related risks and opportunities, an entity would

apply IFRS Sustainability Disclosure Standards. In addition to IFRS Sustainability
Disclosure Standards to identify sustainability-related risks and opportunities, the
entity shall consider the disclosure topics in the industry-based SASB Standards, the
ISSB’s non-mandatory guidance (such as the CDSB Framework application guidance for
water- and biodiversity-related disclosures), the most recent pronouncements of other
standard-setting bodies whose requirements are designed to meet the needs of users
of general purpose financial reporting, and sustainability-related risks and
opportunities identified by entities that operate in the same industries or geographies.
7
To identify disclosures, including metrics, that are likely to be helpful
in assessing how sustainability-related risks and opportunities to
which it is exposed could affect its enterprise value, an entity would
apply the relevant IFRS Sustainability Disclosure Standards. In the
absence of an IFRS Sustainability Disclosure Standard that applies
specifically to a sustainability-related risk and opportunity, an entity
shall use its judgement in identifying disclosures that (a) are relevant
to the decision-making needs of users of general purpose financial
reporting; (b) faithfully represent the entity’s risks and opportunities
in relation to the specify information an entity is required to disclose about specific
sustainability-related risk or opportunity; and (c) are neutral. In making
that judgement, entities would consider the same sources identified in
the preceding paragraph, to the extent that they do not conflict with
an IFRS Sustainability Disclosure Standardrisks and opportunities.
(a) Is the proposal to present fairly the sustainability-related risks and
opportunities to which the entity is exposed, including the aggregation of
information, clear? Why or why not?
(b) Do you agree with the sources of guidance to identify sustainability-related

risks and opportunities and related disclosures? If not, what sources should the
entity be required to consider and why? Please explain how any alternative
sources are consistent with the proposed objective of disclosing sustainability-
related financial information in the Exposure Draft.
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Question 8—Materiality (paragraphs 56–62)

The Exposure Draft defines material information in alignment with the definition in IASB’s Conceptual Framework for General
Purpose Financial Reporting and IAS
1. Information ‘is material if omitting, misstating or obscuring that information could

reasonably be expected to influence decisions that the primary users of general purpose
financial reporting make on the basis of that reporting, which provides information
about a specific reporting entity’.
However, the materiality judgements will vary because the nature of sustainability-
related financial information is different to information included in financial
statements. Whether information is material also needs to be assessed in relation to
enterprise value.
Material sustainability-related financial information disclosed by an entity may change

from one reporting period to another as circumstances and assumptions change, and as
expectations from the primary users of reporting change. Therefore, an entity would be
required to use judgement to identify what is material, and materiality judgements are
reassessed at each reporting date. The Exposure Draft proposes that even if a specific
IFRS Sustainability Disclosure Standard contained specific disclosure requirements, an
entity would need not to provide that disclosure if the resulting information was not
material. Equally, when the specific requirements would be insufficient to meet users’
information needs, an entity would be required to consider whether to disclose
additional information. This approach is consistent with the requirements of IAS 1.
The Exposure Draft also proposes that an entity need not disclose information
otherwise required by the Exposure Draft if local laws or regulations prohibit the
entity from disclosing that information. In such a case, an entity shall identify the type
of information not disclosed and explain the source of the restriction.
(a) Is the definition and application of materiality clear in the context

of sustainability-related financial information? Why or why not?
(b) Do you consider that the proposed definition and application of materiality
will capture the breadth of sustainability-related risks and opportunities
relevant to the enterprise value of a specific entity, including over time? Why
or why not?
(c) Is the Exposure Draft and related Illustrative Guidance useful for identifying
material sustainability-related financial information? Why or why not? If
not, what additional guidance is needed and why?
(d) Do you agree with the proposal to relieve an entity from disclosing
information otherwise required by the Exposure Draft if local laws or
regulations prohibit the entity from disclosing that information? Why or why
not? If not, why?
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Question 10—Location of information (paragraphs 72–78)

The Exposure Draft proposes that an entity be required to disclose information required
by the IFRS Sustainability Disclosure Standards as part of its general purpose financial
reporting—ie as part of the same package of reporting that is targeted at investors and
other providers of financial capital.
However, the Exposure Draft deliberately avoids requiring the information to be

provided in a particular location within the general purpose financial reporting so as
not to limit an entity’s ability to communicate information in an effective and
coherent manner, and to prevent conflicts with specific jurisdictional regulatory
requirements on general purpose financial reporting.
The proposal permits an entity to disclose information required by an IFRS

Sustainability Disclosure Standard in the same location as information disclosed to
meet other requirements, such as information required by regulators. However, the
entity would be required to ensure that the sustainability-related financial disclosures
are clearly identifiable and not obscured by that additional information.
Information required by an IFRS Sustainability Disclosure Standard could also be

included by cross-reference, provided that the information is available to users of
general purpose financial reporting on the same terms and at the same time as the
information to which it is cross-referenced. For example, information required by an
IFRS Sustainability Disclosure Standard could be disclosed in the related financial
statements.
The Exposure Draft also proposes that when IFRS Sustainability Disclosure Standards
require a disclosure of common items of information, an entity shall avoid unnecessary
duplication.
(a) Do you agree with the proposals about the location of sustainability-
related financial disclosures? Why or why not?
(b) Are you aware of any jurisdiction-specific requirements that would make it
difficult for an entity to provide the information required by the Exposure Draft
despite the proposals on location?
(c) Do you agree with the proposal that information required by IFRS
Sustainability Disclosure Standards can be included by cross-reference
provided that the information is available to users of general purpose financial
reporting on the same terms and at the same time as the information to which
it is cross- referenced? Why or why not?
(d) Is it clear that entities are not required to make separate disclosures on each
aspect of governance, strategy and risk management for individual
sustainability-related risks and opportunities, but are encouraged to make
integrated disclosures, especially where the relevant sustainability issues are
managed through the same approach and/or in an integrated way? Why or
why not?
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How to comment
Please submit your comments electronically:
Survey and comment https://www.ifrs.org/projects/work-plan/general-sustainability-

letter online related-disclosures/exposure-draft-and-comment-letters/
Comment letter by commentletters@ifrs.org
email
Your comments will be on the public record and posted on our website unless you
request confidentiality and we grant your request. We normally grant such requests only
if they are supported by a good reason, for example, commercial confidence. Please see
our website for details on this policy and on how we use your personal data. If you
would like to request confidentiality, please contact us at commentletters@ifrs.org
before submitting your survey response or letter.
Deadline
The ISSB will consider all written comments and responses to the survey received by
29 July 2022.
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[Draft] IFRS S1
General Requirements for Disclosure of Sustainability-
related Financial Information
Objective
1
The objective of [draft] IFRS S1 General Requirements for
Disclosure of Sustainability-related Financial Information is to
require an entity to disclose information about its significant
sustainability-related risks and opportunities that is useful to
the primary users of general purpose financial reporting when
they assess enterprise value and decide whether to provide
resources to the entity.3
2
A reporting entity shall disclose material information
about all of the significant sustainability-related risks and
opportunities to which it is exposed. The assessment of
materiality shall be made in the context of the
information necessary for users of general purpose
financial reporting to assess enterprise value.
3
An entity’s general purpose financial reporting shall include a
complete, neutral and accurate depiction of its sustainability-
related financial information.
4
This [draft] Standard sets out how an entity is required to
disclose sustainability-related financial information in order to
provide the users of that information with a sufficient basis to
assess the implications of sustainability-related risks and
opportunities on the entity’s enterprise value.
5
Enterprise value reflects expectations of the amount, timing and
certainty of future cash flows over the short, medium and
long term and the value of those cash flows in the light of the
entity’s risk profile, and its access to finance and cost of capital.
Information that is essential for assessing the enterprise value of
an entity includes information that is provided by the entity in its
financial statements and sustainability-related financial
information.
6
Sustainability-related financial information is broader than
information reported in the financial statements and could
include information about:
(a) an entity’s governance of sustainability-related risks and

opportunities, and its strategy for addressing them;
(b) decisions made by the entity that could result in future

inflows and outflows that have not yet met the criteria
for recognition in the related financial statements;
(c) the entity’s reputation, performance and prospects as a

consequence of the actions it has undertaken, such as its
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and its impacts and dependencies on them; and
3 Throughout this [draft] Standard, the terms ‘primary users’ and ‘users’ are used
interchangeably, with the same meaning.
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(d) the entity’s development of knowledge-based assets.
7
This [draft] Standard also prescribes the basis for disclosing sustainability-
related financial information that:
(a) is comparable both with the entity’s sustainability-related financial

information of previous periods and with the sustainability-related
financial information from other entities; and
(b) is connected to the other information in the entity’s general purpose

financial reporting.
Scope
8
An entity shall apply this [draft] Standard in preparing and disclosing sustainability-
related financial information in accordance with IFRS Sustainability Disclosure Standards.
An entity may apply IFRS Sustainability Disclosure Standards whenirrespective of
whether the entity’s related general purpose financial statements (referred to as
‘financial statements’) are prepared in accordance with IFRS Accounting Standards or
other generally accepted accounting principles or practices (GAAP.).
8
Sustainability-related risks and opportunities that cannot reasonably be
expected to affect assessments of an entity’s enterprise value by primary
users of general purpose financial reporting are outside the scope of this
[draft] Standard.
9
This [draft] Standard uses terminology suitable for profit-oriented entities, including
public-sector business entities. If entities with not-for-profit activities in the private sector
or the public sector apply this [draft] Standard, they maymight need to amend the
descriptions used for some disclosureparticular items of information when applying IFRS
Sustainability Disclosure Standards.
Core content
9
Unless another IFRS Sustainability Disclosure Standard permits or
requires otherwise, an entity shall provide disclosures about:
(a) governance—the governance processes, controls and procedures the
entity uses to monitor and manage sustainability-related risks and
opportunities;
(b) strategy—the approach for addressing sustainability-related

risks and opportunities that could affect the entity’s business
model and strategy over the short, medium and long term;
(c) risk management—the processes the entity used to identify, assess
and manage sustainability-related risks; and
(d) metrics and targets—information used to assess, manage and

monitor the entity’s performance in relation to sustainability-
related risks and opportunities over time.
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Governance
10
The objective of sustainability-related financial
disclosures on governance is to enable users of general
purpose financial reporting to understand the governance
processes, controls and procedures used to monitor and
manage sustainability-related risks and opportunities.
11
To achieve this objective, an entity shall disclose information
about the governance body or bodies (which can include a board,
committee or equivalent body charged with governance) with
oversight of sustainability- related risks and opportunities, and
information about management’s role in those processes.
Specifically, an entity shall disclose:
(a) the identity of the body or individual within a body

responsible for oversight of sustainability-related risks
and opportunities;
how the body’s responsibilities for sustainability-related risks and opportunities are reflected in the entity’s
terms of reference, board mandates and other related policies;
(b) how the body ensures that the appropriate skills and
competencies are available to oversee strategies designed
to respond to sustainability- related risks and
opportunities;
(c) how and how often the body and its committees (audit,
risk or other committees) are informed about
sustainability-related risks and opportunities;
(d) how the body and its committees consider sustainability-

related risks and opportunities when overseeing the
entity’s strategy, its decisions on major transactions, and
its risk management policies, including any assessment
of trade-offs and analysis of sensitivity to uncertainty
that may be required;
(e) how the body and its committees oversee the setting of
targets related to significant sustainability-related risks
and opportunities, and monitor progress towards them
(see paragraphs 27–35), including whether and how
related performance metrics are included in remuneration
policies; and
(f) a description of management’s role in assessing and

managing sustainability-related risks and opportunities,
including whether that role is delegated to a specific
management-level position or committee and how
oversight is exercised over that position or committee.
The description shall include information about whether
dedicated controls and procedures are applied to
management of sustainability- related risks and
opportunities and, if so, how they are integrated with
other internal functions.
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Strategy
12
The objective of sustainability-related financial disclosures on
strategy is to enable users of general purpose financial reporting to
understand an entity’s strategy for addressing significant
sustainability-related risks and opportunities.
10
To achieve this objective, an entity shall disclose information about:
(a) the significant sustainability-related risks and opportunities that it

reasonably expects could affect its business model, strategy and cash
flows, its access to finance and its cost of capital, over the short,
medium or long term (see paragraphs 16–19);
the effects of significant sustainability-related risks and opportunities on its business model and value chain (see paragraph
20);
(b) the effects of significant sustainability-related risks and opportunities
on its strategy and decision-making (see paragraph 21);
(c) the effects of significant sustainability-related risks and opportunities

on its financial position, financial performance and cash flows for the
reporting period, and the anticipated effects over the short, medium
and long term—including how sustainability-related risks and
opportunities are included in the entity's financial planning (see
paragraph 22); and
(d) the resilience of its strategy (including its business model) to

significant sustainability-related risks (see paragraphs 23–24).
Sustainability-related risks and opportunities

13
An entity shall disclose information that enables users of general purpose
financial reporting to understand the significant sustainability-related risks
and opportunities that could reasonably be expected to affect the entity’s
business model, strategy and cash flows, its access to finance and its cost of
capital, over the short, medium or long term. Specifically, the entity shall
disclose:
(a) a description of significant sustainability-related risks and

opportunities and the time horizon over which each could reasonably
be expected to affect its business model, strategy and cash flows, its
access to finance and its cost of capital, over the short, medium or
long term; and
(b) how it defines short, medium and long term and how these definitions
are linked to the entity’s strategic planning horizons and capital
allocation plans.
14
An entity’s sustainability-related risks and opportunities arise from its
dependencies on resources and its impacts on resources, and from the
relationships it maintains that may be positively or negatively affected by
those impacts and dependencies. When an entity’s business model depends,
for example, on a natural resource—like water—it is likely to be affected by
changes in the quality, availability and pricing of that resource. When an
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entity’s activities result in adverse, external impacts—on, for example, local
communities—it could be subjected to stricter government regulation and
consequences of reputational effects—for example, negative effects on the
entity’s brand and higher recruitment costs. Furthermore, when an entity’s
business partners face significant sustainability-related risks and
opportunities, the entity could be exposed to related consequences of its own.
When such impacts, dependencies and relationships create risks or
opportunities for an entity, they can affect the entity’s performance or
prospects, create or erode the value of the enterprise and the financial returns
to providers of financial capital, and the assessment of enterprise value by the
primary user.
15
The short, medium and long term time horizons referred to in paragraph
16(a) can vary and depend on many factors, including industry-specific
characteristics, such as cash flow and business cycles, the expected duration
of capital investments, the time horizons over which the users of general
purpose financial reporting conduct their assessments, and the planning
horizons typically used in an entity’s industry for strategic decision-making.
16
In identifying the significant sustainability-related risks and opportunities
described in paragraph 16, an entity shall apply paragraph 51.
17
financial reporting to understand its assessment of the current and
anticipated effects of significant sustainability-related risks and opportunities
on its business model. Specifically, an entity shall disclose:
(a) a description of the current and anticipated effects of significant

sustainability-related risks and opportunities on its value chain; and
(b) a description of where in its value chain significant sustainability-

related risks and opportunities are concentrated (for example,
geographical areas, facilities or types of assets, inputs, outputs or
distribution channels).
Strategy and decision-making

18
financial reporting to understand the effects of significant sustainability-
related risks and opportunities on its strategy and decision-making.
Specifically, an entity shall disclose:
(a) how it is responding to significant sustainability-related risks and

opportunities;
(b) quantitative and qualitative information about the progress of plans

disclosed in prior reporting periods; and
(c) what trade-offs between sustainability-related risks and opportunities

were considered by the entity (for example, in a decision on the
location of new operations, a trade-off between the environmental
impacts of those operations and the employment opportunities they
would create in a community, and the related effects on enterprise
value).
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Financial position, financial performance and cash
flows
19
financial reporting to understand the effects of significant sustainability-
related risks and opportunities on its financial position, financial performance
and cash flows for the reporting period, and the anticipated effects over the
short, medium and long term—including how sustainability-related risks and
opportunities are included in the entity's financial planning. An entity shall
disclose quantitative information unless it is unable to do so. If an entity is
unable to provide quantitative information, it shall provide qualitative
information. When providing quantitative information, an entity can disclose
single amounts or a range. Specifically, an entity shall disclose:
(a) how significant sustainability-related risks and opportunities have

affected its most recently reported financial position, financial
performance and cash flows;
(b) information about the sustainability-related risks and opportunities

identified in paragraph 22(a) for which there is a significant risk that
there will be a material adjustment to the carrying amounts of assets
and liabilities reported in the financial statements within the next
financial year;
(c) how it expects its financial position to change over time, given its
strategy to address significant sustainability-related risks and
opportunities, reflecting:
(i) its current and committed investment plans and their

anticipated effects on its financial position (for example,
capital expenditure, major acquisitions and divestments, joint
ventures, business transformation, innovation, new business
areas and asset retirements);
(i) its planned sources of funding to implement its strategy; and
(d) how it expects its financial performance to change over time, given its
strategy to address significant sustainability-related risks and
opportunities.
Resilience
20
financial reporting to understand its capacity to adjust to the uncertainties
arising from significant sustainability-related risks. An entity shall disclose a
qualitative and, when applicable, a quantitative analysis of the resilience of
its strategy and cash flows in relation to its significant sustainability-related
risks, including how the analysis was undertaken and its time horizon. When
providing quantitative information, an entity can disclose single amounts or a
range.
21
Other IFRS Sustainability Disclosure Standards will specify the type of
information an entity is required to disclose about its resilience to specific
sustainability-related risks, such as when scenario analysis shall be used.
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Risk management
22
The objective of sustainability-related financial disclosures on risk
management is to enable users of general purpose financial reporting
to understand the process, or processes, by which sustainability-
related risks and opportunities are identified, assessed and managed.
These disclosures shall enable users to assess whether those
processes are integrated into the entity’s overall risk management
processes and to evaluate the entity’s overall risk profile and risk
management processes.
23
To achieve this objective, an entity shall disclose:
(a) the process, or processes, it uses to identify sustainability-related:
(i) risks; and
(ii) opportunities;
(b) the process, or processes, it uses to identify sustainability-related risks

for risk management purposes, including when applicable:
(i) how it assesses the likelihood and effects associated with such
risks (such as the qualitative factors, quantitative thresholds
and other criteria used);
(ii) how it prioritises sustainability-related risks relative to other

types of risks, including its use of risk-assessment tools;
(iii) the input parameters it uses (for example, data sources, the
scope of operations covered and the detail used in
assumptions); and
(iv) whether it has changed the processes used compared to the

prior reporting period;
(c) the process, or processes, it uses to identify, assess and prioritise

sustainability-related opportunities;
(d) the process, or processes, it uses to monitor and manage the

sustainability-related:
(i) risks, including related policies; and
(ii) opportunities, including related policies;
(e) the extent to which and how the sustainability-related risk

identification, assessment and management process, or processes, are
integrated into the entity’s overall risk management process; and
(f) the extent to which and how the sustainability-related opportunity

identification, assessment and management process, or processes, are
integrated into the entity’s overall management process.
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Metrics and targets
The objective of sustainability-related financial disclosures on metrics and targets is to enable users of general purpose
financial reporting to understand how an entity measures, monitors and manages its significant sustainability-related risks and
opportunities. These disclosures shall enable users to understand how the entity assesses its performance, including progress
towards the targets it has set.
24
Metrics shall include those defined in any other applicable IFRS
Sustainability Disclosure Standard, metrics identified from the other
sources identified in paragraph 54 and metrics developed by an entity
itself.
25
An entity shall identify metrics that apply to its activities in line with
its business model and in relation to specific sustainability-related
risks or opportunities. Some entities will have a range of activities
and, therefore, may need to apply metrics that are applicable to
more than one industry.
26
An entity shall disclose the metrics it uses to manage and monitor
sustainability-related risks and opportunities; and the metrics it uses to
measure performance, including progress towards the targets it has set.
27
When a metric has been developed by an entity, it shall disclose:
(a) how the metric is defined, including whether it is an absolute measure

or expressed in relation to another metric (such as revenue or floor
space) and any sources that have been used to construct the metric;
(b) whether measurement of the metric is validated by an external body

and, if so, which body; and
(c) explanations of the methods used to calculate the targets and the
inputs to the calculation, including the significant assumptions made
and the limitations of those methods.
28
An entity shall disclose the targets it has set to assess progress towards
achieving its strategic goals, specifying:
(a) the metric used;
(b) the period over which the target applies;
Conceptual foundations
(b) the base period from which progress is measured; and
(c) any milestones or interim targets.

29
An entity shall disclose:
(a) performance against its disclosed targets and an analysis of trends or

significant changes in its performance; and
(b) revisions to its targets and the explanation for those revisions.
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30
The definition and calculation of metrics, including metrics used to set and
monitor targets, shall be consistent over time. If a metric or target is
redefined or replaced, an entity shall:
(a) explain the changes;
explain the reasons for those changes, including why any replacement metric provides more useful information; and
(b) provide restated comparative figures, unless it is impracticable to do
so.
31
An entity shall label metrics and targets using meaningful, clear and precise
names and descriptions.
General features
11
For sustainability-related financial information to be useful, it shallmust be relevant and
faithfully represent what it purports to represent. These are fundamental qualitative
characteristics. Usefulness of useful sustainability-related financial information. The
usefulness of sustainability-related financial information is enhanced if the information
is comparable, verifiable, timely and understandable. Appendix C sets out theThese
are enhancing qualitative characteristics of useful information.sustainability-related
financial information (see Appendix D).
Reporting entity
32
An entity’s sustainability-related financial disclosures shall be for
the same reporting entity as the related general purpose financial
statements. For example, if the reporting entity is a group, the
consolidated financial statements will be for a parent and its
subsidiaries; consequently, that entity’s sustainability-related
financial disclosures shall enable users of general purpose financial
reporting to assess the enterprise value of the parent and its
subsidiaries.
33
An entity shall disclose the financial statements to which the sustainability-
related financial disclosures relate.
34
When currency is specified as the unit of measure, the entity shall
use the presentation currency of its financial statements.
35
Paragraph 2 requires an entity to disclose material information about all
significant sustainability-related risks and opportunities to which it is
exposed. These risks and opportunities relate to activities, interactions and
relationships and to the use of resources along its value chain, such as:
(a) its employment practices and those of its suppliers, wastage related to
the packaging of the products it sells, or events that could disrupt its
supply chain;
(b) the assets it controls (such as a production facility that relies on scarce
water resources);
(c) investments it controls, including investments in associates and joint

ventures (such as financing a greenhouse gas-emitting activity
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through a joint venture); and
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(d) sources of finance.
36
Other IFRS Sustainability Disclosure Standards will specify how an entity is
required to disclose or measure its significant sustainability-related risks and
opportunities, including those related to its associates, joint ventures and
other financed investments, and those related to its value chain.
Connected information
37
An entity shall provide information that enables users of general
purpose financial reporting to assess the connections between
various sustainability-related risks and opportunities, and to assess
how information about these risks and opportunities is linked to
information in the general purpose financial statements.
38
An entity shall describe the relationships between different pieces of
information. Doing so could require connecting narrative information on
governance, strategy and risk management to related metrics and targets. For
example, to allow users of general purpose financial reporting to assess
connections in information, an entity might need to explain the effect or
likely effect of its strategy on its financial statements or financial plans, or on
metrics and targets used to measure progress against performance.
Furthermore, the entity might need to explain how its use of natural
resources and changes within its supply chain could amplify, change or
reduce its significant sustainability-related risks and opportunities. The entity
may need to link this information to the potential or actual effect on its
production costs, its strategic response to mitigate such risks and its related
investment in new assets. This information may also need to be linked to
information in the financial statements and to specific metrics and targets.
Information that describes connections shall be clear and concise.
39
Examples of connected information include:
(a) an explanation of the combined effects of sustainability-related risks

and opportunities and the entity’s strategy and related metrics and
targets on its financial position, financial performance and cash flows
over the short, medium and long term. For example, an entity may
face decreasing demand for its products because of consumer
preferences for low-carbon alternatives. It may need to explain how
its strategic response, such as closing a major factory, affects its
workforce and communities, as well as the effect of the closure on the
useful lives of assets and impairment assessments.
(b) an explanation of the potential options that were evaluated when an

entity assessed its sustainability-related risks and opportunities, and
the consequences of its decisions to address those risks and
opportunities, including the trade-offs that were considered, as
detailed in paragraph 21(c). For example, an entity might need to
explain how a decision to restructure its operations in response to a
sustainability-related risk could have consequential effects on the
future size and composition of the entity’s workforce.
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Fair presentation
12
A complete set of sustainability-related financial disclosures shall present fairly theall
sustainability-related risks and opportunities to whichthat could reasonably be
expected to affect an entity is exposed. Fair presentation requires the faithful
representation of sustainability-related risks and opportunities in accordance with the
principles set out in this [draft] Standardentity’s prospects.
40
Applying IFRS Sustainability Disclosure Standards, with additional
disclosure when necessary, is presumed to result in sustainability-related
financial disclosures that achieve a fair presentation.
41
A fair presentation also requires an entity:
(a) to disclose information that is relevant, representationally faithful,

comparable, verifiable, timely and understandable; and
(b) to provide additional disclosures when compliance with the specific

requirements in IFRS Sustainability Disclosure Standards is insufficient
to enable users of general purpose financial reporting to assess the
implications of sustainability-related risks and opportunities on the
entity’s enterprise value.
42
When applying this [draft] Standard and other IFRS Sustainability Disclosure
Standards, an entity, after it has considered all relevant facts and
circumstances, shall decide how to aggregate the information in its
sustainability-related financial disclosures. An entity shall not reduce the
understandability of its sustainability-related financial disclosures by
obscuring material information with immaterial information or by
aggregating material items that are dissimilar.
43
Information shall not be aggregated if doing so would obscure information
that is material. Rather, aggregation and disaggregation shall be based on the
characteristics of the sustainability-related risks and opportunities.
Information shall be aggregated when it shares those characteristics and
disaggregated when it does not share them. Information about sustainability-
related risks and opportunities might need to be disaggregated, such as by
geographical location or in consideration of the geopolitical environment. For
example, to ensure that material information is not obscured, an entity might
need to disaggregate disclosures about its use of water to distinguish between
water drawn from abundant sources and water drawn from high-stress
sources.
Identifying sustainability-related risks and opportunities and

disclosures
44
This [draft] Standard requires an entity to disclose material information about
all of the significant sustainability-related risks and opportunities to which it
is exposed (see paragraph 2).
45
To identify sustainability-related risks and opportunities about which
information could reasonably be expected to influence decisions that the
users of general purpose financial reporting make on the basis of that
information, an entity shall refer to IFRS Sustainability Disclosure
Standards, including
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identified disclosure topics. In addition to IFRS Sustainability Disclosure
Standards, an entity shall consider:
(a) the disclosure topics in the industry-based SASB Standards;
(b) the ISSB’s non-mandatory guidance (such as the CDSB Framework

application guidance for water- and biodiversity-related disclosures);
(c) the most recent pronouncements of other standard-setting bodies

whose requirements are designed to meet the needs of users of general
purpose financial reporting; and
(d) the sustainability-related risks and opportunities identified by entities

that operate in the same industries or geographies.
46
To identify disclosures, including metrics, about a significant sustainability-
related risk or opportunity, an entity shall refer to the relevant IFRS
47
In the absence of an IFRS Sustainability Disclosure Standard that applies
specifically to a sustainability-related risk or opportunity, management shall
use its judgement in identifying disclosures that:
(a) are relevant to the decision-making needs of users of general purpose

financial reporting;
(b) faithfully represent the entity’s risks and opportunities in relation to

the specific sustainability-related risk or opportunity; and
(c) are neutral.

48
In making the judgement described in paragraph 53, management shall
consider, to the extent that these do not conflict with an IFRS Sustainability
Disclosure Standard, the metrics associated with the disclosure topics included
in the industry-based SASB Standards, the ISSB’s non-mandatory guidance
(such as the CDSB Framework application guidance for water- and biodiversity-
related disclosures), the most recent pronouncements of other standard-setting
bodies whose requirements are designed to meet the needs of users of general
purpose financial reporting, and the metrics used by entities in the same
industries or geographies.
49
An entity shall disclose the industry or industries specified in the relevant
IFRS Sustainability Disclosure Standard or industry-based SASB Standards that
it has used when identifying disclosures about a significant sustainability-
related risk or opportunity.
Materiality
13
Sustainability-related financial information is material if omitting,
misstating or obscuring that information could that could reasonably be
expected to influence decisions that the primary users of general purpose
financial reporting make on the basis of that reporting, which provides
information about a specific reporting entity.affect an entity’s prospects, an
entity shall apply paragraphs B1–B12.
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50
Material sustainability-related financial information provides
insights into factors that could reasonably be expected to
influence primary users’ assessments of an entity’s enterprise
value. The information relates to activities, interactions and
relationships and to the use of resources along the entity’s value
chain if it could influence the assessment primary users make of
its enterprise value. It can include information about
sustainability-related risks and opportunities with low-
probability and high-impact outcomes.
14
Fair presentation requires disclosure of relevant information about
sustainability-related risks and opportunities that could reasonably be
expected to affect the entity’s prospects, and their faithful representation
in accordance with the principles set out in this Standard. To achieve
faithful representation, an entity shall provide a complete, neutral and
accurate depiction of those sustainability-related risks and opportunities.
15
Materiality is an entity-specific aspect of relevance based on the nature or
magnitude, or both, of the items to which the information relates, in the
context of the entity’s general purpose financial reporting. This [draft]
Standard does not specify any thresholds for materiality or predetermine
what would be material in a particular situationsustainability-related financial
disclosures.
51
An entity shall apply judgement to identify material
sustainability-related financial information. Materiality
judgements shall be reassessed at each reporting date to take
account of changed circumstances and assumptions.
An entity need not provide a specific disclosure that would otherwise be required by an IFRS
Sustainability Disclosure Standard if the information resulting from that disclosure is not
material. This is the case even if the IFRS Sustainability Disclosure Standard contains a list of
specific requirements or describes them as minimum requirements.
16
AnFair presentation also requires an entity shall also consider whether :
(a) to disclose information that is comparable, verifiable, timely and

understandable; and
(b) to disclose additional information whenif compliance with the

specific specifically applicable requirements in an IFRS
Sustainability Disclosure StandardStandards is insufficient to enable
users of general purpose financial reportingreports to
assessunderstand the effect on enterprise valueeffects of the
sustainability-related risks and opportunities to which the entity is
exposed.
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on the entity’s cash flows, its access to finance and cost of capital over the short,
medium and long term.
17
Applying IFRS Sustainability Disclosure Standards, with additional information disclosed
when necessary (see paragraph 15(b)), is presumed to result in sustainability-related
financial disclosures that achieve fair presentation.
Materiality
An entity need notshall disclose material information otherwise required by an IFRS Sustainability
Disclosure Standard if local laws or regulations prohibitabout the entity from disclosingsustainability-related
risks and opportunities that information. If an entity omits material information for that reason, it shall
identify the type of information not disclosed and explain the source of the restriction.
Comparative information
18
An entity shall disclose comparative information in respect of the previous period for all
metrics disclosed in the current period. When such information wouldcould reasonably
be relevantexpected to an understanding of the current period’saffect the entity’s
prospects.
52
In the context of sustainability-related financial disclosures, the
entity shall also disclose comparative information for narrative and
descriptive sustainability- related financial disclosures.
53
When providing sustainability-related financial disclosures an entity shall
disclose is material if omitting, misstating or
comparative
obscuring that information that reflects updated estimates. When the
entity reports comparative information that differs from the information
reported in the previous period it shall disclose:
(a) the difference between the amount reported in the previous period and
the revised comparative amount; and
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(b) the reasons the amounts have been revised.
54
Sometimes, it is impracticable to adjust comparative information for one or
more prior periods to achieve comparability with the current period. For
example, data might not have been collected in the prior period(s) in a way
that allows either retrospective application of a new definition of a metric or
target or retrospective restatement to correct a prior period error, and it may
be impracticable to recreate the information. When it is impracticable to
adjust comparative information for one or more prior periods, an entity shall
disclose that fact.
Frequency of reporting
55
An entity shall report its sustainability-related financial disclosures
at the same time as its related financial statements and the
sustainability-related financial disclosures shall be for the same
reporting period as the financial statements.
19
When an entity changes the end of its reporting period and discloses sustainability-related
financial disclosures for a period longer or shorter than 12 months, it shall disclose:
(a) the period covered by the sustainability-related financial disclosures;
(b) the reason for using a longer or shorter period; and
(c) the fact that the amounts disclosed in the sustainability-related financial
disclosures are not entirely comparable.
56
Normally, an entity prepares sustainability-related financial disclosures for a
12-month period. However, for practical reasons, some entities prefer to
report, for example, for a 52-week period. This [draft] Standard does not
preclude this practice.
57
This [draft] Standard does not mandate which entities would be required to
disclose interim sustainability-related financial information, how frequently it
shall be disclosed, or how soon after the end of an interim period it shall be
disclosed. However, governments, securities regulators, stock exchanges and
accountancy bodies may require entities whose debt or equity securities are
publicly traded to publish interim reports. Paragraph 70 applies if an entity is
required or elects to publish interim sustainability-related financial
information in accordance with IFRS Sustainability Disclosure Standards.
58
In the interest of timeliness and cost considerations, and to avoid repetition of
information previously reported, an entity may be required or choose to
provide less information at interim dates than it provides in its annual
disclosures are intended to provide an
disclosures. The interim
update on the latest complete set of annual disclosures of
sustainability-related financial information. These
disclosures focus on new information, events and
circumstances and do not duplicate information previously
reported. Although the information provided in interim sustainability-
related financial disclosures may be more condensed than in annual
disclosures, an entity is not prohibited or discouraged from publishing a
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sustainability-related financial disclosures as described in this
[draft] Standard in its interim reporting.
20
Information about transactions, other events and conditions that occur
after the end of the reporting period, and before the date on which the
sustainability-related financial disclosures are authorised for issue, shall
be disclosed if non-disclosure could reasonably be expected to influence
decisions that theprimary users of general purpose financial
reportingreports make on the basis of that reporting of those reports,
which include financial statements and sustainability-related financial
disclosures and which provide information about a specific reporting entity.
21
To identify and disclose material information, an entity shall apply
paragraphs B13–B37.
Reporting entity
22
An entity’s sustainability-related financial disclosures shall be for the same
reporting entity as the related financial statements (see paragraph B38).
Connected information
23
An entity shall provide information in a manner that enables users of
general purpose financial reports to understand the following types of
connections:
(a) the connections between the items to which the information relates
—such as connections between various sustainability-related risks
and opportunities that could reasonably be expected to affect the
entity’s prospects; and
(b) the connections between disclosures provided by the entity:
(i) within its sustainability-related financial disclosures—such

as connections between disclosures on governance, strategy,
risk management and metrics and targets; and
(ii) across its sustainability-related financial disclosures and

other general purpose financial reports published by the entity
—such as its related financial statements (see paragraphs
B39–B44).
24
An entity shall identify the financial statements to which the sustainability-
related financial disclosures relate.
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25
Data and assumptions used in preparing the sustainability-related financial
disclosures shall be consistent—to the extent possible considering the
requirements of IFRS Accounting Standards or other applicable GAAP—
with the corresponding data and assumptions used in preparing the
related financial statements (see paragraph B42).
26
When currency is specified as the unit of measure in the sustainability-
related financial disclosures, the entity shall use the presentation
currency of its related financial statements.
Core content
27
Unless another IFRS Sustainability Disclosure Standard permits or
requires otherwise in specified circumstances, an entity shall provide
disclosures about:
(a) governance—the governance processes, controls and procedures the

entity uses to monitor and manage sustainability-related risks and
opportunities (see paragraphs 26–27);
(b) strategy—the approach the entity uses to manage sustainability-

related risks and opportunities (see paragraphs 28–42);
(c) risk management—the processes the entity uses to identify, assess,

prioritise and monitor sustainability-related risks and opportunities
(see paragraphs 43–44); and
(d) metrics and targets—the entity’s performance in relation to

sustainability-related risks and opportunities, including progress
towards any targets the entity has set or is required to meet by law
or regulation (see paragraphs 45–53).
Governance
28
The objective of sustainability-related financial disclosures on governance
is to enable users of general purpose financial reports to understand the
governance processes, controls and procedures an entity uses to monitor,
manage and oversee sustainability-related risks and opportunities.
29
(a) the governance body(s) (which can include a board, committee or

equivalent body charged with governance) or individual(s)
responsible for oversight of sustainability-related risks and
opportunities. Specifically, the entity shall identify that body(s) or
individual(s) and disclose information about:
(i) how responsibilities for sustainability-related risks and

opportunities are reflected in the terms of reference, mandates,
role descriptions and other related policies applicable to that
body(s) or individual(s);
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(ii) how the body(s) or individual(s) determines whether
appropriate skills and competencies are available or will be
developed to oversee strategies designed to respond to
sustainability-related risks and opportunities;
(iii) how and how often the body(s) or individual(s) is informed

about sustainability-related risks and opportunities;
(iv) how the body(s) or individual(s) takes into account

sustainability-related risks and opportunities when overseeing
the entity’s strategy, its decisions on major transactions and its
risk management processes and related policies, including
whether the body(s) or individual(s) has considered trade-offs
associated with those risks and opportunities; and
(v) how the body(s) or individual(s) oversees the setting of targets

related to sustainability-related risks and opportunities, and
monitors progress towards those targets (see paragraph 51),
including whether and how related performance metrics are
included in remuneration policies.
(b) management’s role in the governance processes, controls and

procedures used to monitor, manage and oversee sustainability-related
risks and opportunities, including information about:
(i) whether the role is delegated to a specific management-level

position or management-level committee and how oversight is
exercised over that position or committee; and
(ii) whether management uses controls and procedures to support

the oversight of sustainability-related risks and opportunities
and, if so, how these controls and procedures are integrated
with other internal functions.
Strategy
30
The objective of sustainability-related financial disclosures on strategy is to
enable users of general purpose financial reports to understand an entity ’s
strategy for managing sustainability-related risks and opportunities.
31
Specifically, an entity shall disclose information to enable users of general
purpose financial reports to understand:
(a) the sustainability-related risks and opportunities that could reasonably

be expected to affect the entity’s prospects (see paragraphs 30–31);
(b) the current and anticipated effects of those sustainability-related risks

and opportunities on the entity’s business model and value chain (see
paragraph 32);
(c) the effects of those sustainability-related risks and opportunities on

the entity’s strategy and decision-making (see paragraph 33);
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(d) the effects of those sustainability-related risks and opportunities on
the entity’s financial position, financial performance and cash flows
for the reporting period, and their anticipated effects on the entity ’s
financial position, financial performance and cash flows over the
short, medium and long term, taking into consideration how those
sustainability-related risks and opportunities have been factored into
the entityʼs financial planning (see paragraphs 34–40); and
(e) the resilience of the entity’s strategy and its business model to those
sustainability-related risks (see paragraphs 41–42).
Sustainability-related risks and opportunities

32
financial reports to understand the sustainability-related risks and
opportunities that could reasonably be expected to affect the entity’s
prospects. Specifically, the entity shall:
(a) describe sustainability-related risks and opportunities that could

reasonably be expected to affect the entity’s prospects;
(b) specify the time horizons—short, medium or long term—over which

the effects of each of those sustainability-related risks and
opportunities could reasonably be expected to occur; and
(c) explain how the entity defines ‘short term’, ‘medium term’ and ‘long
term’ and how these definitions are linked to the planning horizons
used by the entity for strategic decision-making.
33
Short-, medium- and long- term time horizons can vary between entities and
depend on many factors, including industry-specific characteristics, such as
cash flow, investment and business cycles, the planning horizons typically
used in an entity’s industry for strategic decision-making and capital
allocation plans, and the time horizons over which users of general purpose
financial reports conduct their assessments of entities in that industry.
Business model and value chain

34
financial reports to understand the current and anticipated effects of
sustainability-related risks and opportunities on the entity’s business model
and value chain. Specifically, the entity shall disclose:
(a) a description of the current and anticipated effects of sustainability-

related risks and opportunities on the entity’s business model and
value chain; and
(b) a description of where in the entity’s business model and value chain
sustainability-related risks and opportunities are concentrated (for
example, geographical areas, facilities and types of assets).
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Strategy
Location of information
and decision-making
35
financial reports to understand the effects of sustainability-related risks and
opportunities on its strategy and decision-making. Specifically, the entity
shall disclose information about:
(a) how the entity has responded to, and plans to respond to,
sustainability-related risks and opportunities in its strategy and
decision-making;
(b) the progress against plans the entity has disclosed in previous
reporting periods, including quantitative and qualitative information;
and
(c) trade-offs between sustainability-related risks and opportunities that

the entity considered (for example, in making a decision on the
location of new operations, an entity might have considered the
environmental impacts of those operations and the employment
opportunities they would create in a community).
Financial position, financial performance and cash flows

36
financial reports to understand:
(a) the effects of sustainability-related risks and opportunities on the

entity’s financial position, financial performance and cash flows for
the reporting period (current financial effects); and
(b) the anticipated effects of sustainability-related risks and opportunities

on the entity’s financial position, financial performance and cash flows
over the short, medium and long term, taking into consideration how
sustainability-related risks and opportunities are included in the
entity’s financial planning (anticipated financial effects).
37
Specifically, an entity shall disclose quantitative and qualitative information
about:
(a) how sustainability-related risks and opportunities have affected its

financial position, financial performance and cash flows for the
reporting period;
(b) the sustainability-related risks and opportunities identified in

paragraph 35(a) for which there is a significant risk of a material
adjustment within the next annual reporting period to the carrying
amounts of assets and liabilities reported in the related financial
statements;
(c) how the entity expects its financial position to change over the short,
medium and long term, given its strategy to manage sustainability-
related risks and opportunities, taking into consideration:
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(i) its investment and disposal plans (for example, plans for
capital expenditure, major acquisitions and divestments, joint
ventures, business transformation, innovation, new business
areas, and asset retirements), including plans the entity is not
contractually committed to; and
(ii) its planned sources of funding to implement its strategy; and
(d) is required to disclosehow the entity expects its financial

performance and cash flows to change over the short, medium and
long term, given its strategy to manage sustainability-related risks and
opportunities.
38
In providing quantitative information, an entity may disclose a single amount
or a range.
39
In preparing disclosures about the anticipated financial effects of a
sustainability-related risk or opportunity, an entity shall:
(a) use all reasonable and supportable information that is available to the
entity at the reporting date without undue cost or effort (see
paragraphs B8–B10); and
(b) use an approach that is commensurate with the skills, capabilities and
resources that are available to the entity for preparing those
disclosures.
40
An entity need not provide quantitative information about the current or
anticipated financial effects of a sustainability-related risk or opportunity if
the entity determines that:
(a) those effects are not separately identifiable; or
(b) the level of measurement uncertainty involved in estimating those

effects is so high that the resulting quantitative information would not
be useful (see paragraphs 77–82).
41
In addition, an entity need not provide quantitative information about the
anticipated financial effects of a sustainability-related risk or opportunity if
the entity does not have the skills, capabilities or resources to provide that
quantitative information.
42
If an entity determines that it need not provide quantitative information
about the current or anticipated financial effects of a sustainability-related
risk or opportunity applying the criteria set out in paragraphs 38–39, the
entity shall:
(a) explain why it has not provided quantitative information;
(b) provide qualitative information about those financial effects,

including identifying line items, totals and subtotals within the related
financial statements that are likely to be affected, or have been
affected, by that sustainability-related risk or opportunity; and
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(c) provide quantitative information about the combined financial effects
of that sustainability-related risk or opportunity with other
sustainability-related risks or opportunities and other factors unless
the entity determines that quantitative information about the combined
financial effects would not be useful.
Resilience
43
financial reports to understand its capacity to adjust to the uncertainties
arising from sustainability-related risks. An entity shall disclose a qualitative
and, if applicable, quantitative assessment of the resilience of its strategy and
business model in relation to its sustainability-related risks, including
information about how the assessment was carried out and its time horizon.
When providing quantitative information, an entity may disclose a single
amount or a range.
44
Other IFRS Sustainability Disclosure Standards may specify the type of
information an entity is required to disclose about its resilience to specific
sustainability-related risks and how to prepare those disclosures, including
whether a scenario analysis is required.
Risk management
45
The objective of sustainability-related financial disclosures on risk
management is to enable users of general purpose financial reports:
(a) to understand an entity’s processes to identify, assess, prioritise and

monitor sustainability-related risks and opportunities, including
whether and how those processes are integrated into and inform
the entity’s overall risk management process; and
(b) to assess the entity’s overall risk profile and its overall risk
management process.
46
(a) the processes and related policies the entity uses to identify, assess,
prioritise and monitor sustainability-related risks, including
information about:
(i) the inputs and parameters the entity uses (for example,
information about data sources and the scope of operations
covered in the processes);
(ii) whether and how the entity uses scenario analysis to inform its
identification of sustainability-related risks;
(iii) how the entity assesses the nature, likelihood and magnitude of
the effects of those risks (for example, whether the entity
considers qualitative factors, quantitative thresholds or other
criteria);
(iv) whether and how the entity prioritises sustainability-related

risks relative to other types of risk;
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(v) how the entity monitors sustainability-related risks; and
(vi) whether and how the entity has changed the processes it uses
compared with the previous reporting period;
(b) the processes the entity uses to identify, assess, prioritise and monitor
sustainability-related opportunities; and
(c) the extent to which, and how, the processes for identifying, assessing,
prioritising and monitoring sustainability-related risks and
opportunities are integrated into and inform the entity’s overall risk
management process.
Metrics and targets

47
The objective of sustainability-related financial disclosures on metrics and
targets is to enable users of general purpose financial reports to
understand an entity’s performance in relation to its sustainability-related
risks and opportunities, including progress towards any targets the entity
has set, and any targets it is required to meet by law or regulation.
48
An entity shall disclose, for each sustainability-related risk and opportunity
that could reasonably be expected to affect the entity’s prospects:
(a) metrics required by an applicable IFRS Sustainability Disclosure

Standard; and
(b) metrics the entity uses to measure and monitor:
(i) that sustainability-related risk or opportunity; and
(ii) its performance in relation to that sustainability-related risk or

opportunity, including progress towards any targets the entity has set, and
any targets it is required to meet by law or regulation.
49
In the absence of an IFRS Sustainability Disclosure Standard that specifically
applies to a sustainability-related risk or opportunity, an entity shall apply
paragraphs 57–58 to identify applicable metrics.
50
Metrics disclosed by an entity applying paragraphs 45–46 shall include
metrics associated with particular business models, activities or other
common features that characterise participation in an industry.
51
If an entity discloses a metric taken from a source other than IFRS
Sustainability Disclosure Standards, the entity shall identify the source and
the metric taken.
52
If a metric has been developed by an entity, the entity shall disclose
information about:
(a) how the metric is defined, including whether it is derived by adjusting

a metric taken from a source other than IFRS Sustainability
Disclosure Standards and, if so, which source and how the metric
disclosed by the entity differs from the metric specified in that source;
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(b) whether the metric is an absolute measure, a measure expressed in
relation to another metric or a qualitative measure (such as a red,
amber, green—or RAG—status);
(c) whether the metric is validated by a third party and, if so, which party;
and
(d) the method used to calculate the metric and the inputs to the
calculation, including the limitations of the method used and the
significant assumptions made.
53
An entity shall disclose information about the targets it has set to monitor
progress towards achieving its strategic goals, and any targets it is required to
meet by law or regulation. For each target, the entity shall disclose:
(a) the metric used to set the target and to monitor progress towards
reaching the target;
(b) the specific quantitative or qualitative target the entity has set or is
required to meet;
(c) the period over which the target applies;
(d) the base period from which progress is measured;
(e) any milestones and interim targets;
(f) performance against each target and an analysis of trends or changes

in the entity’s performance; and
(g) any revisions to the target and an explanation for those revisions.
54
The definition and calculation of metrics, including metrics used to set the
entity’s targets and monitor progress towards reaching them, shall be
consistent over time. If a metric is redefined or replaced, an entity shall apply
paragraph B52.
55
An entity shall label and define metrics and targets using meaningful, clear
and precise names and descriptions.
General requirements
Sources of guidance
Identifying sustainability-related risks and opportunities
56
In identifying sustainability-related risks and opportunities that could
reasonably be expected to affect an entity’s prospects, an entity shall apply
IFRS Sustainability Disclosure Standards.
57
In addition to IFRS Sustainability Disclosure Standards:
(a) an entity shall refer to and consider the applicability of the disclosure
topics in the SASB Standards. An entity might conclude that the
disclosure topics in the SASB Standards are not applicable in the
entity’s circumstances.
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(b) an entity may refer to and consider the applicability of:
(i) the CDSB Framework Application Guidance for Water-related

Disclosures and the CDSB Framework Application Guidance for
Biodiversity-related Disclosures (collectively referred to as
‘CDSB Framework Application Guidance’);
(ii) the most recent pronouncements of other standard-setting

bodies whose requirements are designed to meet the
information needs of users of general purpose financial
reports; and
(iii) the sustainability-related risks and opportunities identified by

entities that operate in the same industry(s) or geographical
region(s).
Identifying applicable disclosure requirements

58
In identifying applicable disclosure requirements about a sustainability-
related risk or opportunity that could reasonably be expected to affect an
entity’s prospects, an entity shall apply the IFRS Sustainability Disclosure
Standard that specifically applies to that sustainability-related risk or
opportunity.
59
In the absence of an IFRS Sustainability Disclosure Standard that specifically
applies to a sustainability-related risk or opportunity, an entity shall apply
judgement to identify information that:
(a) is relevant to the decision-making of users of general purpose financial

reports; and
(b) faithfully represents that sustainability-related risk or opportunity.

60
In making the judgement described in paragraph 57:
(a) an entity shall refer to and consider the applicability of the metrics
associated with the disclosure topics included in the SASB Standards.
An entity might conclude that the metrics specified in the SASB
Standards are not applicable in the entity’s circumstances.
(b) an entity may—to the extent that these sources do not conflict with
IFRS Sustainability Disclosure Standards—refer to and consider the
applicability of:
(i) the CDSB Framework Application Guidance;
(ii) the most recent pronouncements of other standard-setting

bodies whose requirements are designed to meet the
information needs of users of general purpose financial
reports; and
(iii) the information, including metrics, disclosed by entities that

operate in the same industry(s) or geographical region(s).
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(c) an entity may—to the extent that these sources assist the entity in
meeting the objective of this Standard (see paragraphs 1–4) and do not
conflict with IFRS Sustainability Disclosure Standards—refer to and
consider the applicability of the sources specified in Appendix C.
Disclosure of information about sources of guidance

61
An entity shall identify:
(a) the specific standards, pronouncements, industry practice and other

sources of guidance that the entity has applied in preparing its
sustainability-related financial disclosures, including, if applicable,
identifying the disclosure topics in the SASB Standards; and
(b) the industry(s) specified in the IFRS Sustainability Disclosure

Standards, the SASB Standards or other sources of guidance relating
to a particular industry(s) that the entity has applied in preparing its
sustainability-related financial disclosures, including in identifying
applicable metrics.
Location of disclosures
62
An entity is required to provide disclosures required by IFRS Sustainability
Disclosure Standards as part of its general purpose financial
reportingreports.
63
Subject to any regulation or other requirements that apply to an entity, there
are various possible locations in its general purpose financial reportingreports
in which to disclose sustainability-related financial information.
Sustainability- related financial disclosures could be included in an entity’s
management commentary or a similar report when management
commentaryit forms part of an entity’s general purpose financial
reportingreports. Management commentary complements an entity’s
financial statements.or a similar report is a required report in many
jurisdictions. It provides insights into the factors that have affected the
entity’s financial performance and financial position and the factors that
could affect the entity’s ability to create value and generate cash flows.
Management commentary canmight be known by or incorporatedincluded in
reports with various names, including such as ‘management report’,
‘management’s discussion and analysis, analysis’, ‘operating and financial
review, review’, ‘integrated report and report’ or ‘strategic reportreport’.
64
An entity mightmay disclose information required by an IFRS Sustainability
Disclosure Standard in the same location as information disclosed to meet
other requirements, such as information required by regulators. The entity
shall ensure that the sustainability-related financial disclosures are clearly
identifiable and not obscured by that additional information. (see
paragraph B27).
65
Information required by an IFRS Sustainability Disclosure Standard canmay
be included in sustainability-related financial disclosures by cross-reference
to another report published by the entity. If an entity includes information by
cross-reference, the entity shall apply the requirements in paragraphs B45–
B47.
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Timing of reporting
66
An entity shall report its sustainability-related financial disclosures at the
same time as its related financial statements. The entity’s sustainability-
related financial disclosures shall cover the same reporting period as the
related financial statements.
67
Normally, an entity prepares sustainability-related financial disclosures for a
12-month period. However, for practical reasons, some entities prefer to
report, for example, for a 52-week period. , providedThis Standard does not
preclude that practice.
68
When an entity changes the end of its reporting period and provides
sustainability-related financial disclosures for a period longer or shorter than
12 months, it shall disclose:
(a) the period covered by the sustainability-related financial disclosures;
(b) the reason for using a longer or shorter period; and
(c) the fact that the amounts disclosed in the sustainability-related

financial disclosures are not entirely comparable.
69
the information is available to If, after the end of the reporting period but
before the date on which the sustainability-related financial disclosures are
authorised for issue, an entity receives information about conditions that
existed at the end of the reporting period, it shall update disclosures that
relate to those conditions in the light of the new information.
70
An entity shall disclose information about transactions, other events and
conditions that occur after the end of the reporting period, but before the date
on which the sustainability-related financial disclosures are authorised for
issue, if non-disclosure of that information could reasonably be expected to
influence decisions that primary users of general purpose financial reporting
on the same terms and at the same time as the information to which it is
cross-referenced. For example, informationreports make on the basis of those
reports.
71
This Standard does not mandate which entities would be required by an IFRS
Sustainability Disclosure Standard could be disclosed in the related financial
statements. Including information by cross- referencing rather than providing
information directly shall not make the complete set of sustainability-related
financial disclosures less understandable.to provide interim sustainability-
related financial disclosures, how frequently, or how soon after the end of an
interim period. However, governments, securities regulators, stock exchanges
and accountancy bodies may require entities whose debt or equity securities
are publicly traded to publish interim general purpose financial reports. If an
entity is required or elects to publish interim sustainability-related financial
disclosures in accordance with IFRS Sustainability Disclosure Standards, the
entity shall apply paragraph B48.
Comparative information
72
Material information included by cross-reference becomes partUnless
another IFRS Sustainability Disclosure Standard permits or requires
otherwise, an entity shall disclose comparative information in respect of
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reporting period. If such information would be useful for an understanding
of the sustainability-related financial disclosures for the reporting period,
the entity shall also disclose comparative information for narrative and
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descriptive sustainability-related financial information (see paragraphs B49–B59).
73
Amounts reported in sustainability-related financial disclosures might relate, for example,
to metrics and targets or to current and anticipated financial effects of sustainability-
related risks and opportunities.
Statement of compliance
74
. Information included by cross-reference shall An entity whose sustainability-
related financial disclosures comply with all the requirements of IFRS Sustainability
Disclosure Standards. For example, it needs to be relevant, representationally
faithful, comparable, verifiable, timely and understandable. The bodies or
individuals that authorise the general purpose financial shall make an explicit and
unreserved statement of compliance. An entity shall not describe sustainability-related
financial disclosures as complying with IFRS Sustainability Disclosure Standards unless
they comply with all the requirements of IFRS Sustainability Disclosure Standards.
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reporting take the same responsibility for the information
included by cross- reference as they do for the information
included directly.
59
If information required by an IFRS Sustainability Disclosure
Standard is included by reference to information in another
location:
75
the This Standard relieves an entity from disclosing information otherwise
required by an IFRS Sustainability Disclosure Standard if law or regulation
prohibits the entity from disclosing that information (see paragraph B33).
This Standard also relieves an entity from disclosing information about a
sustainability-related opportunity otherwise required by an IFRS Sustainability
Disclosure Standard if that information is commercially sensitive as
described in this Standard (see paragraphs B34–B37). An entity using these
exemptions is not prevented from asserting compliance with IFRS
Judgements, uncertainties and errors
Judgements
76
An entity shall disclose information to enable users of general purpose
financial reports to understand the judgements, apart from those involving
estimations of amounts (see paragraph 77), that the entity has made in the
process of preparing its sustainability-related financial disclosures and that
have the most significant effect on the information included in those
disclosures.
77
In the process of preparing sustainability-related financial disclosures, an
entity makes various judgements, apart from those involving estimations, that
can significantly affect the information reported in the entity’s sustainability-
related financial disclosures. For example, an entity makes judgements in:
(a) identifying sustainability-related risks and opportunities that could be

reasonably expected to affect the entity’s prospects;
(b) determining which sources of guidance to apply in accordance with

paragraphs 54–58;
(c) identifying material information to include in the sustainability-

related financial disclosures; and
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(d) assessing whether an event or change in circumstances is significant
and requires reassessment of the scope of all affected sustainability-
related risks and opportunities throughout the entity’s value chain (see
paragraph B11).
78
Other IFRS Sustainability Disclosure Standards may require disclosure of some
of the information that an entity would otherwise be required to disclose in
accordance with paragraph 74.
Measurement uncertainty
79
An entity shall disclose information to enable users of general purpose
financial reportingreports to understand the most significant uncertainties
affecting the amounts reported in its sustainability-related financial
disclosures.
80
An entity shall :
(a) identify the location of that information and explain how to access
itamounts that it has disclosed that are subject to a high level of
measurement uncertainty; and
(a) the cross-reference shall be to a precisely specified part of

that location.
60
When IFRS Sustainability Disclosure Standards require the
disclosure of common items of information, an entity shall avoid
unnecessary duplication. For example, when an entity integrates
its oversight of sustainability-related risks and opportunities, the
disclosures on governance shall also be integrated rather than
provided in the form of separate governance disclosures for each
significant sustainability-related risk and opportunity.
Sources of estimation and outcome uncertainty

(b) in relation to each amount identified in paragraph 78(a), disclose
information about:
(i) the sources of measurement uncertainty—for example, the dependence of

the amount on the outcome of a future event, on a measurement technique
or on the availability and quality of data from the entity’s value chain; and
(ii) the assumptions, approximations and judgements the entity has made in
measuring the amount.
81
When metricsamounts reported in sustainability-related financial
disclosures cannot be measured directly and can only be estimated,
measurement uncertainty arises. In some cases, an estimate involves
assumptions about possible future events with uncertain outcomes. The use
of reasonable estimates is an essential part of preparing sustainability-
related metricsfinancial disclosures and does not undermine the
usefulness of the information if the estimates are accurately described
and explained. Even a high level of measurement uncertainty would not
necessarily prevent such an estimate from providing useful information.Even
a high level of measurement uncertainty would not necessarily prevent such
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an shall
identify metrics it has disclosed that have significant
estimation uncertainty, disclosing the sources and
82
The requirement in paragraph 77 for an entity to disclose information about
the uncertainties affecting the amounts reported in sustainability-related
financial disclosures relates to the estimates that require the entity ’s most
difficult, subjective or complex judgements. As the number of variables and
assumptions increases, those judgements become more subjective and
complex, and the uncertainty affecting the amounts reported in the
sustainability-related financial disclosures increases accordingly.
83
The type and extent of the information an entity might need to disclose vary
according to the nature of the estimation uncertainties and amount
reported in the sustainability-related financial disclosures—the sources of and
the factors affecting the uncertainties.contributing to the uncertainty
and other circumstances. Examples of the type of information an entity might
need to disclose are:
61
When sustainability-related financial disclosures include
financial data and assumptions, such financial data and
assumptions shall be consistent with the corresponding
financial data and assumptions in the entity’s financial
statements, to the extent possible.
Some IFRS Sustainability Disclosure Standards require the disclosure of information such as
explanations about possible future events that have uncertain outcomes. In judging whether
information about such possible future events is material, an entity shall consider:
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(a) the potential effectsnature of the events on assumption or other source of
measurement uncertainty;
(b) the value, timing and certaintysensitivity of the entity’s future cash flowsdisclosed
amount to the methods, assumptions and estimates underlying its calculation,
including in the long term (the possible outcome);reasons for the sensitivity;
(a) the expected resolution of an uncertainty and
(c) the full range of reasonably possible outcomes and the likelihood of the possible
outcomes within that range.for the disclosed amount; and
62
When considering possible outcomes, an entity shall consider all relevant
facts and circumstances, and consider including information about low-
probability and high-impact outcomes, which, when aggregated, could
become material. For example, an entity might be exposed to several
sustainability-related risks, each of which could cause the same type of
disruption—such as disruptions to the entity’s supply chain. Information
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about an individual source of risk might not be material if disruption from
that source is highly unlikely to occur. However, information about the
aggregate risk—the risk of supply chain disruption from all sources—might
be material.
(d) An entity shall disclose information about the an explanation of changes made to
past assumptions it makes aboutconcerning the disclosed amount, if the future,
and other sources of significant uncertainty, related to remains unresolved.
84
Other IFRS Sustainability Disclosure Standards may require disclosure of some of the
information it discloses about the possible effects of sustainability-related risks or
opportunities, when there is significant outcome uncertainty.that an entity would
otherwise be required to disclose in accordance with paragraphs 77–78.
Errors
85
An entity shall correct material prior period errors by restating the comparative
amounts for the prior period(s) disclosed unless it is impracticable to do so.
86
Prior period errors are omissions from and misstatements in the entity’s
sustainability-related financial disclosures for one or more prior periods. Such errors arise
from a failure to use, or the misuse of, reliable information that:
(a) was available when the general purposesustainability-related financial

reportingdisclosures for those periods wasthat period(s) were authorised for issue;
and
(b) could reasonably be expected to have been obtained and considered in the
preparation of those sustainability-related financial disclosures.
63
Such errors include: the effects of mathematical mistakes, mistakes in
applying the definitions for metrics and targets, oversights or
misinterpretations of facts, and fraud.
Potential current period errors discovered in that period are corrected before the general purpose
financial reporting is authorised for issue. However, material errors are sometimes not discovered
until a subsequent period.
When it is impracticable to determine the effect of an error on all prior periods presented, the entity
shall restate the comparative information to correct the error from the earliest date practicable.
87
Corrections of errors are distinguished from changes in estimates. Estimates are
approximations that an entity maymight need to revise as additional information becomes
known.
88
If an entity identifies a material error in its prior period sustainability-related financial
disclosures, it shall disclose:apply paragraphs B55–B59.
(a) the nature of the prior period error;
(b) the correction, to the extent practicable, for each prior period disclosed; and
(a) if correction of the error is not practicable, the circumstances that led
to the existence of that condition and a description of how and from
when the error has been corrected.
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Statement of compliance
64
An entity whose sustainability-related financial
disclosures comply with all of the relevant requirements
of IFRS Sustainability Disclosure Standards shall include
an explicit and unqualified statement of compliance.
65
Paragraph 62 relieves an entity from disclosing information
otherwise required by an IFRS Sustainability Disclosure
Standard if local laws or regulations prohibit the entity from
disclosing that information. An entity using that relief is not
prevented from asserting compliance with IFRS Sustainability
Disclosure Standards.
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Appendix A Defined terms

This appendix is an integral part of [draft] IFRS S1 and has the same authority as the other parts of the
[draft] Standard.
business
Business model An entity’s system of transforming inputs through its business activities
into outputs and outcomes that aims to fulfil the entity’s strategic purposes
and create value for the entity and hence generate cash flows over the short,
Disclosuredisclosure topic A specific sustainability-related risk or opportunity based on the
activities conducted by entities within a particular industry as set out in an
IFRS Sustainability Disclosure Standard or an industry-baseda SASB
Standard.
Enterprise value The total value of an entity. It is the sum of the value of the
entity’s equity (market capitalisation) and the value of the
entity’s net debt.
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general purpose The provision of

financial
reportingreport
s
IFRS Sustainability
Disclosure Standards
Primary users of
general purpose
financial reporting
(primary users)
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Reports that provide
2023 instruments;
financial information (b) providing or selling loans and other forms of credit; or
about a reporting entity
(c) exercising rights to vote on, or otherwise influence, the
that is useful to primary
entity’s management’s actions that affect the use of the
users in making decisions
entity’s economic resources.
relating to providing
resources to the entity. General purpose financial reporting encompassesreports
Those decisions involve include—but isare not restricted to—an entity’s general
decisions about: purpose financial statements and sustainability-related
financial disclosures.
(a) buying, selling or
holding equity and debt Standards of that name issued by the International
Sustainability Standards Board.
impracticable Applying a requirement is impracticable when an entity cannot
apply it after making every reasonable effort to do so.
material information In the context of sustainability-related financial disclosures,
information is material if omitting, misstating or obscuring
that information could reasonably be expected to influence
decisions that primary users of general purpose financial
reports make on the basis of those reports, which include
financial statements and sustainability-related financial
disclosures and which provide information about a specific
reporting entity.
primary users of Existing and potential investors, lenders and other creditors.
general purpose
financial reports
(primary users)
Reportingreporting entity An entity that is required, or chooses, to prepare
general purpose financial statements.
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Disclosures about 2023
scenario analysis A process for identifying and assessing a potential range of
outcomes of future events under conditions of uncertainty.
sustainability- A particular form of general purpose financial reports that
related risks and
opportunities provide information about the reporting entity’s sustainability-
that are useful to related risks and opportunities that could reasonably be expected
financial to affect the entity’s cash flows, its access to finance or cost of
disclosures capital over the short, medium or long term, including
information about itsthe entity’s governance, strategy and risk
management in relation to those risks and opportunities, and
related metrics and targets.
users of
general
purpose
financial
reporting
when they
assess an
entity’s
enterprise
valuereports
(users)
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Sustainability- Information that gives insight into sustainability-related risks

related financial and opportunities that affect enterprise value, providing a
information sufficient basis for See primary users of general purpose
financial reporting to assess the resources and relationships
on which an entity’s business model and strategy for
sustaining and developing that model depend.
Users general purpose financial reporting

See primary reports (primary users). These definitions describe the same population.
users of Value
value chain The full range of activitiesinteractions, resources and relationships related
to a reporting entity’s business model and the external environment in
which it operates.
A value chain encompasses the activitiesinteractions, resources and

relationships an entity uses and reliesdepends on to create its products or
services from conception to delivery, consumption and end- of-life.
Relevant activities, including interactions, resources and relationships
include those in the entity’s operations, such as human resourceresources;
those along its supply, marketing and distribution channels, such as
materials and service sourcing, and product and service sale and delivery;
and the financing, geographical, geopolitical and regulatory environments
in which the entity operates.
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Appendix B Effective
dateApplication
guidance
This appendix is an integral part of [draft] IFRS S1 and has the same authority as the other
parts of the [draft] Standard.
Sustainability-related risks and opportunities (paragraphs 11–12)

B1 This Standard requires an entity to disclose information about all
expected to affect the entity’s cash flows, its access to finance or cost of
capital over the short, medium or long term (referred to as ‘sustainability-
related risks and opportunities that could reasonably be expected to affect the
entity’s prospects’) (see paragraph 3).
B2 An entity’s sustainability-related risks and opportunities arise out of the

interactions between the entity and its stakeholders, society, the economy and
the natural environment throughout the entity’s value chain. These
interactions—which can be direct and indirect—result from operating an
entity’s business model in pursuit of the entity’s strategic purposes and from
the external environment in which the entity operates. These interactions
take place within an interdependent system in which an entity both depends
on resources and relationships throughout its value chain to generate cash
flows and affects those resources and relationships through its activities and
outputs—contributing to the preservation, regeneration and development of
those resources and relationships or to their degradation and depletion. These
dependencies and impacts might give rise to sustainability-related risks and
opportunities that could reasonably be expected to affect an entity ’s cash
flows, its access to finance and cost of capital over the short, medium and
long term.
B3 For example, if an entity’s business model depends on a natural resource—

such as water—the entity could both affect and be affected by the quality,
availability and affordability of that resource. Specifically, degradation or
depletion of that resource—including resulting from the entity’s own
activities and from other factors—could create a risk of disruption to the
entity’s operations and affect the entity’s business model or strategy and
could ultimately negatively affect the entity’s financial performance and
financial position. In contrast, regeneration and preservation of that resource
— including resulting from the entity’s own activities and from other factors
— could positively affect the entity. Similarly, if an entity operates in a
highly competitive market and requires a highly specialised workforce to
achieve its strategic purposes, the entity’s future success will likely depend
on the entity’s ability to attract and retain that resource. At the same time,
that ability will depend, in part, on the entity’s employment practices—such
as whether the entity invests in employee training and wellbeing—and the
levels of employee satisfaction, engagement and retention. These examples
illustrate the close relationship between the value the entity creates, preserves
or erodes for others and the entity’s own ability to succeed and achieve its
goals.
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B4 Resources and relationships that an entity depends on and affects by its
activities and outputs can take various forms, such as natural, manufactured,
intellectual, human, social or financial. They can be internal—such as the
entity’s workforce, its know-how or its organisational processes—or they can
be external—such as materials and services the entity needs to access or the
relationships it has with suppliers, distributors and customers. Furthermore,
resources and relationships include, but are not limited to, the resources and
relationships recognised as assets in the entity’s financial statements.
B5 An entity’s dependencies and impacts are not limited to resources the entity
engages with directly, and to the entity’s direct relationships. Those
dependencies and impacts also relate to resources and relationships
throughout the entity’s value chain. For example, they can relate to the
entity’s supply and distribution channels; the effects of the consumption and
disposal of the entity’s products; and the entity’s sources of finance and its
investments, including investments in associates and joint ventures. If the
entity’s business partners throughout its value chain face sustainability-
related risks and opportunities, the entity could be exposed to related
consequences of its own.
Identifying sustainability-related risks and opportunities

B6 An entity shall use all reasonable and supportable information that is
available to the entity at the reporting date without undue cost or effort (see
paragraphs B8–B10):
(a) to identify the sustainability-related risks and opportunities that could reasonably be
expected to affect the entity’s prospects; and
(b) to determine the scope of its value chain, including its breadth and composition, in
relation to each of those sustainability-related risks and opportunities.
B7 In identifying the sustainability-related risks and opportunities that could

reasonably be expected to affect its prospects, an entity shall apply the
requirements on sources of guidance in paragraphs 54–55.
Reasonable and supportable information

B8 Reasonable and supportable information used by an entity in preparing its
sustainability-related financial disclosures shall cover factors that are specific
to the entity as well as general conditions in the external environment. In
some cases—such as in identifying sustainability-related risks and
opportunities that could reasonably be expected to affect an entity’s prospects
—reasonable and supportable information includes information about past
events, current conditions and forecasts of future conditions. Other IFRS
Sustainability Disclosure Standards may specify what is reasonable and
supportable information in specific cases.
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B9
An entity may use various sources of data that may be both internal and
external. Possible data sources include the entity’s risk management
processes; industry and peer group experience; and external ratings, reports
and statistics. Information that is used by the entity in preparing its financial
statements, operating its business model, setting its strategy and managing its
risks and opportunities is considered to be available to the entity without
undue cost or effort.
B10
An entity need not undertake an exhaustive search for information to identify
expected to affect the entity’s prospects. The assessment of what constitutes
undue cost or effort depends on the entity’s specific circumstances and
requires a balanced consideration of the costs and efforts for the entity and
the benefits of the resulting information for primary users. That assessment
can change over time as circumstances change.
Reassessment of the scope of sustainability-related risks

and opportunities throughout the value chain
B11 On the occurrence of a significant event or significant change in
circumstances, an entity shall reassess the scope of all affected sustainability-
related risks and opportunities throughout its value chain. A significant event
or significant change in circumstances can occur without the entity being
involved in that event or change in circumstances or as a result of a change in
what the entity assesses to be important to users of general purpose financial
reports. For example, such significant events or significant changes in
circumstances might include:
(a) a significant change in the entity’s value chain (for example, a

supplier in the entity’s value chain makes a change that significantly
alters the supplier’s greenhouse gas emissions);
(b) a significant change in the entity’s business model, activities or

corporate structure (for example, a merger or acquisition that expands
the entity’s value chain); and
(c) a significant change in an entity’s exposure to sustainability-related

risks and opportunities (for example, a supplier in the entity’s value
chain is affected by the introduction of a new regulation that the
entity had not anticipated).
B12 An entity is permitted, but not required, to reassess the scope of any
sustainability-related risk or opportunity throughout its value chain more
frequently than required by paragraph B11.
Materiality (paragraphs 17–19)
B13 17 requires an entity to disclose material information about the sustainability-

Par related risks and opportunities that could reasonably be expected to affect the
agr entity’s prospects. Materiality of information is judged in relation to
ap whether omitting, misstating or obscuring that information could
h reasonably be expected to influence decisions of primary users of
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general purpose financial reports, which provide information about a specific

reporting entity.
B14 The decisions of primary users relate to providing resources to the entity and
involve decisions about:
(a) buying, selling or holding equity and debt instruments;
(b) providing or selling loans and other forms of credit; or
(c) exercising rights to vote on, or otherwise influence, the entity’s

management’s actions that affect the use of the entity’s economic
resources.
B15 The decisions described in paragraph B14 depend on primary users’

expectations about returns, for example, dividends, principal and interest
payments or market price increases. Those expectations depend on primary
users’ assessment of the amount, timing and uncertainty of future net cash
inflows to the entity and on their assessment of stewardship of the entity’s
economic resources by the entity’s management and its governing body(s) or
individual(s).
B16 Assessing whether information could reasonably be expected to influence the

decisions made by primary users requires consideration of the characteristics
of those users and of the entity’s own circumstances.
B17 Sustainability-related financial disclosures are prepared for primary users

who have reasonable knowledge of business and economic activities and who
review and analyse information diligently. At times, even well-informed and
diligent users may need to seek the aid of an adviser to understand
sustainability-related financial information.
B18 Individual primary users may have different, and sometimes even conflicting,
information needs and desires. Information needs of primary users may also
evolve over time. Sustainability-related financial disclosures are intended to
meet common information needs of primary users.
Identifying material information

B19 Materiality judgements are specific to an entity. Consequently, this Standard
does not specify any thresholds for materiality or predetermine what would
be material in a particular situation.
To identify material information about a sustainability-related risk or

B20
opportunity, an entity shall apply, as the starting point, the requirements of
the IFRS Sustainability Disclosure Standard that specifically applies to that
sustainability-related risk or opportunity. In the absence of an IFRS
Sustainability Disclosure Standard that specifically applies to a
sustainability- related risk or opportunity, the entity shall apply the
requirements on sources of guidance specified in paragraphs 57–58. Those
sources specify information, including metrics, that may be relevant to a
particular sustainability-related risk or opportunity, to a particular industry or
in specified circumstances.
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B21
An entity shall assess whether the information identified in applying
paragraph B20, either individually or in combination with other information,
is material in the context of the entity’s sustainability-related financial
disclosures taken as a whole. In assessing whether information is material, an
entity shall consider both quantitative and qualitative factors. For example,
an entity might consider the magnitude and the nature of the effect of a
sustainability-related risk or opportunity on the entity.
B22
In some cases, IFRS Sustainability Disclosure Standards require the
disclosure of information about possible future events with uncertain
outcomes. In judging whether information about such possible future events
is material, an entity shall consider:
(a) the potential effects of the events on the amount, timing and
uncertainty of the entity’s future cash flows over the short, medium
and long term (referred to as ‘the possible outcome’); and
(b) the range of possible outcomes and the likelihood of the possible
outcomes within that range.
B23 When considering possible outcomes, an entity shall consider all pertinent
facts and circumstances. Information about a possible future event is more
likely to be judged as being material if the potential effects are significant
and the event is likely to occur. However, an entity shall also consider
whether information about low-probability and high-impact outcomes might
be material either individually or in combination with information about
other low-probability and high-impact outcomes. For example, an entity
might be exposed to several sustainability-related risks, each of which could
cause the same type of disruption—such as disruption to the entity’s supply
chain. Information about an individual source of risk might not be material if
disruption from that source is highly unlikely to occur. However, information
about the aggregate risk—the risk of supply chain disruption from all
sourcesB1
B24 —might be material.
If a possible future event is expected to affect an entity’s cash flows, but only
many years in the future, information about that event is usually less likely to
be judged material than information about a possible future event with
similar effects that are expected to occur sooner. However, in some
circumstances, an item of information could reasonably be expected to
influence primary users’ decisions regardless of the magnitude of the
potential effects of the future event or the timing of that event. For example,
this might happen if information about a particular sustainability-related risk
or opportunity is highly scrutinised by primary users of an entity’s general
B25 purpose financial reports.
An entity shall apply this [draft]need not disclose information otherwise

required by an IFRS Sustainability Disclosure Standard if the information is
not material. This is the case even if the IFRS Sustainability Disclosure
Standard contains a list of specific requirements or describes them as
minimum requirements.
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B26
An entity shall disclose additional information when compliance with the
specifically applicable requirements in an IFRS Sustainability Disclosure
Standard is insufficient to enable users of general purpose financial reports to
understand the effects of sustainability-related risks and opportunities on the
entity’s cash flows, its access to finance and cost of capital over the short,
B27
An entity shall identify its sustainability-related financial disclosures clearly
and distinguish them from other information provided by the entity (see
paragraph 62). An entity shall not obscure material information. Information
is obscured if it is communicated in a way that would have a similar effect
for annual primary users to omitting or misstating that information.
Examples of circumstances that might result in material information being
obscured include:
(a) material information is not clearly distinguished from additional

information that is not material;
(b) material information is disclosed in the sustainability-related financial

disclosures, but the language used is vague or unclear;
(c) material information about a sustainability-related risk or opportunity

is scattered throughout the sustainability-related financial disclosures;
(d) items of information that are dissimilar are inappropriately

aggregated;
(e) items of information that are similar are inappropriately

disaggregated; and
(f) the understandability of the sustainability-related financial disclosures

is reduced as a result of material information being hidden by
immaterial information to the extent that a primary user is unable to
determine what information is material.
B28 An entity shall reassess its materiality judgements at each reporting date to
take account of changed circumstances and assumptions. Because of changes
in the entity’s individual circumstances, or in the external environment, some
types of information included in an entity’s sustainability-related financial
disclosures for prior periods beginning on or after 1 January 20XXmight no
longer be material. Conversely, some types of information not previously
disclosed might become material.
Aggregation and disaggregation

B29
When . Earlier application is permitted. If an entity applies this [draft]
Standard earlier, it shall disclose that factIFRS Sustainability Disclosure
Standards, it shall consider all facts and circumstances and decide how to
aggregate and disaggregate information in its sustainability-related financial
disclosures. The entity shall not reduce the understandability of its
sustainability-related financial disclosures by obscuring material information
with immaterial information or by aggregating material items of information
that are dissimilar to each other.
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B30
An entity shall not aggregate information if doing so would obscure
information that is material. Information shall be aggregated if items of
information have shared characteristics and shall not be aggregated if they do
not have shared characteristics. The entity might need to disaggregate
information about sustainability-related risks and opportunities, for example,
by geographical location or in consideration of the geopolitical environment.
For example, to ensure that material information is not obscured, an entity
might need to disaggregate information about its use of water to distinguish
between water drawn from abundant sources and water drawn from water-
stressed areas.
Interaction with law or regulation

B31 Law or regulation might specify requirements for an entity to disclose
sustainability-related information in its general purpose financial reports. In
such circumstances, the entity is permitted to include in its sustainability-
related financial disclosures information to meet legal or regulatory
requirements, even if that information is not material. However, such
information shall not obscure material information.
B32 An entity shall disclose material sustainability-related financial information,
even if law or regulation permits the entity not to disclose such information.
B33 An entity need not disclose information otherwise required by an IFRS
Sustainability Disclosure Standard if law or regulation prohibits the entity
from disclosing that information. If an entity omits material information for
that reason, it shall identify the type of information not disclosed and explain
the source of the restriction.
B2 Commercially sensitive information

B34 If an entity determines that information about a sustainability-related
opportunity is commercially sensitive in the limited circumstances described
in paragraph B35, the entity is permitted to omit that information from its
sustainability-related financial disclosures. Such an omission is permitted even
if information is otherwise required by an IFRS Sustainability Disclosure
Standard and the information is material.
B35 An entity qualifies for the exemption specified in paragraph B34 if, and only
if:
(a) information about the sustainability-related opportunity is not

required to already publicly available;
(b) disclosure of that information could reasonably be expected to
prejudice seriously the economic benefits the entity would otherwise
be able to realise in pursuing the opportunity; and
(c) the entity has determined that it is impossible to disclose that

information in a manner—for example, at an aggregated level—that
would enable the entity to meet the objectives of the disclosure
requirements without prejudicing seriously the economic benefits the
entity would otherwise be able to realise in pursuing the opportunity.
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B36
If an entity elects to use the exemption specified in paragraph B34, the entity
shall, for each item of information omitted:
(a) disclose the fact that it has used the exemption; and
(b) reassess, at each reporting date, whether the information qualifies for
the exemption.
B37 An entity is prohibited from using the exemption specified in paragraph B34
in relation to a sustainability-related risk or as a basis for broad non-
disclosure of sustainability-related financial information.
Reporting entity (paragraph 20)

B38 h 20 requires that sustainability-related financial disclosures shall be for the
P same reporting entity as the related financial statements. For example,
a consolidated financial statements prepared in accordance with IFRS
r Accounting Standards provide information about the parent and its
a subsidiaries as a single reporting entity. Consequently, that entity’s
g sustainability-related financial disclosures shall enable users of general
r purpose financial reports to understand the effects of the sustainability-
a related risks and opportunities on the cash flows, access to finance and cost
p of capital over the short, medium and long term for the parent and its
subsidiaries.
Connected information (paragraphs 21–24)
B39 ragraph 21 requires an entity to provide information in a manner that enables

users of general purpose financial reports to understand connections both
between the items to which the information relates and between disclosures
provided by the entity in its general purpose financial reports.
B40 Connected information provides insight into connections between the items
to which the information relates. For example:
(a) if an entity pursued a particular sustainability-related opportunity and

that resulted in an increase in the entity’s revenue, connected
information will depict that relationship between the entity’s strategy
and its financial performance;
(b) if an entity identified a trade-off between two sustainability-related

risks it is exposed to and took action on the basis of its assessment of
that trade-off, connected information will depict the relationship
between those risks and the entity’s strategy; and
(c) if an entity committed to a particular sustainability-related target, but

that commitment has not yet affected the entity’s financial position or
financial performance because the applicable recognition criteria have
not been met, connected information will depict that relationship.
B41 Connected information includes:

P (a) connections between various types of information about a particular
a sustainability-related risk or opportunity, such as:
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(i) between disclosures on governance, strategy and risk

management; and
(ii) between narrative information and quantitative information

(including related metrics and targets and information in the
related financial statements).
(b) connections between disclosures about various sustainability-related

risks and opportunities. For example, if an entity integrates its
oversight of sustainability-related risks and opportunities, the entity
shall integrate the disclosures on governance instead of providing
separate disclosures on governance for each sustainability-related risk
and opportunity.
B42 Drawing connections between disclosures involves, but is not limited to,
providing necessary explanations and cross-references and using consistent
data, assumptions, and units of measure. In providing connected information,
an entity shall:
(a) explain connections between disclosures in a clear and concise

manner;
(b) avoid unnecessary duplication if IFRS Sustainability Disclosure

Standards require the disclosure of common items of information; and
(c) disclose information about significant differences between the data

and assumptions used in preparing the entity’s sustainability-related
financial disclosures and the data and assumptions used in preparing
the related financial statements.
B43 For example, in providing connected information an entity might need to

explain the effect or likely effect of its strategy on its financial statements
and financial planning, or explain how that strategy relates to the metrics the
entity uses to measure progress against targets. Another entity might need to
explain how its use of natural resources or changes within its supply chain
could amplify or, in contrast, reduce its sustainability-related risks and
opportunities. The entity might need to link the information about its use of
natural resources or changes within its supply chain to information about
current or anticipated financial effects on the entity’s production costs, its
strategic response to mitigate those risks and its related investment in new
assets. The entity might need to link narrative information to the related
metrics and targets and to information in the related financial statements.
Other examples of connected information include:

B44
(a) an explanation of the combined effects of the entity’s sustainability-
related risks and opportunities and its strategy on its financial
position, financial performance and cash flows over the short,
medium and long term. For example, an entity might face decreasing
demand for its products because of consumer preferences for lower-
carbon alternatives. The entity might need to explain how its strategic
response, such as closing a major factory, could affect its workforce
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and local communities, and the effect of such a closure on the useful
lives of its assets and on impairment assessments.
(b) a description of the alternatives that an entity evaluated in setting its

strategy in response to its sustainability-related risks and
opportunities, including a description of the trade-offs between those
risks and opportunities that the entity considered (see paragraph
33(c)). For example, an entity might need to explain the potential
effects of its decision to restructure its operations in response to a
sustainability- related risk on the future size and composition of the
entity’s workforce.
Information included by cross-reference (paragraph 63)

B45
Information required by an IFRS Sustainability Disclosure Standard might be
available in another report published by the entity. For example, the required
information could be disclosed in the related financial statements. Material
information can be included in an entity’s sustainability-related financial
disclosures by cross-reference, provided that:
(a) the cross-referenced information is available on the same terms and at

the same time as the sustainability-related financial disclosures; and
(b) the complete set of sustainability-related financial disclosures is not

made less understandable by including information by cross-
B46 reference.
Information included by cross-reference becomes part of the complete set of

sustainability-related financial disclosures and shall comply with the
requirements of IFRS Sustainability Disclosure Standards. For example, it
needs to be relevant, representationally faithful, comparable, verifiable,
timely and understandable. The body(s) or individual(s) that authorises the
general purpose financial reports takes the same responsibility for the
B47 information included by cross-reference as it does for the information
included directly.
If information required by an IFRS Sustainability Disclosure Standard is

included by cross-reference:
(a) the sustainability-related financial disclosures shall clearly identify

the report within which that information is located and explain how to
access that report; and
(b) the cross-reference shall be to a precisely specified part of that report.
Interim reporting (paragraph 69)

B48
In the interest of timeliness and cost considerations, and to avoid repetition of
information previously reported, an entity may be required or choose to
provide less information at interim dates than it provides in its annual
sustainability-related financial disclosures. Interim sustainability-related
financial disclosures are intended to provide an update on the latest complete
set of annual disclosures of sustainability-related financial information.
These disclosures focus on new information, events and circumstances and
do not duplicate information previously reported. the disclosuresAlthough
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provided in interim sustainability-related financial disclosures may be more
condensed than in annual sustainability-related financial disclosures, an
entity is not prohibited or discouraged from publishing a complete set of
sustainability-related financial disclosures as specified in this [draft] Standard
for any period before the dateas part of initial application. Accordingly,its
interim general purpose financial report.
Comparative information (paragraphs 52, 70 and 83–86)

B49 70 requires an entity to disclose comparative information is not required to
bein respect of the preceding period for all amounts disclosed in the first
period in which an entity applies this [draft] Standardreporting period.
Metrics
B50
In some cases, the amount disclosed for a metric is an estimate. Except as
specified in paragraph B51, if an entity identifies new information in relation
to the estimated amount disclosed in the preceding period and the new
information provides evidence of circumstances that existed in that period,
the entity shall:
(a) disclose a revised comparative amount that reflects that new

information;
(b) disclose the difference between the amount disclosed in the preceding
period and the revised comparative amount; and
(c) explain the reasons for revising the comparative amount.

B51
In applying the requirement in paragraph B50, an entity need not disclose a
revised comparative amount:
(a) if it is impracticable to do so (see paragraph B54).
(b) if the metric is forward-looking. Forward-looking metrics relate to

possible future transactions, events and other conditions. The entity is
permitted to revise a comparative amount for a forward-looking metric
if doing so does not involve the use of hindsight.
B52
If an entity redefines or replaces a metric in the reporting period, the entity
shall:
(a) disclose a revised comparative amount, unless it is impracticable to do

so;
(b) explain the changes; and
(c) explain the reasons for those changes, including why the redefined or
replacement metric provides more useful information.
B53
If an entity introduces a new metric in the reporting period, it shall disclose a
comparative amount for that metric unless it is impracticable to do so.
B54
Sometimes, it is impracticable to revise a comparative amount to achieve
Par
comparability with the reporting period. For example, data might not have
agr
been collected in the preceding period in a way that allows retrospective
ap
application of a new definition of a metric, and it might be impracticable to
h
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recreate the data. If it is impracticable to revise a comparative amount for the
preceding period, an entity shall disclose that fact.
Erro
B55 B56 rs
Paragr
aph 83
requir
B57 es an
entity
to
correc
t
B58 materi
al
prior
period
errors.
Such
errors
includ
e: the
effects
of
B59 mathe
matica
l
mistak
es,
mistak
es in
applyi
ng the
definit
ions
for
metric
s or
targets
,
oversi
ghts
or
misint
erpret
ations
of
facts,
and
fraud.
Potent
ial
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reporting period errors discovered
STANDARDS in that period are corrected before the sustainability-
related financial disclosures are authorised for issue. However, material errors are
sometimes not discovered until a subsequent period.
If an entity identifies a material error in its prior period(s) sustainability- related

financial disclosures, it shall disclose:
(c) the nature of the prior period error;
(d) the correction, to the extent practicable, for each prior period disclosed; and
(e) if correction of the error is impracticable, the circumstances that led to the
existence of that condition and a description of how and from when the error has
been corrected.
When it is impracticable to determine the effect of an error on all prior periods

presented, the entity shall restate the comparative information to correct the error from
the earliest date practicable.
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Appendix C
Sources of guidance
This appendix is an integral part of IFRS S1 and has the same authority as the other parts of
the Standard.
C1 This Standard requires (see paragraph 57) that in the absence of an IFRS
Sustainability Disclosure Standard that specifically applies to a
sustainability- related risk or opportunity, an entity shall apply judgement to
identify information that:
(a) is relevant to the decision-making of users of general purpose financial

reports; and
(b) faithfully represents that sustainability-related risk or opportunity.
C2 In making that judgement, an entity may—to the extent that these sources
assist the entity in meeting the objective of this Standard (see paragraphs 1–
4) and do not conflict with IFRS Sustainability Disclosure Standards—refer
to and consider the applicability of:
(a) the Global Reporting Initiative Standards; and
(b) the European Sustainability Reporting Standards.
C3 In applying the sources of guidance specified in paragraph C2, an entity shall

not obscure material information required by IFRS Sustainability Disclosure
Standards (see paragraph B27). If an entity applies the sources of guidance
specified in paragraph C2 without applying the requirements in IFRS
Sustainability Disclosure Standards, the entity shall not make an explicit and
unreserved statement of compliance with IFRS Sustainability Disclosure
Standards.
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Appendix D
Qualitative characteristics of useful sustainability-related
financial information
This appendix is an integral part of [draft] IFRS S1 and has the same authority as the other
parts of the [draft] Standard.
Introduction
C1D1 The Conceptual Framework for Financial Reporting (Conceptual Framework) was
issued by the International Accounting Standards Board (IASB). It describes
the objective of, and the concepts for, that apply to, general purpose financial
reportingreports. One of the purposes purpose of the Conceptual Framework is
to assist the IASB to develop IFRS Accounting Standards for the preparation
of general purpose preparing financial statements that are based on consistent
concepts.
C2D2 Sustainability-related financial information is disclosures are part of general

purpose financial reportingreports. The qualitative characteristics in the
Conceptual Framework, therefore, apply to sustainability-related financial
information. However, the nature of some of the information required to
meet the objectivesobjective of this Standard (see paragraphs 1–4) differs in
some respects from the information provided in general purpose financial
statements.
C3D3 Sustainability-related financial information is useful if it is relevant and

faithfully represents what it purports to represent. TheseRelevance and
faithful representation are fundamental qualitative characteristics. Usefulness
of useful sustainability-related financial information. The usefulness of
sustainability- related financial information is enhanced if the information is
comparable, verifiable, timely and understandable. Comparability,
verifiability, timeliness and understandability are enhancing characteristics of
useful sustainability- related financial information.
Fundamental qualitative characteristics of useful sustainability-
related financial information
Relevance
C4D4 Relevant sustainability-related financial information is capable of making a
difference in the decisions made by the primary users. Information may be
capable of making a difference in a decision even if some users choose not to
take advantage of it or are already aware of it from other sources.
Sustainability-related financial information is capable of making a difference
in decisions made by users if it has predictive value, confirmatory value or
both.
C5D5 Sustainability-related financial information has predictive value if it can be

used as an input to processes employed by primary users to predict future
outcomes. Sustainability-related financial information need not be a
prediction or forecast to have predictive value. Sustainability-related
financial information with predictive value is employed by primary users in
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their own predictions. For example, information about water
quality, which can include information about its pollution, could inform the
expectations of investors, lenders and other creditors about the ability of an
entity to meet local water-quality requirements.
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C6
C7
D6
D7
C8
D8
C9
D9
C10
D10
C11
D11
C12 D12
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can Sustainability-related
2023 financial information has confirmatory value if it
incl provides feedback about (confirms or changes) previous evaluations.
ude
The predictive value and confirmatory value of sustainability-related
inf
financial information are interrelated. Information that has predictive value
or
often also has confirmatory value. For example, information for the current
mat
year about carbongreenhouse gas emissions, which can be used as the basis
ion
for predicting suchgreenhouse gas emissions in future years, can also be
abo
compared with predictions about carbongreenhouse gas emissions for the
ut
current year that were made in past years. The results of those comparisons
the
can help a user to correct and improve the processes that were used to make
wat
those previous predictions.
er
bei Materiality
ng
poll Sustainability-related financial informationInformation is material if
ute omitting, misstating or obscuring that information could reasonably be
d, expected to influence decisions that the primary users of general purpose
cou financial reportingreports make on the basis of that reportingthose reports,
ld which providesprovide information about a specific reporting entity. In other
inf words, materiality is an entity-specific aspect of relevance. The materiality of
or a specific sustainability-related financial disclosure information is assessed in
m the context of an entity’s general purposesustainability-related financial
the reportingdisclosures and is based on the nature or magnitude of the item to
exp which the information relates, or both.
ect
atio Faithful representation
ns Sustainability-related financial information represents phenomena in words
of and numbers. To be useful, the information must not only represent relevant
use phenomena, it must also faithfully represent the substance of the phenomena
rs that it purports to represent.
abo
ut To be a faithful representation, a depiction would be complete, neutral and
the free from error.accurate. The objective of general purpose financial
abil reportingreports is to maximise those qualities to the maximum extent
ity possible.
of
A complete depiction of a sustainability-related risk or opportunity includes
an all material information necessary for the primary users to understand that
enti
risk or opportunity, including how the entity has adapted its strategy, risk
ty management and governance in response to that sustainability-related risk or
to
opportunity, as well as the metrics identified to set targets and measure
me performance.
et
loc Sustainability-related financial disclosureinformation shall be neutral. A
al neutral depiction is one without bias in the selection or disclosure of
wat information. Information is neutral if it is not slanted, weighted, emphasised,
er- de- emphasised or otherwise manipulated to make it more likely that the
qua primary users will receive that information favourably or unfavourably.
lity Neutral information is not information without purpose or without influence
req on behaviour. On the contrary, relevant information is, by definition, capable
uire of making a difference in users’ decisions.
me
nts.
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C13
Some sustainability-related financial information—for example, targets or
plans—is aspirational. A neutral discussion of such matters covers both
aspirations and the factors that could prevent an entity from achieving these
aspirations.
C14
Neutrality is supported by the exercise of prudence. Prudence is the exercise
of caution when making judgements under conditions of uncertainty. The
exercise of prudence means that opportunities are not overstated and risks are
not understated. Equally, the exercise of prudence does not allow for the
understatement of opportunities or the overstatement of risks.
C15
Sustainability-related financial disclosuresinformation shall be accurate.
D13 Information can be accurate without being perfectly precise in all respects.
The amount of precision needed and attainable, and the factors that make
information accurate, depend on the nature of the information and the
nature of the matters to which it addressesrelates. For example, accuracy
requires that:
D14
(a) factual information is free from material error;
(b) descriptions are precise;
(c) estimates, approximations and forecasts are clearly identified as such;
D15 (d) no material errors have beenare made in selecting and applying an
appropriate process for developing an estimate, approximation or
forecast, and the inputs to that process are reasonable and
supportable;
(e) assertions and inputs used in developing estimates are reasonable and
based on information of sufficient quality and quantity; and
(f) information abouton judgements about the future faithfully reflects

both those judgements and the information on which they are based.
Enhancing qualitative characteristics of useful sustainability-
related financial information

C16
The usefulness of sustainability-related financial information is
enhanced if it is comparable, verifiable, timely and understandable.
Comparability
C17
The decisions made by the primary users of general purpose financial
D16 reportingreports involve choosing between alternatives; for example,
selling or holding an investment, or investing in one reporting entity or
another. Comparability is the characteristic that enables users to identify
and understand similarities in, and differences among, items. Unlike the
other qualitative characteristics, comparability does not relate to a single
D17
item. A comparison requires at least two items. Information is more
useful to investors and creditorsusers if it is also comparable, that is, if it
can be compared with:
(a) information provided by the entity in previous periods; and

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(b) information provided by other entities, in particular those with similar activities
or operating within the same industry.
C18
C19
C20
C21
C22
C23
C24
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D18
Sustainability-related financial disclosures shall be provided in a way that
enhances comparability without omitting material information.
D19
Consistency is related to, but is not the same as, comparability. Consistency
refers to the use of the same approaches or methods for providing disclosures
about the same sustainability-related risks and opportunities, from period to
period, both by a reporting entity and other entities. Comparability is the
goal; consistency helps to achieve that goal.
D20 Comparability is not uniformity. For information to be comparable, like
componentsthings shall look alike and different componentsthings shall look
different. Comparability of sustainability-related financial information is not
enhanced by making unlike things look alike any more than it is enhanced by
making like things look different.
Verifiability
D21 Verifiability helps to give investors and creditorsusers confidence that
information is complete, neutral and accurate. Information is verifiable if it is
possible to corroborate either the information itself or the inputs used to
derive it. Verifiable information is more useful to primary users than
information that is not verifiable.
D22 Verifiability means that various knowledgeable and independent observers
could reach consensus, although not necessarily complete agreement, that a
particular depiction is a faithful representation. Quantified information need
not be a single point estimate to be verifiable. A range of possible amounts
and the related probabilities cancould also be verified.
D23 Sustainability-related financial disclosuresinformation shall be provided in a
way that enhances theirits verifiability. Verifiability can be enhanced by, for
example:
(a) including information that can be corroborated by comparing it with

other information available to primary users about thean entity’s
business, about other businesses or about the external environment in
which the entity operates;
(b) providing information about inputs and methods of calculation used to

produce estimates or approximations; and
(c) providing information reviewed and agreed by the entity’s board,

board committees or equivalent bodies.
D24
Some sustainability-related financial disclosuresinformation will be in the
form ofpresented as explanations or forward-looking information. Those
disclosuresThat information can be supportable, for example by faithfully
representing fact-based strategies, plans and risk analyses, for example.. To
help investors and creditorsprimary users decide whether to use such
information, an entity shall describe the underlying assumptions and methods
of producing the information, as well as other factors that provide evidence
that verify that itthe information reflects the actual plans or decisions made
by the entity.
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C25
C26 D27
D28
C27 D29
D30
C28
C29
D31
C30
C31
D25
D26
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Ti o decision-makers in time to be capable of influencing their decisions.
STANDARDS
me Generally, the older the information is, the less useful it is. However, some
lin information may continue to be timely long after the end of a reporting
period because, for example, some users may need to identify and assess
es
trends.
s
T Understandability
i
Sustainability-related financial disclosuresinformation shall be clear and
m
concise. For sustainability-related financial disclosures to be concise, they
e
need to:
l
i (a) to avoid generic information, sometimes called ‘boilerplate’, that is
n not specific to the entity;
e
(b) to avoid duplication of information in the general purpose financial
s
reportingreports, including unnecessary duplication of information
s
also provided in the related financial statements; and
m (c) to use clear language and clearly structured sentences and paragraphs.
e
The clearest form ofa disclosure dependscan take will depend on the nature
a
of the information and might sometimes include tables, graphs or diagrams in
n
addition to narrative text. If graphs or diagrams are used, additional text or
s
tables maymight be necessary to avoid obscuring material detail.
h Clarity might be enhanced by distinguishing information about developments
a in the reporting period from ‘standing’ information that remains unchanged,
v or changes little, from one period to the next—for example, by separately
i describing features of an entity’s sustainability-related governance and risk
n management processes that have changed since the previous reporting period.
g
Disclosures are concise if they include only material information. Any
i immaterial information included shall be provided in a way that avoids
n obscuring material information.
f Some sustainability-related risks and opportunities are inherently complex
o and maymight be challengingdifficult to present in a manner that is easy to
r understand. An entity shall present such information as clearly as possible.
m However, complex information about these risks and opportunities shall not
a be excluded from general purpose financial reportingreports to make those
t reports easier to understand. The exclusion ofExcluding such information
i would render those reports incomplete and, therefore, possibly misleading.
o
n The completeness, clarity and comparability of sustainability-related
financial disclosuresinformation all rely on information being presented as a
a coherent whole. For sustainability-related financial disclosuresinformation to
v be coherent, theyit shall be presented in a way that explains the context and
a the relationshipsconnections between the related items of information.
i
l
a
b
l
e
t
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C32
If sustainability-related risks and opportunities located in one part of an
entity’s general purpose financial reportingreports have implications for
information disclosed in other parts, the entity shall include the information
necessary for users to assess those implications.
C33
Coherence also requires an entity to provide information in a way that allows
D32 users to relate information about its sustainability-related risks and
opportunities to information in the entity’s financial statements.
D33
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Appendix E
Effective date and transition
This appendix is an integral part of IFRS S1 and has the same authority as the other parts of
the Standard.
Effective date
E1 An entity shall apply this Standard for annual reporting periods beginning on
or after 1 January 2024. Earlier application is permitted. If an entity applies
this Standard earlier, it shall disclose that fact and apply IFRS S2 Climate-
related Disclosures at the same time.
E2 For the purposes of applying paragraphs E3–E6, the date of initial

application is the beginning of the annual reporting period in which an entity
first applies this Standard.
Transition
E3 An entity is not required to provide the disclosures specified in this Standard
for any period before the date of initial application. Accordingly, an entity is
not required to disclose comparative information in the first annual reporting
period in which it applies this Standard.
E4 In the first annual reporting period in which an entity applies this Standard,
the entity is permitted to report its sustainability-related financial disclosures
after it publishes its related financial statements. In applying this transition
relief, an entity shall report its sustainability-related financial disclosures:
(a) at the same time as its next second-quarter or half-year interim general purpose
financial report, if the entity is required to provide such an interim report;
(b) at the same time as its next second-quarter or half-year interim general purpose
financial report, but within nine months of the end of the annual reporting period
in which the entity first applies this Standard, if the entity voluntarily provides
such an interim report; or
(c) within nine months of the end of the annual reporting period in which the entity
first applies this Standard, if the entity is not required to and does not voluntarily
provide an interim general purpose financial report.
E5 In the first annual reporting period in which an entity applies this Standard,
the entity is permitted to disclose information on only climate-related risks
and opportunities (in accordance with IFRS S2) and consequently apply the
requirements in this Standard only insofar as they relate to the disclosure of
information on climate-related risks and opportunities. If an entity uses this
transition relief, it shall disclose that fact.
E6 If an entity uses the transition relief in paragraph E5:
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(a) in the first annual reporting period in which the entity applies this
Standard, it is not required to disclose comparative information about
its climate-related risks and opportunities (see paragraph E3); and
(b) in the second annual reporting period in which the entity applies this
Standard, it is not required to disclose comparative information about
its sustainability-related risks and opportunities, other than its
climate-related risks and opportunities.
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Approval by the ISSB Chair and Vice-Chair of Exposure Draftof IFRS S1
General Requirements for the Disclosure of Sustainability- related
Financial Information publishedissued in March 2022June 2023
The Exposure Draft IFRS S1 General Requirements for the Disclosure of Sustainability-related Financial
Information was approved for publication by the Chair and Vice-Chairissue by all 14 members of the
International Sustainability Standards Board.
Emmanuel Faber Chair

Jingdong Hua Vice-Chair
Suzanne Lloyd Vice-Chair
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IFRS SUSTAINABILITY
FOR DISCLOSURE OF
DISCLOSURE
STANDARDS
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Jenny Bofinger-Schuster
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Jeffrey Hales
Michael Jantzi
Hiroshi Komori
Bing Leng
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March 2022

[Draft] IFRS S1 General Requirements for

General Requirements for Disclosure of

Comments to be received by 29 July 2022

ISBN for this part: 978-1-914113-62-8

ISBN for complete publication (three parts): 978-1-914113-61-1

© 2022© IFRS Foundation 2023

Copies of ISSB publications may be ordered from the Foundation by emailing

All rights reserved.

IFRS SUSTAINABILITY DISCLOSURE STANDARD

APPROVAL BY THE ISSB OF IFRS S1 ISSUED IN JUNE 2023

FOR THE BASIS FOR CONCLUSIONS, SEE PART C OF THIS EDITION

BASIS FOR CONCLUSIONS (see separate booklet)

[Draft] IFRS S1 General Requirements for Disclosure of Sustainability-related Financial

Why is the ISSB publishing the Exposure Draft?

Sustainability-related risks and opportunities arise from an entity’s dependencies on

A summary of the proposals in the Exposure Draft

The Exposure Draft includes proposals for definitions and requirements

Proposals in the Exposure Draft would require an entity to disclose material

The information requirements are designed to enable primary users to assess

The proposals would require an entity to explain the connections between

The sustainability-related financial information must be for the same

IFRS S1 General Requirements for Disclosure of

(a) address the questions as stated;

(b) specify the paragraph(s) to which they relate;

(c) contain a clear rationale;

(e) include any alternative the ISSB should consider, if applicable.

Question 4—Core content (paragraphs 11–35)

Metrics and targets

Question 7—Fair presentation (paragraphs 45–55)

To identify significant sustainability-related risks and opportunities, an entity would

(b) Do you agree with the sources of guidance to identify sustainability-related

Question 8—Materiality (paragraphs 56–62)

1. Information ‘is material if omitting, misstating or obscuring that information could

Material sustainability-related financial information disclosed by an entity may change

(a) Is the definition and application of materiality clear in the context

Question 10—Location of information (paragraphs 72–78)

However, the Exposure Draft deliberately avoids requiring the information to be

The proposal permits an entity to disclose information required by an IFRS

Information required by an IFRS Sustainability Disclosure Standard could also be

Survey and comment https://www.ifrs.org/projects/work-plan/general-sustainability-

(a) an entity’s governance of sustainability-related risks and

(b) decisions made by the entity that could result in future

(c) the entity’s reputation, performance and prospects as a

(a) is comparable both with the entity’s sustainability-related financial

(b) is connected to the other information in the entity’s general purpose

(b) strategy—the approach for addressing sustainability-related

(d) metrics and targets—information used to assess, manage and

(a) the identity of the body or individual within a body

(d) how the body and its committees consider sustainability-

(f) a description of management’s role in assessing and

(a) the significant sustainability-related risks and opportunities that it

(c) the effects of significant sustainability-related risks and opportunities

(d) the resilience of its strategy (including its business model) to

Sustainability-related risks and opportunities

(a) a description of significant sustainability-related risks and

(a) a description of the current and anticipated effects of significant

(b) a description of where in its value chain significant sustainability-

Strategy and decision-making

(a) how it is responding to significant sustainability-related risks and

(b) quantitative and qualitative information about the progress of plans

(c) what trade-offs between sustainability-related risks and opportunities

(a) how significant sustainability-related risks and opportunities have