The International Banking Federation has submitted a comment letter on the International Sustainability Standards Board’s exposure draft proposing amendments to the greenhouse gas emissions disclosure requirements in IFRS S2. IBFed supports the ISSB standards as a global baseline and backs the aim of targeted relief, but asks for changes where proposed disclosures would be operationally burdensome and not decision-useful. On Scope 3 Category 15 disclosures, IBFed broadly agrees with allowing entities to exclude emissions associated with derivatives and other financial activities such as facilitated and insurance-associated emissions, but opposes the proposed requirement to provide quantitative information on the magnitude of excluded activities, citing cost and potential need for new systems. It also supports permitting industry classification systems other than the Global Industry Classification Standard, while recommending a simpler approach that allows entities to use judgment and apply a consistently used classification methodology for climate reporting. For jurisdictional relief on the Greenhouse Gas Protocol Corporate Standard and global warming potential values, IBFed broadly supports the proposal and recommends added guidance or implementation support so jurisdictions clearly explain how alternative methodologies align with IFRS S2’s objectives and principles.
International Banking Federation 2025-06-27
International Banking Federation urges the ISSB to simplify proposed IFRS S2 greenhouse gas disclosure amendments
The International Banking Federation (IBFed) supports the ISSB standards as a global baseline but requests changes to reduce operational burdens. IBFed agrees with excluding certain emissions from Scope 3 Category 15 disclosures but opposes requiring quantitative information on excluded activities due to cost concerns. It supports flexibility in industry classification systems and recommends additional guidance for jurisdictional relief on the Greenhouse Gas Protocol Corporate Standard.