Corporate reporting should capture all relevant information about organizations. However, investors and other stakeholders are demanding more, higher-quality information and insights about company performance, risks, opportunities, and long-term prospects than are available from the conventional financial reporting process. To be accountable, companies need to provide a clear and comprehensive picture of their organization’s ability to create sustainable value over time.
IFAC sees a significant opportunity to enhance trust in companies and confidence in markets by including information in corporate reporting that is relevant, reliable, and comparable with respect to measures derived from the financial statements (i.e., “non-GAAP” or “non-IFRS” measures), other “Key Performance Indicators” connected to financial performance, and broader information related to value creation, sustainability or environmental, social, and governance factors.
Our partnership with the International Integrated Reporting Council shows our support for enhancing corporate reporting by including a broader scope of narrative disclosures and metrics. Integrated thinking and forward-looking reporting enable organizations to communicate effectively — and stakeholders to understand — prospects for longer-term value creation. A number of additional standard-focused initiatives and frameworks have also emerged to convey this information.
1. Need for Enhancing the Corporate Reporting System
The corporate reporting landscape has become a mosaic of mandatory and voluntary disclosures under various frameworks and standard-setting initiatives – primarily focused on value creation, sustainability, and environmental, social and governance factors. Stakeholders find it difficult to rationalize the information being provided and to understand the linkage to financial information.1
- IFAC believes that this reporting ecosystem, consisting of multiple and competing reporting workstreams, does not best serve the interests of capital markets, companies or their stakeholders. The resulting complexity and lack of comparability can lead to inefficiency and increased costs — for both companies and investors.2
- IFAC supports the development of and convergence towards relevant, reliable, and comparable narrative information and metrics (e.g., non-monetary volumes, number counts, ratios, percentages, etc.) for which suitable criteria can be developed to facilitate assurance conclusions.
- IFAC believes that such broader-based corporate reporting serves the public interest and that alignment needs to occur before a fragmented or regional approach to reporting and regulation becomes ensconced as standard practice. Both companies and investors increasingly support this approach.3 Ideally, coalescing around best market practices or accepting a single set of high-quality standards should occur before regulatory intervention.
- IFAC supports the efforts of all participants in the Corporate Reporting Dialogue, the Task Force on Climate-Related Financial Disclosures, World Business Council for Sustainable Development, and other organizations who contribute valuable input toward the goal of enhancing corporate reporting. At the same time, IFAC reiterates the need for the emergence and implementation of a uniform, global approach.
 Corporate Reporting Dialogue, “Driving Alignment in Climate-related Reporting,” Executive Summary, page iii, September 2019.
CFA Institute 2017 "Environmental, Social and Governance (ESG) Survey" (p. 18) highlights a lack of appropriate quantitative ESG information, lack of comparability across firms, and questionable data quality/lack of assurance.
McKinsey 2019 survey "More than Values: The value-based sustainability reporting that investors want" (including 50 companies, 27 asset managers, 30 asset owners) identifies the “excessive effort and expense” in providing similar information in answer to multiple requests. Investors and corporate executives cited “inconsistency, incomparability, or lack of alignment in standards’ as the most significant challenge” related to sustainability reporting.
2. Integrated Reporting
The International Integrated Reporting Council’s umbrella framework provides a basis for narrative information and metrics that enable organizations to more effectively communicate their ability to create value over time.
- IFAC believes that integrated reporting, bringing together the relevant information about a company, provides a holistic picture of performance and provides insights on an organization’s ability to create sustainable value over time. Integrated reporting enables companies of all sizes and sectors and their stakeholders to focus on the key factors (or “multiple capitals”) relevant to long term value creation through the lens of governance, strategy, and the business model.
- Crucially, we believe that integrated reporting supports “integrated management thinking” - which fosters organizational decision-making and change focused on broader, longer term value creation. Integrated thinking will hopefully lead to better outcomes from corporate reporting that addresses systemic risks to capital and financial market systems and sustainable development challenges.
- We encourage regulators and standard-setters to use the International Integrated Reporting Framework as a foundation for incorporating and organizing information about value creation and impacts, including narrative reporting and metrics from the various standard-setting initiatives. A common framework can facilitate the development of best practices and standardization.
- In many jurisdictions, the management report (“MD&A” or equivalent) might be the most appropriate channel for including integrated and supplementary narratives and metrics. IFAC supports the efforts of the IASB to update guidance in its Management Commentary Practice Statement – intended to be compatible with jurisdictional requirements and various frameworks and initiatives such as integrated reporting.
3. Role of Accountancy Profession in Enhancing Corporate Reporting
The profession has a key role to play in the development and implementation of reporting frameworks and standard-setting initiatives that go beyond traditional financial reporting, including development of robust internal control processes and systems, assurance, as well as identifying, measuring, and reporting relevant metrics that are supported by best practices or reporting standards.
- IFAC believes that the technical skills, business expertise, and trusted professionalism of accountants are key requirements to working effectively with standard setters, reporting entities, regulators, and other interested stakeholders toward the goal of enhancing corporate reporting. Professional accountants, as employees in a business or as practitioners in a firm, help companies formulate strategies, measure and manage performance, implement reporting and internal control systems, analyze information, and develop governance and risk management policies. These activities are key to the evolution of evidence-based decision-making, reliable information gathering, and consistent and comparable reporting on matters of value creation, sustainability, or environmental, social and governance factors.
- IFAC believes that assurance is critical to confidence in corporate reporting and delivering relevant, reliable, and comparable information. Efforts like the IAASB’s initiative on Extended External Reporting (February 2019) - intended to advance the assurance of non-financial information (including integrated reporting, sustainability reporting, and other reporting about environmental, social, or governance matters) - can improve user confidence, enhance access to capital, assist companies in developing systems and processes, and promote comparability. IFAC supports additional work towards the evolution of assurance practice with respect to non-financial information.
- We believe engagement with the accountancy profession, given the trend towards enhancing the scope of corporate reporting, will maximize the benefit to reporting entities and their stakeholders. The profession must meet the challenge of developing new areas of expertise necessary to support enhancing corporate reporting.
4. The Way Forward
The time for a global solution is now—to answer the demand from investors, policymakers and other stakeholders for a reporting system that delivers consistent, comparable, reliable, and assurable information relevant to enterprise value creation, sustainable development and evolving expectations. A fragmented approach perpetuates inefficiency, increased cost, and a lack of trust. Important work is underway (e.g., WEF/IBC metrics, IOSCO’s task force, EFRAG’s preparatory work, and alignment between the leading reporting initiatives), and these efforts should continue and ultimately contribute to the emerging global system.
Global Approach: A new standard setting board is necessary to build and coordinate a coherent global system of interconnected corporate reporting.
- The IFRS Foundation, with an enhanced remit and composition, should create an International Sustainability Standards Board (“ISSB”), leveraging the independence and success of IFRS governance (i.e., Monitoring Board and IFRS Foundation Trustees) to develop global standards and rationalize the current fragmented ecosystem.
- Clear support from global institutions like IOSCO and appropriate funding are critical to success.
- The IASB must remain focused on financial reporting standards. Coordination between the ISSB and IASB will be necessary to avoid overlaps and gaps (e.g., Management Commentary).
- Applicability of ISSB standards should be determined (e.g., SMEs vs. PIEs).
- The ISSB should engage with both IFRS and non-IFRS jurisdictions to encourage global adoption and use.
- Block 1: Requirements for material non-financial information focused on company performance, risk profile, economic decisions and enterprise value creation should be the remit of the ISSB. This focus is consistent with the work of the IASB and will attract broad global support.
- Block 2: The ISSB should also collaborate with respect to reporting requirements designed to address broader, material sustainable development and company impacts on economy, environment, and people. These requirements may ultimately be incorporated or endorsed into ISSB standards.
- Block 3: The system should accommodate supplemental jurisdictional requirements to support local public accountability. These should not detract from Blocks 1 or 2 and may be absorbed into them over time.
- Framework: Financial and non-financial information should be connected through a conceptual framework. Integrated reporting principles and the work of TCFD should serve as a starting point.
Completing the Ecosystem
- Corporate governance must evolve to provide effective oversight of expanded reporting obligations.
- Enhanced corporate controls and data systems will be necessary to generate high quality information.
- Assurance is a necessary component of the global system. The work by the IAASB will play a critical role.
- Reporting standards and assurance processes must be digital ready.
- Professional accountants and firms need to continue to enhance their competencies to prepare and assure this new information and work closely with experts in sustainability and other fields.
- Providers of sustainability/ESG ratings, rankings or indices should embrace the development of global reporting requirements so that consistent, comparable, reliable, and assurable information can be incorporated into their work.
- Public sector reporting should also evolve to require more comprehensive information.