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TAC Public Meeting September 2024 Paper 5: Cross-industry metrics not GHG

Executive summary

Date 03 September 2024
Paper reference 2024-TAC-016
Project Technical assessment of IFRS S1 and IFRS S2
Topic Cross-industry metrics (excluding greenhouse gas emissions)

Objective of the paper

This paper considers the requirements in IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) and IFRS S2 Climate-related Disclosures (IFRS S2) relating to metrics, including the specified cross-industry metric categories in IFRS S2. The TAC is asked to consider whether the requirements are sufficiently clear and whether there are technical challenges that may prevent entities from providing understandable, relevant, reliable and comparable disclosures.

Decisions for the TAC

The TAC is asked to tentatively decide to:

  • request further clarification from the ISSB as to what the objective of Metrics and Targets means in terms of whether certain information is required to be disclosed regardless of an entity's materiality assessment;
  • maintain the requirements for the disclosure of the cross-industry metric categories in IFRS S2 paragraphs 29(b)–(g) but request that the ISSB clarify the terminology used, including the terms 'vulnerable' and 'aligned with'. The TAC may also observe market practice as it develops and consider providing feedback to the ISSB during its post-implementation review of IFRS S2;
  • request further clarity from the ISSB as to why IFRS S2 paragraph 29(e) is not subject to the permission to use all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort, and what is meant by 'deployed'; and
  • engage with the ISSB in updating the Industry-based Guidance on Implementing IFRS S2 to include metrics that support entities in reporting against the cross-industry metric categories in IFRS S2 paragraphs 29(b)–(e).

Appendices

There are no appendices to this paper.

This paper has been prepared by the Secretariat for the UK Sustainability Disclosure Technical Advisory Committee (TAC) to discuss in a public meeting. This paper does not represent the views of the TAC or any individual TAC member.

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Context

1 IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) sets out the general requirements for the disclosure of metrics that relate to each sustainability-related risk and opportunity that could reasonably be expected to affect the entity's prospects (as identified by the entity). IFRS S2 Climate-related Disclosures (IFRS S2) sets out specific climate-related cross-industry metrics. The relevant references to the requirements in IFRS S1 and IFRS S2 are as follows:

  • IFRS S1 paragraphs 45–50, 52–53, B52
  • IFRS S2 paragraphs 27, 29(b)–(g), 30–32, B64–B65 Appendix A

2 This paper does not include the requirements for the disclosure of greenhouse gas emissions. The TAC will discuss all the requirements related to greenhouse emissions in separate papers—namely, 2024-TAC-013, 2024-TAC-014 and 2024-TAC-015. This paper does not include a discussion about the requirements related to targets which will be discussed in a future meeting.

Endorsement criteria

3 The endorsement criteria applied in the analysis of this technical area include whether:

  1. use of the IFRS Sustainability Disclosure Standard is likely to result in an improvement in the international comparability of sustainability-related reporting in the UK.
  2. use of the IFRS Sustainability Disclosure Standard is likely to support companies in making disclosures that are understandable, relevant, reliable and comparable.
  3. use of the IFRS Sustainability Disclosure Standard is likely to improve the quality of corporate reporting within the UK in the long term.
  4. companies are likely to be able to provide the disclosures required by the IFRS Sustainability Disclosure Standard within the timeframes that a company normally reports without undue cost or effort.
  5. use of the IFRS Sustainability Disclosure Standard is likely to be conducive to the UK's economic growth and international competitiveness, taking into account the costs and benefits of compliance.

Analysis

4 In relation to the requirements relating to targets, there are a number of matters for the TAC to discuss, including:

4.1 the objective for the Metrics and Target section in IFRS S1 which requires the disclosure of metrics that the entity uses to measure its performance, but also any metrics that are required by an applicable IFRS Sustainability Disclosure Standard. Paragraphs 5–10 discuss the changes that were made to the final standard, including the ISSB's reasoning for making the change.

4.2 the cross-industry metric categories in IFRS S2 paragraphs 29(b)–(e). Paragraphs 14–23 discuss the requirements for entities to provide metrics relating to climate-related transition and physical risks and climate-related opportunities. This includes a discussion about the terms ‘vulnerable' and 'aligned with', in addition to the connectivity with other information required by IFRS S2 and information in the financial statements. The TAC is asked to consider if further specificity and/or guidance is required for entities to be able to apply the requirements relating to these cross-industry metric categories.

4.3 the requirement for an entity to disclose whether, and how, it uses an internal carbon price in decision making. Paragraphs 24–27 discuss the requirements, including the potential impact on financial statements.

4.4 the requirement for an entity to disclose whether, and how, it includes climate-related risks and opportunities in executive remuneration policies. Paragraphs 28–31 discuss the requirements, including the connectivity with governance disclosures.

5 IFRS S1 paragraph 45 sets out the objective for sustainability-related financial disclosures on metrics, which 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'.

6 To meet this objective, IFRS S1 paragraph 46 requires the disclosure of metrics 'for each sustainability-related risk and opportunity that could reasonably be expected to affect the entity's prospects. This includes any metrics that are required by an applicable IFRS Sustainability Disclosure Standard and any metric that the entity uses to measure and monitor sustainability-related risks or opportunities, or performance in relation to those risks or opportunities.

7 The objective in the final standard was amended from the Exposure Draft of IFRS S1 as some stakeholders raised concerns that entities could interpret the proposed objective as only requiring the disclosure of metrics that the entity already uses. As noted in the IFRS S1 Basis for Conclusions on General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1 Basis for Conclusions) paragraph BC120, the amendment in the final standard clarifies that entities are required to disclose the metrics that are required by IFRS Sustainability Disclosure Standards, even if they are not already used by the entity, as ‘information provided by disclosing those metrics is material'. As noted in paper 2024-TAC-010 and discussed by the TAC in its July 2024 meeting, some stakeholders noted that the definition of materiality in IFRS S1 focuses on the information needs of the user, which may not align with management's view of which sustainability-related risks and opportunities—and therefore which related metrics—are relevant to the entity. IFRS S2 Basis for Conclusions on Climate-related Disclosures (IFRS S2 Basis for Conclusions) paragraph BC121 clarifies that the disclosure requirements are subject to materiality, and the ISSB's decision to amend the objective was intended 'not to prescribe how entities manage their businesses, but instead to clarify the disclosure requirements for Metrics and Targets, which set out the information that is important for users of general purpose financial reports.' Some may consider that paragraphs BC120 and BC121 in IFRS S2 Basis for Conclusions do not provide sufficient clarity, as the former notes that entities should disclose certain prescribed metrics as they are material, whereas the latter suggests that entities need only disclose the metrics if they are material. However, some stakeholders consider the distinction in these paragraphs clear—that certain metrics cannot be ignored on the basis that the entity is not already using those metrics to manage their business, but that the disclosure of these metrics are still subject to materiality judgements.

8 As an overarching standard for all sustainability-related risks and opportunities, IFRS S1 includes general requirements for the disclosure of metrics. IFRS S1 does not specify any cross-industry metrics, but it is expected that future IFRS Sustainability Disclosure Standards will specify any cross-industry metrics that are applicable to a specific sustainability-related matter.

9 In the absence of IFRS Sustainability Disclosure Standards, IFRS S1 paragraphs 47 and 57-58 require an entity to identify applicable metrics using the sources of guidance that were discussed by the TAC in paper 2024-TAC-011. This includes the instruction that entities 'shall refer to and consider' the SASB Standards and its industry-based metrics. Additionally, IFRS S1 paragraph 48 requires an entity to include 'metrics associated with particular business models, activities or other common features that characterise participation in an industry'. Although most members of the TAC agreed that the use of the SASB materials was not mandatory, the inclusion of the requirement to ‘refer to and consider' the SASB materials in the context of the objective in IFRS S1 may suggest to some that when the SASB materials are rebranded as IFRS standards, all metrics in the SASB materials will become mandatory regardless of whether the entity has determined them as material. However, the ISSB has committed to ensuring the SASB materials are subject to full due process and the TAC will be able to engage with the ISSB during its review of these materials.

10 The TAC may consider requesting further clarification from the ISSB as to what the objective of Metrics and Targets means in terms of whether certain information is required to be disclosed regardless of an entity's materiality assessment.

IFRS S2 cross-industry metrics

11 IFRS S2 paragraphs 29(b)–(g) specifies cross-industry metric categories for the disclosure of climate-related metrics. These metric categories do not include specific metrics but are instead intended to provide common information pertaining to an entity's exposure to, and management of, climate-related risks and opportunities. These metric categories were derived from the TCFD's Guidance on Metrics, Targets and Transition Plans, which also forms the basis of the illustrative guidance in the IFRS S2 Accompanying Guidance on Climate-related Disclosures.

12 In response to the TAC's call for evidence, some stakeholders welcomed the cross-industry metrics requirements as they are broadly aligned with the TCFD recommendations and therefore should be familiar to UK entities. Only one stakeholder welcomed these requirements not being overly prescriptive. However, other stakeholders noted that because there were no prescribed metrics related to the cross-industry metrics, the disclosures are likely to be inconsistent and lack comparability. Additionally, some stakeholders raised concerns that there will likely be significant data challenges when preparing disclosures for these metrics categories, especially regarding climate-related risks and opportunities in the value chain.

13 This paper splits out the metric categories into three parts; those related to financial information (IFRS S2 paragraphs 29(b)–(e)), internal carbon pricing, and remuneration metrics.

Cross-industry metrics categories 29(b)-(e)

14 IFRS S2 paragraphs 29(b)–(e) require entities to disclose information about:

  • the amount and percentage of assets or business activities vulnerable to climate-related transition risks;
  • the amount and percentage of assets or business activities vulnerable to climate-related physical risks;
  • the amount and percentage of assets or business activities aligned with climate-related opportunities; and
  • the amount of capital expenditure, financing or investment deployed towards climate-related risks and opportunities.

15 While these metric categories are purposefully broad, some stakeholders have raised concerns that the requirements are unclear and can be interpreted in different ways. Some stakeholders requested more clarity on the terms used in these requirements—notably the terms ‘vulnerable' and 'aligned with' which are not defined in the standards. In its March 2024 meeting, the Transition Implementation Group (TIG) discussed what ‘vulnerable' meant in the absence of a definition in IFRS S2, and noted that:

[A]ssets 'vulnerable' to climate-related risks: information disclosed about the vulnerability of assets should be such that that the information is material to understand how climate-related risks may affect the entity's performance. For example, the nature of an entity's 'vulnerabilities' could vary greatly depending on the type of assets and how these assets relate to projected future cash flows. Therefore, an entity needs to consider the information to disclose in the context of what information is material.

Although the TIG have already discussed how the term 'vulnerable' could be applied, the TAC may request that the ISSB provide further clarification of the terminology used in the cross-industry metric categories, including the terms 'vulnerable' and 'aligned with'.

16 Additionally, a few stakeholders noted that there are no prevailing methodologies and supporting data for these metric categories, although these are likely to develop over time. A few stakeholders also requested further guidance on whether these metrics should be expressed as a monetary value or as a percentage of revenue.

17 IFRS S2 Basis for Conclusions paragraph BC77 notes that the ISSB intentionally left the cross-industry metric categories as non-specific 'to enable an entity to identify appropriate metrics. The ISSB took this approach to allow for the likelihood that measurement methodologies and the availability and quality of underlying data might evolve over time.' Therefore, it is likely that in the initial years of reporting, disclosures of these cross-industry metrics may be less reliable and may not be comparable.

18 Although some stakeholders are requesting additional guidance, the illustrative guidance in the IFRS S2 Accompanying Guidance on Climate-related Disclosures—which is borrowed from the TCFD Guidance on Metrics, Targets and Transition Plans—includes example metrics for each of the metric categories. Additionally, IFRS S2 paragraph B65 provides a list of factors that an entity is required to consider when preparing disclosures of these cross-industry metric categories, as described in paragraph 20. As market practice develops, the TAC may consider providing feedback to the ISSB during its post-implementation review, especially if disclosures have not improved over time and further clarity or guidance from the ISSB is necessary.

19 The TAC may also consider engaging with the ISSB in relation to improving the industry-based guidance to support entities in reporting against the cross-industry metric categories in IFRS S2 paragraphs 29(b)–(e). For example, a metric that is increasingly used by financial institutions in relation to TCFD reporting is climate value at risk (VaR) which may satisfy these cross-industry metric categories but is not included in any of the guidance accompanying IFRS S2. Given that the types of 'assets or business activities' are often industry-specific, this may be an area where the industry-based guidance (based on the SASB Standards) requires further development. Additionally, many of the illustrative examples in the IFRS S2 Accompanying Guidance on Climate-related Disclosures could be viewed as industry-specific rather than cross-industry. As noted in paper 2024-TAC-011, which was discussed by the TAC in July 2024, some stakeholders raised concerns that the Industry-based Guidance on Implementing IFRS S2 that accompanies IFRS S2 is not sufficiently focused on climate-related matters. When updating this guidance for consultation (the timeline for which is unknown), the ISSB may consider adding industry-based metrics that support entities in reporting against the cross-industry metric categories in IFRS S2 paragraphs 29(b)–(e).

20 Entities should also consider how these cross-industry metric categories are connected with other requirements in IFRS S2. IFRS S2 paragraph B65 outlines a number of instances where an entity shall consider the disclosures under the Strategy section of the standard. Notably, this includes:

  • the time horizons over which climate-related risks and opportunities could reasonably be expected to occur (IFRS S2 paragraph 10);
  • where in the business model and value chain climate-related risks and opportunities are concentrated (IFRS S2 paragraph 13); and
  • the effects of climate-related risks and opportunities on the entity's financial position, financial performance and cash flows for the reporting period (IFRS S2 paragraph 16(a)–(b)).

21 Collectively, these considerations could be used by an entity to understand where their business is vulnerable to climate-related risks or aligned with climate-related opportunities. These considerations could also be expected to support connectivity across the climate-related disclosures.

22 IFRS S2 paragraph B65(e) also requires an entity to consider the connections between the cross-industry metric categories and the information disclosed in the related financial statements. For example, an entity could consider the amounts disclosed for the cross-industry metric categories and the amounts recognised and disclosed in the related financial statements. This might also include consistency between the data and assumptions used for both disclosures. The specific example used in IFRS S2 refers to consideration of 'whether the carrying amount of assets used is consistent with amounts included in the financial statements'. However, entities are not necessarily required to have alignment between the information disclosed for the cross-industry metric categories and the information in the related financial statements when it is not appropriate. Although connectivity with the financial statements is a key objective, in some cases it may not be appropriate to use the exact same information. For example, many of the cross-industry metrics are forward looking and may be calculated using multiple scenarios, resulting in a range rather than a single figure. In these cases, this information may not fully align with information in the financial statements. However, entities are still required to consider the connections between the cross-industry metric categories and the information disclosed in the related financial statements which should strengthen connectivity.

23 IFRS S2 paragraph 30 permits an entity to use all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort for the requirements in paragraph 29(b)–(d) only. This relief does not extend to paragraph 29(e) in relation to the disclosure of the amount of capital expenditure, financing or investment deployed towards climate-related risks and opportunities. The ISSB has not provided an explanation as to why paragraph 29(e) is not included. The reason could be because this requirement is intended to be historical financial figures which should be readily available to the entity. However, this also raises the question as to what is meant by 'deployed' which is not a term widely used in financial reporting. For example, it is not clear whether 'deployed' means expenditure that has already been incurred (past Capex) or funds that have been set aside for a specific purpose but not yet incurred (planned Capex), which may make it difficult to connect disclosures back to the financial statements. The TAC may request that the ISSB clarify why IFRS S2 paragraph 29(e) is not subject to the permission to use all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort, and what is meant by 'deployed'.

Internal carbon price

24 IFRS S2 paragraph 29(f) requires an entity to disclose information about internal carbon prices including:

  • explanation of whether and how the entity is applying a carbon price in decision-making; and
  • the price for each metric tonne of greenhouse gas emissions the entity uses to assess the costs of its greenhouse gas emissions.

As described in IFRS S2 Appendix A, an internal carbon price is a 'price used by an entity to assess the financial implications of changes to investment, production and consumption patterns, and of potential technological progress and future emissions-abatement costs. An entity can use internal carbon prices for a range of business applications.' The two types of internal carbon price are often a shadow price or an internal tax or fee.

25 In response to the TAC's call for evidence, some stakeholders suggested that the requirement for disclosure of an internal carbon price is incorrectly categorised as 'cross-industry' as it is only relevant to certain, high-impact industries. A few stakeholders were also concerned that this information might be seen as commercially sensitive whilst also noting that it would be useful information for users.

26 IFRS S2 does not prescribe a specific price, nor does it require entities to use internal carbon pricing. The requirement in IFRS S2 only requires the disclosure of an internal carbon price if the entity uses one. However, the requirement for entities to disclose ‘whether' they use a carbon price for decision-making means that entities are required to disclose the fact that they do not use one if that is the case. IFRS S2 Basis for Conclusions paragraph BC130 confirms this observation.

27 Although outside of the TAC's remit, further consideration may be given as to the impact of requiring the disclosure of an internal carbon price on the entity's financial statements. Depending on how an internal carbon price is used by the entity, there may be implications for the financial statements. However, the TAC Secretariat have not completed a detailed assessment as to what these implications might be, or whether they are significant enough to warrant any action—this is an area that is currently beyond the TAC's remit. Notably, the use of internal carbon pricing is not included in IASB's research project on pollutant pricing mechanisms which focuses on emissions trading schemes—including the use of carbon credits or allowances for cap and trade schemes—and voluntary schemes including offsetting schemes. The UK Endorsement Board (UKEB) and Financial Reporting Council (FRC) in their respective roles setting accounting standards in the UK could consider whether the disclosure of an internal carbon price could have implications on an entity's financial statements.

Remuneration

28 IFRS S2 paragraph 29(g) requires an entity to disclose:

  • whether and how climate-related considerations are factored into executive remuneration; and
  • the percentage of executive management remuneration recognised in the current period.

29 Similar to the requirements on internal carbon price, an entity need only disclose information about its executive remuneration if climate-related matters are factored into these policies. Although it is not confirmed by the ISSB, it may be assumed using a similar observation to the requirements on internal carbon pricing—that if an entity does not factor climate-related risks and opportunities into executive remuneration policies that it discloses that fact. This may be an issue that the ISSB needs to clarify.

30 The information disclosed in accordance with IFRS S2 paragraph 29(g) should also be connected to the information disclosed in relation to the governance requirements. IFRS S2 paragraph 6(a)(v) requires entities to describe how those that are charged with governance of climate-related matters oversee and monitor the setting of targets and the progress towards those targets, including whether those targets and associated performance metrics are included in remuneration policies.

31 Many large entities in the UK already report on sustainability-related measures within executive remuneration policies. In June 2024, the TAC discussed current practice in the UK in paper 2024-TAC-004b. In the literature review in this paper, the Secretariat observed that both of PwC's reviews on TCFD reporting and FTSE 350 reporting found about 80% companies in the sample reported a non-financial measure—including in many cases a carbon reduction measure—within executive remuneration policies. Additionally, the FRC's 2023 thematic review of climate-related metrics and targets observed that improvements could be made in linking climate-related targets reported in TCFD disclosures and the ESG targets disclosed in the Directors' Remuneration Report. As market practice develops, the TAC may consider providing feedback to the ISSB during its post-implementation review, especially if disclosures have not improved over time and further clarity or guidance from the ISSB is necessary.

Endorsement recommendations

32 In considering the TAC's endorsement recommendations on the requirements relating to the cross-industry metric categories, the Secretariat considered alternative options that have been disregarded. The criteria for amending the standards—notably that changes are considered necessary for the effective application within the UK and that failure to amend the standard would be detrimental to the long-term public good—have not been met in this instance.

33 The alternative options that were considered but not recommended included:

33.1 amending the objective of the Metric and Targets section in IFRS S1 to remove the suggestion that entities are required to disclose certain metrics regardless of whether the information is considered by the entity as material. Paragraphs 5–10 provide a discussion about the objective of the Metrics and Targets section, highlighting the lack of clarity as to whether certain metrics are required to be disclosed regardless of an entity's materiality assessment. Rather than amending IFRS S1 at this stage, it may be more appropriate to obtain further clarity from the ISSB as to their intentions when amending the objective from the Exposure Draft.

33.2 removing the cross-industry metric categories until more specific metrics are provided from the ISSB. Although some stakeholders have raised concerns that the cross-industry metric categories are too broad and may not lead to consistent and comparable information, the ISSB have confirmed that the lack of specificity was purposeful in order to allow market practice to develop.

33.3 adding a transition relief that allows entities to disclose information about cross-industry metric categories in the second or third year of reporting. This option would give entities time to develop appropriate metrics and collect the necessary data which would improve the quality of reporting. However, these cross-industry metric categories are connected to the Strategy disclosures and therefore entities applying the requirements should be able to collect certain data relating to the effects of climate-related risks and opportunities on the entity's financial position, financial performance and cash flows. Additionally, UK entities that are reporting TCFD disclosures are already subject to similar requirements. Furthermore, the ISSB has included a proportionality relief and permits entities to use reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort in relation to the requirements, which should reduce the anticipated cost and burden. This relief should also provide time for entities to develop the metrics and collect the necessary data as this information becomes more widely available over time.

Suggested endorsement recommendation

34 On balance, and based on the analysis provided in this paper, the TAC is asked to tentatively recommend:

34.1 to request further clarification from the ISSB as to what the objective of Metrics and Targets means in terms of whether certain information is required to be disclosed regardless of an entity's materiality assessment. Paragraphs 5–10 provide a discussion about the objective of the Metrics and Targets section, highlighting the lack of clarity as to whether certain metrics are required to be disclosed regardless of an entity's materiality assessment. Rather than amending IFRS S1 at this stage, it may be more appropriate to obtain further clarity from the ISSB as to their intentions when they amended the objective from the proposed Exposure Draft.

34.2 to maintain the requirements for the disclosure of information relating to the cross-industry metric categories in IFRS S2 paragraphs 29(b)–(g) but request that the ISSB provide further clarification as to the terminology used, including the terms ‘vulnerable' and 'aligned with'. The TAC should also observe market practice as it develops and may consider providing feedback to the ISSB during its post-implementation review of IFRS S2. Despite the challenges relating to the lack of specificity and data collection, most stakeholders agree that the cross-industry metric categories are appropriate and will allow market practice to develop. Additionally, the ISSB allows entities to use reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort in relation to the requirements, which should reduce the anticipated cost and burden to reporting entities.

34.3 to request further clarity from the ISSB as to why IFRS S2 paragraph 29(e) is not subject to the permission to use all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort, and what is meant by ‘deployed'. The ISSB has not provided an explanation as to why the requirement in IFRS S2 paragraph 29(e) is not subject to this relief. Additionally, it is not clear what is meant by the term 'deployed' and whether that refers to commitment investment or investment that has already been spent in that reporting period. The lack of clarity could impact the quality of disclosure and may not result in comparable metrics being disclosed.

34.4 to engage with the ISSB in updating the Industry-based Guidance on Implementing IFRS S2 to include metrics that support entities in reporting against the cross-industry metric categories in IFRS S2 paragraphs 29(b)–(e). Given that the types of ‘assets or business activities' are often industry-specific, this may be an area where the industry-based guidance could provide more specific metrics to support entities in applying the requirements for the cross-industry metric categories. Additionally, many of the illustrative examples in the IFRS S2 Accompanying Guidance on Climate-related Disclosures could be viewed as industry-specific rather than cross-industry. The TAC may decide to engage with the ISSB when it updates the Industry-based Guidance on Implementing IFRS S2 (timeline unknown) to include additional and specific metrics relating to climate-related risks and opportunities.

Questions for the TAC

  1. Does the TAC agree with the analysis in this paper in relation to the cross-industry metric requirements in IFRS S1 and IFRS S2?
  2. Does the TAC agree to tentatively recommend to request further clarification from the ISSB as to what the objective of Metrics and Targets means in terms of whether certain information is required to be disclosed regardless of an entity's materiality assessment?
  3. Does the TAC agree to tentatively recommend to maintain the requirements for the disclosure of information relating to the cross-industry metric categories in IFRS S2 paragraphs 29(b)–(g) but request that the ISSB clarify the terminology used, including the terms 'vulnerable' and 'aligned with'?
  4. Does the TAC agree to tentatively recommend to request further clarity from the ISSB as to why IFRS S2 paragraph 29(e) is not subject to the permission to use all reasonable and supportable information that is available to the entity at the reporting date without undue cost or effort, and what is meant by 'deployed'?
  5. Does the TAC agree to tentatively recommend to engage with the ISSB in updating the Industry-based Guidance on Implementing IFRS S2 to include metrics that support entities in reporting against the cross-industry metric categories in IFRS S2 paragraphs 29(b)–(e)?

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