BETTER FINANCE response to the ISSB Consultation on General Requirements for Disclosure and Climate-related Disclosure

Individual, non-professional (“retail”) investors are significantly interested in sustainable investments and by extension rely not only on more data on climate or sustainability-related risks and opportunities, but also on more comparable, and comprehensible data in order to understand the risks and opportunities entities are exposed to.

In order to ensure investors receive consistent, comparable, and reliable information and enable them to make informed judgments about the impact of climate-related risks on current and potential investments, and also – hopefully – on the climate-related impact of investee companies, we recommend:

• Consistency and coordination with other disclosure standards and initiatives
• Clarity and consistency of “materiality” and “enterprise value” throughout the ISSB’s Standards
• Integrating sustainability and financial reporting

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