Non-Renewable Resources Public Comment

Non-Renewable Resources Sustainability Accounting Standards

90-Day Period of Public Comment

Begins: Tuesday, January 14th, 2014
Comment Deadline: Monday, April 14th, 2014








The set of proposed sustainability accounting standards for the Non-Renewable Resources sector will be available for public review from January 14, 2014 to April 14, 2014.


SASB welcomes comments from the public. Those providing comments should keep in mind that the proposed disclosure standards are intended to be integrated in standard filings of publicly-traded companies, such as the Form 10-K. As such, they reflect auditable information that is likely to be material to investors and can be disclosed in a cost-effective manner.


The standards have been developed based on extensive evidence-based research and significant, balanced input from 197 corporations, investors and other stakeholders (representing $3.3T assets under management and $2T market capitalization) in our Industry Working Groups (PDF). After the public comment and a review by SASB’s independent Standards Council, the standards will be issued for use by companies in the sector. All comments received, as well as SASB’s response to each comment, will be posted publicly as part of our transparent process.



The industries in this sector are:

  • Oil & Gas – Exploration & Production
  • Oil & Gas – Midstream
  • Oil & Gas – Refining & Marketing
  • Oil & Gas – Services
  • Coal Operations
  • Metals & Mining
  • Iron & Steel Production
  • Construction Materials


Please provide comments in the form of a letter on official letterhead, submitted by email to: We strongly encourage participants to provide comments on company/organization or individual letterhead signed by the authorized representative.


SASB recommends that letters include the following for each comment:

  • Industry Standard (e.g., Oil & Gas – Exploration & Production)
  • Disclosure Topic (e.g., Greenhouse Gas Emissions)
  • Accounting metric code (e.g., NR0101-02)
  • Line of disclosure, where relevant (e.g., .09)
  • Comment:

Specifically, SASB would like comments to address the following:

  1. Disclosure Topics
    • Identify any disclosure topics in the Standards that may not be material to a reasonable investor, including an explanation.
    • Suggest any disclosure topics not included in the Standards that may be material to a reasonable investor, including evidence supporting your assertion.
  2. Accounting Metrics
    • Provide comments to correct, improve, or add to accounting metrics in the standards.
    • Suggest additional or alternate accounting metrics to measure performance with respect to a disclosure topic.
  3. Cost Effectiveness
    • How costly would it be for companies to collect, analyze, and report information required for the proposed accounting metrics?
    • Do you anticipate this cost to be a barrier to reporting, adoption, or usage of the proposed accounting metrics?
    • What aspects of reporting, if any, would you foresee being most costly for reporting organizations?