Understanding the Exposure Draft of the Standards
The SASB has voted to release the Proposed Changes to Provisional Standards, marking a pivotal point in its standard-setting work. As part of this milestone, the organization has opened the Basis for Conclusions compendium and the Exposure Draft of the Standards for a 90-day public comment period. SASB invites comments from October 2 through December 31, 2017. This process will culminate in ratification of the standards, scheduled for early 2018.
Downloading the Exposure Draft of the Standards
The Basis for Conclusions compendium and Exposure Draft of the Standards are available for download (in PDF format) by filling out the form below.
Please note that there may be differences between the provisional standard and the exposure draft of the standard that are not captured by redlines; these differences comprise negligible formatting and layout issues only in order to improve readability of the documents.
Providing Comments on the Exposure Draft of the Standards
The SASB welcomes stakeholder feedback regarding the Proposed Changes to the Provisional Standards, including the corresponding Basis for Conclusions. Interested parties are encouraged to submit public comments to the SASB for consideration in the ratification process of the Standards.
Comments are recommended to be submitted via the SASB’s Public Comment Portal:
Alternatively, comments may be provided by:
- Emailing comments to email@example.com
- Sending a letter to “Director of Research, 2017 Public Comment Period, Sustainability Accounting Standards Board, 1045 Sansome St., Suite 450, 94111”
The SASB staff tracks and acknowledges receipt of all comments from stakeholders. All public comments received will be made publicly available after the conclusion of the Public Comment Period.
In order to effectively track feedback, the SASB recommends that comments include the following details, as appropriate:
- Industry Standard (e.g., Commercial Banking)
- Disclosure Topic (e.g., Systemic Risk Management)
- Accounting metric code (e.g., FN0102-02)
- Line of disclosure, where relevant (e.g., .09)
- Technical Agenda item number (e.g. #4-10)
Specifically, the SASB encourages feedback which addresses the following:
- Topic-Level Proposed Updates: The extent to which the proposed change to add, remove, or reframe a topic adheres to the SASB’s Principles for Topic Selection (“Principles”), as established by the SASB Conceptual Framework.
- Metric-Level Proposed Updates: The extent to which the proposed change to add, remove, or revise a metric adheres to the SASB’s Criteria for Accounting Metrics (“Criteria”), as established by the SASB Conceptual Framework.
- Technical Protocol Proposed Updates: The extent to which the proposed change to revise a technical protocol enables the technical protocols to serve as the basis for “suitable criteria,” as defined by the PCAOB’s AT Section 101 and as characterized in the SASB Conceptual Framework.
Those providing comments should keep in mind that the proposed standards are intended for use by public companies and by investors to inform investment decisions. The standards are designed to facilitate disclosure of financially material sustainability-related information in a concise, comparable, cost-effective, decision-useful format. The Standards reflect the fact that certain sustainability information is important for assessing the future financial performance of an issuer, particularly over the long term.
The SASB Standards are designed for integration into existing reporting mechanisms, such as SEC filings. Such filings include Form 10-K for U.S. companies, Form 20-F for foreign issuers, Form 40-F for Canadian issuers, quarterly reports on Form 10-Q, current reports on Form 8-K, and registration statements on Forms S-1 and S-3. The SASB Standards are also recognized by the European Commission as a suitable framework for companies to provide information to investors pursuant to EU Directive 2014/95/EU.
PROVIDING PUBLIC COMMENT
A: The SASB voted to approve Exposure Drafts of the proposed Changes to the Standards, as well as accompanying Bases for Conclusion which provide the rationale for the proposed Changes. Public comment, as required by the Rules of Procedure, may be made on the following documents, which are publicly available on the SASB website.
- An Exposure Draft document for each Sector that represents the proposed final version of each individual industry standard with redlines showing each proposed Change.
- A Basis for Conclusion for each Sector which describes the rationale for each proposed Change.
A: The SASB accepts public comments via e-mail and conventional mail. The preferred method of submitting public comment is through the SASB comment portal. However, as an alternative, written public comment letters can also be mailed to: SASB Public Comment, 1045 Sansome Street, San Francisco, CA 94111.
A: The SASB will acknowledge receipt of, review and summarize all public comments received, regardless of the method with which it was sent. The SASB will not necessarily provide specific public responses to each public comment. At a minimum, the SASB staff will group, summarize, and characterize the nature of the comments received related to the applicable proposed Change(s). This summary and characterization will be included within each final Basis for Conclusion, where appropriate, which will be released in conjunction with the ratified standards.
A: All public comment received by the SASB regarding Exposure Drafts will be published on the SASB web-site prior to codification of the standards.
A: Public comments received after the end of the public comment period will be accepted. However, these comments may or may not be included for consideration in the grouping and categorization of public comments noted above. Comments not included for consideration will be considered for future Research Agendas or Technical Agendas.
OUTCOMES FROM THE PUBLIC COMMENT PERIOD
A: Working with the SASB staff, the Board established a Technical Agenda describing elements of the Provisional Standards which were placed under review for potential revision based on stakeholder feedback, regulatory changes, advances in science, and/or the identification of and response to cross-cutting topics that affect multiple industries or sectors. In subsequent Board meetings, the Board reviewed proposed Changes to the Standards as well as supporting Bases for Conclusions which explain the rationale for the proposed Changes for all items on the Technical Agenda. The SASB welcomes public comment on the Exposure Drafts of the Standards as well as the accompanying Bases for Conclusions.
A: While all public comments will be reviewed, comments are most helpful and potentially impactful when they address specific proposed changes. In alignment with the SASB’s Conceptual Framework and Rules of Procedure, respondents are encouraged to provide comment and input as to whether topics included in the Standards or Changes to the Standards are likely to constitute material information, whether metrics fulfill the SASB’s criteria for metric selection, and whether the Standards or Changes to the Standards are technically accurate and constitute a basis for “suitable criteria” for data verification.”
A: Public comments related to the proposed Changes and accompanying Bases for Conclusions which relate to the SASB’s Guiding Principles and Criteria for Standards development per its Conceptual Framework are welcome and will inform the SASB during the subsequent ratification process. Where public comments relate to the criteria listed in the Conceptual Framework, along with supporting evidence, the SASB may direct the SASB Staff to revise the proposed Change to the Standard as well as the accompanying Basis for Conclusion, which will be subsequently presented to the SASB for consideration to be ratified.
A: Public comments not associated with a proposed Change but which exhibit the following characteristics may result in the SASB Staff proposing a change to the provisional standards to the Board:
- Comments relating to the materiality of a topic, adherence to the SASB criteria for metric selection, and the suitability of the technical protocols, per the SASB’s Conceptual Framework.
- Comments not related to proposed Changes will be considered by the SASB for our general standard-setting purposes, including the establishment of future research agendas, technical agendas, proposed Changes, technical bulletins and other revisions and/or guidance. Such recommendations may result in the Board voting to accept the recommendation. Comments which do not meet these criteria or are not accepted by the Board may also result in the inclusion of an item on the Staff’s Research Agenda. Such items will be prioritized by the Staff for additional research and/or stakeholder outreach and may be incorporated into future Technical Agendas and, subsequently, result in Changes to the Standards.
A: Based on the public comments received, the Board may direct the SASB Staff to create a Technical Bulletin to clarify particular issues, topics, angles, metrics or technical protocols in the ratified standards.
PROPOSED CHANGES TO THE PROVISIONAL STANDARDS
A: Recommended changes to the provisional standards are focused on making them more decision-useful, cost-effective, and reflective of the most material topics in each industry. A number of proposed Changes added international consideration for metrics. Examples of such changes are included in the Chemicals (#7-5), Containers & Packaging (7-24), Investment Banking & Brokerage (2-21) industries.