Relief, rigour, and a world on fire: our response to ISSB’s Greenhouse Gas Disclosure proposals
In April 2025, the International Sustainability Standards Board (ISSB) released a pivotal consultation: proposed amendments to IFRS S2 aimed at clarifying and easing the implementation of greenhouse gas emissions disclosures. At Ancoram, we responded with a clear message: relief should never become a loophole.
Where we stand
We support many of the ISSB’s proposals in principle. Flexibility on issues such as classification systems, global warming potential metrics, and jurisdictional methodology is often necessary to accommodate practical realities. However, this flexibility must be accompanied by safeguards: time-bound transitional relief, mandatory progress tracking, and reconciliation to global baselines. Otherwise, what begins as implementation support may erode comparability and accountability across borders.
The danger of exclusion
We take issue with the proposed allowance for financial institutions to permanently exclude facilitated and insurance-associated emissions. These aren’t abstract financial instruments, they directly support high-emitting activities. Excluding them from Scope 3 undermines the credibility of emissions disclosures and risks enabling greenwashing. We’ve called for a sunset clause, clearer justification requirements, and mandatory progress reporting to keep integrity at the core of financial disclosures.
Leadership means pace and precision
Perhaps most critically, our letter calls out the slowing pace of standard-setting at the ISSB. In a world racing towards climate tipping points, delay is a form of denial. We urge the ISSB to move faster, collaborate deeper with other frameworks like EFRAG and GRI, and put scientific and civil society input at the heart of global disclosure efforts.
What’s next
At Ancoram, we remain committed to helping clients navigate this evolving landscape, turning disclosure into strategy, and risk into resilience. We’ll continue to advocate for standards that are not only technically sound but practically powerful; standards that help businesses lead with integrity, not loopholes.
If you’re a sustainability leader, board member, or finance executive grappling with these changes, we’re here to help. Let’s ensure your ESG reporting is both defensible and decision-useful.