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Letter to ISSB on IFRS sustainability disclosure standard methodology

August 9, 2023 

Emmanuel Faber
International Sustainability Standards Board 
Columbus Building 
7 Westferry Circus 
Canary Wharf 
London, United Kingdom 
E14 4HD 

Submitted online at IFRS.org 

RE: IFRS Sustainability Disclosure Standard Methodology for Enhancing the International Applicability of the SASB Standards and SASB Standards Taxonomy Updates 

Dear Mr.  Faber: 

The Virginia Society of CPAs (VSCPA) Accounting & Auditing Advisory Committee has reviewed the IFRS Sustainability Disclosure Standard Methodology for Enhancing the International Applicability of the SASB Standards and SASB Standards Taxonomy Updates (ED), issued by the International Sustainability Standards Board (ISSB). The VSCPA is the leading professional association in Virginia dedicated to enhancing the success of all CPAs and their profession by communicating information and vision, promoting professionalism, and advocating members’ interests. The VSCPA membership consists of nearly 13,000 individual members who actively work in public accounting, private industry, government, and education. 

The Committee generally supports the proposal to prioritize a narrow scope of work to internationalize the SASB Standards, given the requirements of IFRS S1 General Requirements for Disclosure of Sustainability-Related Financial Information to consider the SASB Standards when identifying relevant sustainability-related risks and opportunities and to develop appropriate disclosures in the absence of an IFRS Sustainability Standard. The Committee also provides the following comments with regard to the ED. 

The ISSB should develop a conceptual framework that includes industry-specific requirements, general requirements, and topical standards. This framework could be a combined framework for IFRS Accounting Standards and IFRS Sustainability Disclosure Standards (SDS) or a separate framework for SDS.  

The ISSB should continue to consider the needs of entities that already report under the SASB Standards in order to avoid unnecessary duplication of efforts in determination and reporting of applicable disclosures.  

Industry-specific standards must be a primary component of reporting on sustainability-related risks and opportunities. Stakeholders find sustainability-related disclosures that are specifically tied to their industry to be the most valuable for understanding consistent comparability across partner or competitive entities. 

The VSCPA appreciates the opportunity to respond to the ED. Please direct any questions or concerns to VSCPA Vice President, Advocacy Emily Walker, CAE, at [email protected].  


Zach Borgerding, CPA
Chair, 20232024 VSCPA Accounting & Auditing Advisory Committee  


VSCPA Accounting & Auditing Advisory Committee 20232024  

Zach Borgerding, CPA — Chair 
Michael Phillips, CPA — Vice Chair 
David Allen, CPA
Scott Davis, CPA  
Obed Irfan, CPA  
Joshua Keene, CPA  
Nick Kinsler, CPA  
Daniel Martin, CPA 
Brian Minor, CPA  
Elisa Obillo, CPA 
Krisia Raya, CPA  
Charles Valadez, CPA  
Natalya Yashina, CPA