- We welcome the UK government support for the development of international standards for the disclosure of sustainability-related information.
- We agree with the approach to Scope 3 reporting contained within IFRS S2 and are also broadly supportive of the ISSB’s approach to materiality. We support full alignment with this approach under UK reporting rules, though we note that there are areas of the ISSB disclosure framework that require clarification, and others that require flexibility in application.
- We believe that the use of the GHG Protocol for the purposes of Scope 3 reporting within IFRS S2 will lead to comparable and consistent reporting that is useful for investors and users of accounts, but reporting entities should be allowed to apply the Protocol flexibly.
- We believe that Scope 3 emissions reporting would be beneficial to market efficiency and discipline, but we caution the Government against conflating Scope 3 emissions with transition risk.
Our response to the Department for Science, Innovation and Technology’s (DSIT) call for evidence on ‘Smart Data opportunities in digital markets’
We support the development of a Smart Data ecosystem in the UK, leveraging the Data (Use and Access) Act (DUA Act) to facilitate secure and transparent data sharing. The UK financial services industry is already a global leader in Smart Data initiatives, and DSIT should consider our industry’s experience with Open Banking as a blueprint for wider reform.