The IFRS Foundation Trustees called for submissions on its Consultation Paper (the Paper) which proposed targeted amendments to the IFRS constitution to accommodate an International Sustainability Standards Board to set IFRS Sustainability standards.

Key points from the joint submission include:

• We recommend the approval processes for IFRS accounting standards (accounting standards) and IFRS sustainability standards (sustainability standards) be aligned to remove any misconceptions about the credibility of sustainability standards.
• The exposure draft identifies enterprise value (EV) as a critical determinant of investor decision making. However, the amendments to the Constitution are silent on the role to be played by EV in driving the character of IFRS Sustainability Standards. We caution against drawing too great a nexus between the capital/dimensions of sustainability and EV, as EV still relies to a large degree on the market’s determination, encompassing a range of factors both within and outside of the control of the organisation.
• Significant care will need to be applied to how a conceptual framework for sustainability reporting is established enabling appropriate synergy with that which exists for financial reporting. This will be vital to issues of coherence, choice/treatment of sustainability issues and any measures taken towards establishing an overarching conceptual framework.
• It will be important, particularly in the initial formative years, for both the ISSB and the IASB to have clear, complementary strategies (and integrated where possible) and to (and be seen to) work collaboratively to enable implementation of key priority areas. 
• To respond to common economic, environmental and social drivers that will emerge, it will be critical that, from the outset, there be strong lines of liaison between the two Boards. At present, the amendments to the Constitution do not outline the interaction between the proposed strategies of the Foundation, IASB and the ISSB. Addressing this will be important to aligning the rapidly developing area of sustainability and associated reporting with current financial reporting.