Some may recall that last autumn I asked if anyone here who was interested might make a submission to the IFRS on their consultation on whether they might create sustainability accounting standards, to be created through a new created, but quasi-independent, sustainability standards board that they are promoting.
I was opposed to this because the implication of this proposal is that sustainability standards can exist outside the mainstream of accounting, which is exactly the time institutional failing that was identified as a key reason for the failure of government to manage issues relating to climate change referred to in an HM Treasury report by Professor Sir Partha Dasgupta of Cambridge University to which I referred yesterday.
Submission of comment to this consultation was not made easy. Despite that my review of the 576 comments submitted suggests that 93 (at least) were based in the submission that my colleague Professor Adam Leaver of the University of Sheffield and I made early in in the consultation process.
Some of those commenting came directly from those whose names I recognise from this blog.
I appreciated the joint submission from Caroline Lucas MP and Clive Lewis MP (to evidence a nice bit of cross party working).
But I admit most came because Extinction Rebellion adopted the message that we were making.
But what this suggests is that about one in six of the submissions to the IFRS on this issue agreed on a number of key issues.
The first was that sustainability reporting should be integrated into mainstream financial reporting, and not be treated separately as they have suggested.
Second, that this means the cost of becoming net zero carbon should be put, upfront, on the balance sheets of companies, as sustainable cost accounting suggests.
And, third, that the IFRS should not separate these issues by having a separate standards board.
My grateful thanks to all who offered support. The original submission that Adam and I made is here.
The downside is that the IFRS says it is going ahead with its plans. It looks like there will be more to do.
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It’s standard during such consultations for submissions which are obviously essentially the same (and if you can spot the 93, so can the IFRS) to be treated as one submission. So the 93 will be treated as one.
Well done for wasting the time of those who submitted and the poor unfortunates who had to sift through the submissions.
I am aware of that risk – but actually they just make themselves look foolish and biased when making such claims so I think they will have learned the lessons by now
The implication is that I (yes, I did make a submission) just did a cut and paste of Richard’s submission. In fact I reviewed the consultation questions, looked at Richard’s responses but made my own mind up about what I wanted to say. Some questions I left blank, some my views differ from Richard and on some points we agree.
Even if many of the 93 are similar in outlook that fact that they went to the effort to respond says something about the strength of feeling out there on the topic and it appears that they have recognised this. I just had an email from IFRS that suggests that they were surprised by the level of responses and that they were largely calling for stronger for urgent steps and that they were reviewing their next steps in response to that. In short, I think our input mattered.
Add this to the change in thinking at organisations from the IMF to the UK Treasury then I think we might just be getting somewhere!!
I wholeheartedly agree
And so do I. My response adopted the same structure as the template but I used my own experience in life and perspectives within that template. If that is treated as a “replication” then one can only interpret that as selection bias. If 93 responses are reduced to 1 because they adopt a similar template then there is clear evidence of a fait accompli before the process began – otherwise known as “going through the motions”. Democracy WTF is that? Democracy is a sham – autocracy is the reality. Keep up the good fight Richard – you are not alone.
I am asking for a meeting with the IFRS