Response to ASIC Consultation on Sustainability Reporting Regulatory Guidance

We refer to the Australian Securities and Investments Commission’s invitation to comment on proposals in the Consultation Paper 380: Sustainability Reporting pertaining to the Draft Regulatory Guide 000 Sustainability Reporting. We appreciate the opportunity to provide feedback as ASIC develops its guidance and approach to the sustainability reporting requirements in the Corporation Act.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with AUD2,493.16 billion at 30 June 2024, of which AUD33.03 billion was invested in the shares of 325 Australian listed companies.

As a long-term investor, we consider our returns over time to be dependent on sustainable economic, environmental and social development, as well as on well-functioning, legitimate and efficient markets. We are active investors in over 65 countries and require reliable, consistent and comparable sustainability-related financial information across global capital markets. We strongly support the IFRS Sustainability Disclosure Standards (ISSB standards) as the global baseline of investor-focused standards for sustainability-related financial disclosures. The ISSB standards share the same conceptual foundations as the International Accounting Standards Board (IASB) financial reporting standards, enabling investors to receive sustainability-related financial information that is concurrent, connected and complementary to financial statements.

We welcomed the incorporation of all IFRS S2 requirements, except for industry-based disclosures, in the Australian Accounting Standards Board’s S2 Climate-related Disclosures standard. We commend ASIC’s proposal to issue regulatory guidance to support entities to prepare annual sustainability reports. We hope that this guidance and other capacity building actions by ASIC will encourage Australian listed companies to provide industry-specific metrics and sustainability-related financial disclosures beyond climate on a voluntary basis using AASB S1. This is critical for us to formulate a holistic view of a company’s performance and prospects over time and facilitates cross-border capital flows.

We thank you for considering our perspective and remain at your disposal should you wish to discuss these matters further.

Please find in the annex our responses to the proposals and questions for Consultation Paper 380.

Yours sincerely

Carine Smith Ihenacho
Chief Governance and Compliance Officer

Jeanne Stampe                 
Lead Policy Advisor

Please find our responses to ASIC's consultation in the annex.