ICAS responds to the IIRC proposed revisions to the Framework

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By Anne Adrain, Head of Sustainability and Reporting

20 August 2020

This article summarises the main points in the ICAS response to the proposed revisions to the Framework.

The International Integrated Reporting Council (IIRC) recently consulted on proposed revisions to the Integrated Reporting Framework. 

The ICAS Sustainability Panel and Corporate and Financial Reporting Panels submitted a joint response to the proposed revisions.
The Framework was launched in 2013 and its principles are just as relevant today as they were when the IIRC was formed 10 years ago. 

However, time, and the corporate reporting landscape have moved on, therefore the IIRC took the opportunity to revisit the Framework and introduce some clarifications and additional points of emphasis to ensure that it remains relevant to users and preparers in the current environment. The proposals also to demonstrate how Integrated Reporting can play a role in achieving our financial and sustainable development objectives.

ICAS welcomed the opportunity to provide constructive feedback on the proposed revisions to the Framework. The main points in the ICAS response were as follows:

• While ICAS was supportive of the enhanced governance disclosures and requirements in the proposed revisions, we highlighted that there is also a need to establish strong and robust governance processes over the systems and controls that produce the information to be included in the Integrated Report, specifically in relation to non-financial information.
• While we supported the principles-based approach in the Framework, we highlighted the need for these principles to explicitly recognise:

1. the relationship between sustainable development risks and opportunities and long-term value creation; and
2. their impact on the achievement of the UN SDGs. This approach is addressed in the three fundamental concepts in the SDGD Recommendations (Adams et al, 2020).

• ICAS agreed with the IIRC proposal that the purpose of an Integrated Report should extend beyond the providers of financial capital to include providers of other forms of capital. These parties have an equal stake in how the organisation creates value over time.
• ICAS also encouraged the IIRC to support the convergence and comparability of corporate reporting and the creation of global initiatives and standards that will become the building blocks for the convergence and alignment of global metrics, including those related to Sustainability/ESG.
• Finally, ICAS emphasised that in order for the IIRC to achieve their desire for the Framework become the umbrella framework for corporate reporting, the Framework itself needs to address and incorporate Sustainability/ESG related issues and demonstrate how it can contribute towards the achievement of the UN SDGs.