AICPA, CAQ support SEC’s exploration of climate change disclosures

By Ken Tysiac

The AICPA and the Center for Audit Quality (CAQ) voiced support for the SEC’s exploration of disclosures related to climate change and environmental, social, and governance (ESG) issues in comment letters sent to the commission on Friday.

The SEC in March asked for comments on its disclosure rules and guidance related to climate change disclosures as momentum on this topic has grown. The IFRS Foundation plans to announce a decision in the fall on whether to create an international sustainability standards board, and a merger of the Sustainability Accounting Standards Board (SASB) and the International Integrated Reporting Council (IIRC) has increased the focus on the importance of harmonizing standards and frameworks in this area.

According to the AICPA letter to the SEC, it’s critical for investors to have relevant disclosures about the drivers of value, and market participants need to work toward a comprehensive global reporting solution that includes ESG disclosures and shows how an enterprise uses its resources to create value over the long term.

The AICPA letter:

  • Acknowledges that investor information needs to extend beyond climate-related disclosures to broader ESG disclosures.
  • Supports the proposition that any climate-related disclosures be based on existing frameworks and standards.
  • Says that SEC disclosures should be compatible with emerging international developments, in particular the international sustainability standards board the IFRS Foundation is considering.
  • Supports the SEC’s consideration of assurance over climate-related disclosures and says CPAs are uniquely qualified to enhance the reliability of ESG disclosures through assurance services.
  • Calls for structuring of ESG data in a cost-effective manner for users, a degree of flexibility in any disclosure requirements, and a safe harbor from liability for forward-looking disclosures.
  • Says that a transition period may be necessary for issuers to report complete, accurate, and reliable ESG information.

The CAQ letter:

  • Supports a globally accepted ESG reporting system built from existing standards and frameworks that can be adapted to meet the needs of investors in different jurisdictions.
  • Says that assurance of climate-related and ESG information performed by a public company auditor can enhance the reliability of this information and offer increased investor protection.
  • Calls for aspects of implementation, including transition periods, to be considered by the SEC staff if the SEC determines that it is appropriate to require issuers to make certain climate-related disclosures.
  • Says that a global standard setter is likely necessary for a globally accepted ESG reporting system to be implemented and to operate effectively.
  • Requests scalability and industry specificity in any potential ESG reporting requirements.

“It is important that any potential ESG reporting requirements be scalable to public companies of all sizes and consider the differences in the potential ESG risks and opportunities of different industries and geographies,” the CAQ letter said.

The SEC comment deadline was Sunday, and the commission will review comments as it considers its next steps on ESG issues.

Ken Tysiac ( is the JofA’s editorial director.


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