The Evolution of Sustainability Disclosure Comparing the 2022 SEC, ESRS, and ISSB Proposals

While the SEC, EFRAG, and ISSB proposals deal with similar material, they differ in certain respects, including their enforceability, jurisdictional scope, substantive scope of coverage, and detailed requirements. The following proposal analysis seeks to help companies make sense of the three by comparing them on their alignment to primary international climate disclosure frameworks, details of disclosure, and timelines for implementation.