Comments on the International Sustainability Standards Board’s (ISSB) March 2022 Exposure Draft IFRS S2 Climate-related Disclosures

CRS’s comments on the ISSB’s March 2022 Exposure Draft IFRS S2 Climate-related Disclosures pertain to the transition plans and carbon offsets and cross-industry metric categories and greenhouse gas emissions. CRS’ comments emphasize the importance of not conflating carbon offsets and renewable energy certificates (RECs), disclosure specifically related to voluntary renewable energy procurement, information about voluntary sourcing of electricity (specifically procurement of renewable, non-emitting, or other specified electricity), and requiring a “market-based method” for Scope 2 calculations for all markets in which power generation is differentiated, transacted, and/or allocated to load/customers.