DBT consultation on UK Sustainability Reporting Standards

We refer to the invitation to comment on the Department for Business and Trade’s consultation on the UK Sustainability Reporting Standards. We appreciate the opportunity to contribute our investor perspective on the UK adoption of the ISSB standards and the future sustainability reporting regime.

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 (the fund). NBIM is a globally diversified investment manager with 19,754 billion Norwegian Kroner at end 2024, of which 1,137 billion (ca GBP 80 billion) invested in the United Kingdom. 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 financial information across global capital markets.

We strongly support the ISSB 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. Investors will be able to receive sustainability-related financial information that is concurrent, connected and complementary to financial statements. This is critical for us to formulate a holistic view of a company’s performance and prospects over different time horizons and inform our investment decisions, risk management processes and stewardship activities.

We strongly welcome the UK government’s intention to endorse the ISSB standards, and believe that the amendments from the IFRS standards should be minimized to retain the benefits of global comparability. We therefore encourage the government to reconsider Amendment 5 on the wording referring to the SASB standards, which would create a permanent deviation from the ISSB standards. Should UK entities not be required to consider the SASB materials when identifying the sustainability topics and related disclosures which are relevant to their industry, there is a risk that the industry specificity of such disclosures is weakened, and that the comparability of disclosures with those published by entities in other jurisdictions is affected. Regarding Amendment 3 removing the requirement to use the GICS classification system, we encourage UK authorities to await the outcome of the IFRS standard setting process before considering making changes to the UK version of the standards.

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

Yours sincerely,

Carine Smith Ihenacho
Chief Governance and Compliance Officer 

Elisa Cencig
Head of Policy Engagement