Invitation to comment on Exposure Draft for Amendments to Greenhouse Gas Emissions Disclosures

We refer to the invitation from the International Sustainability Standards Board (ISSB) to comment on the Exposure Draft on Amendments to Greenhouse Gas Emissions Disclosures (ED GHG) under IFRS S2 Climate-related Disclosures (IFRS S2). We welcome the opportunity to provide feedback on the ED GHG, which is intended to address IFRS S2 application challenges by reducing complexity and duplication of reporting. This is a critical step to maintain jurisdictions’ and entities’ momentum in adopting and complying with IFRS Sustainability Disclosure Standards (ISSB Standards).

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. NBIM is a globally diversified investment manager with 1.73 trillion USD at 31 December, 2024. 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 standards as the global baseline of investor-focused standards for sustainability-related financial disclosures. We chair the ISSB Investor Advisory Group that provides strategic guidance on standards development and the investor perspective for standard setting processes. We are also a member of the International Accounting Standards Board (IASB) Capital Markets Committee which provides regular input to IASB from the financial statement user perspective, and support strengthening the connectivity between financial statements and sustainability-related disclosures. This enables us to formulate a holistic view of a company’s performance and prospects over time, and inform our investment decisions, risk management processes and ownership activities.

Please find in the annex our responses to the consultation questions. 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

Jeanne Stampe
Lead Policy Advisor