ISSB Consultation on Proposed Amendments to the SASB Standards

We refer to the invitation to comment on the International Sustainability Standards Board's Exposure Draft of Proposed Amendments to the Sustainability Accounting Standards Board (SASB) Standards. We appreciate the opportunity to contribute our perspective on these important enhancements to the SASB 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 approximately USD 1.94 trillion in assets under management as of 30 June 2025, holding on average 1.5% of all listed companies globally.

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 sustainability-related financial information across global capital markets. We strongly support the ISSB as the global baseline for investor-focused sustainability-related financial disclosures that are connected and complementary to financial statements. This is critical for us to formulate a holistic view of a company’s performance and prospects over time.

We welcome the ISSB's efforts to enhance the SASB Standards and support the proposed amendments. The SASB Standards play an important role within the ISSB architecture. Their industry-specific approach makes them a useful resource to help companies and investors identify and focus on the most financially material sustainability issues for the relevant sector, and the associated disclosure metrics provide important inputs for company-specific analysis. A key strength of the standards is their relative compactness which provides focused, decision-useful information without overwhelming preparers or users. We emphasize the importance of maintaining this characteristic through the standards enhancement process.

As a globally diversified investor, we particularly value the focus on enhancing international applicability of the requirements, and their interoperability with other reporting frameworks. This enables more consistent and comparable disclosures across markets while allowing reporting efficiencies for companies operating across jurisdictions. From our perspective as an investor, interoperability is not simply about aggregating disclosure requirements but rather about streamlining overlapping areas to facilitate consistent data collection without diluting investor-relevant information. The proposed amendments appropriately balance these considerations. We support the ISSB’s approach of aligning with established frameworks and standards where relevant, as this enhances consistency and avoids duplication. This includes drawing on applicable elements from frameworks such as the Taskforce on Nature-related Financial Disclosures (TNFD) recommendations where they align with investor needs.

We broadly agree with the disclosure topics identified in the proposed amendments. Drawing on the expertise of our sector-focused portfolio managers and stewardship specialists, our response proposes targeted refinements, mainly to specific metrics and technical protocols. These refinements aim to further strengthen the connectivity to financial reporting and management accounting, ensure metrics capture information in a decision-useful format, and maintain the standards’ disciplined focus on financially material sustainability issues.

Going forward, we recommend that the ISSB develop a clear roadmap for enhancing additional SASB Standards beyond the nine priority industries, including defined criteria for prioritisation. This would provide visibility on sequencing and timing, supporting consistent planning for preparers and users of sustainability-related financial information. Enhanced clarity would also benefit jurisdictional standard-setters and regulators who are rolling out the standards in their respective disclosure regimes and considering the role of SASB as part of their approach.

Our detailed responses to selected survey questions are provided in Annex 1 to this letter. 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                                                 

Snorre Gjerde
Lead Policy Advisor