ISSB Consultation on Proposed Amendments to the SASB Standards – Phase 1, Part 2

We refer to the invitation to comment on the International Sustainability Standards Board's (ISSB) Exposure Draft of Proposed Amendments to the Sustainability Accounting Standards Board (SASB) Standards (Phase 1, Part 2). 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 2.1 trillion in assets under management as of year-end 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 60 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 broadly support 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 suggested 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 SASB standards’ characteristic compactness and disciplined focus on financially material sustainability issues.

NBIM is a member of the ISSB’s Investor Advisory Group (IAG), and we look forward to continuing to engage through the IAG as the ISSB develops its roadmap for enhancing additional SASB Standards beyond the twelve industries currently under review, and progresses with its standard-setting efforts on nature-related financial risks and the research project on human capital. A roadmap outlining the ISSB's plans for the remaining SASB Standards, including sequencing and timing, will provide clarity for market participants on what to expect going forward, and support consistent planning for preparers and users of sustainability-related financial information.

Our detailed responses to the survey questions are provided in Annex 1 to this letter. For consultation questions already covered in Phase 1, Part 1 of the SASB enhancement consultation process, we refer to our comment letter from November 2025[1].

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
Policy Lead

[1] NBIM, Response to ISSB Consultation on Proposed Amendments to the SASB Standards, 28 November 2025. Available at: https://www.nbim.no/en/publications/consultation-responses/