EFRAG call for input on revision of the European Sustainability Reporting Standards

Brev til EFRAG, 9. mai 2025. Brevet finnes kun på engelsk.

Introduction

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank (Norges Bank) and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with 1.67 trillion EUR at year end 2024. Of this total, ca 284 billion EUR was invested in the shares of 1,066 companies in 27 EU countries. We are a long-term investor, working to safeguard and build financial wealth for future generations.

We welcome the opportunity to contribute to this targeted feedback exercise on European Sustainability Reporting Standards (ESRS) Set 1 revision, following the European Commission's mandate to European Financial Reporting Advisory Group (EFRAG) on March 27, 2025, as part of the Omnibus Simplification Package. We look forward to continuing to provide our input to EFRAG as it develops its technical advice to the European Commission.

We support the important work of the European Commission and EFRAG in promoting better and more harmonised sustainability reporting, as highlighted in previous consultation responses. As a long-term, global investor, we consider our returns over time to be dependent on sustainable development in economic, environmental and social terms. We need consistent, comparable and reliable information from companies on social or environmental issues which are financially material to their business. We rely on information related to the current performance of a company, as well as information on drivers of value that might be predictive of its long-term performance. Given our long-term investment horizon, we particularly value transparent disclosures on sustainability impacts that are most material to business value creation, as these are essential for our understanding of a company's resilience and future performance prospects.

We strongly welcome the drive for simplification of the ESRS. As Corporate Sustainability Reporting Directive (CSRD) implementation begins, we observe that current standards present significant challenges for reporting companies. In our view, there is significant scope for streamlining disclosure requirements. We recommend three key areas of simplification:

This approach would significantly decrease the reporting burden while ensuring that stakeholders receive the most relevant and impactful sustainability information. The remainder of this consultation provides practical examples of how these three key simplifications could be achieved.[1]

Global Alignment for greater efficiency

We acknowledge the important progress made with the May 2024 interoperability guidance jointly published by the IFRS Foundation and EFRAG. However, interoperability alone does not eliminate inconsistencies in reporting requirements. The ESRS shares similar high-level goals with the ISSB standards, specifically IFRS S1 (General Requirements for Disclosure of Sustainability-related Financial Information) and IFRS S2 (Climate-related Disclosures). The ISSB standards build on existing frameworks, such as the Taskforce on Climate-Related Financial Disclosures Recommendations (TCFD), and maintain its four-pillar structure around governance, strategy, risk management, and metrics and targets. We continue supporting this four-pillar structure as it provides a logical and consistent framework for sustainability reporting.

We recommend EFRAG increase the alignment of ESRS with the ISSB standards by adopting identical wording and metrics where they address the same sustainability matters.[2] Disclosure requirements in ESRS should remain at least as robust as those in ISSB Standards, thereby preserving the global baseline.

For example, for internal carbon pricing: ESRS E1 (Climate Change) Disclosure Requirement E1-8 requires disclosure of “whether it applies internal carbon pricing schemes, and if so, how they support its decision making and incentivise the implementation of climate-related policies and targets.”[3] Paragraph 63(c) further requires disclosure of “the carbon prices applied according to the type of scheme and critical assumptions made to determine the prices, including the source of the applied carbon prices and why these are deemed relevant for their chosen application.”[4]

Meanwhile, IFRS S2 paragraph 29(f) requires disclosure of “an explanation of whether and how the entity is applying a carbon price in decision-making (for example, investment decisions, transfer pricing and scenario analysis)” and “the price for each metric tonne of greenhouse gas emissions the entity uses to assess the costs of its greenhouse gas emissions.”[5] While both frameworks address the same topic, there are differences in language and specific metrics that create unnecessary reporting complexity.

Likewise, in the social domain, ESRS S1 (Own Workforce) Disclosure Requirement S1-14, requires exhaustive health and safety metrics including "(a) the percentage of people in its own workforce who are covered by the undertaking's health and safety management system... (c) the number and rate of recordable work-related accidents... (e) with regard to the undertaking's employees, the number of days lost to work-related injuries".[6] The standard even prescribes the exact calculation methodology in Application Requirement (AR) 89, mandating that "the undertaking shall divide the respective number of cases by the number of total hours worked by people in its own workforce and multiplied by 1,000,000".[7]

By comparison, SASB's Metals & Mining Industry Standard metric takes a fundamentally different approach, requiring only "(1) All-incidence rate, (2) fatality rate, (3) near miss frequency rate (NMFR) and (4) average hours of health, safety, and emergency response training for (a) direct employees and (b) contract employees".[8]

These examples[9] illustrate why achieving greater alignment between ESRS and ISSB frameworks would significantly enhance comparability and reduce the burden on reporting companies. We continue to support the ISSB as the global baseline for sustainability reporting given their focus on financial materiality. For disclosures going beyond ISSB, we suggest alignment with established standards like Global Reporting Initiative (GRI) and Taskforce on Nature-related Financial Disclosures (TNFD) to maintain consistency across frameworks. This would reduce reporting burdens for companies subject to multiple regulatory regimes. It would also enable more efficient digital tagging, making sustainability information more accessible and comparable for all stakeholders.

Structural improvements to reduce duplication

The current ESRS structure creates significant reporting inefficiencies through structural duplication. Companies are required to report on same four[10] areas: governance, strategy, impact, risk & opportunity management and metrics & targets across three interconnected layers of standards:

  1. Cross-cutting standards (ESRS 1 & 2) that apply to all companies
  2. Special status materiality-dependent topical standards (ESRS E1-Climate, S1-Own Workforce)
  3. Other topical standards deemed relevant through materiality assessment

We believe structural improvements could significantly reduce duplication. One effective approach would be to consolidate of these cross-cutting elements at the entity level in ESRS 2, with topic-specific standards only requiring additional information unique to the sustainability matter being reported.

For example, a company must describe its governance approach for sustainability matters in ESRS 2, then may repeat largely similar governance information for climate in ESRS E1, for workforce in ESRS S1, and again for each material topic.[11] For most companies, the same board committee or relevant governance structure oversees multiple topics, yet the current structure requires repetitive disclosure of essentially the same governance information across numerous disclosure requirements, creating reporting burden without adding meaningful insight. The standards themselves acknowledge this redundancy - ESRS S1, AR 18 gives companies the option to fulfill certain governance disclosures by cross-referencing ESRS 2 GOV-1.[12] However, this optional cross-referencing approach adds complexity by requiring navigation between interconnected standards.

The same pattern applies to strategy disclosures[13] and impact, risk & opportunity management disclosures[14] where companies must separate and repeat similar information across multiple standards despite typically using integrated frameworks.

We suggest that these disclosures be consolidated based on their nature. For governance disclosures, consolidation at the entity level in ESRS 2 would eliminate significant duplication with minimal information loss. For strategy and impact, risk & opportunity management disclosures, which may contain more topic-specific elements, preparers should have the option to either report this information once at the entity level (when using integrated frameworks) or provide additional topic-specific details only where materially different approaches are used for particular sustainability matters. We acknowledge that metrics and targets are highly topic-specific in nature, but if relevant, companies should have the option to report entity-wide performance indicators at the consolidated level when these span multiple sustainability matters. Similarly, for metrics and targets, while acknowledging their frequently topic-specific nature, companies should have the option to report entity-wide performance indicators at the consolidated level when these span multiple sustainability matters.[15] This would reduce unnecessary segmentation of interconnected performance measurement.

Another area of structural inefficiency relates to Minimum Disclosure Requirements (MDRs). ESRS 2 establishes MDRs on policies, actions, targets and metrics that apply across all material topics.[16] These requirements create a significant layer of duplication because companies must address substantially similar disclosure requirements multiple times - once under ESRS 2’s MDRs and again under each special status and other materiality dependent topical.[17]

For example: ESRS 2, Policies MDR-P, paragraph 65 requires undertakings to provide six specific types of policy information adopted to manage material sustainability matters.[18] ESRS E1 (Climate Change), Disclosure Requirement E1-4, paragraph 24 requires the same information[19] as ESRS 2 MDR-P while adding climate-specific elements.[20] ESRS S1 (Own Workforce), Disclosure Requirement S1-1, paragraph 19 similarly requires the same information[21] as ESRS 2 MDR-P while adding workforce-specific elements (paragraph 20-24).[22] ESRS S2 Level (Workers in the Value Chain) also follows the same pattern, requiring disclosure of policies in accordance with ESRS 2 MDR-P[23] while adding value chain worker-specific elements.[24] This same pattern of duplication applies to actions and targets across all material topics.[25]

Furthermore, ESRS 1 paragraphs 33-34 create an imbalance in how materiality assessment is applied to these requirements.[26] For policies, actions, and targets, when a topic is deemed material, companies must disclose all prescribed disclosure requirements even when individual requirements may not be material to the company's specific circumstances. For metrics, however, undertakings may omit the information prescribed by a datapoint of a disclosure requirement if they assess such information to be not material and conclude that such information is not needed to meet the objective of the disclosure requirement. This inconsistency creates additional complexity in reporting processes.

To address these MDR-related inefficiencies, we recommend a more streamlined approach:

  1. MDRs on policies, actions, targets and metrics that address multiple sustainability matters should be reported once at the entity level in ESRS 2, with clear identification of which material topics they address.
  2. Topic-specific standards should then only require supplementary information that is uniquely relevant to that particular sustainability matter.
  3. The approach for assessing materiality of individual datapoints currently only applicable to metrics (in paragraph 34 of ESRS 1) should be extended to all MDRs, allowing undertakings to omit information on policies, actions, and targets that they determine to be not material at the individual datapoint level
  4. Strengthen cross-referencing in the framework by making it the default approach that connects entity-level MDRs with relevant topic-specific standards.
  5. Review and consolidate overlapping MDRs across standards to eliminate redundancy and align with IFRS S1 by adopting identical wording and metrics where both frameworks address the same matters.[27]

This approach would maintain comprehensive reporting while significantly reducing the burden of redundant disclosures, particularly for companies with integrated sustainability frameworks.

Maintaining the right balance

While streamlining disclosure requirements is essential, we emphasize that any simplification efforts should maintain a careful balance between quantitative and qualitative information. EFRAG should preserve value-added qualitative disclosures that provide context around policies and actions, while reducing excessive process-oriented requirements that add limited decision-useful information.[28] Additionally, it is important to us that during this simplification process an appropriate balance is maintained between environmental, social, and governance disclosure requirements.[29]

For example, on Climate Transition Planning (ESRS E1): Disclosure Requirement E1-6 requires quantitative GHG emissions reporting across scopes 1, 2, and 3, while E1-1 requires qualitative information on transition plans.[30] NBIM Climate Change Expectations document encourages companies to not only disclose emissions data but also explain how climate considerations are integrated into corporate strategy.[31] Without this strategic context, emissions targets lack the information investors need to assess value creation potential. Any simplification of climate-related disclosures should preserve this balance, focusing on streamlining excessive process descriptions while retaining the strategic context that gives meaning to the quantitative metrics.

Likewise, on Human Capital Management (ESRS S1): Disclosure Requirement S1-6 requires quantitative workforce metrics including "key characteristics of employees in its own workforce" with data on composition, diversity and turnover, while S1-7 requires qualitative information on talent development approaches for non-employees.[32] NBIM's Human Capital Expectation document encourages companies to provide both data on workforce composition and explanations of their human capital development strategies.[33] Either type of disclosure alone would provide an incomplete picture.

On Governance (ESRS G1): Disclosure Requirement G1-1 requires qualitative disclosures on business conduct policies and corporate culture, while subsequent requirements such as G1-4, require quantitative data on incidents of corruption or bribery.[34]  NBIM's Anti-Corruption Expectation document states that companies should "publicly disclose their anti-corruption policies and processes, including how they deal with incidents" and that "performance reporting should, where appropriate, use metrics that enable year-on-year comparison."[35] This balanced approach is essential for investors to properly assess business conduct and governance effectiveness.

Granularity reduction

The revised ESRS should ensure that disclosure requirements are not excessively granular, as this can create a significant reporting burden without providing proportionate benefits for users. A more focused approach prioritizing material metrics would enhance decision-usefulness while achieving meaningful simplification. We recommend EFRAG ensure strong engagement with report users, particularly investors, throughout the revision process to identify which detailed requirements truly add value.

For example, ESRS E4 (Biodiversity and Ecosystems) Disclosure Requirement E4-2, AR 17 requires excessive reporting on third-party standards used in biodiversity policies. Amongst other disclosures, companies must report whether standards are "objective and achievable based on a scientific approach to identifying issues"[36] and "developed or maintained through a process of ongoing consultation with stakeholders with balanced input from all relevant stakeholder groups."[37] They must also disclose if standards " encourage a step-wise approach and continuous improvement"[38] and are " verifiable through independent certifying or verifying bodies."[39] This creates an administrative burden focused on process details rather than substantive biodiversity outcomes, with limited proportional benefit for users of sustainability information.

Similarly, ESRS E3 (Water and Marine Resources) Disclosure Requirement E3-4 mandates water consumption reporting with multiple breakdowns. Amongst other disclosures, companies must report "total water consumption in m³," "total water consumption in m³ in areas at water risk, including areas of high-water stress" and "total water stored and changes in storage in m³".[40] For companies operating across numerous watersheds, this creates significant data collection challenges without commensurate analytical insight.[41]

Most relevant data points

As a matter of principle, we find disclosures aligned with IFRS to be most relevant, as they facilitate global comparability and consistency while specifically addressing the information needs of investors. We have emphasized many of these disclosures in our expectation documents, which outline the sustainability information we consider essential for evaluating long-term value creation potential.  

For example, in the cross-cutting standards that apply to all companies (ESRS 2), we find particular value in disclosure requirements that align with IFRS S1, our expectation[42] documents and position papers[43]:

Likewise, in ESRS E1 (Climate Change), which is a special status materiality-dependent topical standard, we find particular value in disclosure requirements that align with IFRS S2, industry-specific SASB metrics, our expectation documents and position papers:

While we value the examples of the most relevant disclosures we have provided here and, in the appendix,[53] we believe there is significant scope to further simplify their implementation requirements without compromising the quality of information provided to users.

We appreciate EFRAG’s willingness to consider our perspective and remain at your disposal should you wish to discuss these matters further.

Yours sincerely

 

 

 

 

Carine Smith Ihenacho                                                          Dr Shilpi Nanda

Chief Governance and Compliance Officer                             Policy Advisor

 

 

 

 

 

 

 

[1] The appendix further contains examples to supplement the consultation.

[2] This consultation additionally recommends consolidating overlapping disclosure requirements and reducing granularity within ESRS. These recommendations make it practically feasible to align ESRS wording and metrics with ISSB standards on same sustainability matters. See for example: appendix, section 2, examples for consolidating overlapping MDRs.

[3] ESRS E1 (Climate Change), Disclosure Requirement E1-8 – Internal carbon pricing, paragraph 62.

[4] ESRS E1 (Climate Change), Disclosure Requirement E1-8 – Internal carbon pricing, paragraph 63(c).

[5] IFRS S2, paragraph 29(f).

[6] ESRS S1 (Own Workforce) Disclosure Requirement S1-14 - Health and safety metrics, paragraph 88.

[7] ESRS S1 (Own Workforce), Disclosure Requirement S1-14 – Health and safety metrics, Application Requirement (AR) 89 for computing the rate of work-related injuries.

[8] Sustainability Accounting Standards Board (SASB)’s Metals & Mining Industry Standard, EM-MM-320a.1.

[9] For more examples, see appendix, section 1.

[10] See ESRS 1, Disclosure Requirement 1.2 - Reporting areas and minimum content disclosure requirements on policies, actions, targets and metrics, paragraph 12.

[11] For examples, see appendix, section 2, examples of repetitive governance disclosures.

[12] ESRS S1 (Own Workforce), Disclosure Requirement S1-2 – Processes for engaging with own workforce and workers' representatives about impacts, AR 18: “When describing what function or role has operational responsibility for such engagement and/or ultimate accountability, the undertaking may disclose whether this is a dedicated role or function or part of a broader role or function, and whether any capacity building activities have been offered to support the staff to undertake engagement. If it cannot identify such a position or function, it may state that this is the case. This disclosure could also be fulfilled by making reference to information disclosed according to ESRS 2 GOV-1 The role of the administrative, management and supervisory bodies.”

[13] For examples, see appendix, section 2.

[14] For examples, see appendix, section 2.

[15] For instance, a food manufacturing company using Rainforest Alliance certified cocoa would face significant duplication challenges under the current ESRS structure. This single certification simultaneously addresses climate, biodiversity, pollution, and social aspects, yet under the current framework, it must be reported multiple times: Under ESRS E1 (Climate Change), Disclosure Requirement E1-4, paragraph 34, the company would report targets related to the percentage of Rainforest Alliance certified cocoa sourced, as part of their overall GHG emissions reduction strategy. Under ESRS E4 (Biodiversity), Disclosure Requirement E4-4, paragraph 32, it would report the same certification targets as measures to protect and restore ecosystems. Under ESRS S2 (Workers in Value Chain), Disclosure Requirement S2-5, paragraph 39, the company would again report the identical certification targets as metrics for ensuring fair labor practices. Meanwhile, SASB's Food & Beverage Processed Foods standard takes a more streamlined approach, requiring simply the "percentage of food ingredients sourced that are certified to third-party environmental and/or social standards" (FB-PF-430a.1), allowing companies to report this information once in a consolidated manner. In such cases, companies would benefit from consolidating these overlapping disclosure requirements at the entity level, and only supplementing with topic-specific targets and metrics where they provide additional material information.

[16] Minimum Disclosure Requirements (MDRs) are established in ESRS 2, section 4.2 for policies (MDR-P) and actions (MDR-A), and section 5 for metrics (MDR-M) and targets (MDR-T). See ESRS 1, Disclosure Requirement 1.2 - Reporting areas and minimum content disclosure requirements on policies, actions, targets and metrics, paragraph 13.

[17] While optional cross-referencing between sections is allowed, this is not the default option and so adds complexity by requiring navigation between interconnected standards.

[18] ESRS 2, Minimum Disclosure Requirement – Policies MDR-P – Policies adopted to manage material sustainability matters, paragraph 65.

[19] ESRS E1, Disclosure Requirement E1-2 – Policies related to climate change mitigation and adaptation, paragraph 24: “The disclosure required by paragraph 22 shall contain the information on the policies the undertaking has in place to manage its material impacts, risks and opportunities related to climate change mitigation and adaptation in accordance with ESRS 2 MDR-P Policies adopted to manage material sustainability matters.”

[20] ESRS E1, Disclosure Requirement E1-2 – Policies related to climate change mitigation and adaptation, paragraph 25.

[21] ESRS S1, Disclosure Requirement S1-1 – Policies related to own workforce, paragraph 19: "The disclosure required by paragraph 17 shall contain the information on the undertaking's policies to manage its material impacts, risks and opportunities related to its own workforce in accordance with ESRS 2 MDR-P Policies adopted to manage material sustainability matters. In addition, the undertaking shall specify if such policies cover specific groups within its own workforce or all of its own workforce."

[22] ESRS S1, Disclosure Requirement S1-1 – Policies related to own workforce, paragraphs 19-24 requires specific workforce policy disclosures.

[23] ESRS S2, Disclosure Requirement S2-1, paragraph 16: “The disclosure required by paragraph 14 shall contain the information on the undertaking’s policies to manage its material impacts, risks and opportunities related to value chain workers in accordance with ESRS 2 MDR-P Policies adopted to manage material sustainability matters. In addition, the undertaking shall specify whether such policies cover specific groups of value chain workers or all value chain workers.”

[24] ESRS S2 Disclosure Requirement S2-1, paragraphs 17-19 add value chain worker-specific policy elements.

[25] See appendix, section 2, examples of repetitive MDRs.

[26] ESRS 1, Disclosure Requirement 3.2 - Material matters and materiality of information, paragraph 34 states: "When disclosing information on metrics for a material sustainability matter according to the Metrics and Targets section of the relevant topical ESRS, the undertaking: (a) shall include the information prescribed by a Disclosure Requirement if it assesses such information to be material; and (b) may omit the information prescribed by a datapoint of a Disclosure Requirement if it assesses such information to be not material and concludes that such information is not needed to meet the objective of the Disclosure Requirement."

[27] For examples, see appendix, section 2, examples for consolidating overlapping MDRs.

[28] For examples, see appendix, section 3, examples of excessively process-oriented qualitative disclosures.

[29] Tax is an area that should be considered for inclusion within governance disclosures, particularly country-by-country reporting of economic value generation and tax payments. NBIM Tax and Transparency Expectations also reiterate this viewpoint: "Multinational enterprises should publish country-by-country breakdowns of how and where their business model generates economic value, where that value is taxed, and the amount of tax paid as a result." See Tax and transparency expectation of companies | Norges Bank Investment Management.

[30] ESRS E1 (Climate Change), Disclosure Requirement E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions, paragraphs 44 to 55; ESRS E1 (Climate Change), Disclosure Requirement E1-1 – Transition plan for climate change mitigation, paragraphs 14 to 17.

[31] 2025 Climate action plan | Norges Bank Investment Management.

[32] ESRS S1 (Own Workforce), Disclosure Requirement S1-6 – Characteristics of the undertaking’s employees, paragraph 48 to 52; ESRS S1 (Own Workforce), Disclosure Requirement S1-7 – Characteristics of non-employees in the undertaking’s own workforce, paragraph 53 to 57.

[33] Human capital management | Norges Bank Investment Management.

[34] ESRS G1 (Business Conduct), Disclosure Requirement G1-1– Business conduct policies and corporate culture, paragraphs 7 to 11; ESRS G1 (Business Conduct), Disclosure Requirement G1-4 – Incidents of corruption or bribery, paragraphs 22 to 26.

[35]Anti-corruption | Norges Bank Investment Management.

[36] ESRS E4 (Biodiversity and Ecosystems) Disclosure Requirement E4-2 - Policies related to biodiversity and ecosystems, AR 17a.

[37] ESRS E4 (Biodiversity and Ecosystems) Disclosure Requirement E4-2 - Policies related to biodiversity and ecosystems, AR 17b.

[38] ESRS E4 (Biodiversity and Ecosystems) Disclosure Requirement E4-2 - Policies related to biodiversity and ecosystems, AR 17c.

[39] ESRS E4 (Biodiversity and Ecosystems) Disclosure Requirement E4-2 - Policies related to biodiversity and ecosystems, AR 17d.

[40] ESRS E3 (Water and Marine Resources) Disclosure Requirement E3-4 – Water consumption, paragraph 28.

[41] For examples, see appendix, section 4.

[42] Our expectations | Norges Bank Investment Management.

[43] Position papers | Norges Bank Investment Management.

[44] NBIM Human Rights Expectations: "Companies should report the above information for supply chains and other business relationships, taking a full value-chain perspective, including downstream." See Human rights expectation of companies I Norges Bank Investment Management. NBIM Climate Change Expectations: "Companies should assess and report on their exposure to climate-related risks and opportunities in their value chain." See Climate change expectation of companies | Norges Bank Investment Management. Also see, IFRS S1, paragraphs 32-33.

[45] NBIM Corporate Sustainability Reporting Position Paper: "The board should ensure that company reporting reflects all material sustainability risks and opportunities." See Corporate sustainability reporting position paper | Norges Bank Investment Management. Also see, IFRS S1, paragraph 11.

[46] NBIM Biodiversity and Ecosystems Expectations: "Companies should set measurable goals and targets for improved management of biodiversity and ecosystems, and report on their performance against these." See Biodiversity and ecosystems expectation of companies I Norges Bank Investment Management. NBIM Climate Change Expectations: "Companies should set short-, medium-, and long-term emission reduction targets that include Scope 1, 2, and material Scope 3 emissions... Companies should report annually on progress made towards their targets." See Climate change expectation of companies | Norges Bank Investment Management. Also see, IFRS S1 paragraph 51.

[47] NBIM Human Rights Expectations: "Companies should have appropriate governance structures in place to ensure effective oversight of human rights issues." See Human rights expectation of companies I Norges Bank Investment Management.NBIM Climate Change Expectations (2023): "Board oversight: Company boards should ensure climate risks and opportunities are integrated into corporate strategy and risk management. They should be transparent on how they establish oversight by disclosing details of the associated governance structure." See Climate change expectation of companies | Norges Bank Investment Management. Also see, IFRS S1 paragraph 27(a).

[48] NBIM Climate Change Expectations: "Companies should implement remuneration and incentive structures that effectively promote good management of climate-related risks and opportunities." See Climate change expectation of companies | Norges Bank Investment Management. NBIM CEO Remuneration Position Paper: "Executive remuneration should incentivise the creation of long-term shareholder value and reflect broader environmental and social performance." See CEO remuneration position paper | Norges Bank Investment Management. Also see, IFRS S1, paragraph 27(a)(v).

[49] NBIM Climate Change Expectations: "Companies should commit to net zero by 2050 or sooner and align their activities with the objectives of the Paris Agreement." See Climate change expectation of companies | Norges Bank Investment Management. Also see, IFRS S2, paragraph 33(h) and industry-specific SASB metrics such as EM-EP-110a.3 (Oil & Gas Exploration & Production).

[50] NBIM Climate Change Expectations: "Companies should disclose how their capital allocation aligns with their emission reduction plans and the Paris Agreement." See Climate change expectation of companies | Norges Bank Investment Management.  Also see, IFRS S2, paragraph 29(e) and industry-specific SASB metrics such as EM-EP-420a.3 (Oil & Gas Exploration & Production).

[51] NBIM Climate Change Expectations: "Companies should set science-based interim emission reduction targets that cover scope 1, scope 2 and material scope 3 emissions, consistent with net zero by 2050." See Climate change expectation of companies | Norges Bank Investment Management. Also see, IFRS S2, paragraph 36(a)-(b) and industry-specific SASB metrics such as IF-EU-110a.3 (Electric Utilities & Power Generators).

[52] NBIM Climate Change Expectations: "To ensure their investment decisions are consistent with their emission reduction plans, companies should implement internal carbon pricing mechanisms." See Climate change expectation of companies | Norges Bank Investment Management. Also see, IFRS S2, paragraph 29(f) and industry-specific SASB metrics such as EM-MM-110a.2 (Metals & Mining).

[53] For more examples, see appendix, section 5.

Last ned brevet og appendikset (pdf)