13 February 2023 Climate Disclosure Unit Market Conduct Division The Treasury Langton Crescent Parkes ACT 2600 Via email: climatereportingconsultation@treasury.gov.au
Dear Sir/Madam SUBMISSION – CLIMATE-RELATED FINANCIAL DISCLOSURE: CONSULTATION PAPER We appreciate the opportunity to provide comment to Treasury on the Climate-related Financial Disclosure Consultation Paper (the Consultation Paper). Pitcher Partners is an association of independent firms operating from all major cities in Australia. Firms in the Pitcher Partners network are full service firms and we are committed to high ethical standards across all areas of our practice. Our clients come from a wide range of industries and include listed and non-listed disclosing entities, large private businesses, family groups, government entities, not-for-profit entities and small to medium sized enterprises. Overall, we support the Government commitment to applying standardized climate-related financial disclosure requirements to large businesses in order to meet the growing demand for disclosure by investors. Our support is based on the following: • • • • •
Adoption of consistent standards as that developed internationally by the International Sustainability Standards Board (ISSB) with any Australian modifications determined necessary. The introduction of a phased approach for climate-related financial disclosures that first targets larger listed entities with a plan to cover more entities over time subject to exceeding certain income thresholds. Initial focus should be on listed and disclosing entities over a certain income threshold ($100 million was the threshold for the introduction of modern slavery reporting and may be an appropriate threshold to use in this case also). The disclosures would be best located as part of the material risks disclosure in the operating and financial review (applying to listed entities only) which is part of the directors’ report, rather than be included as part of the financial report. The establishment of an appropriate regulatory framework along with an organisation responsible for development and issue of the standard, preferably a sister board of the AASB and included in the oversight of the Financial Reporting Council.