In a joint representation to the Sustainability Reporting Standards Exposure Draft 1 on Climate-related disclosures, the chartered accountancy bodies expressed concerns that the proposed definition of climate-related public policy programmes – which limits company disclosures to policies with climate-related outcomes as their primary objective – was too narrow. There was a risk that policies could be scoped in or out by changing their objective, and this could lead to greenwashing, ICAEW and CIPFA explained.
Instead, they suggested broadening the scope to include all material policies that contribute to a country’s climate targets, to ensure genuine and comprehensive climate reporting. It would also make requirements more meaningful by enabling the comparison of trade-offs between different measures.
ICAEW and CIPFA warned against pausing the introduction of climate reporting, which they said would send out the “wrong signals”, and called for a phased implementation process to enable public sector entities to set up the necessary processes, upskill the workforce and to start on data collection.
Additionally, given the significant amount of ESG information which is subjective, it must be capable of being assured to drive rigour and ensure trust, the bodies said.
ICAEW and CIPFA also emphasised the critical role of government policies and regulations in achieving global emissions targets and driving positive climate change. They advocated for strong government action on climate change, reinforcing their commitment to environmental sustainability.
The bodies highlighted the importance of comprehensive climate reporting in supporting global efforts to combat climate change. They called on IPSASB to consider their recommendations to ensure that the final standard promotes transparency, accountability, and genuine progress towards climate goals.
Henning Diederichs, ICAEW Senior Technical Manager, Public Sector, said:
“Comprehensive climate reporting is an essential part of sustainability work and it’s important that the final standard promotes transparency, accountability and genuine progress.
“We are concerned that the current narrow scope of climate-related disclosures could lead to greenwashing, and instead we propose that all material policies are included to provide a more accurate and comprehensive view of a country’s climate activity. This will not only enhance the credibility of public sector reporting, but also support informed decision-making and foster greater trust among stakeholders.
“Climate reporting is not easy for the private sector and will be equally challenging for the public sector, but it is in the public interest to see the reporting on major policies that impact our climate. We will all need to work together to upskill the workforce to meet these challenges, but IPSASB should put a marker down to show what the public sector should be aiming for.”
Amit Verma, CIPFA Sustainability Policy Manager, said:
“CIPFA supports the inclusion of public policy programmes in climate-related reporting but is concerned that restricting disclosures to only climate-related policies could lead to greenwashing. This narrow approach focuses solely on policies with climate outcomes as their primary objective, reducing transparency around policies that, while aimed at other goals—such as economic growth—may still have significant climate impacts.
“We urge the IPSASB to broaden the scope to include all material policies that contribute to a jurisdiction’s climate goals. A more comprehensive approach would provide a clearer picture, capturing both positive and negative climate impacts, as well as the trade-offs involved. Expanding the scope will enhance transparency, better meet user needs, and reduce the risk of greenwashing in public sector climate reporting.”
ENDS
Notes to editors:
About CIPFA
The Chartered Institute of Public Finance and Accountancy (CIPFA) is a global leader in public financial management, dedicated to improving public services and governance through innovative research and practical solutions.
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