Discussion Paper - The Future of Sustainability Reporting in the Bailiwick of Guernsey (July 2024)

Summary

This is a Discussion Paper issued by the Guernsey Financial Services Commission (GFSC) seeking industry input on how the Bailiwick of Guernsey should approach sustainability reporting, including possible adoption of the International Sustainability Standards Board's (ISSB) IFRS S1 and S2 standards. It summarises international developments (TCFD, ISSB, EU SFDR, UK SDRs, US SEC rules) and poses 15 questions to gather views from the finance sector; it does not itself impose binding requirements.

• Scope of discussion: Covers whether and how the Bailiwick should adopt ISSB S1 (general sustainability disclosures) and S2 (climate-related disclosures), including scope 3 emissions reporting.
• Governance ideas: Explores possible amendments to the Code of Corporate Governance to require Board consideration of environmental risks, and the concept of a firm-level 'sustainability champion'.
• Anti-greenwashing: Seeks views on introducing a general anti-greenwashing rule for the Bailiwick, similar to the UK's.
• Fund sector focus: Specifically asks how relevant ISSB standards would be for regulated investment funds, both open and closed ended.
• Publicly accountable entities: Asks stakeholders to identify which sectors or entity types in the Bailiwick should be treated as 'publicly accountable entities' subject to ISSB-consistent disclosure.

As a discussion paper, it creates no immediate legal obligations; it invites feedback that will inform future GFSC policy and possible regulatory changes on sustainability reporting.

Applies to

regulated financial services sector, licensees, investment funds (open and closed ended), asset managers

Deadlines

• 25 October 2024: Deadline for stakeholders to submit responses to the Discussion Paper via the Commission's Consultation Hub