Summary of Differences between IFRS Sustainability Disclosure Standards and the SSBJ Exposure Drafts
Secretariat of the Sustainability Standards Board of Japan (SSBJ)
Introduction
Following the establishment of the International Sustainability Standards Board (“ISSB”), the Sustainability Standards Board of Japan (“the SSBJ”) was established in July
2022 to develop Sustainability Disclosure Standards to be applied in Japan and to contribute to the development of international sustainability disclosure standards.
On March 29, 2024, the SSBJ issued the following three Exposure Drafts of the Sustainability Disclosure Standards (hereinafter collectively referred to as “the SSBJ EDs”):
1
2
3

Universal Sustainability Disclosure Standard Exposure Draft “Application of the Sustainability Disclosure Standards” (hereinafter referred to as “theApplication ED”)
Theme-based Sustainability Disclosure Standard Exposure Draft No. 1 “General Disclosures” (hereinafter referred to as “the General ED”)
Theme-based Sustainability Disclosure Standard Exposure Draft No. 2 “Climate-related Disclosures” (hereinafter referred to as “the Climate ED”)

The SSBJ EDs do not prescribe the scope of companies that would be required to apply the sustainability disclosure standards issued by the SSBJ (hereinafter referred to as
the “the SSBJ Standards”). However, the SSBJ developed the Exposure Drafts, following the direction indicated by the Financial Services Agency that the scope of companies
that would be required to apply the SSBJ Standards should be those companies which center their business on constructive dialogue with global investors (all or a portion ofcompanies listed on the Prime Market of the Tokyo Stock Exchange (TSE)). The SSBJ Standards can also be applied by companies other than those listed on the Prime Marketof the TSE (for example, for companies subject to laws and regulations other than the Financial Instruments and Exchange Act and required to provide sustainability-related
financial disclosures, or for companies that prepare sustainability-related financial disclosures on a voluntary basis). However, it should be noted that the SSBJ EDs were notdeveloped under the assumption that these companies would apply the SSBJ Standards.
In developing high-quality and internationally consistent sustainability disclosure standards, the SSBJ concluded that it would be useful for market participants to align the SSBJ
Standards with the ISSB’s IFRS Sustainability Disclosure Standards. Accordingly, the SSBJ decided to incorporate all requirements in the IFRS Sustainability Disclosure Standards(namely, IFRS S1 “General Requirements for Disclosure of Sustainability-related Financial Information” and IFRS S2 “Climate-related Disclosures”) and to add, when considerednecessary, any jurisdiction-specific alternatives the entity can choose to apply.
The SSBJ proposes to add some jurisdiction-specific alternatives under the following assumptions:

If a company chooses not to apply any of the jurisdiction-specific alternatives, it is intended that disclosures prepared in accordance with the SSBJ Standards will also
result in being prepared in accordance with the IFRS Sustainability Disclosure Standards.
If a company chooses to apply the jurisdiction-specific alternatives, disclosures prepared in accordance with the SSBJ Standards do not always result in noncompliance with the IFRS Sustainability Disclosure Standards; the disclosures prepared in accordance with the SSBJ Standards may or may not result in compliancewith the IFRS Sustainability Disclosure Standards.

1

The SSBJ also proposes to add some jurisdiction-specific requirements that are not included in the IFRS Sustainability Disclosure Standards. It is intended that the companies
preparing disclosures for these additional requirements would not be required to obtain additional information beyond the information obtained in the process of preparing disclosuresin accordance with IFRS Sustainability Disclosure Standards.
The objective of this document is to explain the differences between IFRS Sustainability Disclosure Standards and the SSBJ EDs. It should be noted that this document was
prepared by the Secretariat of the SSBJ for the convenience of the readers of the SSBJ EDs and was not discussed nor approved by the SSBJ.
Classification of differences
This document classifies the differences between the IFRS Sustainability Disclosure Standards and the proposals in the SSBJ EDs as follows:
I.

II.

Requirements that permit treatments that are different from the requirements of the IFRS Sustainability Disclosure Standards ·············································· 3(1) Alternatives that companies may choose to apply in lieu of the requirements of the IFRS Sustainability Disclosure Standards ········································ 3(2) Items that specify treatments when laws and regulations that require or permit disclosures in accordance with the SSBJ Standards provide specificrequirements ············································································································································································ 8(3) Items that specify treatments when the SSBJ Standards are applied voluntarily ······························································································· 9Requirements that are not included in the IFRS Sustainability Disclosure Standards ······························································································ 122

Ⅰ.

Requirements that permit treatments that are different from the requirements of the IFRS Sustainability Disclosure Standards(1) Alternatives that companies may choose to apply in lieu of the requirements of the IFRS Sustainability Disclosure Standards
Requirements
Proposals in the SSBJ EDs1 2
in the IFRS Sustainability Disclosure Standards
1. Sources of Guidance
An entity shall refer to and consider the applicability
An entity shall refer to and consider the applicabilityof the disclosure topics in the SASB Standards. of the disclosure topics in the SASB Standards (last(S1.55(a))
revised in December 2023) issued by the IFRSFoundation. (paragraph 45 of the Application ED)
If the IFRS Foundation makes revisions to the SASB
Standards, an entity may refer to and consider theapplicability of the revised SASB Standards in lieu of
the SASB Standards (last revised in December 2023).
(paragraph 46 of the Application ED)
In the absence of an IFRS Sustainability Disclosure
In the absence of a sustainability disclosure standard
Standard that specifically applies to a sustainability- issued by the SSBJ that specifically applies to a
related risk or opportunity, an entity shall apply sustainability-related risk or opportunity, an entity shalljudgement to identify information. (S1.57)
apply judgement to identify information. (paragraph 53
In making the judgement described in paragraph 57, of the Application ED)
an entity shall refer to and consider the applicability of
In making the judgement described in paragraph 53,
the metrics associated with the disclosure topics an entity shall refer to and consider the applicability ofincluded in the SASB Standards. (S1.58(a))
the metrics associated with the disclosure topics
included in the SASB Standards (last revised in
December 2023). (paragraph 54 of the Application ED)
If the IFRS Foundation makes revisions to the SASB
Standards, an entity may refer to and consider theapplicability of the revised SASB Standards in lieu of
the SASB Standards (last revised in December 2023).
(paragraph 55 of the Application ED)
An entity shall identify the industry(s) specified in the
An entity shall disclose the industry(s) specified in
IFRS Sustainability Disclosure Standards, the SASB the SSBJ Standards, the SASB Standards or otherStandards or other sources of guidance relating to a sources of guidance relating to a particular industry(s)particular industry(s) that the entity has applied in that the entity has applied in preparing its sustainabilitypreparing its sustainability-related financial disclosures, related financial disclosures, including in identifying
including in identifying applicable metrics. (S1.59(b))
applicable metrics. (paragraph 62 of the Application
ED)
1
2

Descriptions
The SSBJ EDs clarify that “the SASB Standards”
refer to the SASB Standards last revised in December
2023.
Whenever the IFRS Foundation makes revisions to
the SASB Standards, it would be necessary for the SSBJ
to both discuss the contents of the revisions and makeavailable the Japanese translation of those revised
SASB Standards. It is assumed that, if the IFRSFoundation makes revisions to the SASB Standards, the
SSBJ will discuss the contents of the revisions and,following its due process, amend the SSBJ Standards to
update the reference to the SASB Standards to the latest
version.
At the same time, based on the needs heard fromconstituents, the Application ED proposes to permit anentity to refer to and consider its applicability based on
the revised SASB Standard (in the original Englishtext). (paragraph BC74 of the Application ED)

The English translation of specific paragraphs in the SSBJ EDs in this document are provided by the Secretariat of the SSBJ for information purposes only.
The English translation of the SSBJ EDs provided by the Secretariat of the SSBJ for reference. Underline added by the Secretariat of the SSBJ for emphasis.

3Requirementsin the IFRS Sustainability Disclosure Standards

Proposals in the SSBJ EDs1 2

Descriptions

The SASB Standards issued by the IFRS Foundation
include the revised SASB Standards that an entity has
chosen to refer to and consider for applicability.
(paragraph 63 of the Application ED)
2. Reporting PeriodAn
entity’ssustainability-related
financialAnentity’ssustainability-related
financialdisclosures shall cover the same reporting period as the disclosures shall cover the same reporting period as therelated financial statements. (S1.64)
related financial statements.
However, if paragraph 71 of the Application ED
applies, or if the Thematic Standards issued by the SSBJ
includes specific requirements to do so, an entity mayreport information for different periods.
(paragraph 70 of the Application ED)
In measuring greenhouse gas emissions, if an entity
is subject to the Japanese Act on Promotion of Global
Warming Countermeasures and chooses to report thegreenhouse gas emissions measured under that Act, theentity shall use the latest greenhouse gas emissions datathat has been submitted to the authorities as of the dateauthorized for the issuance of the sustainability related
financial disclosures.
(paragraph 53 of the Climate ED)
If the difference between the calculation period forreporting greenhouse gas emissions and the reporting
period for sustainability-related financial disclosures(and related financial statements) exceeds one year, anentity shall disclose:(1) the fact that the difference between the calculation
period for reporting greenhouse gas emissions andthe reporting period for sustainability-related
financial disclosures (and related financial
statements) exceeds one year;(2) the calculation period for reporting greenhouse gas
emissions; and(3) if, between the end of (2) and the end of thereporting period for the sustainability-related
financial disclosures (and related financial
statements), a significant event has occurred or
there has been a significant change in
4

In principle, the requirements of the SSBJ EDs are thesame as those of the IFRS Sustainability DisclosureStandards. However, the SSBJ EDs propose exceptions
listed below.

Paragraph 53 of the Climate ED does not propose torequire adjustments or recalculations in accordance withthe “Greenhouse Gas Protocol: A Corporate Accounting
and Reporting Standard (2004)” (“the GHG Protocol(2004)”) to align the calculation period for greenhousegas emissions with the reporting period for thesustainability-related financial disclosures (and related
financial statements).
This proposal is based on the current disclosure
requirements under the Financial Instruments andExchange Act and the Japanese Act on Promotion of
Global Warming Countermeasures.
If these
requirements change, the difference between thereporting period for sustainability-related financial
disclosures (and related financial statements) and thecalculation period for greenhouse gas emissions could
be reduced or eliminated.
(paragraph BC121 of the Climate ED)

Requirementsin the IFRS Sustainability Disclosure Standards

Proposals in the SSBJ EDs1 2circumstances regarding the entity’s greenhousegas emissions, the changes and effect of such
event.
(paragraph 54 of the Climate ED)
If an entity is required to report metrics by law or
regulation in the jurisdiction in which the entity operates
and the calculation period for reporting those metrics isdifferent from the reporting period of sustainabilityrelated disclosures (and the related financial
statements), the entity may use the calculation period forreporting those metrics in reporting those metrics if, andonly if, it meets the following conditions:(1) the length of the calculation period for reporting
those metrics is the same as the length of thereporting period of sustainability-related
disclosures (and the related financial statements);(2) the entity discloses the name of the law or
regulation which requires the reporting of themetrics and the calculation period under that law
or regulation; and(3) if a significant event or significant change incircumstances related to the metrics occurs
between the end of the calculation period forreporting the metrics and the end of the reporting
periodofentity’ssustainability-related
disclosures (and the related financial statements),
the entity discloses the effects of those events orchanges in circumstances.
(paragraph 71 of the Application ED)

3. Scope 2 Greenhouse Gas Emissions
For Scope 2 greenhouse gas emissions, an entity shall
For Scope 2 greenhouse gas emissions, an entity shalldisclose its location-based Scope 2 greenhouse gas disclose its location-based Scope 2 greenhouse gas
emissions, and provide information about any emissions, and disclose either information about:contractual instruments that is necessary to inform (1) any contractual instruments that is necessary tousers’ understanding of the entity’s Scope 2 greenhouse
inform users’ understanding of the entity’s Scope 2
gas emissions. (S2.29(a)(v))
greenhouse gas emissions, if any: or(2) market-based Scope 2 greenhouse gas emissions.
(paragraphs 56 and 57 of the Climate ED)
5

Descriptions

In addition to metrics related to the greenhouse gas
emissions, certain metrics, such as those reported under
the Pollutant Release and Transfer Register (PRTR)
require the use of a calculation period that may bedifferent from the reporting period of sustainabilityrelated disclosures (and the related financial
statements). Paragraph 71 of the Application ED wasadded to permit entities use the calculation period thatwas used to report the metrics to the authorities.

Regarding (1), the requirement is the same as that in
the IFRS Sustainability Disclosure Standards.
Regarding (2), the alternative was added because,
among other reasons, it was considered that the marketbased Scope 2 greenhouse gas emissions reflect theentity’s efforts to reduce greenhouse gas emission, andthat it would be useful for primary users to disclose thisinformation together with the location-based Scope 2
greenhouse gas emissions. (paragraph BC132 of theRequirementsin the IFRS Sustainability Disclosure Standards

Proposals in the SSBJ EDs1 2

Descriptions
Climate ED)

4. Financed Emissions
For Scope 3 greenhouse gas emissions, an entity shalldisclose additional information about the entity’s
Category 15 greenhouse gas emissions or those
associated with its investments (financed emissions), if
the entity’s activities include asset management,commercial banking or insurance. (S2.29(a)(vi)(2))

A reporting entity that participates in one or more of
the following activities shall disclose additional
information about financed emissions:(1) asset management activities;(2) commercial banking activities; and(3) insurance activities(paragraphs 60 and C3 of the Climate ED)“Asset management activities” are activities tomanage investment portfolios on a commission or fee
basis for institutional, retail and high net-worth
investors.
“Commercial banking activities” are activities to
accept deposits and make loans to individuals andcorporations, and engage in lending to infrastructure,real estate and other projects.
“Insurance activities” are activities to provide bothtraditional and non-traditional insurance-related
products.
(paragraphs C4-C6 of the Climate ED)
A reporting entity may choose not to disclose
additional information about financed emissions if theentity engages in these activities and is not regulated by
the laws and regulations of the jurisdiction in which it
operates to engage in such activities. If an entity
chooses not to disclose such information, it shalldisclose that fact. (paragraph 61 of the Climate ED)

5. Climate-related Risks and Opportunities
An entity shall disclose information relevant to the
An entity shall disclose either information relevant tocross-industry metric categories of:the cross-industry metric categories of climate-related(b) climate-related transition risks—the amount and transition risks:
percentage of assets or business activities (1) the amount and percentage of assets or businessvulnerable to climate-related transition risks
activities vulnerable to climate-related transition(S2.29(b))
risks; or(2) information about the magnitude of the assets orbusiness activities vulnerable to climate-relatedtransition risks.
(paragraph 80 of the Climate ED)
6

In principle, the requirements of the Climate ED are
the same as those of IFRS S2, however, the Climate ED
proposes the additions described below.

The Climate ED defines the three activities,
considering the “Industry Description” of the activities
in the IFRS S2 “Industry-Specific Guidance”.

Entities engaging in these defined activities usuallywould be regulated if such activities are conducted inJapan.

In all of these cases, requirement (1) is the same asthat of IFRS Sustainability Disclosure Standards.
Requirement (2) is not exactly the same as that of IFRS
S2, but requires the disclosure of information thatmeets the same disclosure objective as in IFRS S2.
The requirement refers to “information about themagnitude” because, while it is desirable to disclosequantitative information, it would be appropriate topermit methods that more faithfully represent what theentity purports to represent.

Requirements
Proposals in the SSBJ EDs1 2
in the IFRS Sustainability Disclosure Standards(c) climate-related physical risks—the amount andAn entity shall disclose either information relevant topercentage of assets or business activities the cross-industry metric categories of climate-related
vulnerable to climate-related physical risks physical risks:(S2.29(c))(1) the amount and percentage of assets or businessactivities vulnerable to climate-related physicalrisks; or(2) information about the magnitude of the assets orbusiness activities vulnerable to climate-related
physical risks.
(paragraph 81 of the Climate ED)(d) climate-related opportunities—the amount andAn entity shall disclose either information relevant topercentage of assets or business activities aligned the cross-industry metric categories of climate-relatedwith climate-related opportunities (S2.29(d))
opportunities:(1) the amount and percentage of assets or businessactivitiesalignedwithclimate-related
opportunities; or(2) information about the magnitude of the assets orbusiness activities aligned with climate-related
opportunities.
(paragraph 82 of the Climate ED)
6. Remuneration
An entity shall disclose information relevant to the
An entity shall disclose information relevant to thecross-industry metric categories of:
remuneration of:(g) remuneration—the entity shall disclose:(1) if climate-related considerations are factored into(i)a description of whether and how climateexecutive remuneration, information about:related considerations are factored into(i) how to factor climate-related considerations
executive remuneration (see also paragraphinto executive remuneration;6(a)(v)); and(ii) the percentage of executive remuneration(ii) the percentage of executive management
recognized in the current period that is linked
remuneration recognised in the current period
to climate-related considerations; andthat is linked to climate-related considerations. (2) if climate-related considerations are not factored(S2.29(g))
into executive remuneration, information of thatfact.
(paragraph 87 of the Climate ED)
If climate-related considerations factored into
executive remuneration but are combined with otherconsiderations and cannot be separately identified, theentity may disclose that fact and the information
required under paragraph 87(1)(i) and (ii) of the Climate
7

Descriptions(paragraph BC171 of the Climate ED)

Paragraph 87 of the Climate ED is the same as therequirements of the IFRS Sustainability DisclosureStandards.
Because there may be cases where climate-related
considerations are factored into executive remuneration
but combined with other considerations, and climaterelated considerations cannot always be separately
identified, paragraph 88 of the Climate ED proposes topermit this alternative.
(paragraph BC189 of the Climate ED)

Requirementsin the IFRS Sustainability Disclosure Standards

Proposals in the SSBJ EDs1 2

Descriptions

ED may be provided for the combined considerations
that include the climate-related considerations.
(paragraph 88 of the Climate ED)(2) Items that specify treatments when laws and regulations that require or permit disclosures in accordance with the SSBJ Standards provide specific requirements
Requirements
Proposals in the SSBJ EDs3 4
Descriptionsin the IFRS Sustainability Disclosure Standards
1. Location of Disclosures
An entity is required to provide disclosures required
An entity shall disclose sustainability-related by IFRS Sustainability Disclosure Standards as part of financial disclosures together with its related financial
its general purpose financial reports. (S1.60)
statements.
However, an entity may choose not to disclosesustainability-related financial disclosures separatelyfrom its related financial statements if laws andregulations that require or permit disclosure inaccordance with the SSBJ Standards prohibit suchdisclosure or permit non-disclosure.
(paragraph 64 of the Application ED)
2. Reporting at the Same TimeAn entity shall report its sustainability-related
An entity shall report sustainability-related financial financial disclosures at the same time as its related disclosures at the same time as its related financial
financial statements. (S1.64)
statements in principle.
However, an entity may choose not to reportsustainability-related financial disclosures at the sametime as its related financial statements if laws andregulations that require or permit disclosures inaccordance with the SSBJ Standards prohibit suchdisclosure or permit non-disclosure.
(paragraph 69 of the Application ED)
3. Comparative information
Unless another IFRS Sustainability Disclosure
An entity shall disclose comparative information in
There is no difference between the SSBJ Standards
Standard permits or requires otherwise, an entity shall respect of the preceding period for all amounts disclosed and the IFRS Sustainability Disclosure Standards if the

3
4

The English translation of specific paragraphs in the SSBJ EDs in this document are provided by the Secretariat of the SSBJ for information purposes only.
Underline added by the Secretariat of the SSBJ for emphasis.

8Requirementsin the IFRS Sustainability Disclosure Standards
disclose comparative information in respect of thepreceding period for all amounts disclosed in thereporting period. If such information would be usefulfor an understanding of the sustainability-related
financial disclosures for the reporting period, the entity
shall also disclose comparative information for
narrative and descriptive sustainability-related financial
information. (S1.70)

Proposals in the SSBJ EDs3 4

Descriptionsin the reporting period. If such information would be Thematic Standards issued by the SSBJ prohibit touseful for an understanding of the sustainability-related disclose or permit not to disclose comparative
financial disclosures for the reporting period, the entity information in respect of the preceding period.
shall disclose comparative information for narrative anddescriptive sustainability-related financial information.
However, in either case, an entity need not disclosecomparative information for the preceding reporting
period if laws and regulations that require or permit
disclosure in accordance with the SSBJ Standards or a
specific SSBJ Standard prohibits such disclosure or
permits non-disclosure.
(paragraph 76 of the Application ED)

4. Errors
An entity shall correct material prior period errors by
An entity shall correct material prior period errors by
In Japan, laws and regulations may require therestating the comparative amounts for the prior restating the comparative amounts for the prior resubmission of financial reports for the prior period(s)period(s) disclosed unless it is impracticable to do so. period(s) disclosed unless it is impracticable to do so.
to correct prior period errors.
(S1.83)
However, if material prior period errors cannot becorrected by restating the comparative amounts for theprior period(s) disclosed in applicable law or regulationthat requires disclosure in accordance with the SSBJ
Standards, the entity shall apply the requirements of thelaws and regulations without restating the comparative
amounts.
(paragraph 90 of the Application ED)(3) Items that specify treatments when the SSBJ Standards are applied voluntarily
Requirements
Proposals in the SSBJ EDs5 6in the IFRS Sustainability Disclosure Standards
1. Location of Disclosures
An entity is required to provide disclosures required
An entity shall disclose sustainability-related by IFRS Sustainability Disclosure Standards as part of financial disclosures together with its related financial
its general purpose financial reports. (S1.60)
statements.
However, an entity may choose not to disclose
5
6

Descriptions

The English translation of specific paragraphs in the SSBJ EDs in this document are provided by the Secretariat of the SSBJ for information purposes only.
Underline added by the Secretariat of the SSBJ for emphasis.

9Requirementsin the IFRS Sustainability Disclosure Standards

Proposals in the SSBJ EDs5 6

Descriptions

sustainability-related financial disclosures together with
its related financial statements if it voluntarily discloses
sustainability-related
financialdisclosuresinaccordance with the SSBJ Standards, rather than as aresult of compliance with laws and regulations that
require or permit disclosures in accordance with the
SSBJ Standards.
(paragraph 64 of the Application ED)
2. Reporting at the Same TimeAn entity shall report its sustainability-related
An entity shall report, in principle, sustainabilityfinancial disclosures at the same time as its related related financial disclosures at the same time as its
financial statements. (S1.64)
related financial statements.
However, an entity may choose not to reportsustainability-related financial disclosures at the sametime as its related financial statements if it voluntarily
reports sustainability-related financial disclosures inaccordance with the SSBJ Standards, rather than as aresult of compliance with laws and regulations that
require or permit disclosures in accordance with the
SSBJ Standards.
(paragraph 69 of the Application ED)
3. Comparative information
Unless another IFRS Sustainability Disclosure
An entity shall disclose comparative information inStandard permits or requires otherwise, an entity shall respect of the preceding period for all amounts disclosed
disclose comparative information in respect of the in the reporting period. If such information would be
preceding period for all amounts disclosed in the useful for an understanding of the sustainability-related
reporting period. If such information would be useful financial disclosures for the reporting period, the entity
for an understanding of the sustainability-related shall disclose comparative information for narrative andfinancial disclosures for the reporting period, the entity descriptive sustainability-related financial information.
shall also disclose comparative information for
However, in either case, an entity may choose not tonarrative and descriptive sustainability-related financial disclose comparative information for the preceding
information. (S1.70)
reporting period if it voluntarily reports sustainabilityrelated financial disclosures in accordance with the
SSBJ Standards, rather than as a result of compliancewith laws and regulations that require or permit
disclosures in accordance with the SSBJ Standards.
(paragraph 76 of the Application ED)
4. Transition relief(No applicable requirements)
If an entity that has been voluntarily disclosed in
10-

There is no difference between the SSBJ Standards
and the IFRS Sustainability Disclosure Standards if theThematic Standards issued by the SSBJ prohibit todisclose or permit not to disclose comparative
information in respect of the preceding period.

In the first annual reporting period in which the SSBJRequirementsin the IFRS Sustainability Disclosure Standards

Proposals in the SSBJ EDs5 6

Descriptions

accordance with the SSBJ Standards decides to disclose
to comply with laws and regulations that require or
permit disclosure in accordance with the SSBJ
Standards, the entity may apply transitional relief for the
first annual reporting period in which the SSBJ
Standards are applied in accordance with such laws andregulations as “first annual reporting period”.
(paragraph 100 of the Application ED, paragraph 44 of
the General ED and paragraph 107 of the Climate ED)

Standards are applied under the Financial Instruments
and Exchange Act, it would be unreasonable for thescope of the transitional relief to differ depending onwhether the entity has previously voluntarily disclosed
in accordance with the SSBJ Standards. Furthermore, if
the SSBJ Standards did not provide this specific relief,
there would be a concern that entities that were actively
engaged in disclosures would be hesitant to disclose,
and the amount of information disclosed would
decrease, resulting in reduced benefits for primaryusers.
(paragraph BC169 of the Application ED, paragraph
BC65 of the General ED, and paragraph BC217 of the
Climate ED)

11

Ⅱ.

Requirements that are not included in the IFRS Sustainability Disclosure Standards

Requirementsin the IFRS Sustainability Disclosure Standards
1. Units of presentation(No applicable requirements)

Proposals in the SSBJ EDs7 8

An entity shall disclose the unit of the presentation(for example, metric tonnes of CO2 equivalent (mt(e)),
grams (g), joules (J)) in relation to the amounts reportedinsustainability-related
financialdisclosures.
(paragraph 11 of the Application ED)(No applicable requirements)
Unless otherwise specified, an entity may use units
such as thousands, millions or billions to disclose
reporting amounts if it is easier to understand theinformation and material information is not omitted or
obscured. In this case, the entity shall clearly disclose
which unit they used. (paragraph 12 of the Application
ED)
An entity shall disclose its absolute gross greenhouse
An entity shall present its greenhouse gas emissions
gas emissions generated during the reporting period, expressed as metric tonnes of CO2 equivalent (mt(e)).
expressed as metric tonnes of CO2 equivalent
However, an entity may use units such as thousand(S2.29(a)(i))
metrics tonnes (kilo tonnes (kt(e)), million metrics
tonnes (Mt(e)) or billion metrics tonnes (Gt(e)) forpresentation if absolute gross greenhouse gas emissions
for Scope 1, Scope 2 and Scope 3 disclosed inaccordance with paragraph 49 of the Climate ED arelarge, respectively.
If an entity chooses to apply this alternative, the entity
shall use the same unit for presentation to disclose thegreenhouse gas emissions for each Scope.
(paragraph 50 of the Climate ED)
2. Related financial statements
An entity shall identify the financial statements to
An entity shall identify the financial statements towhich the sustainability-related financial disclosures which the sustainability-related financial disclosuresrelate. (S1.22)
relate.
If the related financial statements are not reported in
the same document as the sustainability-related
financial disclosures, an entity shall disclose (1) how to
obtain the related financial statements and (2) the name7
8

Descriptions
Regarding reported amounts, the Application ED
proposes an additional requirement to make information
more understandable by presenting information of units.
IFRS Accounting Standards prescribe similar
requirements (paragraph 53 of IAS 1 “Presentation of
Financial Statements”).

--

The English translation of specific paragraphs in the SSBJ EDs in this document are provided by the SSBJ Secretariat for information purposes only.
Underlining was added by the Secretariat of the SSBJ for emphasis.

12

Requirementsin the IFRS Sustainability Disclosure Standards

Proposals in the SSBJ EDs7 8

Descriptionsof the accounting standards applied in preparing therelated financial statements.
(paragraph 9 of the Application ED)
3. Date of authorization for issue(No applicable requirements)

4. Applicable Law or Regulation(No applicable requirements)

5. Resilience Assessment(No applicable requirements)

An entity shall disclose the date of authorization for
Disclosure of the date of authorization for issue isissuing sustainability-related financial disclosures and required in IFRS Accounting Standards (paragraph 17
the name of the authorizing body or individual. of IAS 10 “Events After the Reporting Period”).
(paragraph 73 of the Application ED)
However, this disclosure is not required in Japanese
accounting standards (Japanese GAAP).
If an entity discloses in accordance with the SSBJ Standards subject to the requirements of laws andregulations, the entity shall disclose the name of suchlaws and regulations. If an entity discloses voluntarilyin accordance the SSBJ Standards without being
required by laws and regulations, the entity shalldisclose that fact. (paragraph 81 of the Application ED)
In principle, an entity shall assess the entity’s
resilience at each reporting period. However, an entity
may disclose based on the results of the entity’s
resilience assessment in the previous reporting period if
other Theme-based Sustainability Disclosure Standards
issued by the SSBJ do not have specific requirements,
and the entity’s resilience assessment in the reporting
period is expected to remain unchanged significantly
from the results of the entity’s resilience assessment in
the previous reporting period. (paragraph 26 of theGeneral ED)

Regarding of the frequency of the resilienceassessment, IFRS S1 is not necessarily clear as towhether an entity is required to assess its resilience ineach reporting period. On the other hand, IFRS S2
requires an entity to assess the entity’s climate resiliencein each reporting period, with additional requirements
taking into account the difficultly in applying therequirements. Similar requirements are incorporated in
the Climate ED.
(paragraph BC49 of the General ED)
The General ED proposes to require an entity toassess the entity’s resilience in each reporting period,
but to permit the entity to disclose based on the resultsof the entity’s resilience assessment in the previous
reporting period if certain criteria are met.
(paragraph BC50 of the General ED)

6. Total absolute amount of greenhouse gas emissions(No applicable requirements)
An entity shall disclose the total absolute amount ofThis requirement was added because, among other
Scope 1, Scope 2 and Scope 3 greenhouse gas reasons, it was considered that primary users would firstemissions. (paragraph 49 of the Climate ED)
obtain an understanding of the total absolute amount of13

Requirementsin the IFRS Sustainability Disclosure Standards

Proposals in the SSBJ EDs7 8

Descriptions
greenhouse gas emissions for the three Scopes and theoverall picture of the climate change risks to which anentity is exposed and then conduct a more in-depth
analysis to identify which specific scope greenhouse gas
emissions are the most prevalent and which category or
categories within Scope 3 are the most prevalent when
Scope 3 greenhouse gas emissions are large.
(paragraph BC101 of the Climate ED)

7. Measuring greenhouse gas emissions using a method other than the GHG Protocol (2004)(No applicable requirements)
If an entity chooses to measure using a method otherthan the GHG Protocol (2004), and the amount ofgreenhouse gas emissions measured using the method
other than the GHG Protocol (2004) is material, theentity shall disclose, in addition to the total amount, thedisaggregation of the amount of its greenhouse gas
emissions disclosed in accordance with paragraph 49 of
the Climate ED disaggregated in the following manner:(1) the amount of its greenhouse gas emissions
measured in accordance with the GHG Protocol(2004); and(2) the amount of its greenhouse gas emissions
measured in accordance with a method other thanthe GHG Protocol (2004).
(paragraph 52 of the Climate ED)
8. Scope 3 Greenhouse Gas Emissions
An entity shall disclose information relevant to the
An entity shall disclose the disaggregated Scope 3
cross-industry metric categories of:greenhouse gas emissions by categories relevant to the(a) greenhouse gases—the entity shall:activities of the reporting entity in accordance with the(vi) for Scope 3 greenhouse gas emissions disclosed in Scope 3 categories described in the Greenhouse Gas
accordance with paragraph 29(a)(i)(3), and with Protocol Corporate Value Chain (Scope 3) Accounting
reference to paragraphs B32–B57, disclose:
and Reporting Standard (2011). (paragraph 58 of the(1) the categories included within the entity’s measure Climate ED)
of Scope 3 greenhouse gas emissions, in accordance
However, an entity shall disclose the categories in thewith the Scope 3 categories described in the Greenhouse Greenhouse Gas Protocol Corporate Value Chain
Gas Protocol Corporate Value Chain (Scope 3) (Scope 3) Accounting and Reporting Standard (2011)
Accounting and Reporting Standard (2011)that are relevant to the reporting entity if the entity(S2.29(a)(vi)(1))
measures Scope 3 greenhouse gas emissions using amethod other than the GHG Protocol (2004) and cannot
disclose the Scope 3 greenhouse gas emissions by
14-

The disclosure of the Scope 3 greenhouse gas
emissions is required to be disaggregated by categories
because, among other reasons, it was considered that thedisclosure would allow entities to provide information
about greenhouse gas emissions related to various
activities by emission sources, which vary in nature andtime horizon.
(paragraph BC139 of the Climate ED)

Requirementsin the IFRS Sustainability Disclosure Standards

Proposals in the SSBJ EDs7 8

Descriptions

categories relevant to the activities of the reporting
entity. (paragraph 59 of the Climate ED)
9. Internal carbon prices
An entity shall disclose information relevant to theRegarding internal carbon prices:cross-industry metric categories of:(1) If an entity applies an internal carbon price in its(f) internal carbon prices—the entity shall disclose:decision-making, the entity shall disclose(i)an explanation of whether and how the entity
information about:is applying a carbon price in decision-making(i) how the entity is applying a carbon price (for(for example, investment decisions, transfer
example, investment decisions, transfer pricing
pricing and scenario analysis); andand scenario analysis); and(ii) the price for each metric tonne of greenhouse(ii) the internal carbon prices used to assess thegas emissions the entity uses to assess the costs
costs of its greenhouse gas emissions (the priceof its greenhouse gas emissions.
for each metric tonne of greenhouse gas(S2.29(f))
emissions).
(2) If an entity does not apply an internal carbon pricein its decision-making, the entity shall disclose thatfact.
(paragraph 84 of the Climate ED)
If an entity applies internal carbon prices in its
decision-making, and uses multiple internal carbon
prices in the decision-making for the same purpose (forexample, using different internal carbon prices in eachbusiness for the same investment decision purpose), theentity shall disclose each internal carbon price inapplying paragraph 84(1)(ii) of the Climate ED.
However, the entity may disclose a range (minimum andmaximum) of internal carbon prices used for the same
purpose. (paragraph 85 of the Climate ED)
If an entity applies internal carbon prices in its
decision-making and uses the internal carbon prices for
multiple purposes (for example, investment decisions,transfer pricing and scenario analysis), the entity shalldisclose the information in paragraph 84(1)(i) and (ii) of
the Climate ED for each purpose. (paragraph 86 of the
Climate ED)[End of Document]

15