Open letter to the Chair of the IFRS Foundation Trustees

Posted by CHARLES CHO - Oct 21, 2020

Last week, under the initiative and leadership of Carol Adams, Professors of Accounting conducting research in the field of sustainability accounting and reporting and Editors of accounting journals that publish this research wrote to the Chair of the IFRS Foundation Trustees in light of the IFRS Foundation’s Consultation Paper on Sustainability Reporting.

As a signatory, I am reproducing the letter on this blog (also attached as PDF and available online here as well).

* Note that the letter has now been updated with supporting references (which are separately posted here).


To: Erkki Liikanen, Chair, IFRS Foundation Trustees

From:  Professors of Accounting conducting research in the field of sustainability accounting and reporting and Editors of accounting journals that publish this research

Date:  15th October 2020 

Open Letter regarding the IFRS Foundation’s Consultation Paper on Sustainability Reporting 

We write to you as Professors of Accounting researching in the field of sustainability accounting and reporting to summarise key findings from independent academic research.  We do not write to give our support or otherwise to your proposal to establish a Sustainability Standards Board (SSB), or to address in detail each consultation question.

Signatories to this letter include Editors of the key accounting journals publishing research in this field, the Accounting, Auditing and Accountability Journal, Accounting Forum, Accounting Organizations and Society, Critical Perspectives on Accounting, the Sustainability Accounting, Management and Policy Journal and the Social and Environmental Accountability Journal. Together these journals have published a substantial volume of rigorous qualitative and quantitative research into sustainability (social and environmental) accounting and reporting over more than three decades.

We are seriously concerned about assertions made in your Consultation Paper and other reports informing your proposals including those of Accountancy Europe and the World Economic Forum with the Big 4. Your proposals lack adequate evidence-based justification.

We are concerned that there has been little or no engagement with the extensive body of published accounting research on the topic of sustainability accounting and reporting and note that your informal engagements have not included academics (para 4 of your consultation paper).  

Findings of independent academic research

Independent academic research finds that:

  • Traditional corporate reporting, through what it counts and what it leaves as invisible, has led to significant environmental and human rights abuses and greater inequality between developed and lesser developed countries (Adams and Harte, 1998; 2000; Adams and McPhail, 2004; Antonini et al., 2020; Bebbington et al., 2014; Burchell et al., 1985; Gray et al., 1996; 2014; Gray, 2006; 2010; Hopwood, 2009; McPhail and Adams, 2016; Milne, 1996; Russell and Thomson, 2009; Schaltegger and Burritt, 2000; Sinkovics, et al., 2016; Williams and Adams, 2013).
  • Sustainability accounting and reporting practices have either a significant positive or significant detrimental impact on the future well-being of the planet and its people, depending on their purpose and design (Adams, 2004; 2017; Adams et al., 2016; Bebbington and Larrinaga, 2014; Bebbington et al., 2020; Contrafatto and Burns, 2013; Gray, 2006; 2010; Narayanana and Adams, 2017; Qian and Schaltegger, 2017).
  • A significant number of investors ignore climate change and other sustainable development risks that have an impact on long term value creation (Campbell and Slack, 2011; Pellegrino and Lodhia, 2012; Slack and Tsalavoutas, 2018; Solomon et al., 2013).
  • Corporate and investor know-how being under-developed and resourcing of their responses to sustainable development issues being insufficient to meet the complexity of the challenge (Adams, 2017; Adams and McNicholas, 2017; Bebbington, et al., 2020; Slack and Campbell, 2016).
  • A profit and financial materiality focus leads sustainability reporting to make a negative impact on or reduced contribution to sustainable development (Adams, 2015; 2017; Michelon et al., 2020a; 2020b; O’Dwyer and Unerman, 2020; Schaltegger and Burritt, 2018; Schneider et al., 2017; Unerman et al., 2018).
  • Significant impediments to high quality, transparent sustainability reporting include:

    • Its largely voluntary nature (Adams, 2002; 2004; Adams and Kuasirikun, 2000; Cho et al., 2010; 2015a; 2018; Michelon et al., 2015);
    • Where mandatory, being mostly unenforced (Adams et al., 1995; Bebbington et al., 2012; Chauvey et al., 2015; Peters and Romi, 2013; Senn and Giordano-Spring, 2020);
    • Lack of disclosures on management approach, strategy (including long term targets), governance oversight and governing body accountability that facilitate the integration of sustainable development issues into decision making (Adams et al., 2020; O’Dwyer and Humphrey, 2020);
    • Approaches to materiality that significantly narrow the identification of sustainable development issues that come under corporate purview (Adams, 2004; Antonini et al., 2020; O’Dwyer and Humphrey, 2020; Rodrigue, 2014; Rodrigue et al. 2015);
    • External assurance engagements tending to be limited in scope to quantified indicators due to cost concerns and assurance provider conservatism (particularly by the Big 4) (Adams and Evans, 2004; Michelon et al., 2019; O’Dwyer et al., 2005; 2011);
    • Lesser developed countries lacking the skills and resources to comply with and enforce disclosure requirements (Abayo et al., 1993; Albu et al., forthcoming; Belal and Cooper, 2011; Lodhia, 2003; Dissanayake et al., forthcoming; Tilt et al., forthcoming);
    • National governments being slow to respond to the scientific evidence concerning impact of organisations on sustainable development issues and hence slow to implement regulation of the private sector (Albu et al., forthcoming; Bebbington et al., 2012; Chauvey et al., 2012; Cho et al., 2013; Lodhia, 2012).
  • Different regions/ countries facing differing social and environmental sustainability issues and hence having different priorities (Adams, 2017; Larrinaga, et al., 2020; Luque-Vílchez and Larrinaga, 2016).
  • Key drivers of sustainability reporting are a desire to minimise short term profit variations, gain stakeholder approval and enhance corporate reputation (particularly after reputation damaging incidents) (Adams and Whelan, 2009; Bebbington et al., 2008; Birkey et al., 2016; Blanc et al., 2019; Cho, 2009; Cho et al. 2012; 2014; 2015b; Patten; 1992, Arora and Lodhia, 2017).
  • The longest standing sustainability reporting standard setter, the Global Reporting Initiative, has by far the greatest number of users.  Multi-stakeholder input to the GRI Standards, and hence reputation amongst stakeholders, is a key reason for corporate take-up of the GRI Standards (KPMG, 2020).

Consultation Paper proposals that are inconsistent with research findings

Your proposals not only fail to be cognisant of this body of research evidence, but overall will exacerbate the lack of corporate and investor responsiveness to sustainable development issues and accountability thereon.  Further, a number of the above findings refute assertions in your Consultation Paper.   We are particularly concerned about the following unsupported assumptions and statements in the Consultation Paper:

  • Its claim that establishing an additional sustainability reporting standard setting body will lead to a reduction in the total number of global standard setting bodies.
  • Its assumption (eg para 28) that stakeholders speak with one mind on the desired outcomes of sustainability reporting.  They do not. Stakeholder expectations are diverse and sometimes conflicting.
  • Its assertion (paragraphs 50-51) that anything other than an investor-oriented approach to materiality would increase complexity and delay standard adoption.  There is no evidence for either assertion.
  • The proposal (paragraphs 50-51) to begin with one purpose and conceptual framework and then switch to another will reduce complexity.  We believe this will add complexity and render early standards not fit for purpose.  A holistic evidence-based approach would be more relevant, more insightful and more impactful for dealing with sustainability issues.
  • Your assertion that issues with the scope and take up of assurance relate to “difficulties of setting out qualitative sustainability-related disclosure requirements” (para 52).  This ignores other key limitations on assurance – see above.  

We call for an alternative approach to that you propose.  The definition of materiality (together with the other Fundamental Concepts) in the SDGD Recommendations (from the perspective of value creation for organisations and society and impact on sustainable development) was informed by academic research, was the outcome of a documented consultation and is a suitable starting point. 

We urge you not to make decisions on a way forward without consulting and being informed by 30 years of significant and validated sustainability research published by our specialist research communities in this field.  The well-being of future generations is in your hands.  


Professor Carol Adams, CA, Professor of Accounting, Durham University Business School, UK and Swinburne Business School, Australia. Founding Editor and Editor-in-Chief, Sustainability Accounting, Management and Policy Journal (Contact for correspondence

Professor Marcia Annisette, FCCA, CPA, CGA, Professor of Accounting, Schulich School of Business, York University, Canada. Co-Editor-in-Chief, Accounting Organizations and Society.

Professor Charles H. Cho, CPA, CGA, Professor of Accounting and Erivan K. Haub Chair in Business & Sustainability, Schulich School of Business, York University, Canada. Editor, Accounting Forum.

Professor Christine Cooper, Professor of Accounting, University of Edinburgh Business School, UK. Co-Editor-in-Chief, Critical Perspectives on Accounting.

Professor Massimo Contrafatto, Professore Associato di Economia Aziendale, Università di Bergamo, Italy.

Professor James Guthrie, AM, Distinguished Professor of Accounting, Macquarie Business School, Macquarie University, Australia. Founding Editor and Editor-in-Chief, Accounting, Auditing and Accountability Journal.

Professor Katsuhiko Kokubu, Professor of Accounting, Graduate School of Business Management, Kobe University, Japan. Editor-in Chief, Japan Forum of Business and Society Annals.

Professor Matias Laine, Professor of Accounting, Tampere University, Finland.

Professor Carlos Larrinaga, Catedrático de Economía Financiera y Contabilidad, Universidad de Burgos, Spain.

Professor Sumit Lodhia, CPA, CA, Professor of Accounting, UniSA Business, University of South Australia, Australia.  Editor, Accounting Forum.

Professor Giovanna Michelon, Professor of Accounting, University of Bristol, UK.  Editor, Accounting Forum.

Professor Markus J. Milne, FCPA, Professor of Accounting, UC Business School, University of Canterbury, New Zealand.

Professor Brendan O'Dwyer, CAI, FCA, Professor of Accounting, Alliance Manchester Business School, UK and University of Amsterdam Business School, the Netherlands.

Professor Lee Parker, FCPA, CA, Distinguished Professor of Accounting, RMIT, University Australia and Professor of Accounting, University of Glasgow, UK.  Founding Editor and Editor-in-Chief, Accounting, Auditing and Accountability Journal.

Professor Dennis M. Patten, CPA, Distinguished Professor of Accounting, Illinois State University, United States.

Professor Michelle Rodrigue, CPA, CA, Professor of Accounting, School of Accounting, Université Laval, Canada. Joint Editor, Social and Environmental Accountability Journal.

Professor Stefan Schaltegger, Professur für Nachhaltigkeitsmanagement, Leuphana Universität Lüneburg, Germany.

Professor Carol Tilt, FCPA, CA, Professor of Accounting, UniSA Business, University of South Australia. Australia.  Editor, Accounting Forum.

Professor Helen Tregidga, Professor of Accounting, School of Business and Management, Royal Holloway, University of London, UK. Joint Editor, Social and Environmental Accountability Journal.



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