ISSB and SASB - The Sustainability Management Wiki

Authors: Jan Sprattler
Edited by: –
Last updated: December 17, 2025

Executive summary

This article explains the role of ISSB and SASB in sustainability reporting. It highlights why global standards are needed to address systemic risks such as climate change and social inequality. The ISSB was created to provide a global baseline for sustainability disclosures, introducing IFRS S1 and IFRS S2 as core standards. SASB complements these by offering industry-specific metrics.

The literature review clarifies conceptual foundations, including materiality, transparency, and comparability. It shows how sustainability reporting evolved from voluntary frameworks to structured standards. The ISSB aims to harmonize reporting globally, reduce complexity, and improve decision-useful information for investors.

Theoretical perspectives such as Stakeholder Theory and Legitimacy Theory explain why standards matter for governance and accountability. Institutional and Regulatory Space theories reveal how political and social dynamics shape standard-setting. Disclosure Theory addresses motivations for voluntary reporting and risks like greenwashing.

Practical implementation requires readiness checks, materiality assessments, internal processes, integration into financial reporting, and continuous improvement. Companies face challenges such as resource constraints, data quality issues, and conceptual ambiguities. External assurance is becoming critical for credibility.

Overall, ISSB and SASB represent a major step toward consistent, comparable sustainability reporting. Their success depends on global adoption, interoperability with other frameworks, and effective implementation by organizations.

1 Introduction

The research foundation starts from the understanding that corporate reporting must expand its scope to include social and environmental dimensions that go beyond conventional financial statement reporting. ¹ Organisations require established standards to assess their impacts, as they operate within defined social and planetary boundaries. ² Traditional annual reports are designed to present historical financial information to investors. ³ Yet they provide little insight into how sustainability-related risks and opportunities affect a company’s financial prospects. Capital markets often fail to recognise corporate externalities because their primary objective remains centred on economic profitability and shareholder wealth. ⁴ This short-term focus produces market failures, resulting in long-term collective harm, commonly described as the “tragedy of the commons”. ³ ⁵

Sustainability standards therefore represent a direct response to environmental and social challenges that pose systemic risks to financial stability. ⁶ Climate change is widely acknowledged as both an existential threat and a systemic risk to the global financial system. ⁷ The long-term stability of economies is further endangered by resource scarcity and biodiversity loss, whose economic impacts remain systematically underestimated. ⁸ ⁹ These risks are intensified by ongoing human rights violations and social inequality, caused by neglecting basic principles such as equality, inclusion, health and safety, fair wages, and the prohibition of forced labour. ³

The relevance of this research lies in the fact that sustainability reporting standards (SRS) are designed to address “global grand challenges”6 by shaping how companies disclose information, how investors make decisions, and how organisations are held accountable to their stakeholders. From an academic perspective, ISSB Standards provide a valuable opportunity to analyse global standard-setting processes, with a focus on legitimacy, governance, and institutional dynamics. ¹ ⁴ ⁶ From a practical perspective, the standards offer a consistent framework that reduces complexity, lowers transaction costs, and enhances comparability. As a result, they strengthen market efficiency and investor trust. ³ At the same time, they aim to improve transparency, support organisations in achieving the Sustainable Development Goals (SDGs), and reduce information gaps between companies, regulators, and the wider public. ¹ ¹⁰ ¹¹

Against this background, this thesis is intended to focus on the ISSB as the most recent attempt to establish a global baseline for sustainability reporting. Particular emphasis is placed on the integration of the SASB Standards. The two standards, IFRS S1 and IFRS S2, set out the fundamental disclosure requirements, while SASB adds industry-specific metrics. ¹ ¹² Together, these frameworks aim to deliver decision-useful ESG information, improve comparability across companies and industries, and ensure assurance and credibility through standardised reporting practices. ¹

2 Literature review

2.1 Conceptual foundations

This section introduces the conceptual foundations of sustainability reporting standards (SRS). It provides the definitional and structural foundation for analysing ISSB and SASB by clarifying what constitutes a reporting standard, outlining their scope and objectives, and explaining the relevance of the IFRS S1 and S2 standards. These conceptual foundations create the framework for the subsequent historical, theoretical, and practical analysis.

2.1.1 Conceptual clarification

The conceptual basis for analysing ISSB and SASB is established by defining and discussing the concept of SRS. It aims to clarify the core characteristics of SRS and to distinguish them from other reporting-related instruments. Due to the growing global relevance of sustainability reporting for companies, policymakers and stakeholders, it is considered essential to define SRS in a consistent and precise manner. ⁷ ¹¹ Despite its increasing importance, the term “sustainability reporting standard” is used inconsistently in academic and professional contexts. This leads to conceptual ambiguity and reduces the comparability of disclosed sustainability information. ¹³ ¹⁴ In recent years, the field has been characterised by a growing number of frameworks and terminologies, often referred to as the “alphabet soup” of sustainability reporting. ¹ ⁷ ¹¹ Examples such as “Corporate Citizenship Report”, “Corporate (Social) Responsibility Report” or “Sustainable Development Report” show that there is no uniform use of terms. This fragmentation continues to influence professional practice and academic debate on sustainability disclosures. ¹⁵ ¹⁶ Against this background, the following discussion develops a coherent understanding of SRS by first addressing their main characteristics, then their content and structural elements, and finally their distinction from related instruments.

The growing importance of sustainability-related topics has also led to the development of structured reporting frameworks. These frameworks are designed to enhance the quality and reliability of ESG-related information disclosed by companies. To achieve this, sustainability reporting standards aim to promote transparency, accountability and comparability. They do so by applying materiality principles and providing clearly defined disclosure requirements. ² ¹⁰ Transparency is considered essential. Stakeholders increasingly expect companies to publish complete and reliable information on environmental and social topics. Non-financial indicators are now widely used to evaluate corporate performance beyond traditional financial figures. ¹⁷ Structured ESG reporting reduces information gaps between companies and their stakeholders. ¹⁸ However, in practice, reporting quality is still limited. Two key weaknesses are selective disclosure and a lack of explanation for how materiality is assessed. ⁷ ¹¹ The objective of accountability refers to the growing expectation that companies take responsibility for the environmental and social impacts of their operations. Stakeholders now demand that companies explain how they respond to these expectations and how they contribute to sustainable development. ¹¹ ¹⁷ Another important goal of sustainability reporting standards is to improve comparability. Yet, inconsistent terminology and differences in methodology limit the usefulness of reported data across companies and time periods. ¹⁹ A key challenge remains the lack of a common understanding of materiality. ¹⁴ This conceptual divergence reduces the effectiveness of standardisation and limits the potential for greater transparency, better reporting quality and increased investor confidence. ³ ¹³

SRS pursue their core objectives through defined content elements and structural requirements. Their main purpose is to establish a consistent method for disclosing environmental, social and governance information. These ESG topics are increasingly used to evaluate corporate performance and inform internal decisions, as well as to respond to external stakeholder expectations. ¹⁷ Historically, corporate reporting has developed from stand-alone environmental or social reports into more integrated formats. One key conceptual foundation is the “Triple Bottom Line”21 approach. It was introduced in the 1990s and suggested that companies should not only focus on profit but also on social and environmental performance. This approach, often described as “People, Planet, Profit”22 expanded the idea of value creation and contributed to the development of integrated reporting frameworks. ²⁰ ²¹ ²² The current practice shows a shift toward disclosure methods which combine multiple aspects of sustainability reporting. While many companies still prepare separate sustainability reports, other channels are increasingly used. These include, for example, the management commentary or company websites. ³ ¹³ ²² The credibility and usefulness of sustainability reporting depends on the level of standardisation. Due to many sustainability disclosures were voluntary in the past, companies developed different ways of reporting. This has led to inconsistent practices and the use of heterogeneous terminology, making it difficult to compare information across companies and sectors. ¹³ ²² Assurance constitutes another essential dimension. Materiality assessments help to decide which information is relevant. However, assurance practices are not applied consistently. As a result, it is often unclear whether the reported information is reliable and useful for decision-making. ¹⁷ Another defining element of sustainability reporting standards is their orientation towards the users of the information. Investor-focused standards prioritise financial materiality and enterprise value. In contrast, stakeholder-oriented standards also include broader societal and environmental impacts. ⁶ ¹¹ ¹³

Figure 1: Conceptual distinction between SRS and related instruments

As illustrated in Figure 1 and supported by the conceptual work of Ali et al. (2023), Hahn and Kühnen (2013), Eng et al. (2021), and Barker (2025), SRS can be understood as instruments that pursue a normative sustainability objective, follow a structured reporting process, and contain binding or increasingly mandatory disclosure requirements. ³ ¹¹ ²² ²³ These characteristics distinguish them from other instruments such as ESG ratings or voluntary principles, which typically lack one or more of these features. ESG ratings are closely linked to sustainability reporting because they rely on publicly available information to assess the sustainability performance of companies. Nevertheless, they do not provide specific guidance on how this information should be prepared or reported. Instead, they function as external assessments based on proprietary methods and therefore do not qualify as reporting standards in a strict sense. ²³ A second distinction is to be made between sustainability reporting standards and principle-based frameworks or voluntary codes of conduct. Examples of such instruments include the United Nations Sustainable Development Goals (SDGs), the United Nations Global Compact (UNGC), the Core Conventions of the International Labour Organisation (ILO) and the Guidelines for Multinational Enterprises issued by the Organisation for Economic Cooperation and Development (OECD). These initiatives reflect internationally agreed values and high-level sustainability objectives. However, they do not provide concrete guidance on how companies are supposed to report their sustainability performance. Their aim is to define broad societal expectations and encourage responsible business conduct, rather than to establish binding or standardised reporting requirements. The SDGs, for instance, serve as a global framework for the orientation of corporate sustainability strategies. However, they do not contain legally binding or standardised instructions for sustainability reporting. ⁸ In contrast, SRS are developed to offer detailed and structured guidance that enables companies to collect, organise and disclose ESG-related information in a consistent and comparable manner. ¹⁹ The following section introduces the ISSB and SASB. Their respective roles in sustainability reporting will be explained by applying the conceptual distinctions outlined above.

2.1.2 Definition and scope

The SASB has been established in 2011 with the purpose of creating sustainability reporting standards specifically designed for individual industries. ²⁴ ²⁵ Its main goal is to help publicly listed companies disclose financially material ESG information that is relevant and useful to investors. ¹⁸ The SASB Standards are structured by industry and currently cover 77 industries across 11 sectors. ²⁴ They are designed to help companies identify sustainability topics and performance metrics that are financially material within a given industry. ¹⁸ The SASB Standards are applied on a voluntary basis. This means that companies may freely decide whether and how to use them in their reporting. The standards focus on sustainability-related risks and opportunities that could reasonably affect a company’s financial position, performance or cash flows, which are essential to capital-market participants (e.g. investors, analysts, etc.). ²³ The standard-setting process originally followed a structured and evidence-based procedure. It combined empirical research with stakeholder consultation and was overseen by an independent standards board. ¹⁸ Since August 2022, the technical responsibility for the SASB Standards has been transferred to the ISSB, which is now integrating them into a globally consistent sustainability reporting framework based on IFRS. ²⁶ The ISSB was established in November 2021 by the Trustees of the IFRS Foundation, with the announcement made at COP26 in Glasgow (UN Climate Conference). ²⁶ The creation of the ISSB aimed to address the global demand for harmonized sustainability reporting across capital markets. ¹ The ISSB is considered to be a sister organisation to the International Accounting Standards Board (IASB), which is responsible for the development of globally recognized financial reporting standards. The IFRS Foundation itself has been established in 2001 with the objective to improve transparency and comparability of financial reporting and to enable well-informed investment and economic decisions. ²⁶–30

The ISSB is working on the development of sustainability disclosure standards intended to serve as global baseline for sustainability reporting. These standards are designed to align closely with traditional financial reporting systems. ¹ ⁶ In June 2023, the ISSB published its first two standards. These are IFRS S1 “General Requirements for Disclosure of Sustainability-related Financial Information” and IFRS S2 “Climate-related Disclosures”. ²⁶ ²⁷ These standards mark the beginning of a uniform framework for sustainability-related information, to be used by companies across jurisdictions. The primary users of ISSB Standards are investors, lenders and other creditors. These are considered the main audience of general-purpose financial reporting. ¹ ²⁶ For these users, comparable and decision-useful information is essential to evaluate how companies are exposed to sustainability-related risks and opportunities in both the short and the long term. ²⁶ ²⁷ The conceptual framework of the ISSB defines this user group and explains the related disclosure objectives. Additionally, it introduces qualitative characteristics to ensure that the disclosed information is reliable and supports informed decision-making. In 2023, the SASB Standards have been revised to remove US-specific terminology. They have been adapted to globally recognized wording to improve their international applicability. ²⁶ ²⁷ As a result, the ISSB maintains these revised SASB Standards as legacy material. They apply in cases where no sector-specific IFRS Sustainability Disclosure Standards are available. ²⁸ The two frameworks follow different implementation approaches. While the ISSB aims to establish a global baseline for sustainability disclosures through its mandatory standards, the SASB Standards were originally developed as a voluntary reporting tool. ²³ ²⁶ The formal implementation of ISSB Standards remains under the authority of national jurisdictions. Starting with the reporting year 2024, the IFRS Sustainability Disclosure Standards are expected to become mandatory in jurisdictions that decide to adopt them. ²⁹ Several countries have already declared their intention to integrate the ISSB framework into their national regulatory systems. These include Brazil, Mexico, Canada, Singapore, Hong Kong, and Japan. ¹⁰ In addition to publishing global standards, the ISSB supports international alignment through its interoperability strategy. This approach includes the so-called “building blocks” model. ²⁶ According to this model, the IFRS Sustainability Disclosure Standards constitute a global baseline (referred to as Block 1). Jurisdictions may then expand these requirements by adding jurisdiction-specific disclosures (Block 2) without compromising international comparability. ¹ The modular architecture allows policymakers to align sustainability reporting with national priorities, while ensuring consistency with global disclosure frameworks. ³⁰ This reduces duplication and reporting burdens for companies operating in multiple jurisdictions. ²³ The following section introduces the structure and role of IFRS S1 and IFRS S2 as central components of the ISSB disclosure system.

2.1.3 Structure and role of IFRS S1 and S2

With IFRS S1 and IFRS S2, the ISSB has introduced two core standards that form the foundation of an internationally interoperable framework for sustainability-related disclosures. ¹ The framework is conceptually anchored in IFRS S1, which defines the requirements for reporting sustainability-related financial information. ³¹ Companies must disclose such information whenever it has an impact on their financial position, operational performance, or future prospects. The primary objective is to provide investors and creditors with relevant and comparable information to support informed decision-making. ³¹ IFRS S1 builds on the established principles of financial reporting under IFRS and extends them by incorporating a sustainability perspective into disclosure practices. ²⁷ ³² IFRS S2 complements IFRS S1 by introducing specific requirements for reporting on climate-related risks and opportunities. ¹ These include physical risks (e.g., from more frequent extreme weather events) and transition risks (e.g., arising from policy changes or technological shifts). At the same time, opportunities may arise from the potential positive effects of climate change, such as the development of new business models or efficiency gains. ³² This alignment allows organisations to follow sector-specific guidance from the SASB Standards, which provide a central reference for implementing IFRS Sustainability Disclosure Standards in specific industries. ¹² ²⁴ Under IFRS S1, companies are required to consider SASB disclosure topics and metrics in cases where no specific ISSB standard is available. ³¹ IFRS S2 builds on this by requiring companies to refer to industry-based climate disclosure guidance, derived from the SASB Standards and adapted for international applicability. ³¹ ³² The alignment is further operationalised through the TCFD’s four-pillar model, which provides a structured framework to enhance comparability and consistency across entities. ² ²⁷ ³² The first pillar, Governance, requires organisations to disclose information on responsibilities, reporting lines, and performance metrics, with IFRS S2 expanding these requirements by introducing climate-specific obligations. The second pillar, Strategy, addresses the ways in which sustainability-related risks and opportunities affect the business model, value chain, strategic decision-making, and financial planning. IFRS S2 supplements this by requiring disclosures on physical and transition risks, transition plans, and climate resilience assessments, typically based on scenario analysis. The third pillar, Risk Management, concerns the integration of sustainability- and climate-related risks into enterprise risk management systems. This includes evaluation methods, prioritisation processes, and the use of scenarios. IFRS S2 remains fully aligned with IFRS S1 in this regard. Finally, the fourth pillar, Metrics and Targets, obliges companies to disclose key indicators, targets, timelines, and progress assessments. ³¹ ³²

IFRS S2 introduces enhanced disclosure requirements for climate-related aspects, including cross-industry metrics such as Scope 1–3 greenhouse gas emissions, climate-related investments, internal carbon pricing, and links to executive compensation. Companies are also required to disclose industry-specific metrics based on official guidance and, in the case of emission targets, to specify the relevant scopes, indicate whether the targets are gross or net, and disclose any reliance on offsetting mechanisms. ³²

Beyond these disclosure areas, the standards establish four overarching conceptual principles, each designed to enhance the quality, clarity, and decision-usefulness of sustainability information. The first, fair presentation, obliges companies to present all material sustainability-related information in a complete and unbiased manner. The second, materiality, is defined from an investor perspective, requiring companies to assess, at entity level, which quantitative and qualitative factors may influence the decisions of report users. The third, reporting entity, ensures alignment between sustainability disclosures and financial statements by prescribing consistent reporting boundaries, assumptions, and scope definitions. Finally, the principle of connected information requires companies to establish explicit links between sustainability and financial disclosures in order to demonstrate how sustainability-related risks and opportunities affect enterprise value and long-term performance. In this regard, the ISSB’s broader ambition to consolidate and integrate existing standards is clearly reflected in the structure, content, and underlying logic of IFRS S1 and IFRS S2. ³¹ ³² However, this ambition did not emerge on its own. It has its roots in historical and institutional developments, particularly the evolution of SASB and the later creation of the ISSB, which will be discussed in the next section.

3 Historical and institutional background

3.1 Development and role of SASB and ISSB

The SASB was founded in 2011 at the initiative of Jean Rogers and officially registered as a non-profit organisation under Section “501(c)(3)” of the U.S. tax code in the following year. ¹⁸ Its establishment responded to the inconsistent quality and limited comparability of ESG reports. According to Hales (2021), companies used different metrics even when reporting on the same issues. This created difficulties for investors in evaluating the information in a consistent and comparable way. In addition, the absence of regulatory requirements and audit obligations, especially in the United States, contributed to this situation. ¹² Starting in 2012, SASB began developing its standards with financial support from Bloomberg Philanthropies. The standard-setting process followed five stages: industry analysis, consultation with interdisciplinary working groups, public comment, finalization, and provisional release. ¹⁸

By 2016, this process developed 77 standards across 11 sectors (such as Health Care, Infrastructure and Consumer Goods), covering 444 financially material ESG topics. ¹⁸ ²⁴ To illustrate, the Consumer Finance Sustainability Accounting Standard (Financial sector) sets out disclosures for Customer Privacy, Data Security and Selling Practices. Each of these topics is linked to specific accounting metrics that aims to capture the financially material sustainability-related risks and opportunities relevant for companies in this industry. ²⁴ ³³

The SASB standards are based on an investor-oriented concept of materiality derived from U.S. securities law. This concept became established early in the U.S. due to the absence of binding ESG regulations. One important result of this approach was the creation of the “Materiality Map”. ¹⁸ ³⁴ This tool is intended to support investors in identifying climate-related risks and understanding their financial relevance. ³² ³⁵ In the same year, the SASB received public support from major institutional investors. Representatives from BlackRock, CalPERS, CalSTRS, and Wells Fargo highlighted the usefulness of the initiative for better-informed investment decisions. ¹² ²³ In response, the U.S. Securities and Exchange Commission (SEC) published a concept release to collect public input on possible ESG reporting obligations. ¹⁸ ³⁵ This supported the institutional role of the SASB further. In 2017 and 2018, the newly created Standards Board completed the standard-setting process and formally launched the standards as a codified framework. ¹⁸

3.2 Formation of the ISSB and institutional consolidation

The development and institutionalisation of the SASB Standards created a basis for later consolidation in sustainability reporting and led to SASB’s integration into the ISSB structure. ¹² ³⁶ The ISSB is the result of multiple consolidation steps (see Figure 2). ³⁷ Several organisations had supported harmonisation efforts before the establishment of the ISSB. These included the World Economic Forum, Accountancy Europe and IFAC. ³⁰ Their goal was to improve the consistency and comparability of ESG disclosures. ⁷ At the center of the consolidation efforts were five organisations, often referred to as the “Group of Five” ¹⁶ ²⁷, each representing a different approach to sustainability reporting:

Carbon Disclosure Project (CDP): disclosure of environmental impacts. ¹ ³⁸
Climate Disclosure Standards Board (CDSB): framework for environmental and climate-related reporting. ¹ ³⁸
International Integrated Reporting Council (IIRC): six-capitals model linking financial and non-financial information. ¹
Global Reporting Initiative (GRI): stakeholder-oriented standards focused on wider social and environmental impacts. ³⁹
Sustainability Accounting Standards Board (SASB): investor-focused standards based on financial materiality. ¹⁸

In September 2020, these organisations came together to publish a “Statement of Intent” setting out their plan to improve the coherence of corporate reporting. ¹⁶ ³⁷ Figure 2 summarises the consolidation that followed. First, IIRC and SASB merged to form the Value Reporting Foundation (VRF), which was officially established in June 2. On 3 November 2021, the IFRS Foundation announced the formation of the ISSB during COP26 (UN Climate Conference, 2021). ¹ The CDSB consolidation was completed on 31 January 2022 (IFRS Foundation integration), and the VRF consolidation took effect on 1 August 2. Since then, the ISSB has taken responsibility for the further development of the SASB standards and has adopted the recommendations of the TCFD (governance, strategy, risk, metrics & targets). ¹ ²⁸ ³² The establishment and consolidation of the ISSB have led to academic discussions, which will be analysed in Chapter 3.3 by using relevant theoretical perspectives.

3.3 Integration into IFRS architecture

As outlined in previous section, the ISSB is fully embedded into the existing institutional architecture of the IFRS Foundation. Its work is based on the same constitutional framework that also governs the IASB. ¹¹ As a result, the ISSB follows the same standard-setting structure, procedures and terminology as the IASB. ²⁹ This includes the use of defined terms such as reporting entity and reporting period, as well as consistency in language, format and style. ²⁷ ⁴⁰ This alignment is supposed to enable an efficient and effective integration into the IFRS framework. The primary users of ISSB Standards are the same as those defined by the IASB (investors, lenders and other creditors). ¹ Both the ISSB and the IASB are advised by the IFRS Advisory Council and the Integrated Reporting and Connectivity Council. Furthermore, the standard-setting work of the ISSB is subject to the same oversight mechanisms as that of the IASB. The Due Process Oversight Committee (DPOC) of the IFRS Foundation monitors compliance with the established procedures for both boards. ²⁷ ³² ³⁷ As the IFRS Foundation itself underlines, “The IFRS Foundation’s due process applies to the standard-setting work of the International Accounting Standards Board (IASB), the International Sustainability Standards Board (ISSB) and the IFRS Interpretations Committee” (IFRS Foundation, 2024, p. 1). ⁴¹ As part of its modular and interoperable architecture, IFRS S1 and S2 incorporate elements from other standards, frameworks and institutions. This approach is intended to enhance relevance, consistency and comparability of sustainability-related disclosures. ³² The table below provides an overview of how IFRS S1 and S2 interact with these external reference points.

Framework / Standard

Connection to ISSB Standards

SASB Standards (SASB)

• See Section 3.1.3 and 3.2.1.

Task Force for Climate-related Financial Disclosures (TCFD)

• Both IFRS S1 and S2 are conceptually aligned with the TCFD recommendations, with IFRS S2 fully incorporating them. Separate TCFD reporting is therefore not required when applying ISSB Standards. ¹⁸

Climate Disclosure Standards Board (CDSB)

• Contributed to the foundation of the ISSB and was consolidated into it in 2022 (including staff and intellectual property). ¹

• IFRS S1 allows the use of CDSB guidance in cases where no specific ISSB Standard exists. ³²

• CDSB resources support the identification of sustainability-related risks and disclosures.ds

International Accounting Standards Board (IASB)

• Builds on the institutional link between the ISSB and IASB outlined previously.

• IFRS S1 incorporates key IASB concepts and definitions, such as materiality from the Conceptual Framework, IAS 1 (Presentation of Financial Statements) and IAS 8 (Accounting Policies). ³²

• References to IASB’s Management Commentary further strengthen the alignment between financial and sustainability disclosures. ²⁹

Integrated Reporting Framework (IRF)

• IFRS S1 draws on IRF principles, including the six capitals model, which links long-term value creation with stakeholder interactions and resource use.

• Originating from the VRF, the IRF supports integration and structured presentation of disclosures under ISSB Standards.

• Considered a useful tool to enhance connectivity and a potential reference for future Management Commentary (voluntary use). ¹ ³⁶

Greenhouse Gas Protocol

• IFRS S2 requires disclosure of gross GHG emissions (in metric tonnes CO₂e) across all three scopes:

o Scope 1: direct emissions from owned or controlled sources

o Scope 2: indirect emissions from purchased energy

o Scope 3: all other indirect emissions across the value chain

• Emissions must be measured in line with the GHG Protocol (2004), unless another method is required. For Scope 3, companies must specify which of the 15 categories from the GHG Value Chain Standard (2011) are included.

• Companies must also disclose the calculation method and attribution approach used (e.g. equity share or control). ³² ⁴⁰ ⁴²

Global Reporting Initiative (GRI)

• In 2022, the ISSB and GRI signed a Memorandum of Understanding (MoU) to coordinate standard-setting and reduce reporting burdens. ¹ ⁴²

• The collaboration aims to ensure compatibility between ISSB’s investor-focused baseline and GRI’s multi-stakeholder standards. ³²

• Described as a “two-pillar” system (ISSB for investors, GRI for multi-stakeholder needs), supporting harmonisation and interoperability. ⁴³

• Entities may consider GRI Standards to inform disclosures, but not for identifying risks and opportunities. ³²

European Sustainability Reporting Standards (ESRS)

• May 2024: Interoperability Guidance with ISSB was published, showing high alignment in climate-related disclosures.

• 46 paragraph-level correspondences were identified between IFRS S2 and ESRS E1: Governance (9), Strategy (4), Risk Management (10), Metrics (7), and Targets (13).

• The definition of financial materiality is aligned with IFRS S1. ⁶ ¹⁰ ⁴⁰

Jurisdictions

• The ISSB Standards provide a global baseline, but adoption decisions remain with national authorities. ²

• The framework is supported by the G7, G20, IOSCO, FSB, and more than 40 jurisdictions. ³²

• The IFRS Foundation engages with jurisdictions through forums and technical dialogue.

• May 2024: The IFRS Foundation published the Jurisdictional Guide to support national implementation. ⁴⁴

• September 2024: A Voluntary Application Guide was issued for companies in jurisdictions without mandatory requirements. ⁴⁵

Table 1: IFRS S1/S2 – External interactions and interoperability

In addition to the structural interactions illustrated above, the following comparison focuses on the key conceptual differences between the ISSB Standards (IFRS S1/S2), the GRI Standards, and the ESRS. These three frameworks represent the most influential approaches in current practice and are often positioned against each other in both academic and policy debates. ⁶ A clear distinction is essential, as it anchors multiple academic debates, including those on governance, legitimacy, materiality, and interoperability (Section 3.3), and guides reporting choices in practice (Section 4). Figure 3 provides an overview of the most relevant distinctions regarding materiality concept, target audience, reporting purpose, and legal status. ¹⁴ ³⁹ ³² ⁴⁰ ⁴⁶

4 Theoretical frameworks and academic debates

This section explains how academic perspectives can help to understand the role of the ISSB and SASB and the debates around them. It includes five theories that are often used in the academic literature on SRS. Each perspective is introduced in simple terms and then linked to examples from the literature. These examples show how the concept is reflected in current debates on the ISSB and SASB. The aim is to show that these debates are not only about technical reporting requirements, but also about how governance, stakeholder influence, and global acceptance influence the development of sustainability reporting standards.

4.1 Stakeholder theory

The application of theory makes it possible to move beyond technical reporting requirements and to analyse the underlying logics of sustainability disclosure. Stakeholder Theory is particularly relevant in this context, as it explains how organisations balance the expectations of different stakeholder groups and create value through these relationships. As Freeman et al. (2010) put it, “Business can be understood as a set of relationships among groups which have a stake in the activities that make up the business” (p. 25). ⁴⁷ These groups include both primary stakeholders, such as financiers, customers, suppliers, employees, and communities, as well as secondary stakeholders with indirect influence. ³⁸ The theory assumes that long-term success depends on creating value for all stakeholders and rejects the notion that the sole purpose of a business is to maximise shareholder value. ²⁹ ⁴⁷

It is therefore relevant for understanding the difference between investor-focused approaches, such as the ISSB Standards, and the double materiality approach of the ESRS. ² A central debate is about the connection between the audience of the report and the materiality concept that is applied. The ISSB Standards focus on financial materiality, which can exclude environmental and social impacts not affecting enterprise value. ⁴ On the other hand, the GRI Standards and the ESRS apply different approaches to determining materiality (see Figure 3). This means that they look at both the financial effects of sustainability matters on the company and the effects of the company on people and the environment. Afolabi et al. (2023) note that a broader approach can improve accountability to a wider group of stakeholders. ⁴³ These differences are also visible in consultation results. In the IFRS Foundation’s 2020 consultation, 72% of academic respondents opposed the main proposals, including the creation of the ISSB. ⁴ Kulik and Dobler (2023) explain that this was mainly due to its focus on investors. ²⁹ Most responses came from preparers and users, while only 7.3% came from academics. ² According to Bohn et al. (2024), investors were divided on whether a single materiality approach should be applied. ² Oll et al. (2025) explain that the concept of materiality is still contested and not clearly defined. ¹⁴ Consequently, no single definition that can be applied to both investor-focused and stakeholder-focused reporting. Differences in how materiality is defined make global alignment difficult. ¹ Jurisdictions that work with double materiality are unlikely to accept an investor-only approach without changes. ⁶ The ISSB addresses this challenge through its “building blocks” model. In the EU, double materiality is already part of the reporting requirements. ² This means that the ISSB Standards are only likely to be adopted if they also include this concept. ³⁸

4.2 Legitimacy theory

Legitimacy Theory is one of the most commonly used frameworks to explain corporate disclosure practices in sustainability reporting. Legitimacy Theory was introduced by Dowling and Pfeffer in 1975 and describes how organisations adjust their actions to align with societal expectations in order to be accepted. ⁴⁸ In this context, Suchman (1995) defines legitimacy as “a generalized perception or assumption that the actions of an entity are desirable, proper, or appropriate within some socially constructed system of norms, values, beliefs, and definitions” (p. 574). ⁴⁹ In this sense, sustainability reporting depends on legitimacy as a form of collective judgment. Such judgment supports long-term acceptance and trust in the reporting organisation. ² ⁴⁹

The ISSB needs to build and maintain legitimacy because it operates within existing reporting frameworks and must take into account the priorities of different stakeholder groups. ²⁹ Since its creation, several researchers have questioned whether the ISSB is perceived as a legitimate global standard setter. Key concerns relate to the necessity of establishing a new international body, the expertise available within the IFRS Foundation, and the extent to which the consultation process reflected a broad and diverse range of stakeholder views. ¹

Another commonly raised point is the ISSB’s strong focus on the needs of investors. ² Some experts argue that other frameworks, such as the GRI, already have broader recognition and place more emphasis on the interests of a wider group of stakeholders. ⁵⁰ Current discussions look at how the ISSB’s governance works in practice, whether its procedures follow accepted quality standards, whether powerful actors have too much influence, and whether the standards will be accepted across different countries. ⁶ An example that shows how legitimacy concerns appear in practice is the comparison between the GRI and the ISSB (see Figure 3). The GRI has built its position by involving a wide range of stakeholders. ⁴⁶ In contrast, the ISSB is mainly supported by its link to the IFRS Foundation and its connection to financial reporting through the IASB. ¹ This approach has been criticised by Adams and Mueller (2022), who question whether the IFRS Foundation possesses the necessary expertise to lead standard setting in the field of sustainability. ⁴ Similarly, Adams and Abhayawansa (2022) question whether a new global standard setter is needed at all. They argue that the decision to establish the ISSB was based on “a lack of analysis of the alternatives, an overestimation of the IFRS Foundation’s expertise and mischaracterisation of sustainable development/ESG financing” (p. 10). ⁷

As mentioned earlier, academic respondents expressed concerns about the ISSB’s investor focus and its limited expertise in sustainability during the consultation process. ¹ According to legitimacy theory, it is not possible to establish legitimacy through structural alignment and affiliations alone. ⁴⁹ ⁵¹ Carungu et al. (2025) emphasise that even the IASB needed to build its legitimacy over time through active efforts. ⁶ Expertise in financial reporting does not automatically lead into trust in the field of sustainability. Legitimacy in standard setting must be actively earned and is shaped by ongoing negotiations between actors with competing interests and influence within the reporting landscape. ² ³⁹ The ISSB needs to maintain ongoing communication about its value and necessity, because sustainability reporting involves multiple perspectives and interests. As of 2024, however, the ISSB Standards had not yet been made mandatory in any jurisdiction. ² To address this, the ISSB has stepped up its communication and promotion efforts (promotional strategy, cf. Suchman, 1995, p. 586), which can be seen as an attempt to build legitimacy by influencing public and policymaker perceptions of the organisation. ⁴⁹

Another key aspect of the legitimacy debate concerns the inclusiveness of the ISSB’s consultation process. Although the ISSB is designed to serve global capital markets, the consultation input was largely dominated by preparers and the accounting profession, while investors and stakeholders from the Global South were underrepresented. ² ²⁹ This imbalance raises concerns about input legitimacy, understood as “the participation of affected parties in rule-making or standard-setting so as to establish congruence between affectedness and voice in decision-making” (Richardson & Eberlein, 2011, p. 223). ⁵² Even the most carefully designed procedures risk losing credibility if important perspectives are overlooked. Critics also question whether consultations merely create an “appearance of deliberation” while reinforcing dominant actor influence. ¹⁶ Critical voices, especially academics and minority positions, were marginalised or aggregated into generalised summaries. These concerns are linked to the notion of “financial capture,” referring to the strong influence of capital market actors over the ISSB’s agenda. ¹ ² ⁴²

4.3 Institutional theory

Institutional Theory offers a powerful lens to explain why organisations often adopt reporting standards not primarily out of intrinsic motivation, but in response to institutional demands and societal expectations. Rooted in New Institutionalism, it highlights how organisations adjust their behaviour to align with external pressures, whether these take the form of formal rules such as laws and reporting requirements or informal norms such as public pressure on ESG issues. ⁵³ ⁵⁴ Companies often follow standards like IFRS S1/S2 because they want to meet stakeholder expectations and appear legitimate. ⁶ Accordingly, as a global standard setter, the ISSB must meet institutional expectations to be accepted. ⁵⁴ This includes transparent decision-making, involvement of stakeholders, and ensuring alignment (interoperability, i.e. compatibility with frameworks such as GRI or ESRS). ⁶ However, companies tend to implement ISSB Standards mainly to comply with institutional requirements for ESG disclosure rather than out of genuine conviction. ¹⁰ This perspective links Institutional Theory directly to Legitimacy Theory: sustainability standards become essential because they help firms demonstrate responsibility and trustworthiness to stakeholders while fulfilling regulatory requirements. ⁵¹ The adoption of ISSB and SASB standards thus functions as a legitimacy-building mechanism, enabling organisations to maintain their market position, funding access, and reputation. Rather than reflecting genuine sustainability convictions, implementation is largely driven by institutional pressures from governments, NGOs, media, and industry associations. Consequently, organisations can only secure long-term success by aligning with these institutional expectations.

4.4 Regulatory space theory

Unlike theories that focus on organisations alone, Regulatory Space Theory emphasises the dynamic and contested space in which sustainability reporting standards emerge. ⁶ This space is shaped by five key dimensions:

National legal and political cultures
Historical context
Dominant organisations (e.g. ISSB or EFRAG)
Inter-organisational connections
Nature of the issues being negotiated (e.g. materiality, interoperability, stakeholder access)

Actors within this space use strategies to strengthen their positions, for instance through alliances. Standard-setters like the ISSB cannot be regarded merely as technical bodies but are also engaged in politically driven negotiation processes. In this context, legitimacy becomes a crucial resource for expanding regulatory influence. Moreover, agenda-setting represents one of the most contested aspects of the standard-setting process, as competition revolves around which sustainability issues are prioritised. Ultimately, the decisive factor is how reliably and relevantly these issues are perceived by the actors involved. ⁶ ⁴³ ⁵⁵ In the literature, the “Split of the Cake” narrative is described as an example of the power struggles within the regulatory space. These fundamental disagreements contribute to institutional fragmentation and hinder global convergence. ¹⁹ ³⁴ ⁵⁶ The tensions are particularly evident in the interoperability challenges between the ISSB and ESRS frameworks. ³⁰ According to Rowbottom (2023), the ISSB has strategically sought alliances with actors aligned with the IFRS Foundation (e.g. through the Corporate Reporting Dialogue and the consolidation of SASB, CDSB, and TCFD) to strengthen its institutional position and institutionalise its concept of financial materiality. ¹⁶ This has led to the marginalisation of alternative frameworks, particularly the GRI, which continues to promote impact-based reporting. ⁴ ⁴³ Oll et al. (2025) explain that the lack of agreement on materiality is not only due to unclear definitions, but primarily because the concept itself is highly contested. ¹⁴ These debates highlight the value of Regulatory Space Theory, which views ISSB standard-setting as the outcome of political struggles rather than technical differences. ⁶

4.5 Disclosure theory

At its core, Disclosure Theory explains the theoretical foundation of corporate reporting and the underlying motivations for companies to disclose information. In particular, a key branch of this theory is the Voluntary Disclosure Theory (VDT), which helps to understand why firms choose to report voluntarily under ISSB and SASB standards rather than doing so solely in response to regulatory requirements. ⁵⁷ ⁵⁸ The theory originally stems from financial reporting and explains how companies share information to reduce knowledge gaps between management teams and external investors. ⁵⁹ Many companies go beyond mandatory disclosure requirements to demonstrate strong performance and gain investor trust. At the same time, companies with better environmental performance are more likely to disclose sustainability-related information. ⁵⁸

Recent studies on the application of SASB standards show exactly this pattern of positive correlation between strong ESG performance, well-structured governance systems, and the voluntary adoption of SASB standards. ²⁸ Especially companies with previously low ESG disclosure have started to report more targeted information, while well-managed firms use the standards to strengthen their position in the capital market. ¹² Firms following ESG reporting guidelines disclose on average 39 % more sustainability information, and content-focused verification leads to 23 % more detailed reporting. ¹⁰ ¹⁸ However, the theory has its limitations because it is based on the assumption of truthful reporting. ⁵⁸ In practice, some companies use vague or hard-to-verify statements to present themselves in a good light without implementing actual changes. ²¹ ²² This raises the question of whether voluntary disclosures always reflect reality. In some cases, voluntary reporting is not aimed at increasing transparency but is instead used to manage impressions or achieve symbolic legitimacy, often referred to as “greenwashing”. ²¹ ⁵⁸ A clear understanding of these dynamics is essential for evaluating how and why companies apply ISSB and SASB standards, as it highlights the strategic motivations behind voluntary sustainability reporting. However, the persistence of contested concepts, diverging stakeholder expectations, and strategic reporting practices underlines the need for further research.

4.6 Research gaps

Since the establishment of the ISSB in 2021, together with the growing adoption of SASB and the increasing demand for sustainability reporting, research has expanded rapidly, examining their institutional development and role in global sustainability reporting. Accordingly, the following section first summarises the current state of research by identifying three main themes, and on this basis outlines the key research gaps and future directions highlighted in recent studies. One recurring topic in the literature concerns the challenges to the ISSB’s legitimacy and governance structures. While the ISSB relies on its link to the IFRS Foundation to build authority, it has been criticised for focusing too narrowly on investors and neglecting other stakeholders. Its restricted scope raises doubts about its authority, as it allows powerful actors to dominate decision-making and undermines the organisation’s prospects of gaining global recognition as a standard setter. ¹ ² ⁴ Moreover, most of the literature still focuses on SASB adoption, as ISSB-related research remains limited due to its recent establishment. Findings show that investor requirements, ownership structures, and corporate governance standards shape the conditions under which companies adopt voluntary sustainability standards. While these measures improve the consistency of ESG disclosures, they often serve strategic purposes rather than driving substantive change. At the same time, the ISSB faces difficulties in achieving alignment with GRI and ESRS, as institutional fragmentation continues to hinder convergence. ⁶ ¹² ¹⁸ ²⁸ Another key strand in the literature is materiality and interoperability, often described as the most contested issues in sustainability reporting. Different materiality approaches between standard setters result in divergent reporting methods, making global standardisation difficult and leading to inconsistent practices across countries. ¹³ ¹⁴ ⁴³

Building on the current state of research, several areas remain underexplored and call for further investigation, with the identified research gaps reflecting both explicit suggestions from the literature and gaps synthesised from the analysis of existing studies. The literature indicates that investor demand, ownership structures, and governance systems affect disclosure practices, but it does not explain how these factors influence the actual implementation of IFRS S1 and S2. Future studies need to examine the methods organisations and regulatory bodies use for standard enforcement by analysing industry-specific barriers, regional differences, and their influence on financial management and ISSB credibility. ¹ ⁴ ²⁸ Although the distinction between financial and double materiality has been well defined, research has yet to explore how these concepts are operationalised in practice. Future research should therefore employ experimental and qualitative methods to analyse how stakeholders identify and apply material information, addressing the current knowledge deficit. Further attention should also be given to the institutionalisation of materiality processes and to interdisciplinary approaches that can help overcome the limitations of the existing literature. ¹⁴ ¹⁵ ³⁴ In addition, the political and social dimensions of standard-setting remain underexplored, particularly regarding the influence of professional actors and regulatory bodies on the ISSB’s development. ⁶ ³⁰ The position of integrated reporting in relation to ISSB and ESRS remains unresolved and requires further analysis. ⁶⁰ Moreover, there is little evidence on how sustainability reporting supports developing countries in achieving their SDG targets. ⁶¹ Methodologically, future studies should advance in three directions: developing qualitative approaches, applying digital and AI-based text analysis, and creating reliable metrics to assess the credibility of sustainability disclosures and strengthen the robustness of ISSB research. ¹⁸ ⁶²

5 Practical implementation

This chapter explains how companies can implement the IFRS Sustainability Disclosure Standards (IFRS S1/S2) in practice. The process of implementation follows a structured format which requires detailed planning, internal coordination, and appropriate tool use for continuous execution. The main objective is to support organisations in building ISSB-compliant internal reporting systems by applying standardised and efficient processes. At present, there is no single regulatory blueprint for applying the ISSB Standards. ² Existing guidance from the IFRS Foundation and related bodies provides principles and illustrative examples, but it does not amount to a coherent framework for corporate implementation. ³² Therefore, this chapter presents a process-based model which outlines standard business procedures for firms through regulatory instructions, academic studies, professional resources, and insights from early adopters. The resulting five-step structure comprises the following stages: (1) readiness and gap analysis, (2) materiality assessment, (3) internal processes and tools, (4) integration into corporate reporting, and (5) continuous improvement and assurance (see Figure 4). Each section explains the corresponding implementation phase through process descriptions, supporting tools, and case examples. The framework includes an analysis of internal and external factors that drive progress, as well as internal and external factors that could block effective implementation. The dual approach of this framework enables researchers to study both the factors that support implementation and the actual obstacles that occur during practice, which results in a more accurate assessment of implementation practice.

Figure 4: Corporate implementation process for ISSB standards

5.1 Readiness & gap analysis

The first step in implementing IFRS Sustainability Disclosure Standards is to evaluate current reporting systems and internal structures. The evaluation aims to determine the state of operational preparedness and to identify any gaps that do not align with the new standards. ³¹ ⁶² This readiness check (or status quo) enables companies to realistically assess their ability to meet ISSB disclosure obligations. The assessment covers data origins, internal operational procedures, organisational responsibilities, and existing reporting systems. The gap analysis uses the readiness check results to evaluate present content and procedures against the IFRS S1 and S2 requirements. The goal of this process is to identify structural vulnerabilities, which enables organisations to establish their most critical needs and tackle potential threats before they become major issues. ²⁵ ³² There are multiple guidance materials and tools that support implementation at this stage. The Voluntary Application Guide provides companies with practical advice on how to start applying the standards and explains the proportionality principle. ⁴⁵ Interoperability mappings such as the ESRS–ISSB Interoperability Guidance allow firms to evaluate how well their current disclosures align with IFRS S1 and S2. In addition, audit firms such as KPMG, EY, and PwC provide checklists, gap analysis tools, and maturity models that help companies benchmark the quality and coverage of their existing disclosures and design targeted action plans. ⁴⁰ ⁶³

In practice, companies increasingly rely on such tools and frameworks to strengthen their reporting in line with ISSB requirements. ³⁹ This can be illustrated by the case of HSBC, which has developed an ESG framework that integrates ISSB disclosure obligations into its governance, risk management, and reporting systems. ¹⁰ The bank complements its internal readiness efforts with external checklists from audit firms to conduct the gap analysis. ⁴²

The successful execution of readiness assessments is supported by a combination of internal and external drivers. These organisational factors enable companies to align their systems with IFRS S1/S2. From an internal perspective, a key enabler is the organisation’s absorptive capacity, which remains a driver throughout subsequent phases. The ability to receive external knowledge and integrate it into company structures allows firms to understand ISSB requirements, identify disclosure gaps, and define appropriate next steps. ⁶² This capability is crucial for translating regulatory expectations into operational readiness. ³² Another internal driver is prior experience with Integrated Reporting (IR). Companies that have already applied IR typically possess mature disclosure systems and established governance frameworks. Such structures enable more systematic gap analysis and enhance the implementation of SASB topics. ²⁴ ²⁸ ⁶⁰ From an external perspective, the compatibility with existing sustainability frameworks functions as a further enabling factor. When companies already report according to standards such as TCFD, GRI, or ESRS, they can more easily link these systems to IFRS S1 and S2. This reduces duplication and complexity and encourages early alignment with ISSB Standards. ⁶ ³¹ ⁴⁰

Despite these enabling conditions, several internal and external barriers may hinder the readiness and gap analysis process. One major internal barrier is the limited availability of financial and human resources. The development of ISSB-compliant systems often demands significant investment, which may exceed the capacity of smaller or less mature organisations. ³² ⁶² This issue recurs in later phases. A second internal constraint is the lack of implementation capacity. Companies that have not previously applied frameworks such as TCFD, GRI, or IR often face difficulties in identifying and closing disclosure gaps. A missing foundation in structured sustainability reporting hinders effective alignment with IFRS S1/S2. An important external barrier arises from conceptual ambiguities in the ISSB Standards themselves. The interpretation of materiality thresholds and the practical implementation of SASB metrics remain unclear for many companies. In particular, the phrase “could reasonably be expected” in IFRS S1 introduces a level of subjectivity that creates uncertainty in application. ¹⁸ ³¹ ⁴³ As described in legitimacy theory, such ambiguity can lead to symbolic rather than substantive compliance, for example when companies produce compliance-oriented checklists without adjusting their internal processes. ⁴² This reduces the effectiveness and credibility of sustainability reporting. ²

5.2 Materiality assessment

In the second phase of implementation, materiality assessments guide the selection of ESG topics that need to be reported under ISSB Standards. The framework exists to determine which sustainability matters require disclosure in general purpose financial reports, as explained in Chapter 3.1.3. To achieve this, companies must assess sustainability-related risks and opportunities that affect their business operations, including climate-related threats, emerging social conflicts, and regulatory changes. The financial significance of each identified topic is then evaluated using methods such as the SASB Standards, the TCFD framework, or internal risk assessments. ²⁵ ³¹ Each materiality judgment must be transparently documented and traceable, based on expert evaluation. Such judgments are expected to rely on forward-looking, company-specific criteria and to be recorded in a consistent and reliable manner. ⁴ ³⁴ The results of the assessment determine which ESG topics require disclosure, thereby shaping the overall structure and content of sustainability reporting. As a cross-functional task, the process requires collaboration across departments to reflect sector-specific conditions, governance arrangements, and business structures. ³²

In recent years, companies have applied materiality assessments using a variety of tools. These include materiality matrices, as used by companies such as Unilever and Nestlé, structured mappings applied by Nedbank and Stora Enso, and SASB sector-specific metrics, as in the case of Sunrun and Suncor. ³⁴ ³⁸ However, these approaches differ in scope, methodology, and level of transparency. As a result, many materiality assessment processes are often insufficiently developed and inconsistently documented in practice, which limits their comparability and reduces the reliability of reported outcomes. ¹ ¹⁴

Materiality assessments are supported by a combination of internal and external drivers that enable their implementation. A key internal driver is the use of digital tools and data management systems. The implementation of XBRL technology allows companies to improve their ESG data collection, organisation, and analysis capabilities. ⁶² Standardisation ensures consistent disclosure practices and forms the basis for the process and governance aspects addressed in Phase 3. An important external driver is the increasing demand from capital market actors for high-quality, decision-useful ESG data. Investors are increasingly focusing on the sustainability performance of companies and rely on materiality assessments to provide relevant and comparable information that supports long-term investment decisions. ⁴² Businesses need to perform their assessments with greater accuracy and detail because external market requirements now demand it. ¹² A further external component is external assurance, which operates as a credibility improvement system. Organisations achieve materiality judgment transparency through independent verification processes, which helps establish trust with stakeholders. The approach follows the legitimacy function of assurance practices as described in Chapter 3.3.2 and enables capital market participants to accept disclosed sustainability information. ¹³ ¹⁵

On the other hand, materiality assessments encounter internal and external barriers that make effective implementation challenging. A major internal obstacle lies in the conceptual complexity of materiality. The combination of financial materiality with double materiality creates confusion about which method to use, which makes the assessment process more difficult and results in different company and jurisdictional practices. ⁴ ¹⁴ ³⁴ A central external barrier is data availability and quality. Non-financial information is often qualitative and fragmented across the value chain, which makes standardisation difficult and reduces the reliability and comparability of results. ⁹ A final challenge exists because of the risk that strategic actors may exploit the system. The discussion in Chapters 3.3.2 and 3.3.5 shows that materiality functions as a concept that managers and institutions actively shape through their framing processes. Organisations tend to report specific ESG matters that match investor requirements but ignore various social issues that need attention. The practice of choosing which sustainability information to disclose creates reporting transparency problems, which simultaneously harms the credibility of sustainability reports and makes stakeholders question their authenticity. ⁶⁴ ⁶⁵

5.3 Internal processes & tools

In this third stage, companies turn plans into action. They bring sustainability reporting into their management systems and develop the capabilities they need to meet new requirements. That means setting up solid data systems, linking sustainability risks with overall risk management, encouraging teamwork across departments, and ensuring that governance structures clearly define roles while strengthening ESG knowledge. ¹⁰ ³⁸ ⁶⁰ ⁶² A variety of tools and systems are applied in this phase to integrate ISSB requirements into current reporting frameworks. For example, the ISSB Industry-based Guidance is used to address sector-related matters from the SASB Standards and to explain the reasons behind the exclusion of specific topics. ³¹ The SASB Standards and the Materiality Map help companies identify financially material ESG topics consistently across 77 industries within a single framework. ¹⁴ ²⁴ ³³ ³⁴ The IFRS Sustainability Standards Navigator and IFRS Sustainability Knowledge Hub are used as main platforms that provide comprehensive access to all standards alongside supporting materials and training resources. ⁶⁶ ⁶⁷ Moreover, digital solutions increasingly help to operationalise disclosure requirements. The standardised XBRL format links sustainability reports to financial reporting taxonomies. ¹⁰ AI and machine-learning applications support the processing of large regulatory datasets and enable the extraction of ESG-relevant information. ¹⁷ ²³ In addition, emerging monitoring tools, including digital dashboards, drones and social media analytics, provide companies with insights into environmental risks and stakeholder perceptions. ³² ³⁸

These tools provide the foundation, but as full ISSB/SASB integration remains limited, only a few companies illustrate how the principles outlined above can be applied. Among them, Nedbank is cited as a best-practice example of materiality integration in corporate reporting. ³⁸ Its approach links business purpose to strategic planning and resource distribution, and it achieved top scores for its corporate purpose definition in integrated reports. This makes clear that strong governance and clear processes help companies better identify and communicate what really matters in sustainability. In a similar way, Novo Nordisk demonstrates how clear purpose and stakeholder dialogue translate standards into tangible outcomes. ³⁸

Successfully integrating ISSB requirements into business operations relies on both internal structures and external pressures. A central factor during this stage is absorptive capacity combined with knowledge management systems. In contrast to the first phase, absorptive capacity here enables the practical integration of tools and processes. Organisations which successfully acquire outside information for operational integration are more likely to achieve effective implementation in their reporting systems. This capability enables firms to decrease uncertainty while improving their learning processes and enables them to adapt internal operations to changing requirements. ³² ³⁸ ⁶² Another important driver is the use of digital tools and modern technology. The adoption of the XBRL format creates a structured connection between sustainability disclosures and financial reporting systems, which allows companies to present information in a standardised and machine-readable way. This improves comparability across industries and jurisdictions and reduces reporting complexity. Similarly, AI and ESG databases such as Bloomberg, MSCI, CDP, and DJSI make it easier to collect and process data. These tools are supposed to help companies manage large and diverse datasets, identify relevant ESG factors more efficiently, and improve the quality of their disclosures. ¹⁷ ²³ ⁴⁴ In addition, Phase 3 of the implementation process is shaped by external drivers, especially market dynamics and investor needs. This need for reliable ESG data, which enables sustained risk and opportunity assessment, continues to increase among capital market participants. Businesses need to align their operational systems with ISSB Standards because market demand increasingly requires it. This alignment improves the reliability of sustainability disclosure information. ¹² ¹⁹ ³²

Despite enabling conditions, companies also face significant internal barriers. The first major obstacle relates to high costs and limited resources. ⁶² ISSB compliance demands substantial investment in reporting systems, staff training, and digital frameworks. ³¹ The costs are too high for small businesses operating in developing markets, which discourages smaller firms from applying the standards in practice. ⁴³ A second key barrier arises from the lack of expertise and internal operational capabilities. Companies encounter difficulties when they need to find qualified staff with expertise in sustainability metrics and reporting frameworks. ¹⁵ ⁶² The translation of technical requirements into practice is challenging for middle management, and the simultaneous use of multiple standards creates complexity that exceeds available skill levels. ⁹ ¹⁰ ³⁹ Third, insufficient data management systems and fragmented governance frameworks hinder the coordination of reliable information across the value chain. ¹ Firms often face delays because they rely on multiple data sources and external providers. The lack of proper coordination systems in governance structures makes it harder to link sustainability reporting with financial reporting, which results in inconsistent and unreliable disclosure practices. ⁴ ⁹

5.4 Integration into corporate reporting

The first three phases laid the groundwork: readiness checks confirmed the status quo, materiality assessments identified key disclosure elements, and internal processes built effective data management systems. The fourth stage unites all the preceding work into one complete system. This stage represents the core transfer of sustainability information from internal preparation to external reporting. Organisations need to develop comprehensive and reliable ESG disclosure reports that link environmental, social, and governance elements to financial results. ⁷ ⁴⁵ The official reporting documents become the main focus of this stage because sustainability must be explicitly reflected in them. Companies need to show how sustainability risks and opportunities affect their financial position, performance, and cash flow management. ³² ³⁷ The primary function of this stage requires organisations to use ESG disclosures to support their strategic planning and resource distribution activities. Financial reporting now requires sustainability integration, with the corporate report serving as the main platform that unites sustainability data and financial performance information. ³⁶ ⁴² ⁶² ⁶⁷ In this stage, companies must publish sustainability disclosures as part of their general financial reports and within the same cycle as their financial statements. ²⁷ The standards require organisations to report on four elements, which include governance, strategy, risk management, and metrics & targets that follow the TCFD framework. ¹ ³²

Academic literature contains limited information about ISSB best-practice cases of implementation, because most research focuses on standard-setting procedures and conceptual debates rather than concrete corporate practices. Nevertheless, Allianz’s Annual Report illustrates how companies are beginning to implement ISSB Standards. ⁶⁸ The finance department took over sustainability reporting at Allianz before IFRS S1 and S2 implementation, integrating ESG information into financial data governance and control structures. This integration ensures consistency in data collection, validation, and assurance processes. ⁶⁹ The company has added a dedicated Sustainability Statement to its annual report, which highlights how ESG matters are embedded in financial reporting and thereby reflects the integration objective of Phase 4. ⁶⁸ The World Economic Forum presents Allianz through a case study, which shows their approach to mandatory sustainability reporting by focusing on their efforts to obtain trustworthy value-chain data and their commitment to deliver information that supports decision-making. ⁷⁰ The company follows IFRS S1 by publishing ESG disclosures simultaneously with its financial results and demonstrates its approach to financial performance, risk management, and long-term value creation through climate scenario analyses and net-zero targets. ³¹

Following the Allianz example, it is useful to examine the key factors that explain why and how companies adopt IFRS S1 and S2. In contrast to the earlier phases, the drivers at this stage are primarily externally oriented. They reflect the increasing demand from global investors and regulators to make sustainability visible in official financial reports. The fourth stage relies on institutional factors together with international disclosure requirements rather than operational aspects. A first important driver is the global demand for harmonised sustainability information. The growing fragmentation of frameworks has increased complexity and reduced comparability, thereby reinforcing calls for a global baseline. ⁷ The demand for sustainability reporting received backing from international organisations, including IOSCO, which actively supported the ISSB initiative. ² A second driver is the governance and legitimacy of the IFRS Foundation. ¹ The IASB preserves its authority through its achievement of global accounting standard adoption in 140 nations, which enables the IFRS Foundation to build institutional credibility for sustainability reporting standard adoption. ² ³² The ongoing process between the ISSB and the IFRS Foundation strengthens trust between regulators and market participants, thereby facilitating the global adoption of the ISSB framework. Finally, investor demand for financially material information acts as a strong driver. As discussed earlier, the ISSB addresses this through its single-materiality approach, which ensures comparability and relevance for capital markets. ⁵⁶

In contrast, the ISSB faces several obstacles that limit the effective implementation of its standards. Some of these challenges, already identified in earlier phases, remain particularly relevant at this stage. First, companies encounter materiality concepts as one of their primary external challenges. ¹⁴ This divergence in materiality approaches can act as a driver (see 4.4.1), but at the same time it functions as a barrier, because companies operating across jurisdictions face conflicting expectations that complicate implementation and risk undermining the global acceptance of the standards. ³⁰ Furthermore, the IFRS Foundation faces challenges because it does not possess enough expertise or trustworthiness when dealing with sustainability matters. The lack of ESG focus throughout history, together with restricted academic involvement, has resulted in non-investor stakeholders developing distrust. ⁴ At this stage, resource constraints become particularly critical because firms must integrate sustainability disclosures directly into their financial reporting cycle. ³¹ ³² This requires synchronising ESG and financial data systems, building robust controls, and preparing disclosures within the same timelines as financial statements. Such integration demands significant investment in IT infrastructure and skilled staff, which many companies in developing markets cannot provide due to limited absorptive capacity and inadequate infrastructure. ⁶²

5.5 Continuous improvement & assurance

In the last phase of implementation, the focus shifts to the continuous improvement of sustainability reporting and the establishment of assurance practices. The reporting process under IFRS S1 and IFRS S2 requires continuous learning and improvement as an ongoing activity. Organisations must perform regular evaluations of their governance systems, strategic plans, risk management approaches, and performance indicators to keep their disclosure information accurate and relevant. ²⁷ ³¹ The ISSB implemented this principle through its standard-setting process by releasing draft versions for public review before undergoing multiple revisions, which resulted in the final standards in 2. Its current work plan continues this approach by providing implementation support and revising the SASB Standards. ²⁴ Continuous improvement means approaching sustainability reporting as an ongoing process. Organisations build feedback systems, strengthen learning, and adjust to regulatory changes. ²⁵ It also involves monitoring relevant frameworks and adjusting reporting accordingly. The method enables companies to achieve clearer data and more consistent results, thereby improving the comparability of disclosures. This reduces the risk that disclosed information becomes obsolete for investors. ³² Studies show that firms with stronger absorptive capacity are more able to take in feedback and turn it into concrete changes in reporting. ⁶²

The second important element in this phase is assurance, which is not required by the ISSB, although several countries have already made it mandatory. ³² For example, the EU requires companies reporting under ESRS to get their sustainability information verified by independent external experts. ³⁷ Independent checks increase the credibility of reports and address investor demand for trustworthy information. ⁴² External reviews enhance reliability because they build market trust, ensuring that sustainability disclosures remain useful over time. ¹⁵ The IAASB’s proposed ISSA 5000 standard provides the first global framework for sustainability assurance, aiming to establish consistent practices across jurisdictions. ⁷¹ Recent developments indicate that external assurance has become an essential requirement for producing high-quality reports and is expected to gain further importance in the coming years, although challenges remain in terms of cost, consistency, and the verification of qualitative data. ⁴²

Translating this into practice requires robust routines and documentation. ³¹ PwC recommends that businesses establish specific KPIs and maintain comprehensive audit documentation when conducting sustainability data assessments with the same level of rigour as financial audits. ³⁸ ⁶¹ These measures result in reliable, traceable, and consistent sustainability disclosures by implementing internal control systems and external validation processes, which provide capital markets with dependable information. ³² Companies can also benchmark their performance against these standards through the WEF/Big4 ESG metrics initiative (a joint project by the World Economic Forum and the four largest audit firms to create cross-industry sustainability benchmarks). ⁷⁰ This process enables organisations to build a continuous improvement system that incorporates strong assurance mechanisms to enhance disclosure reliability and meet investor and stakeholder requirements. ³⁸ ⁴²

The development of a continuous improvement and assurance system depends on both internal and external drivers. A first external driver is the ISSB’s own standard-setting procedure. The ISSB distributed draft versions, and stakeholders provided feedback to help shape the development of subsequent proposals until the final standards were issued in June 2. The reporting process follows a continuous cycle, which shows that it requires ongoing improvement through multiple rounds of development and adjustment. This approach was reinforced through transition reliefs, such as the temporary exclusion of Scope-3 data and the climate-first sequencing of disclosures. ³¹ ³² Second, an internal driver results from the implementation of SASB Standards through IFRS S1. ²⁴ ³¹ Organisations need to apply SASB metrics that match their industry sector when they conduct sustainability risk and opportunity assessments and disclosure processes. The reporting system needs to adapt its requirements when SASB metrics undergo changes. Therefore, companies must disclose their performance data using sector-based metrics, which enables effective result assessments. ²⁴ ³⁵ Research supports the effectiveness of such disclosures for capital market decision-making. ¹⁸ Evidence also shows that precise, company-specific disclosures add value, while generic reporting can reduce it. Investors who want to confirm the dependability of their investments represent the third external element that pushes organisations to implement ESG reporting. Investors now demand that sustainability information must be both relevant and reliable. External assurance addresses this expectation by reducing information gaps and enhancing report reliability. Third-party verification functions as a strategic business asset that helps organisations protect their reputation while establishing trust with their stakeholders. Stakeholders emphasize that assurance is necessary for the ISSB to produce trustworthy reports based on consultation outcomes, although the ISSB does not require it. The credibility of reports is considered to depend on their auditability. ³ ¹³ ⁴²

By contrast, the fifth phase of the process emphasises the establishment of a continuous reporting cycle that evolves with each iteration. At the same time, it entails considerable challenges that require ongoing organisational commitment. The main external challenge stems from the need for substantial financial investment to establish new reporting systems and assurance procedures. Companies must invest in advanced data management tools, robust internal controls, and extensive staff training to implement IFRS S1/S2. ³² ⁶² The requirements of these standards often exceed the available resources of many SMEs. ⁴³ The initial costs of Scope 3 reporting are reduced through transitional reliefs, as companies can adopt the requirements gradually or use temporary exemptions. ³¹ ³² However, this support applies only at the outset, since ongoing improvement still requires annual updates of data systems and broader assurance coverage. ³² Financial limitations therefore remain a persistent obstacle that hinders the ability of firms to maintain reliable disclosure practices over time. ⁴² A critical internal barrier to continuous improvement is the difficulty of maintaining reliable data that needs continuous refinement and verification between reporting periods. The challenge in monitoring Scope 3 emissions comes from the fact that supply chain data is fragmented, while social performance indicators follow no common standard. ⁴² The measurement approaches used in different sectors operate independently from one another because no universal measurement standards exist. ³ The process of verifying disclosures faces further difficulties because assurance providers identify two main barriers: inadequate calculation models and unverified external information sources. The intended iterative learning process becomes slower because companies must proceed step by step to expand data coverage and develop internal controls. ³² ⁴² ⁶² Third, effective implementation depends on specific expertise and the ability to integrate new information. On the internal side, companies are expected to develop expertise in sustainability data, scenario modelling, and sector-based metrics. ⁴⁰ In practice, this knowledge is often lacking, which makes proper implementation of the standards more difficult. Organisations with low absorptive capacity struggle to translate regulatory requirements and assurance feedback into concrete reporting improvements. ³¹ ³² ⁶² On the external side, the situation is also constrained, as in many markets there are not enough qualified auditors to deliver reliable assurance. ³¹ The current shortage of third-party verifiers limits the ability of businesses to use verification as a means of establishing credibility, which weakens the effectiveness of this last stage. ¹⁵ ⁴²

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1
De Villiers, C., Dimes, R., La Torre, M. & Molinari, M. The International Sustainability Standards Board’s (ISSB) past, present, and future: critical reflections and a research agenda. Pacific Accounting Review 36, 255–273 (2024).
2
Bohn, L., Macagnan, C. B. & Kronbauer, C. A. Navigating legitimacy: diverse stakeholder perspectives on the IFRS Foundation’s establishment of the ISSB. Meditari Accountancy Research 33, 86–113 (2025).
3
Barker, R. Corporate sustainability reporting. Journal of Accounting and Public Policy 49, 107280 (2025).
4
Adams, C. A. & Mueller, F. Academics and policymakers at odds: the case of the IFRS Foundation Trustees’ consultation paper on sustainability reporting. Sustainability Accounting, Management and Policy Journal 13, 1310–1333 (2022).
5
Hardin, G. The Tragedy of the Commons. Science 162, 1243–1248 (1968).
6
Carungu, J., Di Pietra, R., Molinari, M. & Nicolò, G. Confronting sustainability grand challenges: how do standard-setters shape sustainability reporting standards and accountability practices? Accounting, Auditing & Accountability Journal (2025) doi:10.1108/AAAJ-06-2024-7142.
7
Adams, C. A. & Abhayawansa, S. Connecting the COVID-19 pandemic, environmental, social and governance (ESG) investing and calls for ‘harmonisation’ of sustainability reporting. Critical Perspectives on Accounting 82, 102309 (2022).
8
United Nations General Assembly. Transforming Our World: The 2030 Agenda for Sustainable Development. https://sdgs.un.org/2030agenda (Accessed 15 June 2025).
9
Sobkowiak, M., Cuckston, T. & Thomson, I. Framing sustainable development challenges: accounting for SDG-15 in the UK. Accounting, Auditing & Accountability Journal 33, 1671–1703 (2020).
10
Elidrisy, A. Comparative Review of ESG Reporting Standards: ESRS European Sustainability Reporting Standards” versus ISSB “International Sustainability Standards Board. International Multilingual Journal of Science and Technology 9, (2024).
11
Ali, I., Fukofuka, P. T. & Narayan, A. K. Critical reflections on sustainability reporting standard setting. Sustainability Accounting, Management and Policy Journal 14, 776–791 (2023).
12
Schiehll, E. & Kolahgar, S. Common ownership and investor‐focused disclosure: Evidence from ESG financial materiality. Business Strategy and the Environment 34, 497–515 (2025).
13
Pizzi, S., Principale, S. & De Nuccio, E. Material sustainability information and reporting standards. Exploring the differences between GRI and SASB. Meditari Accountancy Research 31, 1654–1674 (2023).
14
Oll, J., Spandel, T., Schiemann, F. & Akkermann, J. The concept of materiality in sustainability reporting: from essential contestation to research opportunities. Sustainability Accounting, Management and Policy Journal 16, 321–350 (2025).
15
La Torre, M., Sabelfeld, S., Blomkvist, M. & Dumay, J. Rebuilding trust: sustainability and non-financial reporting and the European Union regulation. Meditari Accountancy Research 28, 701–725 (2020).
16
Rowbottom, N. Orchestration and consolidation in corporate sustainability reporting. The legacy of the Corporate Reporting Dialogue. Accounting, Auditing & Accountability Journal 36, 885–912 (2023).
17
Diwan, H. & Amarayil Sreeraman, B. From financial reporting to ESG reporting: a bibliometric analysis of the evolution in corporate sustainability disclosures. Environment, Development and Sustainability 26, 13769–13805 (2023).
18
Bochkay, K., Hales, J. & Serafeim, G. Disclosure standards and communication norms: evidence of voluntary sustainability standards as a coordinating device for capital markets. Review of Accounting Studies (2025) doi:10.1007/s11142-025-09882-8.
19
Abhayawansa, S. Swimming against the tide: back to single materiality for sustainability reporting. Sustainability Accounting, Management and Policy Journal 13, 1361–1385 (2022).
20
Elkington, J. Accounting for the Triple Bottom Line. Measuring Business Excellence 2, 18–22 (1998).
21
Beske, F., Haustein, E. & Lorson, P. C. Materiality analysis in sustainability and integrated reports. Sustainability Accounting, Management and Policy Journal 11, 162–186 (2020).
22
Hahn, R. & Kühnen, M. Determinants of sustainability reporting: a review of results, trends, theory, and opportunities in an expanding field of research. Journal of Cleaner Production 59, 5–21 (2013).
23
Eng, L. L., Fikru, M. & Vichitsarawong, T. Comparing the informativeness of sustainability disclosures versus ESG disclosure ratings. Sustainability Accounting, Management and Policy Journal 13, 494–518 (2022).
24
IFRS Foundation. SASB Standards. IFRS Sustainability https://sasb.ifrs.org (Accessed 4 June 2025).
25
Busco, C., Consolandi, C., Eccles, R. G. & Sofra, E. A Preliminary Analysis of SASB Reporting: Disclosure Topics, Financial Relevance, and the Financial Intensity of ESG Materiality. J Applied Corp Finance 32, 117–125 (2020).
26
International Sustainability Standards Board (ISSB). IFRS Foundation https://www.ifrs.org/groups/international-sustainability-standards-board (Accessed 29 May 2025).
27
Teixeira, A. An Architecture for General-purpose Financial Reporting – The Development of ISSB Sustainability Disclosure Standards. SSRN Electronic Journal (2023) doi:10.2139/ssrn.4492082.
28
Carvalho, A. R. & Lopes, A. I. Determinants of Voluntary Adoption of SASB Standards to Disclose Sustainability Issues: An International Perspective. Research in Production and Development 11, 16 (2025).
29
Kulik, A. & Dobler, M. Stakeholder participation in the ISSB’s standard-setting process: the consultations on the first exposure drafts on sustainability reporting. Sustainability Accounting, Management and Policy Journal 14, 349–380 (2023).
30
Giner, B. & Luque-Vílchez, M. A commentary on the “new” institutional actors in sustainability reporting standard-setting: a European perspective. Sustainability Accounting, Management and Policy Journal 13, 1284–1309 (2022).
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IFRS Foundation. IFRS S1 Basis for Conclusions on General Requirements for Disclosure of Sustainability-Related Financial Information. (2023).
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35
Hales, J. Sustainability Accounting Standards Board (SASB). in Sustainability Accounting Standards Board (SASB) vol. 3 37–41 (World Scientific Publishing, 2021).
36
De Villiers, C. & Dimes, R. Will the formation of the International Sustainability Standards Board result in the death of integrated reporting? Journal of Accounting & Organizational Change 19, 279–295 (2023).
37
Krivogorsky, V. Sustainability reporting with two different voices: The European Union and the International Sustainability Standards Board. Journal of International Accounting, Auditing and Taxation 56, 100635 (2024).
38
Samans, R. & Nelson, J. Sustainable Enterprise Value Creation: Implementing Stakeholder Capitalism through Full ESG Integration. (Springer International Publishing, Cham, 2022). doi:10.1007/978-3-030-93560-3.
39
De Villiers, C., La Torre, M. & Molinari, M. The Global Reporting Initiative’s (GRI) past, present and future: critical reflections and a research agenda on sustainability reporting (standard-setting). Pacific Accounting Review 34, 728–747 (2022).
40
IFRS Foundation & EFRAG. ESRS–ISSB Standards Interoperability Guidance. https://www.ifrs.org/content/dam/ifrs/supporting-implementation/issb-standards/esrs-issb-standards-interoperability-guidance.pdf (2024).
41
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42
Millar, J. & Slack, R. Global investor responses to the International Sustainability Standards Board draft sustainability and climate-change standards: sites of dissonance or consensus. Sustainability Accounting, Management and Policy Journal 15, 573–604 (2024).
43
Afolabi, H., Ram, R. & Rimmel, G. Influence and behaviour of the new standard setters in the sustainability reporting arena: implications for the Global Reporting Initiative’s current position. Sustainability Accounting, Management and Policy Journal 14, 743–775 (2023).
44
IFRS Foundation. The Jurisdictional Journey towards Globally Comparable Information for Capital Markets: Inaugural Jurisdictional Guide for the Adoption or Other Use of ISSB Standards. https://www.ifrs.org/content/dam/ifrs/supporting-implementation/adoption-guide/inaugural-jurisdictional-guide.pdf (Accessed 30 May 2025).
45
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46
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47
Freeman, R. E. Stakeholder Theory: The State of the Art. (Cambridge University Press, Cambridge, 2010).
48
Dowling, J. & Pfeffer, J. Organizational Legitimacy: Social Values and Organizational Behavior. The Pacific Sociological Review 18, 122–136 (1975).
49
Suchman, M. C. Managing Legitimacy: Strategic and Institutional Approaches. The Academy of Management Review 20, 571 (1995).
50
Leeson, R. & Kuszewski, J. GRI and stakeholder engagement: setting standards in the public interest. Sustainability Accounting, Management and Policy Journal 14, 877–883 (2023).
51
Deegan, C. M. Legitimacy theory: Despite its enduring popularity and contribution, time is right for a necessary makeover. Accounting, Auditing & Accountability Journal (2019) doi:10.1108/AAAJ-08-2018-3638.
52
Richardson, A. J. & Eberlein, B. Legitimating Transnational Standard-Setting: The Case of the International Accounting Standards Board. Journal of Business Ethics 98, 217–245 (2011).
53
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