Why Letting Jurisdictions Choose Their Own GWP Values Threatens Comparability

As part of our submission to the ISSB’s Exposure Draft on amendments to IFRS S2, Eco Sustainability has formally registered its stance.

In this opinion editorial, we offer our insights and position. To view our Technical Opinion, please see the full text of our formal submission.

Full Text From ISSB Exposure Draft

Question 4 — Applicability of jurisdictional relief for global warming potential values

The ISSB proposes to amend paragraphs B21–B22 of IFRS S2 to extend the jurisdictional relief in the Standard. The ISSB proposes that if an entity is required, in whole or in part, by a jurisdictional authority or exchange on which it is listed to use global warming potential (GWP) values other than the GWP values required by IFRS S2, the entity would be permitted to use the jurisdictionally required GWP values for the relevant part of the entity, for as long as that requirement applies.

Paragraphs BC44–BC49 of the Basis for Conclusions describe the reasons for the proposed amendment.

Do you agree with the proposed amendment? Why or why not?

☐ Broadly agree

☑ Broadly disagree

☐ Neither agree nor disagree

We Broadly Disagree

Eco Sustainability broadly disagrees with the proposal to allow jurisdictional relief for the use of alternative GWP values. While we recognise the intention to support local compliance, we believe this approach undermines global consistency, scientific credibility, and stakeholder trust in sustainability disclosures.

Why This Matters

1. It breaks global comparability. Allowing different GWP datasets across jurisdictions (for example, AR4 versus AR6) results in significant variations in reported emissions. This is particularly problematic for short-lived climate pollutants like methane, where GWP values differ substantially. The result is data that cannot be reliably compared between companies or countries.

2. It weakens core reporting principles. The GHG Protocol and ISO 14064 are built on principles of consistency, transparency, and comparability. Allowing divergent GWP values violates these principles and increases the risk of misinterpretation or manipulation.

3. It sends mixed signals to investors and regulators. Inconsistent GWP values distort emissions baselines and performance trends. This creates confusion in transition planning, climate risk assessments, and financial modelling.

4. It complicates verification and assurance. When different GWP values are used across a company’s operations, it becomes harder for third-party verifiers to confirm the accuracy and completeness of the data. This weakens the credibility of the disclosures.

Our Recommendation

Eco Sustainability recommends that the ISSB reject broad jurisdictional relief for GWP values. Instead, we propose the following:

1. Require dual disclosure. Entities should report emissions using the IFRS-aligned GWP (such as AR6), and where required by local authorities, provide a secondary calculation using the jurisdictionally mandated GWP. Both figures should be disclosed with a clear explanation of the difference.

2. Provide reconciliation guidance. ISSB should issue guidelines on how to explain differences in GWP assumptions, so that users of sustainability reports can understand and compare disclosures across markets.

3. Avoid permanent exemptions. Where local GWP requirements exist, temporary relief may be acceptable. However, it should come with a clear roadmap toward full alignment with IFRS S2.

4. Support capacity building. Help jurisdictions transition toward consistent GWP frameworks by providing mapping tools and technical support.

Conclusion

Scientific integrity cannot be location-dependent. GWP values should not vary by geography if the goal is to produce meaningful, comparable emissions disclosures. While we support accommodating local realities, this must not come at the expense of global alignment. A unified approach protects credibility, enables fair comparison, and strengthens confidence in sustainability reporting.

About Eco Sustainability

As a trusted advisor on sustainability and climate policy, Eco Sustainability is not only aligned with global standards. We help shape them by actively engaging in technical consultations and contributing to international standard-setting processes.