Members of the NYSSCPA's Sustainability Committee, in a recent comment letter, expressed support for the the IFRS Foundation creating a new Sustainability Standards Board (SSB), saying it was the best way to establish consistent and comparable international sustainability accounting and reporting standards.

The Society was responding to a concept paper released by the IFRS Foundation in October, which asked for comment on how the foundation could contribute to sustainability reporting, in particular cutting down on the confusion that has arisen from the veritable galaxy of standards and frameworks available. One possibility raised in the paper, among several, was for the foundation to create a new Sustainability Standards Board that would create and maintain standards in a manner similar to the financial reporting standards it already oversees.

Such a board, said the paper, would initially be focused entirely on climate change risk, but left open the possibility that, as time goes on, expanding its focus into other areas of sustainability reporting. It would operate alongside the IASB, and the two boards would benefit from the increasing interconnectedness between financial reporting and sustainability reporting.

The Society, in its comment letter, said the formation of a new board would help standardize sustainability reporting, which would "advance the goal of comprehensive corporate reporting, by creating a single globally recognized authority for guidance on both financial and sustainability reporting, which would in turn facilitate the creation of integrated reports." As far as the board itself, the Society said that "the IFRS Foundation should avoid the expenses, conflicts and delays that will occur if they strive to recreate the existing expertise and processes of the leading sustainability and integrated reporting organizations." Instead, the Society urged the foundation to fill the seats with representatives from the major organizations, namely the Sustainability Accounting Standards Board, the International Integrated Reporting Council, the Global Reporting Initiative, the Carbon Disclosure Project, and the Climate Disclosure Standards Board.

"We suggest providing seats on the envisioned SSB board to at least two representatives from the Group of 5 and encourage the SSB to delegate a significant amount of their work to the Group of 5," said the Society.

Some members of this group of five have also commented on the IFRS Foundation proposal, though so far no member has explicitly gone out and expressed support for the a new board.