28 Nov 2013
Responses to the consultation did not avoid addressing significant issues however, with even the fundamental terminology – including the term “integrated reporting” – coming under stakeholder scrutiny for being allegedly too confusing or insufficiently defined.
Key technical issues raised in the comment process included:
There were plenty of questions on materiality. Only 22% of respondents “fully agreed” with the IIRC’s proposed approach, while 39% disagreed and had a major qualification. But a further 33% agreed with minor qualifications - so overall more than half supported the materiality proposals. The split between providers of capital (on whom the framework’s principles are focused) and preparers of reports was very marked, with 88% of providers agreeing with the IIRC’s definition, and the majority of report preparers disagreeing (52%).
Deeper responses on materiality were varied. Concerns were raised over prioritising the providers of financial capital over other stakeholders; treating investors as a homogenous group; and confusion with a “growing pool of materiality definitions”. Respondents were clearly uncomfortable with the legal ‘baggage’ associated with materiality – including litigation risk arising from multiple materiality thresholds in other reporting frameworks.
The IIRC’s response to such concerns has been relaxed. In their view, the framework is seen as a work in progress that will evolve as practice evolves. “It’s important to understand that first,” said Mark O’Sullivan, a Corporate reporting director at PwC and one of the IIRC’s Working Group members “the framework was subject to comment from a multi-stakeholder group, so a difference of opinion isn’t worrying, and second, it is not and will not be final – it’s a starting point.”
Responses also demonstrated an appetite for “those charged with governance” to include a statement acknowledging responsibility for the integrated report. But they expressed confusion and concern over the legal implications of such a statement – especially over forward-looking information.
The IIRC itself is understood to be concerned about enforcing sign-off on every element of the report, because it may discourage companies from including the information that makes the report truly integrated.
With the framework published, the IIRC will turn their attention to analysing how integrated reports are being prepared. The rest of their work will focus on market testing, monitoring regulatory action and encouraging adoption.