Enhancing Biodiversity - Sustainability Reporting in the Bailiwick of Guernsey

1. Introduction

This paper provides feedback on the responses received to the Commission’s Discussion Paper (“DP”) on The Future of Sustainability Reporting in the Bailiwick of Guernsey issued in July 2024.

1.1 Who is affected by the proposals in this paper?

The paper sets out a policy position and makes specific proposals to amend governance and anti-greenwashing obligations which are relevant to all persons supervised by the Commission.


1.2 Background 

The DP noted the importance and relevance of sustainability-related risk to the financial services industry and sought to explore the next steps which are being taken and which might be taken in the Bailiwick in the future to meet the challenges presented.

The DP provided a summary of international developments in the area of sustainability reporting, including the work of the International Sustainability Standards Board (ISSB). The paper sought to gather information and views from the finance sector on the potential impact of the introduction of the standards that have been issued by the ISSB. 

The DP also sought views on additional steps which might be taken to enhance licensees’ sustainability risk governance and management.

The Commission received 39 responses to the DP from a wide range of persons, including supervised entities across the full spectrum of financial services sectors, industry associations representing supervised entities, professional services firms, and sustainability and technology consultants.

The Commission would like to thank all respondents for providing their feedback to the DP.

1.3 International developments 

Following the publication by the International Sustainability Standards Board of its two disclosure standards (the “ISSB Standards”) in 2023 there has been progress in developing disclosure frameworks internationally with the International Financial Reporting Standards Foundation estimating that jurisdictions representing approximately 57% of global GDP had made progress towards the adoption or other use of ISSB Standards [1]. Certain significant jurisdictions have recently modified or slowed the pace of implementation of corporate sustainability disclosure regimes.

• The consultation on the UK’s Sustainability Reporting Standards (SRS), based on the ISSB Standards, has only just recently commenced, although this represents just the first steps in the potential endorsement of the standards by the UK government, for use initially on a voluntary basis.  The FCA is yet to consult on proposals to require the use of any such endorsed UK SRS by listed companies, and the UK government has yet to complete an assessment of the merits of such requirements for entities outside of the FCA’s remit.
• Reflecting a change in the political landscape, in March the US Securities and Exchange Commission voted to end its defence of the climate disclosure rules for large corporations, introduced in 2024, which indicates a change of approach to one aligned with the priorities of the new US Government.
• In February 2025 the European Commission adopted proposals for an Omnibus Directive aiming to simplify sustainability reporting requirements removing an estimated 80% of companies from the scope of the Corporate Sustainability Reporting Directive (CSRD).

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[1] International Financial Reporting Standards Foundation - Progress on Corporate Climate-related Disclosures—2024 Report