GRI, SASB, ISSB, and the claim that does not hold up

One claim, tested

Tamarack Outfitters’ annual report says: “Our stores are carbon-neutral.” Before a reader can accept that sentence, three questions have to be answered: under which framework is it reported, to whom is it material, and what evidence stands behind it? Those three questions are this lesson.

The landscape, and how it consolidated

For twenty years sustainability reporting had several competing frameworks, each with its own audience:

• GRI (Global Reporting Initiative) — impact-focused and multi-stakeholder: what the company does to the world, reported for society, regulators and communities.
• SASB (Sustainability Accounting Standards Board) — investor-focused and industry-specific: which sustainability topics are financially material for, say, an apparel retailer versus a mining company.
• Integrated Reporting (<IR>) — a framework for telling the value-creation story across six capitals (financial, manufactured, intellectual, human, social, natural).

In 2021 the IFRS Foundation created the International Sustainability Standards Board (ISSB). During 2022 it absorbed the CDSB and, on 1 August 2022, the Value Reporting Foundation — the home of SASB and <IR>. In June 2023 the ISSB issued IFRS S1 (General Requirements for Disclosure of Sustainability-related Financial Information) and IFRS S2 (Climate-related Disclosures), effective for periods beginning 1 January 2024, subject to each jurisdiction adopting them. SASB did not vanish: S1 requires a reporter to refer to and consider the SASB industry topics when deciding what to disclose. So the right picture is not “SASB is the standard” but “SASB is the industry layer beneath IFRS S1”. GRI continues alongside as the impact-reporting standard.

Canada, as at 17 September 2026

The Canadian Sustainability Standards Board (CSSB) issued CSDS 1 and CSDS 2 — the Canadian adoptions of S1 and S2 — on 18 December 2024, effective for periods beginning 1 January 2025. They are voluntary unless a regulator or government mandates them, and they give Canadian reporters longer transition reliefs than the ISSB’s one year: climate-first reporting for up to two years and Scope 3 relief for three.

No securities regulator has mandated them. The CSA proposed a climate-disclosure rule (NI 51-107) in October 2021 and never finalised it; on 23 April 2025 it paused both its climate and its diversity disclosure projects, while restating that material climate-related risk is already disclosable under existing continuous-disclosure rules and that misleading disclosure, including greenwashing, remains enforceable. So for a Canadian public company today: sustainability disclosure under CSDS is voluntary; disclosure of material climate risk is not.

Financial versus impact materiality

Financial materiality — the IFRS S1 test, aligned with the accounting standards — asks whether omitting or misstating the information could reasonably be expected to influence the decisions of the primary users of general-purpose financial reports: investors, lenders and creditors. Impact materiality — GRI’s test — asks whether the company’s effect on people or the environment is significant, regardless of whether it feeds back into the company’s cash flows. Reporting under both is called double materiality. Tamarack’s carbon-neutral claim is financially material if customers, lenders or a future carbon price make it so; it is impact-material if the emissions themselves matter to society.

What would make the claim hold up

Greenwashing is a sustainability claim that is unsupported, exaggerated or misleading. To accept “carbon-neutral” a reader would ask: which scopes does the claim cover (stores’ Scope 1 and 2 only, or the supply chain too)? How were emissions measured, and against which standard? How much of the neutrality comes from offsets, and are they verified? Is there third-party assurance over the figures? A claim that cannot answer those questions is marketing. It is also a faithful-representation problem in the Module 1 sense — neither complete nor neutral — with reputational, regulatory and litigation risk attached.

The informal layer: culture and tone at the top

A framework tells a company what to disclose; it cannot make the people inside it want to tell the truth. Whether a claim like “carbon-neutral” is tested before it is printed depends on the company’s organisational culture — its shared, unwritten assumptions about how things are done — and specifically on its ethical climate: what employees believe the company actually rewards when a number is inconvenient. Module 5 covered the formal governance layer — board, committees, auditor. Culture is the informal layer underneath it, and three things set it:

• Tone at the top. What the CEO and the board do, not what they say. A CEO who asks “is it true?” before “does it sell?” teaches the marketing team to check the offsets; one who celebrates the slogan teaches them not to.
• A code of conduct. The written statement of expected behaviour, signed annually, that turns the tone into a rule staff can point to when pushed.
• A whistle-blower channel. The confidential hotline the audit committee must establish (NI 52-110 s. 2.3(7)) so that an employee who knows the claim is hollow can say so without going through the manager who made it.

The accounting link is direct. Every self-graded estimate in this course — NRV, recoverable amount, the probability of losing a lawsuit, a warranty rate — is only as faithful as the culture that produced it. A strong tone at the top is a control over the numbers; a weak one is the reason greenwashing and earnings management appear together.