유럽, 미국, IFRS 지속가능성 공시기준(안)의 특징 분석 및 회계학적 고찰

초록

Recently the establishment of sustainability disclosure standards(SDS) and the revision of related regulation are being expedited worldwide. South Korea is not an exception. SDS is expected to play an important role in financial and nonfinancial reporting of firms in conjunction with existing accounting disclosure standards. This exploratory study compares and contrasts the characteristics of SDS(rules) of Europe, US, and IFRS, and critically discusses their accounting implications. Firstly, it explores the meaning of the establishment of new standards, given the existing accounting disclosure standards is already in place to dictate the reporting of material information concerning sustainability-related matters. IFRS accounting standards and US GAAP require that the material sustainability-related information shall be reported in financial statements, which include notes to the financial statements. The recent regulatory move toward the establishment of SDS reflects the partial failure(inability) of the accounting disclosure standards to fully enforce the full reporting of sustainability-related information in financial statements. This study compares and discusses the approaches EU, US, and IFRS have taken to address this issue. Secondly, given the partial failure of the existing accounting disclosure standards to induce full disclosure of sustainability-related information, the basic issue on hand is which part of the financial statements could be problematic with regard to the disclosure of sustainability-related information: the mis-presentation of numbers in the financial statements, insufficient information on the numbers in the notes to the financial statements, and/or insufficient information on things material yet not enough to be recognized in financial statements(except notes). This study compares and discusses how the SDS(rules) of EU, US, and IFRS are related to this issue. Thirdly, it compares and contrasts the management latitude embedded in three SDS(rules) in terms of “materiality” in determining the items to be disclosed. This issue is especially important given that the recent worldwide move towards the establishment of SDS is partially rooted on the fact that the principle-based disclosure requirements coupled with “materiality” principle has not been effective in inducing a full disclosure of sustainability-related information, in the context of accounting disclosure standards and/or voluntary sustainability-related information disclosure system. The “materiality” principle present in SDS entails at least three important questions. First is how can the management identify material information from the perspective of investors, in the face of the difficulty of monetizing the effects of the ESG matters, which are mostly forward-looking, uncertain, and soft information? The next related question is how SDS can induce a true and fair presentation of sustainability-related information? The problem arises from the presence of agency problems in general business situations, which makes worse the reporting environment. For example, the low possibility of being caught for mis-reporting of forward-looking soft information would give the management a wrong incentive to distorting the information for the benefit of management itself and/or present investors at the cost of current and/or future investors. Finally, considering the characteristics of sustainability-related information, the assurance of sustainability information becomes largely troublesome. This makes assurance providers more dependent on the management for the application of materiality principle as well as assurance, compared to the assurance of accounting information. Thus a reasonable assurance of sustainability=related information, up to the level applied to the assurance of accounting information, seems almost not possible. Considering all these, it is not easy to imagine how the materiality principle applied to SDS, especially present in IFRS SDS, will work in practice. With regard to the application of materiality principle, EU is the most stringent among three SDS(rules)-setting bodies, in that it specifies disclosure requirements specifically and declares that they are presumed to be material “until proven untrue”. IFRS bestows the most latitude to the management, consistent with its accounting standards, which makes its SDS in reality not significantly different from existing voluntary disclosure standards(frameworks). US rather adopts a mixed approach, focusing on the strict regulation towards more detailed reporting of the effects of climate-related matters on the numbers of the financial statements in notes to the financial statements, while it relies on materiality principle for other soft information subject to a filing requirement. At the time of writing, EU and US regulatory bodies are holding a rather strong position with regard to the exposure drafts of their SDS(rules), suggesting the possibility of their integration in the near future be very low. Above all, EU adopts double materiality principle, which makes EU SDS distinct from US rules and IFRS SDS. This poses a great challenge to the integration of those SDS(rules). Further, their stance concerning the application of materiality principle is also quite different from one another. Apart from the future of three SDS(rules), the regulatory move towards the disclosure of sustainability-related information casts a lot of new research questions in the accounting field and also requires the integrated thinking in accounting, where financial accounting and managerial accounting are traditionally loosely coupled.

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