Table 1.

Comparability conceptualization by existing sustainability reporting standard setters

GRI standards (2021)
Comparability-related statementsFocusFacets
The organization shall select, compile and report information consistently to enable an analysis of changes in the organization’s impacts over time and an analysis of these impacts relative to those of other organizationsConsistency in selection
Consistency in the measurement method
Comparison over time 
Inter-firm comparison
Facet 1
Facet 3
Facet 2
Facet 2
Information reported in a comparable way enables the organizations and other users to assess the organization’s current impacts against its past impacts and its goals and targetsComparison over time, against goals and targetsFacet 2
It also enables external parties to assess and benchmark the organization’s impacts against impacts of other organizations as part of rating activities, investment decision and advocacy programsInter-firm comparisonFacet 2
To apply the comparability principle, the organization should:
–Present information for the current reporting period and at least two previous periods, as well as any goals and targets that have been set
Comparison over time, against goals and targetsFacet 2
–Use accepted international metrics (e.g. kilograms and litres) and standard conversion factors and protocols, where applicable for compiling and reporting information
–Maintain consistency in the methods used to measure and calculate data and in explaining the methods and assumptions used
–Maintain consistency in the manner of representing the information
–Report total numbers or absolute data (e.g. metrics, tons of CO2 equivalent) as well as ratios or normalized data (e.g. CO2 emissions per unit produced) to enable comparisons, and provide explanatory notes when using ratios
–Provide contextual information (e.g. the organization’s size, geographical location) to help information users understand the factors that contribute to differences between the organization’s impacts and the impacts of other organizations
–Present the current disclosures alongside restatements of historical data to enable comparisons if there have been changes in the information reported previously. This can include changes in the length of the reporting period, in the measurement methodologies, in the definitions used or in other elements of reporting. The organization is required to report restatements of information under Disclosure 2–4 in GRI 2: General Disclosures 2021
–If restatements of historical data are not provided, explain the changes to provide contextual information for interpreting the current disclosures
Measurement methodFacet 3
Consistency in measurement methodsFacet 3
Consistency in representationFacet 3
Measurement methodFacet 3
Provide details on context to ease inter-firm comparisonFacet 3
Provide details on restatements to ease comparison over timeFacet 3
Provide details on context to ease comparison over timeFacet 3
ESRS 1 General Disclosure principles (Exposure draft)
RequirementFocusFacets
33. Sustainability information is comparable when it is consistent over time, and to the greatest extent possible, presented in a way that enables comparisons between undertakings (across sectors and within a specific sector)Comparison over time
Inter-firm comparison
Facet 2
Facet 2
33. (continued) A point of reference for comparison can be a target, a baseline, an industry benchmark, comparable information from either other entities or from an internationally recognized organization, etcComparison over time, against goals and targets
Benchmarking
Facet 2
Facet 2
34. Consistency refers to the use of the same approaches or methods for the same sustainability matter, from period to period by the undertaking (as well as by other undertakings to the maximum extent possible)Consistency in measurement methods
Comparison over time
Inter-firm comparison
Facet 3
Facet 2
Facet 2
SASB standards
RequirementFocusFacets
Comparable: Metrics will yield primarily (a) quantitative data that allow for peer-to-peer benchmarking within the industry and year-on-year benchmarking for an issuer, but also (b) qualitative information that facilitates comparison of disclosureFocus immediately on item level, not a selection issue
Comparison over time
Comparison to other organizations
Facet 1
Facet 2
Facet 2
The standard includes activity metrics to measure the scale of the issuer’s business, providing operational context and facilitating normalization of SASB accounting metrics, which is important for the analysis of related disclosuresNormalization
Relative comparison to other organizations
Facet 3
Facet 3
Activity metrics may include high-level business data such as total number of employees, quantity of products produced or services provided, number of facilities or number of customers. They may also include industry-specific data such as plant capacity utilization (e.g. for specialty chemical companies), number of transactions (e.g. for internet media and services companies), hospital bed days (e.g. for health care delivery companies) or proven and probable reserves (e.g. for oil and gas exploration and production companies).
An issuer’s disclosure of these activity metrics should:
–Convey contextual information that would not otherwise be apparent from SASB accounting metrics
–Be deemed generally useful for investors relying on SASB accounting metrics in performing their own calculation and creating their own ratios
–Be explained and consistently disclosed from period to period to the extent they continue to be relevant
Provide details on context to ease relative comparison to other organizationsFacet 3
Exposure draft 1 IFRS S1 General requirements for disclosure of sustainability-related financial information
RequirementFocusFacets
C17. The decisions made by the primary users of general-purpose financial reporting involve choosing between alternatives; for example, selling or holding an investment, or investing in one reporting entity or anotherInter-firm comparisonFacet 2
Comparability is the characteristics that enables users to identify and understand similarities in, and differences among, items. Unlike the other qualitative characteristics, comparability does not relate to a single item. A comparison requires at least two items. Information is more to investors and creditors if it is also comparable, that is, if it can be compare with:
(a) Information provided by the entity in previous periods; and
(b) Information provided by other entities, in particular those with similar activities or operating within the same industry
Immediately on item level, no selection issue
Comparison over time
Inter-firm (with similar activities)
Facet 1
Facet 2
Facet 2
C19. Consistency is related to, but is not the same as, comparability. Consistency refers to the use of the same approach or methods for disclosures about the same sustainability-related risks and opportunities, from period to period, both by a reporting entity and other entities. Comparability is the goal; consistency helps to achieve that goalConsistency in measurement methods
Consistency in representation
Facet 3
Facet 3
Source: created by the authors, based on EFRAG (2022), GRI (2021), IFRS Foundation (2022) and SASB (2017) 

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