DATE: December 13, 2022
STATUS: Open for public comment
What makes a good investor impact report?
Who checks, and how?
Overview: Impact Frontiers is launching an effort in 2023 to build consensus on a common set of elements that any impact report verification should include by verifiers, reflecting a common set of elements that constitute complete and high-quality impact reporting by investors. These will serve as a shared foundation that will enable appropriate consistency among methodologies used by disparate third-party verifiers, increasing the amount and quality of information about impact that flows up the capital chain.
We will begin by comparing the beta impact performance report verification methodology drafted by BlueMark to other voluntary standards (e.g., IAASB ISAE 3000 (Revised), IAASB EER Guidance, AccountAbility AA 1000 AS), and release an exposure draft consensus methodology for feedback in mid-2023.
In Q1-Q2 2023 we are seeking input from verifiers, asset managers, asset owners, civil society organizations, industry associations, and standard-setters to help shape the exposure draft. In Q3-Q4 2023 will hold another roond of open feedback to improve the draft before handing it off to one or more voluntary-standard setters in early 2024.
Context: Impact reports produced by investors vary significantly in the quality and scope of information covered and are often of limited use to investor stakeholders wanting to critically evaluate those reports for their own impact performance management purposes. This variability/heterogeneity in reports is – in large part – due to a lack of clarity and guidance regarding what content an impact report should include, and who and how of assessing whether impact reports are complete and reliable.
While recent years have seen the emergence of standards and criteria for independent assessment of impact reporting practice, there has been less progress on an independent assessment of investors’ impact performance.
For third-party verification to advance transparency and accountability for impact performance will require a shared understanding throughout the sector regarding:
- The types of assessments available (e.g., assessment of the completeness of an impact report versus data assurance of the impact indicators within the report);
- The levels of assessment available (e.g., in financial audits, ‘reasonable assurance’ provides for review of a larger sample size and greater confidence than ‘limited assurance’ does);
- For each type and level of assessment, the process, standards, and criteria by which an investor’s impact performance report will be assessed; and
- The expected qualifications of verifiers.
Otherwise, there is a risk that report preparers and report consumers alike will struggle to understand whether different verifiers verify different things or with different methodologies.
The current moment – when impact performance report verification is still nascent but beginning to get traction – presents a critical opportunity to forestall the perception or the reality of a proliferation of potentially inconsistent verification frameworks with opaque criteria from multiple verifiers. There is an equally important opportunity to establish clear and transparent governance about how those criteria will evolve over time.
In 2022, BlueMark published a framework for evaluating the completeness and reliability of fund managers’ impact reports based on 18 months of research, including analyses of impact reports, interviews with 50+ impact investing experts, and a pilot of the methodology with seven investment funds participating in Impact Frontiers cohorts. The report can be downloaded here:
Raising the Bar 2.0: Introducing BlueMark’s Framework for Evaluating Impact Reporting