ADOPTION OF IFRS SUSTAINABILITY STANDARDS (IFRS-S) IN BRAZIL: CONTRIBUTIONS TO THE DEVELOPMENT OF CLIMATE-RELATED DISCLOSURE INDICATORS

Objective: The main objective of this article is to develop climate-related disclosure indicators that are applicable to the Brazilian business context. Method: The Delphi method was used to achieve this objective, involving several experts representing various user groups that influence the formulation of accounting standards in Brazil. The Delphi method is a decision-making tool that establishes an effective communication process, facilitating the resolution of complex problems


INTRODUCTION
Since the last major international financial crisis in 2008, investors' needs and demands are no longer limited to financial information (Brockett & Rezaee, 2012).They are increasingly aware of potential risks and financial opportunities due to environmental factors such as climate change (Pointner & Ritzberger-Grünwald, 2019).This led them to seek more information about corporate performance in Environmental, Social and Governance (ESG) aspects to better understand the risks and opportunities of companies and how they are managed (Ioannou;Li & Serafeim, 2016;Clarkson;Li;Richardson & Tsang, 2019;Widyawati, 2020;Bui;Houqe & Zaman, 2021).As a result, investors put pressure on companies to disclose double materiality in their reports: (1) the risks of climate change in the activities of companies and their economic sectors, and (2) the opportunities created by companies focused on climate change adaptation and mitigation (Pinchot, Zhou, Christianson;McClamrock & Sato, 2021).
So far, the most prominent guidelines used by companies worldwide for the dissemination of climate-related information are provided by five organizations: the Carbon Disclosure Project (CDP), the Climate Disclosure Standards Board (CDSB), the Global Reporting Initiative (GRI), Sustainability Accounting Standards Board (SASB), the International Sustainability Standards Board (ISSB) and the International Integrated Reporting Council (IIRC).While they have provided a valuable set of publicly available resources to guide the assessment and dissemination of climate-related risks and opportunities, they do not provide a complete coverage of physical climate hazards or refer to a comprehensive set of metrics to measure physical climate risks.In addition, the different guidance provided by each organization makes existing disclosures highly fragmented; preparers use language, terms of reference, structure, and content according to the objectives and readers of each company's reports.As a result, existing disclosures are often incomplete, inconsistent and immeasurable (IFAC, 2021), which creates confusion among users and causes a crisis of confidence in the information produced (Shauki, 2022).
Investors' interest in climate-related information, without the support of an appropriate disclosure scheme, encouraged the International Sustainability Standards Board (ISSB), formed by the International Financial Reporting Standards (IFRS), to publish IFRS S2, a climate-related disclosures standard in 2023.The standard is designed to provide more consistent, complete, comparable and verifiable information on climate-related risks and opportunities, including consistent metrics and comparable standard qualitative disclosures for global markets.The standard-making process (public hearings and outreach from the IASB) enabled investors to assess an entity's exposure and manage climate-related risks and opportunities across markets, facilitating capital allocation and management decisions.
The Brazilian Committee of Sustainability Pronouncements (CBPS) led the "Task Force" of Brazil on the new IFRS-S standards to harmonize the main indicators of dissemination of the Climate Exposure Project with the regulations and commercial characteristics in force in Brazil.The official translation of the standards is carried out by the Institute of Independent Auditing of Brazil (Ibracon), which is also the only organization contractually authorized by the IFRS Foundation to carry out the translations of the International Financial Reporting Standards (IFRS).This is common in a process of adopting IFRS standards, as many jurisdictions, including Brazil, have cultural, legal, political and tax controversies obstacles to an immediate full adoption of IFRS standards (IFRS, 2023).This convergence aims to introduce a mechanism that allows entities with varying capacities and preparedness to apply this new standard, reducing the potential burden on entities in Brazil.Some pragmatic issues may have to be resolved during this process, such as overlapping and repetition between indicators and ways to avoid the need for so many indicators that will make the pattern of dissemination heavy.Therefore, some indicators can be removed, although some alternatives are usually available.There are two possible reasons why disclosure indicators should be removed: (1) that are not relevant information for business characteristics in Brazil; (2) if the information is relevant, providing the necessary information is too expensive and challenging in Brazil.
Here, the idea is that instead of having general and global indicators, focusing on those that are more particular and weighted is certainly more prioritized.The perceptions of the constituents in this case can be a valuable contribution to the Brazilian Working Group on Climate Related Disclosures.The main objective of this work was to develop climate-related dissemination indicators provided in the Climate Exposure Project for further implementation in the Brazilian context.Our role in this study was in the appropriate focus channel, considering that researchers can participate in the process of accounting regulation, indirectly transferring their knowledge to the normalizers through their research (Álvarez;Calvo & Mora, 2012) or articulating their views on the proposals issued by the normalizers to other parties.than the normalizers (Jorissen;Lybaert;Orens & Van der Tas, 2012), as the scientific journals.Furthermore, as suggested by Barth (2000) and Cooper and Robson (2006), there is a continuing need for more involvement of researchers in the standard-setting process, presenting their knowledge and arguments.It is believed that improving the participation of researchers supports the notion of greater legitimacy of accounting standards (Larson, 2007).It may be because they are not affected by the norm, but are experts in the subject.Consequently, their opinions are less biased and tend to be conceptual and based on their research knowledge (Barth, 2006).Moreover, Gray (2002) also calls for normative research in environmental accounting and the process of making accounting a useful tool for the dissemination of this type of business information (Parker, 2005).
At the same time, the participation of a community of accountancy researchers in recent consultancies on environmental accounting issues is still limited (Adams & Mueller, 2022).To achieve the main objective of this study, we used a rigorous qualitative and quantitative methodology -the Delphi method.We argue that this method may be a rigorous scientific method for ex-ante analysis of constituents' perceptions and levels of consensus on new regulations, including the climate-related disclosure pattern.In addition, the Delphi method in such circumstances presents some main advantages that the surveys do not present as a source of complementary information for due process, which can be summarized as follows: (1) the number of responses obtained by the monitor does not affect the results because it is not necessary to represent any target population, (2) the Delphi method allows less biased conclusions because it can consider the opinions of all parties, directly or indirectly interested or affected, (3) the monitor knows the interviewee and his experience in the subject under study to maximize interaction with the respondent to clarify any aspect during the process, and (4) the data obtained may be richer because the principle of anonymity is maintained during the process, thus offering a more rigorous (quantitative and qualitative) view than the standard analysis of comment letters.Our study provides an important contribution to the accounting literature, where most current climate-related disclosure studies are ex-post analyzes, which use a descriptive content analysis to review the existing implementation of such disclosure.For example, Santos and Rodrigues (2021) assessed how banks in Portugal report climate-related information.Lombard, Schimperna, Paoloni and Galeotti (2022) investigated the quality and quantity of climate-related information released by 34 companies listed in the Italian industrial sector.Leicht and Leicht (2022) examined the development of climate-related disclosure in non-financial reports from listed companies in Germany.Suta et al. (2022) examined how the new sustainability reporting requirements proposed by the Climate Exposure Project could affect the current reporting conditions of publicly quoted European car manufacturers.Moreno and Caminero (2022) reviewed the recommendations of the Task Force on Climate-Related Financial Disclosures (TCFD) on climate-related disclosure of 12 Spanish financial institutions, the results of which showed that the number of reported disclosures increased annually.In short, this study is the first to use the Delphi method to develop climate-related dissemination indicators.
Thus, this new study fills the gap in the literature, where most studies on climate-related disclosure were ex-post -usually based on a content analysis to evaluate the implementation of existing disclosures.Although the interpretations of these studies can be used ex-ante, they are not in a position to solve the problems and provide solutions to the regulatory decisions faced by the standardization bodies.Moreover, standardization bodies may face some difficulties in understanding the implications of such studies.Therefore, it is expected that the results of this study will meet the needs of the national standard setter for an efficient transfer of knowledge.In this case, the weight, applicability score and consensus level of climate-related disclosure indicators found in this study may provide additional information for the national normalizer to finalize climate-related disclosures in Brazil, which was even the first country in the world to adopt the report of sustainability-related financial information issued by the ISSB after the release of Resolution 193 of the Securities Commission (CVM).

METHODOLOGICAL PLATFORM
Delphi is a decision-making method initially developed by Norman Dalkey and Olaf Helmer in the 1960s to predict how technology can affect conflict (Dalkey & Helmer, 1963).This method establishes an effective communication process, allowing individuals to solve complex problems (Mitroff & Turoff, 2002;Okoli & Pawlowski, 2004).Delphi is ideal for establishing a value opinion or estimating when models are impractical or impossible due to lack of relevant technical, economic or historical data or whether a set of personal judgments needs to be established (Rowe & Wright, 1999).
The Delphi method has been used for several purposes (Beiderbeck & Frevel, 2021).Novakowski and Wellar (2008) classify most of these purposes into three categories: regulatory Delphi, forecast Delphi, and political Delphi.The first Delphi is used to gain consensus on the preferred future.The second Delphi is used to make future predictions.Finally, the third Delphi exploits an interest with political consequences.
The climate-related disclosure standard is part of the accounting regulations; thus, this study is included in the first Delphi group.This technique was also used by Etxeberria, Garayar and Sánchez (2015), Coy and Dixon (2004) and Álvarez, Calvo and Moura (2012), who simulated a pattern-setting process using the Delphi method.
The Delphi method can be considered an additional tool for ex-ante studies related to an accounting standard-setting process.Although Delphi's position does not replace any part of an accounting standard-setting process, be it IFRS or national standards, this method may complement it (Álvarez, Calvo & Moura, 2012).Much evidence has been accumulated to show the usefulness, internal coherence and external validity of the Delphi method, especially when properly planned and implemented (Nakatsu & Iacosou, 2009).Delphi can be a rigorous scientific method for ex-ante analysis of constituents' perceptions of new regulations under such conditions.Therefore, we must strictly design this method.
Thus, the Delphi method is a practical and applicable technique based on the principle that forecasts by a structured group of experts are more accurate than those coming from unstructured or individual groups.
To strictly design the Delphi method, we adopted the steps and process of a regulatory Delphi proposed by Novakowski and Wellar (2008).Theoretically, the Delphi process can be iterated continuously until it is determined that consensus has been reached (Hsu & Sandford, 2007).However, it is crucial to strike a balance between time, money and potential exhaustion of experts (Jones, 1992;Rowe, 1994;Hasson;Keeney & McKenna, 2000).As two rounds of Delphi proved to be appropriate, we conducted only two on the example of previous literature (Labuschagne & Brent, 2008;Bélanger;Vanasse;Parent;Allard & Pellerin, 2012;Fefer;Stone;Daigle & Silka, 2016;Von Ruschkowski;Burns;Arnberger;Smaldone & Meybin, 2013;Hai;Thinh;Tuan;Cham;Anh;Thuy;Ha;Bao;Van Huong & Khanh;Van 015).Overall, this study took about 4.5 months to complete.The steps in the Delphi process are described and explained step by step in the following sections.

Selection of Experts
In this study, we carefully select experts from those who have appropriate knowledge and are familiar with the objectives of this research.The experts selected are Brazilian, representing the eight user groups that affect the formulation of accounting standards.Using Kieso, Weygandt and Warfield as a reference (2014), these users consist of investors (primary users), regulators, preparers, academics, professional associations, financial communities, accounting firms and business entities.
Here we follow the suggestion of the literature to use specialists from various backgrounds and with diverse interests, so that all points of view can be captured.Moreover, they are undoubtedly users of our findings.As noted by Linstone and Turoff (1975), it is highly recommended to invite experts who are potential users of the discoveries.
The panel should contain experts or at least informed advocates (Goodman, 1987).Therefore, we must consider some criteria for qualification of specialists.Related to this issue, empirical studies based on the Delphi method have provided some recommendations.The professional experience (in years) and the level of schooling are two standard criteria for selecting a specialist.Thus, we selected specialists with 5 years or more of professional experience in the areas of financial accounting and sustainability with a minimum educational qualification of bachelor (e.g.Fefer; Stone; Daigle & Silka, 2016;Musa;Mohammad;Thirumoorthi;Moghavemi & Kasim, 2015;Ahmad & Wong, 2019).Initially, 67 selected specialists were invited, but only 21 agreed to take part in this study.
Of the 21 experts approved, only 16 people who responded in the first round had a response rate of 76%.This is in line with the previous discussion on the average number of experts used in a Delphi study (e.g., Richey;Mar & Horner, 1985;Vatalis;Manoliadis & Mavridis, 2012;Espino;Castillo-Lopez;Rodriguez-Hernandez & Canteras-Jordana, 2014;Quyên, 2014;Tseng;Lim & Wong, 2015;Hsu;Chang & Luo, 20117).The profiles of these experts (four from a corporate entity, one from an accounting firm, one from an academic institution, one investor, one from a financial community, two preparers, five regulators, and one from a professional association) are presented in Table 1 below:

Preparation of the Questionnaire
To design this study questionnaire, we used climate-related disclosure indicators provided in the Climate Exposure Project.This document builds on the climate-related dissemination prototype developed by the IFRS Foundation's Technical Preparation Working Group (TRWG) in December 2021 (TRWG, 2021).This document also includes the recommendations of the Financial Stability Board's Task Force on Climate Related Disclosures (TCDF, 2017;2021) and components of the structure and standards of international sustainability bodies, namely the CDP, CDSB, GRI, IIRC and SASB, as set out in a prototype climate-related disclosure standard in December 2020 (IRRC, 2020).In addition, as in the TCFD (2021), climate-related disclosure in the Climate Exposure Draft also provides information that enables users of general purpose financial reporting to understand four main aspects: Governance, Strategy, Risk Management, and Metrics and Targets.Each aspect is accompanied by indicators that need to be disclosed.There are 42 climate-related dissemination indicators (8 Governance, 15 Strategy, 9 Risk Management and 10 Metrics and Targets).See Table 2 for a detailed description of the indicators.The identity of the unit or individual within the unit responsible for overseeing climate-related risks and opportunities Governance 02 A description of how the unit's responsibilities related to climate-related risks and opportunities are reflected in the entity's terms of reference, the mandate of the board of directors and other policies Governance 03 A description of how the unit ensures that there are adequate skills and competences to supervise strategies designed to respond to climate-related risks and opportunities Governance 04 A description of how and how often the unit and its committees (audit, risk or other) are notified of climate-related risks and opportunities Governance 05 A description of how the unit and its committees consider climate-related risks and opportunities when overseeing the entity's strategy, key transaction decisions, and risk management policies Governance 06 A description of how the unit and its committees oversee the establishment of targets related to significant climate-related risks and opportunities and monitor progress toward those targets Governance 07 Description of the role of management in assessing and managing climate-related risks and opportunities Governance 08 How unique controls and procedures are applied to managing climate-related risks and opportunities Strategy

Strategy
A description of significant climate-related risks and opportunities and the period in which those risks and opportunities affect the entity in terms of business models, strategies and cash flows; access to finance; and cost of capital, whether in the short, medium or long term

Strategy
A description of how the entity defines the short, medium, and long term and how those definitions relate to the dimensions of the entity's strategic planning and capital allocation plans

Strategy
A description of whether the identified risk is a physical risk or a transient risk (an acute physical risk may include an increasing severity of extreme weather events such as hurricanes and floods; chronic physical risks include rising sea levels or rising mean temperatures; transition risks may include regulatory, technological, market, legal or reputational risks)

Strategy
A description of the impacts (current and future) of significant climate-related risks and opportunities in the entity's value chain

Strategy
A description of where significant climate-related risks and opportunities are concentrated in the entity's value chain (for example, geographical area, installation or asset type, entry, exit or distribution channel)

Strategy
Information about how the entity responds to significant climate-related risks and opportunities, including (1) how the entity plans to achieve specific climate-related goals, (2) how current and future changes in the entity's business model occur, and (3) how the entity plans to be funded

Strategy
Information about how the entity plans climate-related targets, which include (1) the review process, (2) the number of emission reduction targets to be achieved, and (3) the purpose of using carbon offsets (actions to eliminate CO2 emissions produced in one place with emissions reduction actions elsewhere) in achieving the emissions targets

Strategy
Quantitative and qualitative information on the progress of the plans disclosed in the previous reporting period

Strategy
Information on how climate-related risks and opportunities have significantly affected the most recently reported financial position, financial performance and cash flows

Strategy
Information about identified climate-related risks and opportunities, where there is a significant risk that there will be a material adjustment to the accounting values of assets and liabilities reported in subsequent financial statements Strategy 11 Information about how the entity expects its financial position to change over time, given its strategy to address significant climate-related risks and opportunities, which reflects (1) the entity's current investment plans and commitments and their impact on the entity's financial position and ( 2) ) the sources of funding the entity plans to implement its strategy Strategy 12 Information on how the financial performance of the entity is expected to change over time, based on the implementation of strategies to address significant climaterelated risks and opportunities (for example: (1) an increase in revenues or costs of products and improvement of online services with a low carbon economy, in line with updates to international agreements on climate change, (2) physical damage to assets caused by climate events and (3) climate adaptation or mitigation costs) Strategy 13 An explanation of why the entity would not be able to disclose quantitative

First round Delphi
In the first round, we sent a closed questionnaire (modified Delphi) and an open questionnaire (traditional Delphi), as suggested by Kerlinger (1973) andCuster et al. (1999).The first questionnaire asked experts to assess the applicability of climate-related disclosure indicators.Therefore, we set a Likert scale of 1 to 4 to evaluate applicability (1 for less applicable and 4 for more applicable).A scale of even points was used because we expected experts to make a definitive decision on the applicability of the indicators questioned, instead of selecting a neutral option (Garland, 1991).The second questionnaire allowed experts to make comments and add appropriate indicators that were not on the list.The experts had 2 weeks to return the questionnaires.However, it took almost a month after giving the experts three reminders.Eventually, we ended up with 76% of responses (16 out of 21 experts).
We review and summarize the results quantitatively after getting answers from the 16 experts.We used the mean and median as the preferred parameter/statistic to identify where most of the expert positions in the response continuum were (Novakowski & Wellar, 2008).To indicate that experts consider the proposed indicators applicable, we take an acceptable limit for the average and median of the two main measures (3 and 4).This threshold was established because the inclination to a negative response increased when using a even point scale (Garland, 1991;Johns, 2005).
In addition, we also calculate the interquartile range (IQR) and the percentage of responses for the two main measures (3 and 4) as additional statistical analysis.Since the applicability score was measured using scales of 4 units, the IQR should not exceed 1 (Raskin, 1994;Rayens & Hahn, 2000).Following Huang et al. ( 2022), who successfully applied a Delphi exercise to develop an indicator, we specify that the percentage of responses in points 3 and 4 must be greater than 70%.Below all these thresholds, climate-related disclosure indicators were excluded from further analysis.Some indicators have been removed, but others have been added based on the experts' recommendations in this round.We reviewed the questionnaires according to these results and redistributed them to the experts in the second round.

Second Round Delphi
The second round was held to obtain the consensus of experts (Jairath & Weinstein, 1994).We asked the experts to express their agreement (Yes/No) on each indicator that was determined based on the results of the first round.In addition, we asked experts to rate the applicability of the climate-related dissemination indicators recommended in the first round using a Likert scale of 1 to 4. The applicability score was then analyzed similarly to the first round.The questionnaires were distributed to the 16 experts; however, only 15 returned after waiting 3 weeks and giving three reminders, presenting a response rate of 93.75%.
After receiving feedback from the 15 experts in the second round, we measured the consensus of experts on the climate-related dissemination indicators.The consensus was based on a score of 80% or higher (at least 12 out of 15 experts agreed on an indicator).We follow what Lynn (1986) and Davis (1992) suggested: monitors should seek an 80% or better deal when they have more than five experts on a panel.This level of agreement will determine which climate-related disclosure indicators will be included.Calculating the proportion of agreement to measure consensus is in fact the most widely used approach (Jairath & Weinstein, 1994).However, some criticisms have been made of this approach, notably as regards the possibility that the values will be inflated due to the risk of casual agreement.It is reasonable, since a casual agreement is a matter of concern in the assessment of consensus among experts, especially when the option is dichotomous (Wynd;Schmidt & Schaefer, 2003), as the Yes/No questions in this study.In addition, Cohen (1960) criticized the use of simple proportion agreements as a "primitive" measure.Therefore, the level of agreement we set above needs to be adjusted for a casual agreement.
In order to carry out such an analysis, we adopted the method developed by Polit et al. ( 2007), which they called the modified kappa statistic (k † ).These statistics are called modified Kappa Coefficient because they consider only certain types of agreement, i.e. the agreement of experts that the indicator questioned is relevant.The agreement on irrelevance is ignored because it does not inform judgments about the validity of an indicator.
To obtain k♫ , we needed to calculate the probability of random agreement (Pc) using the formula of the binomial random variable, as shown in Equation 1 below: where n and r represent the number of experts involved in the Delphi rounds and the number of experts who responded "Yes" to an indicator, respectively; meanwhile, 0.5 is a given number that represents the probability of a casual agreement.From now on, k s . is calculated using the basic formula for Kappa (Wynd;Schmidt & Schaefer, 2003), as Equation 2 follows: The numerator in Equation (2) represents the actual agreement observed beyond chance.The denominator indicates the maximum agreement beyond that predicted by chance.We interpret k valence using the criteria established by Fleiss (1971) and Cicchetti and Sparrow (1981).Thus, k Ds is considered "reasonable" if the value is between 0.40 and 0.59, "good" if the values are between 0.60 and 0.74, and "excellent" if the values are above 0.74.Following Molnar et al. (1999), indicators with a Kappa value of less than 0.74 or representing only less than an "excellent" agreement would be eliminated.

Delphi results: First Round
In the first round, 42 appropriate climate-related dissemination indicators (as shown in Table 2) were included in the data collection tool, which was initially sent to the expert panel.From the applicability point of view, the responses in this round revealed that the median values of all indicators were in the range of 3 to 4, and all IQIs were less than or equal to 1.However, we found that three indicators have an average value of less than 3 (2.75), and the proportion of responses 3 and 4 is less than 70% (0.625): (1) "the identity of the unit or individual within the unit that is responsible for overseeing climate-related risks and opportunities" ( Governance-01); (2) "an explanation of why the entity would not be able to disclose quantitative information from Strategy-09 to Strategy-12 (above) if that were the case" (Strategy-13); and (3) "an internal price for carbon, which is the each metric ton of greenhouse gas emissions the entity uses to assess the cost of the entity's greenhouse gas emissions' (Metrics and Targets-06).So we had to eliminate them.These results are shown in Table 3.A number of experts representing business entities, a financial community, regulators, investors and preparers contributed to eliminating these three indicators.
During the feedback process, experts gave us reasons why they tended to choose the lower two scales (1 or 2) for these indicators.For example, regarding Governance-01, experts argued that this indicator is too detailed, especially for the initial application in Brazil as of 2026, according to CVM Resolution 193.Disclosure should avoid complexity and focus on relevant information, such as the direct impact of climate-related risks and opportunities on business performance.In addition, the position of monitors is not explicitly stated -whether they are in a unit, in different units, but within the same entity, or independently monitored by a committee designated by a business association or chamber of commerce.If the same unit has the authority to execute and supervise, there is a risk of abuse of power.
In addition, Strategy-13 has a low average applicability score, as it is also considered too detailed and tends to be redundant, as it only repeats the previous indicators within the same aspect.Finally, experts attributed lower scores to Metrics and Goals-06 because companies in Brazil did not implement a carbon pricing policy.Therefore, experts may assume that companies are unfamiliar with the concept of carbon prices that can be applied.This disclosure is expected to be challenging and prone to errors or inaccuracies.
In addition, some additional indicators were included on the basis of the comments and recommendations of the experts received in the open questionnaire for this round.According to the results, some experts added an indicator for Governance and Strategy.Two additional indicators were recommended for the Governance aspect.Six indicators have been added for Risk Management.The Metrics and Targets aspects had two additional indicators.In addition, an expert also recommends an additional disclosure aspect related to Environmental Ethics with a disclosure indicator: "analysis of how the pattern of relationship between values exists in the neighboring community affected by climate change".However, this indicator still implements one of the principles of good corporate governance, namely accountability, which may be specifically related to the environmental impact caused by the company's activities (OECD, 2015).Consequently, we have included this indicator in the Governance strand and, therefore, this strand has two additional indicators.Table 4 briefly describes these additional climaterelated disclosure indicators.In summary, 3 indicators were removed, while 11 were added based on the results of the first round.

Delphi results: Second Round
In the second round, 50 climate-related disclosure indicators were included in the questionnaire, consisting of 9 Governance, 15 Strategy, 15 Risk Management and 11 Metrics and Targets.This set of indicators consists of 11 additional indicators drawn from the experts' recommendations in the previous round.Experts have therefore been asked to provide applicability scores for these new indicators in this round.Subsequently, they were analyzed quantitatively as the original indicators (see Table 5).According to Table 5, we found that three indicators had average applicability score lower than 3: (1) "analysis of how the relationship between values exists in the neighboring community affected by climate change" (Governance-10); (2) "information related to the types of equipment that produce greenhouse gas emissions and how they are used to reduce the production of greenhouse gases" (Metrics and Targets-11); and (3) "information related to the future costs for the recovery of environmental pollution due to the greenhouse gas emissions produced" (Metrics and Targets-12).However, it was found that one indicator presented an AIQ greater than 1 -"information related to the guidelines for implementing corporate governance" (Governance-09).These indicators had to be removed, while the rest were kept temporarily until consensual measurement.
Table 6 presents the level of consensus of experts on the appropriate indicators that should be reported in a climate-related disclosure.Indicators with consensus level < 80% and/or with k -values < 0.76 (agreement less than "excellent") were removed from the list.The result shows that "information about how management responds to the level of risk identified"  and "information about the company's risk management implementation management unit" (Risk Management-13) were removed because their consensus level and k - values were only 0.733 and 0.727, respectively.Consequently, there were 44 indicators left for climate-related disclosure: 7 Governance, 15 Strategy, 13 Risk Management and 9 Metrics and Targets.

Analysis of Final Results
A number of useful analyzes could be made based on the results presented in the previous section.For clarity, the analysis was carried out separately at the indicator and aspect levels and with respect to the consensus of experts.To sharpen the analysis, we calculate the weight of indicators and aspects using the average applicability scores in this section.The weight of a climate-related disclosure indicator is the division between its average applicability score and the sum of the average applicability scores of all climate-related disclosure indicators in that respect.However, the weight of a climate-related disclosure aspect is the division between the sum of the average applicability scores of all climate-related disclosure indicators in that aspect and the sum of the average applicability scores of all climaterelated disclosure indicators.

Indicator level
The applicability score of each indicator showed its relevance or priority indicators for climate-related dissemination.For example, from the Governance aspect (see Table 7), "a description of how the unit's responsibilities related to climate-related risks and opportunities are reflected in the entity's terms of reference, in the mandate of the board of directors and other policies" ( Governance-02) has the highest average score of applicability (3.44) compared to other indicators.Governance 04 3,00 0,135 Source: Survey data (2023).Note: Applicability score ≥ 2.5 is highly applicable.
In addition, if a score of 3.25 or higher were considered highly applicable, there were 29% (2/7) of climate-related disclosure indicators in the Governance aspect.From the perspective of the Strategy aspect, "information on identified climate-related risks and opportunities where there is a significant risk that there is a material adjustment to the book values of assets and liabilities reported in subsequent financial statements" (Strategy-10) with a score of 3.31 was the most applicable indicator.Strategy-01, Strategy-06, Strategy-07 and Strategy-09 were jointly below this dissemination indicator with a score of 3.25.
On the other hand, the additional expert indicator on "information related to share classification, mitigation and adaptation" (Strategy-16) has the lowest average applicability score (3).In addition, 'information on the results of a climate resilience analysis related to (1) the implications of the strategy's implementation, (2) the areas of uncertainty analyzed and (3) the entity's ability to adapt its climate resilience strategy to climate change in the short, medium and long term' (Strategy-14) was also considered a lower-rated indicator.In summary, 33% (5/15) of the climate-related disclosure indicators in the Strategy aspect were highly relevant, according to the criterion discussed.From the Risk Management aspect, as presented in Table 8, "the input parameters used by the entity (e.g., data source, scope of operations, detailed assumptions used)" (Risk Management-4) has the highest average applicability score.In addition, the additional indicator recommended by the expert on "information related to the solutions that should be conducted when a risk occurs" (Risk Management-15), with score 3, has the lowest average score of applicability.Solutions to the risks may be important, but the disclosure of this information does not appear to be essential and is usually intended solely for internal parts of the entity.A disclosure on the assessment of climate-related risks is probably more useful in this case, particularly at a practical level in Brazil.The high applicability score (3.25) for such disclosure (see Risk Management-08) seems to justify this argument.Overall, there were 69% (9/13) of highly applicable climate-related disclosure indicators.
From the Metrics and Goals aspect (see Table 9), the three most applicable climaterelated disclosure indicators were Metrics and Goals-10 (3.5),  and .The most applicable indicator (Metrics and Goals-10) was related to "targets set by the entity to mitigate or adapt to climate-related risks or maximize climaterelated opportunities."This may be due to the fact that this indicator is mandatory and directly represents the main objective of the corresponding aspect.This information is especially useful for primary users to better assess a company's progress in managing or adapting to climaterelated issues.It also provides a basis for comparing goals of other companies that are still in the same business sector or industry.The lowest score (3) in this respect is associated with the Metrics and Goals-07: "remuneration, namely the percentage of executive management remuneration recognized in the current period on the basis of climate-related considerations".Basically, 56% (5/9) of the indicators were highly relevant.

DISCUSSIONS
This study was the first to develop climate-related dissemination indicators for implementation in Brazil using the Delphi regulatory method.As there are no rules to determine specialization, this method has required a panel of experts (Shaw et al., 2012).In the present study, the panel experts are key persons in several agencies involved in the accounting regulation process in Brazil.All panel members have at least 5 years of professional experience in financial accounting and sustainability, with minimum educational qualification of bachelor's degree.Its competence and diversity have helped to strengthen the consensus decision.
This study brought an academic contribution by demonstrating the use of the Delphi method as a corroborating tool for the definition of an accounting standard.It can guide accounting researchers in using this method for similar purposes in order to produce more useful and reliable results than other existing studies.For example, previous studies on this topic used only descriptive statistics to calculate the consensus of experts.This approach is the most widely used, but it may mislead researchers' conclusions on the consensus of experts due to the possible existence of a casual agreement.It is reasonable, since a casual agreement is a matter of concern in assessing consensus among experts, especially when the option is dichotomous (Yes/No).Therefore, we use the kappa statistic as inferential statistic to adjust the degree of agreement with coincidence agreement (see Table 6).
According to the consensus of experts, 44 applicable indicators were explicitly identified, representing four aspects of dissemination: Governance, Strategy, Risk Management and Metrics and Targets, each with 7, 15, 13 and 9 indicators, respectively.The level of consensus of all the indicators finalized was higher than 80% and the values of k † were higher than 0.76, demonstrating excellent consensus.
From the Governance aspect, the most applicable indicator is "a description of how the unit's responsibilities related to climate-related risks and opportunities are reflected in the entity's terms of reference, in the mandate of the board of directors and in other policies" (Governance-02 ).This is reasonable, since responsibility is the fundamental principle of corporate governance, especially for state-owned, public and private companies.Strengthening the role and responsibility of the unit, especially with regard to climate-related risks and opportunities, can increase corporate responsibility and the quality of dissemination on such topics.In addition, the responsibility of a climate unit is also expected to improve performance and build trust between stakeholders.This may be why experts have awarded the highest score to this indicator.
In addition, as the IAI suggested in its comment letter, the Governance aspect should also contain information about the criteria that entities will use to assess the skills of the administration or the committee responsible for identifying climate-related risks and opportunities.This criterion must be accepted from a global perspective or from individual jurisdictions in order to achieve the same objectives.However, none of the experts who took part in our Delphi rounds ignored this.
In the Strategy aspect, "information related to action classification, mitigation and adaptation" (Strategy-16) received the lowest expert score.This may be due to the fact that experts consider that this disclosure indicator is not part of the strategy, but rather of a detailed action plan that is important in a company's program.Meanwhile, the details of a company's action plan will provide competitors with information they can use to their benefit.Thus, companies typically tend to protect this information to maintain their competitive advantage.
Risk Management-4, "the input parameters used by the entity (for example, data source, scope of operations, detailed assumptions used)," has the highest score in the Risk Management aspect.This is reasonable as the points of this indicator reflect the risk management process as detailed in the risk management guidelines published by the International Organization for Standardization in 2018.The second highest average score of applicability was 'information on whether the processes that the entity has changed are compared with processes in the previous reporting period' (Risk Management-5).After executing a mitigation strategy, some assessments may need to be conducted to determine the next action plan to improve the company's previous plan in the reporting period to mitigate climate issues.It is therefore indispensable to compare this reporting period with the previous one.
Under Metrics and Targets, 'the remuneration, including the percentage of executive management remuneration recognized in the current period on the basis of climate-related considerations' has the lowest score.The determination of the level of remuneration of executives on the basis of climate considerations is empirically supported.For example, Callan and Thomas (2014) and Kartadjumena and Rodgers (2019) showed that top executives would be rewarded with higher pay if they could motivate companies to get more involved in climate and environmental issues.However, Arndt and Bigelow (2000) found that management will be motivated to disclose additional (discretionary) information, including executive compensation, when the company's position is threatened by the withdrawal of resources by suppliers (investors).In other words, the disclosure of this indicator is only a legitimacy management tactic to improve the interpretation of controversial actions.Under normal circumstances, companies have no intention of disclosing such information.Perhaps this is why experts tend to give Metrics and Goals-07 a relatively low score compared to other indicators.
When viewed from the point of view of publicity, the Strategy is the aspect that carries the greatest weight amongst the others.This result is in line with what Deloitte (2018) observed; investors' increasing attention to corporate sustainability is seen in the hope that a board of directors will have transparency regarding the company's strategy in dealing with social, environmental and climate issues and in its disclosure to stakeholders.After the Strategy, Risk Management appears as the second most considered aspect.Climate change risk management can be considered as an extension of existing risk management and become part of the management and decision-making process.
However, what is most surprising of the results is that Governance is considered the least thoughtful aspect, given that a governance system is a basic guide for companies to supervise and guide managers in managing corporate resources.It can lead a company to a favorable condition for the functioning of its operations.However, as Connelly et al. (2012) found that the adoption of so-called "good" corporate governance practices does not guarantee the company's performance.Hermiyetti and Manik (2013) pointed out that good governance mechanisms, particularly in developing countries, serve only as a form of corporate compliance with law and government regulation (formality purposes).Thus, implementing good corporate governance becomes ineffective and not ideal for improving a company's financial performance.However, increasing financial performance through some strategies becomes a requirement for a company to attract investors.Perhaps that is why the Governance aspect has the lowest weight, while the Strategy aspect has the highest weight.
The results of this study thus provide an important contribution at a practical level, especially in the case of a developing country like Brazil, where most companies still use GRI to disseminate annual information, imitating their counterparts in developed countries, but may not constantly adapt to changing needs and conditions within the local context.While IRG is the most common global framework for the dissemination of climate-related information, some critical studies have indicated several possible weaknesses of IRG.For example, Knebel and Seele (2015) and Boiral (2013) stated that GRI failed to achieve some qualitative characteristics, such as comparability, standardization and therefore transparency of climaterelated disclosure, which may be due to the flexibility of reporting and voluntary guidelines.However, the Climate Exposure Project studied in this article maintains these qualitative characteristics.

CONCLUSION
The growing demand for climate-related risks and opportunities from investors led to the publication of IFRS-S2 by the ISSB.In Brazil, the National Standards Organization (CFC) is in the process of studying and adopting this new standard as a national standard.In its application, the CFC considers that the harmonization of the key indicators of the new standard needs to be carried out so that it is in accordance with the existing regulations and commercial characteristics in Brazil.To ensure harmonization with the regulations and commercial characteristics of Brazil, the contribution of the constituents can provide valuable additional information to the CFC, via CBPS, finalize the Climate Exhibition Project for implementation in the local jurisdiction.Our study aimed to contribute to this process of regulatory accounting by developing weighted and applicable climate-related disclosure indicators using the Delphi method.
In this case, our paper demonstrates the potential contribution of the Delphi method to developing weighted and applicable indicators for an accounting report.This study can also guide researchers in using this method for such purposes in order to produce useful and reliable results.Despite the valuable results, it is important to recognize certain limitations of our study.First, as regards the use of the Delphi method itself, several studies have noted some limitations of Delphi when used by standardization bodies and other institutions to obtain additional input and information from constituents.Critics of Delphi cited potential issues such as manipulation by monitors, challenges in determining correctness, and the possibility of inappropriate application due to insufficient knowledge.The three identified limitations impact the decisionmaking process for selecting experts, developing the questionnaire and interpreting the results.Therefore, we encourage new studies to use other multi-criteria decision-making techniques, such as the Analytical Hierarchy Process (AHP) or the Analytical Network Process (ANP).Secondly, we had only one academic during the Delphi rounds, and their views are usually less biased, as they have no particular interest in the results, but are experts on the subject.Therefore, we strongly encourage new research to invite more academics and scholars on the subject to contribute with this first movement in search of the full adoption of financial sustainability reports.
Below the threshold, so the indicator is deleted.a = Additional indicators based on the experts' recommendations in the first round.Number of experts = 15.Source: Research statistics (2023).

Table 1 .
Profiles of experts involved in the Delphi rounds

Table 2 .
Climate-Related Disclosure Indicators Indicators

Table 3 -
Mean, Median, Index and Proportion of Responses 3 and 4 of each Indicator Note: * = If it is below the threshold, the indicator is deleted.The number of experts = 16.Source: Research data (2023).

Table 4 .
Additional Climate-Related Disclosure Indicators Indicators

Table 5 .
Mean, median, IQI and proportion of responses 3 and 4 of each additional indicator Below the threshold, so the indicator is deleted.Number of experts = 15.

Table 6 .
Level of consensus on climate-related dissemination indicators

Table 7 .
Governance Local Priority Indicators Based on Applicability Score

Table 8 .
Governance Local Priority Indicators Based on Applicability Score Additional indicators based on the experts' recommendations in the first round.An applicability score ≥ 2.5 is highly applicable.Source: Survey data (2023).

Table 9 .
Local priority metrics and targets indicators based on applicability score An applicability score ≥ 2.5 is highly applicable.Source: Survey data (2023).Regardless of these aspects, overall, Metrics and Goals-10, Governance-02, Risk Management-04 and Risk Management-05 were the four main climate-related disclosure indicators.By contrast, the lowest average score of applicability among all indicators of all aspects was associated with Governance-04, Strategy-14, Strategy-16, Risk Management-15 and Metrics and Goals-07.The overall priority of all indicators is presented in Table 11.In summary, there were approximately 48% (21/44) of highly applicable climate-related disclosure indicators.Among these indicators of high relevance were 10% (21/02) Governance, 24% (21/05) Strategy, 42% (21/09) Risk Management and 24% (21/05) Metrics and Target Indicators.