Industry-based Guidance on implementing
Climate-related Disclosures
Volume 44—Solar Technology & Project Developers
June 2023
IFRS S2
IFRS
® Sustainability Disclosure Standard
International Sustainability Standards Board
This Industry-based Guidance accompanies IFRS S2 Climate related Disclosures (published
June 2023; see separate booklet) and is issued by the International Sustainability
Standards Board (ISSB).
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IFRS S2 CLIMATE-RELATED DISCLOSURES–JUNE 2023
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Introduction
This volume is part of the Industry-based Guidance on Implementing IFRS S2 Climate-related
Disclosures. This guidance suggests possible ways to apply some of the disclosure requirements in
IFRS S2 but does not create additional requirements.
This volume suggests possible ways to identify, measure and disclose information about
climate-related risks and opportunities that are associated with particular business
models, economic activities and other common features that characterise participation in
this industry.
This industry-based guidance has been derived from Sustainability Accounting Standards
Board (SASB) Standards, which are maintained by the International Sustainability
Standards Board (ISSB). The metric codes used in SASB Standards have been included for
ease of reference. For additional context regarding the industry-based guidance contained
in this volume, including structure and terminology, application and illustrative
examples, refer to Section III of the Accompanying Guidance to IFRS S2.
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Volume 44—Solar Technology & Project Developers
Industry Description
Solar Technology & Project Developers industry entities manufacture solar energy
equipment, including solar photovoltaic (PV) modules, polysilicon feedstock, solar
thermal electricity-generation systems, solar inverters and other related components.
Entities also may develop, build and manage solar energy projects and offer financing or
maintenance services to customers. The industry uses two primary technologies: PV and
concentrated solar power (CSP). Within solar PV, two main technologies exist: crystalline
silicon-based solar and thin-film solar, which includes panels made using copper indium
gallium selenide and cadmium telluride. The primary markets for solar panels are
residential, non-residential (commercial and industrial) and utility-scale projects. Entities
in the industry operate globally.
Sustainability Disclosure Topics & Metrics
Table 1. Sustainability Disclosure Topics & Metrics
TOPIC
METRIC
CATEGORY
UNIT OF
MEASURE
CODE
Energy
Management
in
Manufacturing
(1) Total energy consumed,
(2) percentage grid electricity and
(3) percentage renewable
Quantitative
Gigajoules
(GJ),
Percentage
(%)
RR-ST-130a.1
Water
Management
in
Manufacturing
(1) Total water withdrawn, (2) total water
consumed; percentage of each in
regions with High or Extremely High
Baseline Water Stress
Quantitative
Thousand
cubic metres
(m³),
Percentage
(%)
RR-ST-140a.1
Description of water management risks
and discussion of strategies and
practices to mitigate those risks
Discussion
and Analysis
n/a
RR-ST-140a.2
Management
of Energy
Infrastructure
Integration &
Related
Regulations
Description of risks associated with
integration of solar energy into existing
energy infrastructure and discussion of
efforts to manage those risks
Discussion
and Analysis
n/a
RR-ST-410a.1
Description of risks and opportunities
associated with energy policy and its
effect on the integration of solar energy
into existing energy infrastructure
Discussion
and Analysis
n/a
RR-ST-410a.2
Table 2. Activity Metrics
ACTIVITY METRIC
CATEGORY
UNIT OF
MEASURE
CODE
Total capacity of photovoltaic (PV) solar modules
produced
Quantitative
Megawatts
(MW)
RR-ST-000.A
continued...
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...continued
ACTIVITY METRIC
CATEGORY
UNIT OF
MEASURE
CODE
Total capacity of completed solar energy systems 74
Quantitative
Megawatts
(MW)
RR-ST-000.B
Total project development assets 75
Quantitative
Presentation
currency
RR-ST-000.C
Energy Management in Manufacturing
Topic Summary
Solar panel manufacturing typically uses electrical energy purchased from the grid.
Energy can account for a considerable share of the total cost of production. Considering
rising energy costs and regulatory uncertainty surrounding the future of fossil-based
energy, entities that diversify their energy sources may manage the associated risks and
maintain a reliable energy supply more effectively. Entities that minimise energy use
through effective energy management may reduce costs and gain a competitive
advantage through operational efficiency and competitive pricing of products.
Competitively priced products are particularly important given the intense price
competition within the solar technology industry.
Metrics
RR-ST-130a.1. (1) Total energy consumed, (2) percentage grid electricity and
(3) percentage renewable
1
The entity shall disclose (1) the total amount of energy it consumed as an
aggregate figure, in gigajoules (GJ).
1.1
The scope of energy consumption includes energy from all sources,
including energy purchased from external sources and energy produced by
the entity itself (self-generated). For example, direct fuel usage, purchased
electricity, and heating, cooling and steam energy are all included within
the scope of energy consumption.
1.2
The scope of energy consumption includes only energy directly consumed
by the entity during the reporting period.
74
Note to RR-ST-000.B – Solar energy systems are defined as any system that converts sunlight into
electrical energy, including photovoltaic (PV) systems and solar thermal electric systems.
Completed systems are defined by the entity, consistent with its existing public disclosure of
completed systems.
75
Note to RR-ST-000.C – Project development assets are defined by the entity, consistent with its
existing public disclosure of project development assets, regardless of terminology used by the
entity (e.g., “Project assets,” “Project assets—plants and land,” “Solar Energy Systems Held for
Development and Sale,” etc.). At a minimum, project development assets include assets that are
associated with solar energy systems that are under development or fully developed, owned by
the entity, and held for sale or intended to be sold to a third party prior to the execution of a
definitive sales agreement, and assets that consist primarily of capitalised costs incurred in
connection with the development of solar energy systems.
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1.3
In calculating energy consumption from fuels and biofuels, the entity shall
use higher heating values (HHV), also known as gross calorific values
(GCV), which are measured directly or taken from the Intergovernmental
Panel on Climate Change (IPCC).
2
The entity shall disclose (2) the percentage of energy it consumed that was
supplied from grid electricity.
2.1
The percentage shall be calculated as purchased grid electricity
consumption divided by total energy consumption.
3
The entity shall disclose (3) the percentage of energy it consumed that was
renewable energy.
3.1
Renewable energy is defined as energy from sources that are replenished
at a rate greater than or equal to their rate of depletion, such as
geothermal, wind, solar, hydro and biomass.
3.2
The percentage shall be calculated as renewable energy consumption
divided by total energy consumption.
3.3
The scope of renewable energy includes renewable fuel the entity
consumed, renewable energy the entity directly produced and renewable
energy the entity purchased, if purchased through a renewable power
purchase agreement (PPA) that explicitly includes renewable energy
certificates (RECs) or Guarantees of Origin (GOs), a Green‐e Energy
Certified utility or supplier programme, or other green power products
that explicitly include RECs or GOs, or for which Green‐e Energy Certified
RECs are paired with grid electricity.
3.3.1
For any renewable electricity generated on-site, any RECs and GOs
shall be retained (not sold) and retired or cancelled on behalf of the
entity for the entity to claim them as renewable energy.
3.3.2
For renewable PPAs and green power products, the agreement shall
explicitly include and convey that RECs and GOs be retained or
replaced and retired or cancelled on behalf of the entity for the
entity to claim them as renewable energy.
3.3.3
The renewable portion of the electricity grid mix that is outside of
the control or influence of the entity is excluded from the scope of
renewable energy.
3.4
For the purposes of this disclosure, the scope of renewable energy from
biomass sources is limited to materials certified to a third-party standard
(for example, Forest Stewardship Council, Sustainable Forest Initiative,
Programme for the Endorsement of Forest Certification or American Tree
Farm System), materials considered eligible sources of supply according to
the Green-e Framework for Renewable Energy Certification, Version 1.0 (2017) or
Green-e regional standards, or materials eligible for an applicable
jurisdictional renewable portfolio standard.
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4
The entity shall apply conversion factors consistently for all data reported under
this disclosure, such as the use of HHVs for fuel usage (including biofuels) and
conversion of kilowatt hours (kWh) to GJ (for energy data including electricity
from solar or wind energy).
Water Management in Manufacturing
Topic Summary
Solar photovoltaic panel manufacturing can be water-intensive, and ultra-pure water is a
critical input in some processes. The manufacturing process also may generate
wastewater, which must be treated before disposal or reuse, and therefore may result in
incremental operating costs and capital expenditures. Furthermore, depending on the
location, solar equipment manufacturing facilities may face water scarcity and related
cost increases or operational disruptions. Water resource use may generate tension with
local water users and associated risks, potentially disrupting manufacturing operations
and adversely affecting brand value. To mitigate water supply and treatment risks,
entities may adopt various strategies such as recycling process water, improving
production techniques to lower water intensity, and improving water treatment systems.
Metrics
RR-ST-140a.1. (1) Total water withdrawn, (2) total water consumed; percentage of
each in regions with High or Extremely High Baseline Water Stress
1
The entity shall disclose the amount of water, in thousands of cubic meters, that
was withdrawn from all sources.
1.1
Water sources include surface water (including water from wetlands,
rivers, lakes, and oceans), groundwater, rainwater collected directly and
stored by the entity, and water and wastewater obtained from municipal
water supplies, water utilities, or other entities.
2
The entity may disclose portions of its supply by source if, for example, significant
portions of withdrawals are from non-freshwater sources.
2.1
Fresh water may be defined according to the local laws and regulations
where the entity operates. If no legal definition exists, fresh water shall be
considered to be water that has less than 1,000 parts per million of
dissolved solids.
2.2
Water obtained from a water utility in compliance with jurisdictional
drinking water regulations can be assumed to meet the definition of fresh
water.
3
The entity shall disclose the amount of water, in thousands of cubic meters, that
was consumed in its operations.
3.1
Water consumption is defined as:
3.1.1
Water that evaporates during withdrawal, use and discharge
3.1.2
Water that is directly or indirectly incorporated into the entity’s
product or service
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3.1.3
Water that does not otherwise return to the same catchment area
from which it was withdrawn, such as water returned to another
catchment area or the sea.
4
The entity shall analyze all of its operations for water risks and identify activities
that withdraw and consume water in locations with High (40–80 percent) or
Extremely High (>80 percent) Baseline Water Stress as classified by the World
Resources Institute’s (WRI) Water Risk Atlas tool, Aqueduct.
5
The entity shall disclose its water withdrawn in locations with High or Extremely
High Baseline Water Stress as a percentage of the total water withdrawn.
6
The entity shall disclose its water consumed in locations with High or Extremely
High Baseline Water Stress as a percentage of the total water consumed.
RR-ST-140a.2. Description of water management risks and discussion of
strategies and practices to mitigate those risks
1
The entity shall describe its water management risks associated with water
withdrawals, water consumption and discharge of water or wastewater.
1.1
Risks associated with water withdrawals and water consumption include
risks to the availability of adequate, clean water resources, which include:
1.1.1
Environmental constraints—such as operating in water-stressed
regions,
drought,
concerns
of
aquatic
impingement
or
entrainment, interannual or seasonal variability, and risks from
the impact of climate change
1.1.2
Regulatory and financial constraints—such as volatility in water
costs, stakeholder perceptions and concerns related to water
withdrawals (for example, those from local communities, non-
governmental organisations and regulatory agencies), direct
competition with and impact from the actions of other users (for
example, commercial and municipal users), restrictions to
withdrawals because of regulations, and constraints on the entity’s
ability to obtain and retain water rights or permits
1.2
Risks associated with the discharge of water or wastewater include the
ability to obtain rights or permits related to discharges, regulatory
compliance related to discharges, restrictions to discharges, the ability to
maintain control over the temperature of water discharges, liabilities,
reputational risks and increased operating costs because of regulation,
stakeholder perceptions and concerns related to water discharges (for
example, those from local communities, non-governmental organisations
and regulatory agencies).
2
The entity may describe water management risks in the context of:
2.1
How risks may vary by withdrawal source, including surface water
(including water from wetlands, rivers, lakes and oceans), groundwater,
rainwater collected directly and stored by the entity, and water and
wastewater obtained from municipal water supplies, water utilities or
other entities; and
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2.2
How risks may vary by discharge destinations, including surface water,
groundwater or wastewater utilities.
3
The entity may discuss the potential effects that water management risks may
have on its operations and the time line over which such risks are expected to
manifest.
3.1
Effects include those associated with costs, revenue, liabilities, continuity
of operations and reputation.
4
The entity shall discuss its short- and long-term strategies or plans to mitigate
water management risks, which include:
4.1
The scope of its strategy, plans, goals or targets, such as how they relate to
various business units, geographies or water-consuming operational
processes.
4.2
Any water management goals or targets it has prioritised, and an analysis
of performance against those goals or targets.
4.2.1
Goals and targets include those associated with reducing water
withdrawals,
reducing
water
consumption,
reducing
water
discharges, reducing aquatic impingements, improving the quality
of water discharges and regulatory compliance.
4.3
The activities and investments required to achieve the plans, goals or
targets, and any risks or limiting factors that might affect achievement of
the plans or targets.
4.4
Disclosure of strategies, plans, goals or targets shall be limited to activities
that were ongoing (active) or reached completion during the reporting
period.
5
For water management targets, the entity shall additionally disclose:
5.1
Whether the target is absolute or intensity-based, and the metric
denominator if it is an intensity-based target.
5.2
The time lines for the water management activities, including the start
year, the target year and the base year.
5.3
The mechanism(s) for achieving the target, including:
5.3.1
Efficiency efforts, such as the use of water recycling or closed-loop
systems;
5.3.2
Product innovations, such as redesigning products or services to
require less water;
5.3.3
Process and equipment innovations, such as those that enable the
reduction of aquatic impingements or entrainments;
5.3.4
Use of tools and technologies (for example, the World Wildlife
Fund Water Risk Filter, the Global Water Tool and Water Footprint
Network Footprint Assessment Tool) to analyse water use, risks and
opportunities; and
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5.3.5
Collaborations or programmes in place with the community or
other organisations
5.4
The percentage reduction or improvement from the base year, in which
the base year is the first year against which water management targets are
evaluated towards the achievement of the target.
6
The entity shall discuss whether its water management practices result in any
additional lifecycle impacts or trade-offs in its organisation, including trade-offs
in land use, energy production and greenhouse gas (GHG) emissions, and why the
entity chose these practices despite lifecycle trade-offs.
Management of Energy Infrastructure Integration & Related
Regulations
Topic Summary
Entities in the industry have faced challenges in establishing solar energy as a cost-
competitive means of energy production and GHG reduction, and they have encountered
difficulty in capturing a greater market share of global energy generation. To promote
greater adoption of solar, the industry may benefit by preventing systemic disruptions to
the existing energy infrastructure and essential energy services. Entities are innovating to
overcome the technical challenges of increasing solar integration with the grid. They also
are engaging regulatory agencies and policymakers to reduce regulatory barriers to solar
energy adoption, many of which are emerging because of concerns regarding increasing
overall grid electricity costs and grid disruptions. Solar entities are investing in
innovative technologies to reduce hardware and installation costs, and they are pursuing
business-model innovation to reduce the cost of capital and facilitate the purchase of
solar energy systems. Solar technology entities may improve their competitiveness
through deploying one or more of these strategies successfully to ensure their ability to
scale over the long term.
Metrics
RR-ST-410a.1. Description of risks associated with integration of solar energy into
existing energy infrastructure and discussion of efforts to manage those risks
1
The entity shall describe risks, challenges and barriers surrounding the
integration of solar energy into the existing energy infrastructure in terms of its
products and services.
1.1
Relevant information to provide may include:
1.1.1
Technological barriers to increased integration of solar energy,
such as limited transmission network connectivity, lack of access
to
high-capacity
transmission
networks,
variability
in
interconnection
standards,
and
inverter
interconnection
requirements
1.1.2
Operational barriers to increased integration of solar energy, such
as curtailment and challenges associated with the variable nature
of solar energy
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1.1.3
Customer
motivations
for
seeking
increased
solar
energy
integration, such as economic advantages, regulatory compliance,
risk mitigation, and public perception or reputational risk
2
The entity shall discuss its strategy and approach to design, development and
sales to integrate solar energy into the existing energy infrastructure.
2.1
Relevant strategies and approaches may include:
2.1.1
Technical product design
2.1.2
New product or product components development (for example,
smart inverters)
2.1.3
Technical innovation to reduce the cost of solar energy modules or
systems
2.1.4
Third-party partnerships and product integrations
2.1.5
Project design (for example, project siting in regions with reduced
curtailment risk)
2.1.6
Project risk transfer (for example, power purchase agreements
(PPAs) with curtailment caps)
2.1.7
Marketing and sales (for example, focus on regions or customer
segments with less grid integration risk)
2.1.8
Incorporating energy storage technology or ‘smart grid’ technology
into
solar
energy
systems,
whether
through
proprietary
technological development or collaboration with third parties
2.1.9
Products designed to operate ‘off-grid’ or as part of ‘micro-grids’
2.1.10 Innovation that decreases solar energy’s levelised cost of energy
(LCOE) through the reduction in ‘soft costs’, including financing,
leasing, customer acquisition and development costs
2.1.11 Innovation that increases the total addressable solar energy market
2.2
Relevant information to provide includes:
2.2.1
Whether the entity pursues more than one approach
2.2.2
Whether the entity’s approach varies by market
2.2.3
The intensity of R&D requirements for the entity’s approach and
strategy
2.2.4
The level of competition relative to the entity’s approach and
strategy
2.2.5
How the entity evaluates the success of its approach
3
The scope of disclosure shall include all the entity’s solar energy-related products,
product components, projects, project development efforts and services, as well as
the associated marketing and sales strategies, in the markets in which the entity
operates.
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The entity may describe how energy infrastructure influences the establishment
of sales targets, strategies for specific product categories, technologies or
marketing practices in specific regions, research and development (R&D)
objectives, and partnerships.
RR-ST-410a.2. Description of risks and opportunities associated with energy
policy and its effect on the integration of solar energy into existing energy
infrastructure
1
The entity shall discuss the risks and opportunities associated with energy policy
and the effect energy policy has on solar energy integration into existing energy
infrastructure, in which:
1.1
Relevant risks and opportunities may include:
1.1.1
Direct or indirect government subsidization of solar energy
1.1.2
International trade policy disputes and agreements
1.1.3
Public policies that set out minimum requirements for renewable
energy generation (for example, renewable portfolio standards)
1.1.4
Public policies that affect the monetisation of solar energy
generation, which may include net metering, time-of-use rates,
feed-in tariffs, utility fixed fees and renewable energy priority
dispatch
1.1.5
Public policies that affect the financing and tax structure of solar
energy, which may include investment tax credits, property-
assessed clean energy, loan guarantees and depreciation schedules
1.1.6
Public policies pertaining to any external social costs created by
distributed solar energy generation
1.1.7
Policies pertaining to electricity transmission, which may include
regional transmission planning, interconnected transmission
networks,
interconnection
standards
and
high-capacity
transmission networks
1.1.8
Replacements to ageing energy generation and transmission
infrastructure
2
The entity shall identify the risks and opportunities related to legislation,
regulation, rule-making and the overall political environment (hereafter referred
to collectively as ‘regulatory and political environment’) regarding energy policy
and the integration of solar energy into energy infrastructure.
2.1
The scope shall include existing, emerging and known future risks and
opportunities.
2.2
The scope shall include risks and opportunities that may exist at each
jurisdictional level, international governmental organisations, and
regulatory organisations.
2.2.1
The scope shall include the relevant policies of utilities, rule-
makers and regulators.
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3
Relevant information to provide includes, but is not limited to, the impact on
demand for the entity’s solar energy products and services and the impact on
business viability related to risks and opportunities associated with energy policy
and the impact energy policy has on the integration of solar energy into the
existing energy infrastructure.
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