SSBJ Commercially Sensitive Information: What Can Stay Out

A manufacturer plans to recover a critical material from used products. Together with other public information, its launch country and contracted feedstock volume could reveal the supply plan and weaken its negotiating position.

SSBJ may permit the company to omit those details if they are otherwise required and all paragraph 13 conditions are met. It does not allow the company to remove a material risk or an entire strategy section.

Paragraphs 13 to 16 of SSBJ’s Universal Standard set the conditions. They also require a visible disclosure and a fresh assessment at each reporting date.

The relief covers opportunities

Paragraph 13 concerns information about a sustainability-related opportunity. Paragraph 16 says it cannot be used for sustainability-related risks or as a broad basis for withholding sustainability-related financial information (SSBJ, Universal Standard detail).

A company cannot remove a material transition risk by labelling it commercially sensitive. It also cannot apply one confidentiality decision to an entire strategy section.

The SSBJ basis for conclusions explains why the relief is limited to opportunities. Disclosure about an opportunity can reveal the economic benefit a company expects from a commercial plan. Risk information does not receive the same relief.

The rule is different from a legal prohibition. Paragraph 11 covers information that a law in the company’s jurisdiction prohibits it from disclosing. In that case, the company identifies the type of omitted information and names the law. Commercial sensitivity under paragraph 13 has its own test.

Paragraph 12 covers a different case. If a law merely permits the company not to disclose information, material sustainability-related financial information must still be disclosed. The reporting file should therefore distinguish a legal prohibition from a legal permission.

Test the launch information

For the low-carbon launch above, the reporting team first checks whether the launch country and contracted feedstock volume are already public. It then records why disclosure would seriously prejudice the expected economic benefit.

Before withholding the details, the team drafts a broader version. It might name the product category without naming the launch country or contracted volume. If that version meets the disclosure objective without causing serious prejudice, the company uses it.

Paragraph 13 requires all of the following:

• The information is not publicly available.
• Disclosure could seriously prejudice the expected economic benefit.
• Aggregation cannot meet the disclosure objective without that prejudice.

Paragraph 14 requires a statement

Paragraph 14 requires the company to disclose, for each item of information omitted, that it used paragraph 13.

The report does not need to reveal the confidential content in that statement. It does need to show that the company used the relief. A reader should not have to infer that something is missing.

The statement applies to each omitted item. If the company withholds details about two opportunities, its internal file should map each paragraph 14 statement to the relevant item. That same mapping identifies what the team must reassess next year.

Paragraph 15 requires a new assessment at each reporting-period end. If the launch became public during the year, the first condition fails and the prior omission cannot be repeated.

A decision made in March may no longer fit the facts at the December reporting date.

SSBJ’s 30 May 2025 handbook

SSBJ published a handbook on commercially sensitive information on 30 May 2025. The handbook is non-authoritative guidance and does not form part of the SSBJ Standards (SSBJ handbook index).

For this launch, cite paragraphs 13 to 16 in the decision record.

Build an evidence file for each omitted item

SSBJ does not prescribe a template for the internal file.

The file should identify the exact sentence or metric proposed for omission, plus any related financial effect, rather than use a broad label such as confidential strategy.

Record the sustainability-related opportunity it belongs to. Paragraph 13 cannot support an omission about a risk, so this classification needs evidence.

The public-information check should be dated and link to the company pages and market announcements reviewed, because those pages can change later.

For the materials-recovery launch, the reviewer can save the investor-relations news archive and the product page as they appeared on the assessment date. A permit register may already reveal the launch country. That result belongs in the same file, even when the company’s own site says nothing.

Record which economic benefit disclosure could damage and how. Keep the supporting forecast or decision paper under the access controls used for other confidential strategy records.

For this launch, the file can explain that naming the contracted feedstock volume would reveal how much material the company has secured. The supporting supply agreement remains confidential; the reporting file records why the public detail would cause the stated harm.

Test a less specific disclosure. Draft the aggregated version that the team considered. Record why it would still cause serious prejudice if the company rejects it. If aggregation works, use it in the report.

Name the approver and the date. The standard does not assign the decision to a particular committee. The company should place it within its existing disclosure governance and preserve the approval record.

The report must include the paragraph 14 statement. The internal file needs the next paragraph 15 review date.

Try a broader disclosure

The manufacturer may be able to say that it is developing circular services without naming the launch country or volume. If this broader line meets the disclosure objective, it goes into the report. The launch details remain private.

The broader line may still reveal the supply plan. In that case, the company records why the paragraph 13 conditions hold. The report states that the item has not been disclosed under paragraph 13. The team reviews the decision again at the next reporting date.

IFRS S1 B34 to B37

IFRS S1 paragraphs B34 to B37 contain the corresponding relief. IFRS Foundation educational material uses the example of a confidential plan to dispose of a subsidiary when explaining anticipated financial effects. The material asks whether another form of disclosure can meet the objective without seriously prejudicing the expected benefit (IFRS Foundation educational material).

Response 31 from the IFRS Sustainability Standards Transition Implementation Group confirms that the IFRS S1 relief applies when a company reports only climate-related disclosures under IFRS S2. A climate-first filer can use the relief, but the same conditions still apply (IFRS Foundation TIG responses).

An SSBJ and ISSB reporter can keep the same evidence behind both reports. Each report must separately satisfy the standard applied to it.

Put the reassessment into the reporting workflow

Store the omission decision beside the opportunity and the disclosure it affects.

When the launch becomes public, send the item back to the reporting team. Its record should show what the company checked and who approved the decision at the prior reporting date.

At the next period end, the reviewer checks the same public sources again. If a launch announcement now names the country, the prior public-information result is no longer current. The team updates the disclosure instead of copying last year’s conclusion.

Socious Report keeps the paragraph 13 decision and its source records with the SSBJ draft. The free SSBJ readiness check checks whether each part of the reporting process has an owner and evidence.