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Carbon Tracker Response to the FASB’s Invitation to Comment

Barbara Davidson
24 July 2025

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Carbon Tracker submitted a joint response with Ceres and the Climate Accounting and Audit Project to the FASB’s Invitation to Comment on its future standard-setting agenda. Our submission covered insufficient disclosure of key estimates and assumptions in companies’ financial statements, with a main focus on Question 31, which asked whether the FASB should revisit the recognition and measurement guidance for Asset Retirement Obligations (AROs). Our letter emphasised the need for greater transparency and consistency in the treatment of AROs, which are often understated or omitted entirely, leaving investors without a full view of financial risk. We provided recommendations to enhance disclosure of both recognized and unrecognized AROs, information critical for investors to assess long-term liabilities and financial resilience. Please download the file for a detailed response.
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