SASB Asset Management & Custody Activities

1. Download the Standard: Access the SASB Asset Management & Custody Activities standard (industry code FN-AC) for free at sasb.org. Review the full set of disclosure topics and associated metrics to understand what is required.

1. Conduct a Materiality Assessment: Map the SASB-defined topics — transparent information and fair advice, employee incentives and risk-taking, business ethics, and systemic risk management — against your organization's existing ESG data and reporting gaps.

1. Assign Internal Ownership: Designate cross-functional owners for each disclosure topic (e.g., Compliance for business ethics, HR for employee incentives, Risk for systemic risk management) to ensure accurate data collection.

1. Collect and Validate Data: Gather quantitative and qualitative data for each required metric. Use SASB's technical protocols and unit-of-measure guidance to ensure consistency and comparability.

1. Draft Disclosures: Prepare disclosures aligned to SASB's format, typically embedded in your annual report, sustainability report, or SEC filing. Reference the SASB standard explicitly to signal adoption to investors.

1. Consider Third-Party Assurance: Engage an external auditor or assurance provider to verify disclosed metrics — increasingly expected by institutional investors and ESG rating agencies.

1. Publish and Register: Publish your disclosures and optionally register your adoption on the SASB website or through the IFRS Foundation's disclosure portal to improve visibility with investors.

1. Update Annually: Review SASB standard updates and align future disclosures with the latest version, particularly as SASB standards are integrated into IFRS Sustainability Disclosure Standards (ISSB).

The SASB Asset Management & Custody Activities standard (FN-AC) defines four core disclosure topics, each with specific quantitative and qualitative metrics that organizations are expected to report against.

Transparent Information & Fair Advice for Customers covers metrics related to the number and percentage of covered employees with a record of investment-related investigations, consumer-initiated complaints, private civil litigations, or other regulatory proceedings. It also includes total amount of monetary losses from legal proceedings associated with marketing and communication of financial product-related information.

Employee Incentives & Risk-Taking addresses the percentage of revenue from performance-based fees and the approach to ensuring incentive structures do not encourage excessive risk-taking. This topic reflects concerns about misaligned compensation structures that contributed to systemic financial instability.

Business Ethics requires disclosure of total amount of monetary losses from legal proceedings associated with fraud, insider trading, anti-trust, anti-competitive behavior, market manipulation, malpractice, or other related financial industry laws or regulations.

Systemic Risk Management covers the percentage of open-end fund assets under management (AUM) by category, exposure to securities lending, and a description of approach to incorporation of environmental, social, and governance (ESG) factors in investment and/or wealth management processes and strategies. This topic is particularly relevant for large asset managers whose activities may have systemic implications for financial markets.

Activity metrics — such as total registered and unregistered AUM, total assets under custody and supervision, and number of registered investment advisers — provide context for normalizing the above disclosures.

SASB standards have become one of the most widely referenced ESG disclosure frameworks globally, particularly among institutional investors and publicly listed companies. As of the mid-2020s, thousands of companies across 77 industries have voluntarily adopted SASB standards, with the financial services sector — including asset management — among the most active adopters. Major institutional investors including BlackRock, Vanguard, and State Street have explicitly requested SASB-aligned disclosures from portfolio companies, significantly driving adoption rates.

A pivotal development occurred in 2022 when the IFRS Foundation consolidated SASB under the newly formed International Sustainability Standards Board (ISSB). SASB standards now serve as the industry-specific implementation guidance for IFRS S1 and S2, dramatically elevating their global credibility and regulatory relevance. This integration has accelerated adoption in jurisdictions moving toward mandatory IFRS-aligned sustainability disclosure, including the EU, UK, Canada, Australia, and Japan.

In the asset management space specifically, SASB's FN-AC standard competes with broader frameworks like GRI and CDP, but is differentiated by its investor-grade, financially material focus. While GRI is more widely used for stakeholder-facing sustainability reports, SASB is increasingly preferred for investor communications and regulatory filings. The SEC's climate disclosure rules and similar regulations in other markets are expected to further entrench SASB-aligned metrics as baseline expectations for public asset managers. Demand for SASB expertise among sustainability professionals in finance continues to grow, though the framework's self-reported nature and lack of formal certification remain points of criticism from investors seeking assured, comparable data.

The Sustainability Accounting Standards Board (SASB) was founded in 2011 by Jean Rogers in San Francisco, with a mission to develop industry-specific sustainability accounting standards that help businesses disclose financially material ESG information to investors. Modeled loosely on the Financial Accounting Standards Board (FASB), SASB sought to bring rigor and comparability to sustainability reporting by focusing on what is material to investors — not just what is broadly relevant to society. The Asset Management & Custody Activities standard was among the 77 industry standards developed through SASB's multi-year, multi-stakeholder process involving industry working groups, investor input, and public comment periods.

SASB published its full suite of provisional standards in 2018 after years of development and piloting. In 2019, SASB merged with the International Integrated Reporting Council (IIRC) to form the Value Reporting Foundation (VRF). A further consolidation occurred in 2022 when the VRF was absorbed into the IFRS Foundation, placing SASB standards under the stewardship of the newly established International Sustainability Standards Board (ISSB). The ISSB has since incorporated SASB's industry-specific metrics as implementation guidance for its global baseline sustainability disclosure standards (IFRS S1 and S2), cementing SASB's role as the de facto industry-specific layer of the emerging global sustainability reporting architecture.