Governance Retrospective Briefing — March 21, 2022
Regulators built data-sharing, resilience, and sustainability oversight mandates from late 2020 through early 2022, giving Zeph Tech governance teams the frameworks they still brief boards on.
Why it matters: Governance leaders saw a wave of structural reforms between November 2020 and March 2022. EU lawmakers stood up data-sharing rules and corporate due diligence duties, bank supervisors locked in operational resilience expectations, global standard setters formed the ISSB, and the SEC advanced climate disclosures.
November 2020 — European Commission proposal for the Data Governance Act. The framework introduced data intermediary registration, public-sector reuse conditions, and the European Data Innovation Board. The proposal remains the baseline for data altruism and trusted intermediary obligations.
- Public bodies must assess requests for re-use of protected data and apply harmonised charging policies.
- Data intermediation services must register, maintain structural separation, and comply with transparency requirements.
March 2021 — Basel Committee Principles for Operational Resilience. Global systemically important banks received supervisory expectations to map critical operations, establish impact tolerances, and integrate third-party risk. The principles anchor regulatory examinations for resilience planning.
- Firms must document critical operations, mapping dependencies across people, information, technology, and third parties.
- Supervisors expect scenario testing and board oversight over resilience strategies and recovery metrics.
November 2021 — IFRS Foundation establishes the International Sustainability Standards Board. The IFRS Foundation announced the ISSB at COP26 and consolidated the Value Reporting Foundation and Climate Disclosure Standards Board. The announcement set the stage for global sustainability disclosure baselines.
- The consolidation accelerates development of IFRS Sustainability Disclosure Standards building on SASB and TCFD frameworks.
- Jurisdictions now align climate and ESG reporting reforms around the ISSB technical agenda.
February 2022 — EU Corporate Sustainability Due Diligence Directive proposal. The Commission’s draft directive imposes human-rights and environmental due diligence duties on large EU and non-EU companies. COM(2022) 71 requires board oversight and climate transition planning for in-scope firms.
- Companies must identify, prevent, and mitigate adverse impacts across their operations and value chains, with enforcement by national supervisors.
- Large EU companies must adopt climate transition plans aligned with the Paris Agreement and can tie executive pay to plan implementation.
March 2022 — SEC climate disclosure proposal (Release 33-11042). The Commission’s draft rule would require Scope 1 and 2 greenhouse gas disclosures and climate risk governance reporting in Form 10-K. The proposal extends assurance and attestation requirements for large filers.
- Registrants must report board oversight of climate risks, scenario analysis outputs, and climate-related financial statement metrics.
- Large accelerated and accelerated filers must obtain assurance over emissions disclosures on a phased timeline.
Action for operators: Update governance dashboards to track these EU and U.S. obligations—board reporting, resilience testing, and due diligence programmes should reflect the mandates ahead of 2023–2024 enforcement waves.