This diagram shows how sustainability data can flow through a (NOVA-aligned) structured, governed market to enable trusted decisions. It begins with raw inputs and ends with real-world outcomes, and maps the various steps in-between, including how the sharing of data is governed. 

At its foundation are codified science, raw data, and algorithms. These come from science and standards bodies via sensors or related data providers. They are structured through harmonised (using existing standards) models, taxonomies, and ontologies, and stored or managed through technical systems such including databases, data lakes, and aggregation platforms. This layer provides the basic ingredients for sustainability intelligence.

In parallel, the policy and legal layer defines the rights, responsibilities, and protections that govern the underlying data. This includes statutory and voluntary rules, contract structures, redress mechanisms, liabilities, access management, terms and conditions, and pathways for conformance and dispute resolution. Policy frames what should be done and the legal frameworks encode these requirements into enforceable commitments for all participants. Together, these provide guardrails to ensure data sharing is lawful, ethical, and accountable, enabling organisations to operate with clarity and confidence.

Sitting above this layer are the technical infrastructure and metadata practices that ensure consistency, provenance, and interoperability. Principles, standards, and commitments guide how data is produced, maintained, and exchanged. 

Together, these feed into Scheme definitions: where multilateral licences define the full rules for publishing, accessing, and using data. The Scheme rules cover policy, legal, technical, and security needs, and are the basis for pre-competitive collaboration.

To drive adoption and make the Scheme rules operational, a data governance process brings together domain experts, implementation bodies, and market catalysts, policy, assurance practices, and verification. This layer ensures that the market can ‘go far together’.

To enable scale, Schemes can be delivered using Trust Frameworks (which address identity verification, assurance processes, onboarding, monitoring and enforcement). These enable safe participation for organisations across supply chains and sectors to share data effectively.

Above this, discovery and access interfaces allow both humans and machines to find, request, and use data. Portals and aggregators can surface what is available using standard web processes for search.

The next layer brings in tools for analysis. These turn data into insight, ranging from impact assessments to risk identification, forecasting to exposure analysis, vulnerability assessments to reporting. These are the analytical bridge between raw data and meaningful insights.

All these tools can feed into a wide range of applications: analytics platforms to reporting systems, dashboards to insights engines, or tools that support financial, operational, and policy decisions. 

Using these insights, organisations can design or support financial instruments, including loans, insurance, multimodal investment, transition bonds, or other products that depend on consistent, assurable evidence (the data). 

At the top are outcomes that deliver impact: market-facing solutions, actionable research and derisked innovation, leading to better decisions: targeted investment, effective transition planning and implementation, improved resilience and adaptation, disaster risk reduction, mitigation, and reconstruction.

Combined, this diagram shows how sustainability data can be made usable, dependable, and valuable to support society-wide decision-making.

Examples:

• Perseus
• Open Energy

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Goals of this document

In the context of environmental information, comprehensive financial and non-financial reporting by organisations, we aim to demonstrate opportunities that could reduce effort and complement ongoing international initiatives. We present the scope and complexity of data sharing across markets, supply and value-chains. We highlight challenges that create friction, inertia and inhibit action in delivering goals, including hard-programmed habits and underlying presuppositions and premises. We highlight solutions that can reduce friction in data-sharing and propose levers of change that can help unlock innovation (e.g. policy and regulatory, perception shifts, behavioural changes). 

Intended audience(s)

Our primary audience includes decision-makers and their advisors who wish to understand the transformative potential of data, and how its usage can be unlocked at scale to enable it to act as a flow of evidence that informs action. While it covers ‘technology concepts’ it is not ‘about’ technology. Rather, it addresses designing the conditions for success that would enable millions of experts, practitioners and organisations to better discover, access and use the data they need to make informed decisions. 

This includes, but is not limited to: policymakers and regulators working on Sustainable Finance, Corporate Reporting and Value Chain Due Diligence; experts working across Environmental, Social, and Corporate Governance (ESG), Corporate Social Responsibility (CSR) and related reporting frameworks (e.g. TCFD, SASB); Chief Data Officers and related leaders working on data strategy and policy; solution providers seeking to improve scenario modelling; business leaders optimising efficiency and reducing risk in decision-making.

Executive Summary

The wealth of data we have, and that is becoming available, must now be made usable to help us address climate and environmental risks, and to radically improve our investments in, and planning and management of our global infrastructure. While there is an ocean of available capital, the lack of comprehensive, trusted and quality data-flow is leading to a misallocation of resources, missed opportunities and is creating catastrophic risks on our global balance sheets. Our infrastructure for accessing this data is as important as our physical infrastructure in averting our climate, biodiversity and related crises, but it is being dangerously neglected.

Data for non-financial reporting is, and will increasingly be, required across global value chains. Global cooperation will be needed, ensuring timely, trusted coordination to enable data to flow in ways that all value-chain partners can engage with, align with and accept. Data sharing will, therefore, require an industry-neutral, geography-neutral and context-neutral trust framework and governance to underpin sharing in a non-partisan manner.

Today, the majority of corporate environmental sustainability data published are delivered ‘somewhere online’, often in a PDF format, often inconsistently, in ways that are then aggregated into portals or commercial services that then attempt to translate them into value or risk assessments. There are substantial gaps in the materiality of much of this data, it is often incomplete or not ‘actionable’. The process of data collection, access, sharing and usage are, at best, not fit for purpose.

Fortunately, there are many initiatives addressing the issues of what data may be material (e.g. TCFD, SASB, GRI, CDSB, GHG Protocol). Given that element of the challenge is well understood, our focus is on how to make the information more accessible, usable and impactful.

The opportunity exists to directly affect two parts of the data value chain. Firstly, we can enable better discovery, access and usage of the ‘outputs’ (e.g. TCFD reports). Secondly, and significantly, we can enable better discovery, access and usage of the ‘inputs’ (e.g. the energy consumption of a factory that generates emissions). 

There is a bold but achievable route to deliver access to the environmental data with the quality and scope that will be needed for the success of Sustainable Finance, corporate environmental reporting and multinational corporate management of Science Based Targets for GHG emission reduction. This solution can overcome the significant political and cultural barriers and challenges to the current situation of access to suitable data for corporate reporting, financial disclosures and systemic risk modelling.

The proposed solution builds on the proven potential of existing shared data standards development (e.g. currently deployed in Open Banking) and those that lie at the core of the EU’s Digital and Data Strategies, including the Green Deal Dataspace.

Open Banking has already used this approach with great success. Open Banking is used by two million consumers in the UK, and Open Banking practices are now in development across over twenty countries, including Australia, Bahrain, Europe, Hong Kong, India, Japan, Mexico, Malaysia, New Zealand, Rwanda, Singapore and the USA and beyond. The Open Banking market is projected to grow to over $40B by 2026.

Our direct experience shows that the key features of the creation of data flows are not technical (‘ICT’). Therefore, rather than a focus on ‘which data’, ‘which technology’ or ‘what data standards’ (many exist), instead the solution requires addressing the processes and practices that enable data flows that can unlock continuous improvement — using data as material evidence that drives decisions.  In order to achieve this at scale, across industries and borders, we need a functioning data ecosystem of users and suppliers of data, and the best way to achieve this is to adopt common, open standards for data sharing. To deliver this requires a governance framework for data access that creates trust.

At the heart of the architecture is a federated approach to data sharing, namely that the data is not centrally stored, it is left with the data owner or controller and consent managed to allow those with permissions to access with conditional rules that have been agreed by the market.  

A data governance trust framework addresses three foundational issues. Firstly, it helps align the discovery and access of data in a manner that can scale to millions of use cases. Secondly, it aligns the actors in the system around a secure and trusted environment from which they have a direct benefit to participate (as either a supplier or a consumer of data). Thirdly, critically, a trusted framework can help align organisations around legal, IP, liability and rights issues in a manner that can unlock data sharing between organisations and across borders.

Practical experience in Open Banking, and development of ‘Open Energy’, shows that implementation can grow organically, with strong leadership, appropriate governance, starting small around core use cases, and expanding progressively. Implementation strategies can build on existing experience. 

The approach needs organisations to take forward development together. To satisfy all needs, it is best co-designed by the future participants, with that process facilitated by an independent, neutral body. Whilst there are various international, sectoral and regional initiatives attempting to align data standards (for example around taxonomies and ontologies such as the EU taxonomy for sustainable activities), there is a significant (and unnecessary) gap in initiatives to facilitate data discovery, access and usage. Yet, success in this area is essential and can also resolve or reduce some of the most difficult problems around the alignment of data.

A roadmap for this work would include a 3-6 month process of planning, stakeholder curation and engagement, and scoping of test use-cases. Implementation can be delivered through a continuous development process that combines multi-disciplinary working groups to triage, prioritise and work through specific issues linked to the use-case. In parallel, the use case is developed in an active sandbox environment to test the recommendations and identify material blockers. The solution is tested with users and the outcomes fed back into the scoping process for refinement. This process can be run on a continuous 3 or 6-month loop until viable solutions have been identified, tested and proven.  

Photo credit: @lceusebio, unsplash. Design: Philpott Design

With a view to better explaining the potential for open and shared data to address climate change, the Open Data Institute (ODI) and Icebreaker One have developed a Data Spectrum for Energy.

Icebreaker One is exploring how to rapidly evolve financial and energy systems to embed net-zero into all investments in a manner that is demonstrable, provable and uses data to hold organisations to account.

This work is built upon in our development of Shared Data.

If you have feedback on our joint Data Spectrum for Energy, please get in touch.

The SERI aim is to create a clear, impactful and detailed data governance framework (the Standard for Environment, Risk and Insurance) that enables government, businesses, consumers and 3rd party developers to understand the potential of sector-wide data sharing in insurance to develop climate-ready financial products. Using industry-defined use cases to frame user needs, it will detail the steps to implementation in the UK and empower decision-makers to mandate, measure and act upon the data-flows that enable Net Zero. 

“While these risks may form in full over time, they are becoming apparent now. Firms are enhancing their approaches to managing these risks, but face barriers to implementing the forward-looking, strategic approach necessary to minimise the risks. The CFRF aims to reduce these barriers by developing practical tools and approaches to address climate-related financial risks.”

Climate change and society’s response to it presents financial risks and opportunities that are relevant across the whole financial sector. In the UK, this falls within the remit of the Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA) objectives.

We are working with the FCA’s Climate Financial Risk Forum: Innovation Working Group (CFRF-IWG) to help shape potential areas for product innovation and the underlying data sharing that might enable it. The objective of the CFRF is to build capacity and share best practice across financial regulators and industry to advance our sector’s responses to the financial risks from climate change.

It has convened representatives from across the financial sector, including banks, insurers, and asset managers as well as observers to represent a broader range of firms and ensure the outputs of the CFRF are communicated.

Concurrently, we are working with the FCA’s team on Open Finance, which is exploring how the role of Open Banking might be built upon to include Investments, Pensions, Savings, Consumer Credit, Mortgages and General Insurance.

What is Open Banking and why is it relevant to Icebreaker One?

Open Banking is a regulated standard that addresses the sharing of sensitive data across the banking sector. It addresses:

• Rights
• Liability models
• Dispute resolution and redress
• Consent
• Security
• Legal frameworks
• Usability 
• Logistics
• Technology architecture
• Operating principles

Open Banking was created by convening teams to develop common principles and practice for sector-wide data sharing. They included existing and challenger banks, trade bodies, fintechs, Treasury and regulators. In the UK, this led to the creation of an independent non-profit (funded by the banks) to develop and take the standard to market, with a directory of accredited organisations using it that now numbers in the hundreds.

Open Banking has created an open and safe marketplace for innovation

The standard was (and is) developed openly—as a result, it has helped to catalyse initiatives around the world.  Similar initiatives now exist across Australia, Bahrain, Europe, Hong Kong, India, Japan, Mexico, Malaysia, New Zealand, Rwanda, Singapore and the USA.

Icebreaker One is building on this approach to help companies and regulators design and develop new financial products and services, with a shared set of principles and practice that are aligned with regulatory best-practice.

If you would like to get involved, join us today.