ITFA

SYS.01 Objective

International banks and trade-finance participants faced a thicket of overlapping regulatory and voluntary ESG frameworks, yet reported sustainability data inconsistently. That inconsistency made comparison, assurance and practical action difficult. The programme set out to find a common, usable view of what organisations actually reported, how requirements differed by jurisdiction, which standards overlapped, and what a minimum comparable reporting standard might look like.

The brief was specific rather than generic corporate ESG analysis: map the regulatory and reporting frameworks including ISSB, SFDR, the EU Taxonomy, PRA/FCA expectations and Basel III/IV; compare country-level rules, compliance steps, reporting frequency and penalties; separate risk-management reporting from transition reporting; cover Scope 1, 2 and 3 emissions, GHG measures, circular economy and biodiversity; bring a trade and supply-chain-finance lens to all of it; and translate the result into a dashboard or resource practitioners could navigate and use.

SYS.02 Creative response

Three parties, three contributions. Dr Rebecca Harding of Rebeccanomics was the research lead and principal authorial voice across the sustainable trade and ESG work. ITFA supplied industry authority, members and convening power: with Sean Edwards, ITFA Chairman, Head of Legal and Special Adviser at a major Japanese global bank, and draftsman of the Uniform Rules for Forfaiting, URTEPO and the Standard Definitions for Techniques of Supply Chain Finance. W'A.I supported the programme with AI-assisted comparative research, digital and visual communication, case-study positioning and presentation support.

ITFA members and Council were both the research participants and the intended owners of any follow-on standards or platform activity.

• Primary research. A confidential survey of ITFA members and approximately 40 interviews.
• AI-assisted bank comparison. A comparative analysis that initially covered 12 banks and was expanded toward 20 after Rebecca Harding asked to add institutions including Société Générale, Investec, UBS, BNY Mellon and MUFG. Each entry examined methodology, regulations followed, reported activity, supplementary disclosure and SASB mapping.
• The report. “Too Big for Us to Fail: The Regulatory Paradox: Towards a Unified, Consistent, and Comparable Standard for Sustainability Reporting in Trade and Supply Chain Finance, Action Research Update”.
• Working files. An AI-generated Word analysis and an Excel hub that Rebecca Harding believed could become a more granular dashboard.
• Case study. A March 2024 W'A.I case-study treatment explaining AI-driven ESG reporting insights in international banking; W'A.I is acknowledged on page 12 of the report.
• Sustainable Trade Platform presentation. Visual and deck work aligned to sustainability, international trade, education and inclusion, with emphasis on digital transformation and resilient supply chains.
• Abu Dhabi conference campaign. Press and campaign planning for ITFA's September 2023 Abu Dhabi conference, with Coalition Greenwich and ITGA engaged.
• Council and platform proposition. A follow-on direction for an ITFA Council to define ESG audit standards, and a web platform to operationalise the work.

The strategic intent was to move from diagnosis to infrastructure. The research showed why existing sustainability reporting was too fragmented for reliable trade-finance comparison; the proposed Council and platform would turn that diagnosis into an industry-backed auditing and education system: common definitions, trusted digital identity, secure financial-services integration and accessible training.

SYS.03 Results

~40, interviews, alongside a confidential ITFA member survey

12 → 20+, banks in the AI-assisted comparative analysis

PAGE 12, W'A.I acknowledged in the published report

Observations were aligned against GRI, SASB, TCFD and the Equator Principles. The research, report and case-study phase is established; a detailed January ESG activity update was requested in April 2024, indicating continuing reporting and communications work around the programme.

There is no confirmation that the proposed ITFA Council defined a final audit standard, that the web platform was built, or that a common standard was formally adopted. An April 2026 conversation concerns refreshing Rebeccanomics papers under Rebecca Harding's own identity, a separate matter, not proof of continued ITFA delivery. The 20-bank and 75% Scope 3 figures come from the later case-study framing and should be rechecked against the final dataset before republication.

SYS.04 The work