07/09/2023 - EFRAG publishes its final comment letters on the ISSB consultations on Agenda priorities and SASB methodology

​EFRAG has published its final comment letters in response to the ISSB RFI Agenda Priorities as well as the ISSB ED Internationalisation of SASB Standards and related Taxonomy.

• EFRAG's final comment letter to the ISSB RFI Agenda Priorities

In the final comment letter EFRAG suggests the ISSB to put the emphasis on i) a clear direction of travel with a definition of the universe of sustainability related information to be ultimately covered and of the corresponding underlying concepts, ii) the priority to be given to interoperability in structure and content with other sustainability reporting standards, and iii) connectivity to be included as a priority topic in the standard-setting workplan, together with the topical standards.

EFRAG considers that the first priority of the ISSB is beginning new research and standard-setting projects (including connectivity) and supporting the implementation of the ISSB standards IFRS S1 and IFRS S2.

EFRAG further considers a mechanism to monitor and address interpretation issues should be created.

Also, EFRAG recommends the ISSB to explicitly integrate the investors' interest in impact materiality.

EFRAG does not put forward a prioritisation of the different research projects and the subsequent standards to be developed, because it develops comprehensive standards in accordance with the CSRD. EFRAG disagrees with the approach to describe the topic on biodiversity so broadly that it becomes all encompassing. 

EFRAG applauds the intention of the ISSB to broaden its coverage to social topics, highlights the intrinsic links between human capital and human rights and cautions against unbundling these topics.

EFRAG considers that a project on connectivity (not integration in reporting) should be given high priority to develop guidance on connected information.

Should the ISSB start a project on integration in reporting, EFRAG considers it should be pursued as a formal joint project of the IASB and ISSB.

More details can be found in the full comment letter here.

• EFRAG's final comment letter to the ISSB ED Internationalisation of SASB Standards

In the final comment letter EFRAG generally agrees that the proposed methodology would improve the international applicability of the SASB standards but points to the following improvements that could be made: i) keeping an acceptable comparability level when working with national references and ii) the ratification status of international references.

EFRAG considers the proposed methodology a reasonable transition approach, pending a more extensive standard setting activity to enhance the SASB standards, as done for S2 Climate. 

The ISSB should develop a gap analysis between the SASB standards and sustainability reporting frameworks developed more recently or being developed. The ISSB should also avoid relying on metrics behind a payment wall.

EFRAG agrees to update the SASB XBRL Taxonomy to reflect the amended SASB standards accordingly, as suggested. EFRAG invites the ISSB to work with EFRAG on a harmonisation of the sector specific digital XBRL taxonomies of the ESRS and ISSB standards.

More details can be found in the full comment letter, here.