ISSB's Request for Information (RFI) on its agenda priorities

In its final comment letter EFRAG suggests that the ISSB puts the emphasis on:

• 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;
• the priority to be given to interoperability in structure and content with other sustainability reporting standards; and
• 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 should be beginning new research and standard-setting projects (including connectivity) and supporting the implementation of ISSB Standards IFRS S1 and IFRS S2.

EFRAG explicitly recommends the ISSB to integrate the investors’ interest in impact materiality. 

EFRAG considers that a project on connectivity (not integration in reporting) should be given a high priority to develop guidance on connected information.  Further should the ISSB begin a project on integration in reporting, EFRAG considers it should be pursued as a formal joint project of the International Accounting Standards Board (IASB) and ISSB.

ISSB's Exposure Draft 'Methodology for Enhancing the International Applicability of the SASB Standards and SASB Standards Taxonomy Updates

In its final comment letter, EFRAG generally agrees that the proposed methodology would improve the international applicability of the SASB standards but suggests the following improvements: 

• keeping an acceptable comparability level when working with national references; and
• 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.

EFRAG suggests 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 European Sustainabiity Reporting Standards (ESRS) and ISSB standards.

The press release with links to the final comment letters are available on the EFRAG website.