The FRC welcomes the opportunity to provide comments on the ISSB's consultation and agrees the the proposed approaches outlined in paragraph 9 of the exposure draft will lead to improved international applicability of the Sustainability Accounting Standards Board's (SASB's) standards.  However, whilst the FRC considers that the exposure draft is a 'reasonable initial effort which will result in incremental improvements to the SASB standards', it believes that there should be a more comprehensive follow up review of the SASB standards 'if they are genuinly to be fully internationally applicable and consistent with other IFRS Sustainability Disclosure Standards'.  The FRC suggests that this review should consider:

• the appropriateness of the Sustainable Industry Classification System (SICS);
• whether the industry-based requirements are principally industry-specific or industry-relevant requirements;
• the underlying research that informs the content;
• the structure of the content and how it fits with other IFRS Sustainability Disclosure Standards; and
• reframing the disclosure topics to focus on sustainability-related risks and opportunities to support the application of IFRS S1.

An appendix provides detailed responses to the specific questions posed in the exposure draft.

A press release and the full comment letter are available on the FRC website.