In its draft 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 priority of the ISSB should be:

1. the beginning of new research and standard-setting projects including connectivity between financial reporting and sustainability reporting.
2. supporting the implementation of ISSB Standards IFRS S1 and IFRS S2 and researching targeted enhancements to the ISSB Standards.
3. to enhance the Sustainability Accounting Standards Board (SASB) Standards.

In selecting projects, EFRAG recommends the ISSB to clarify the criterion "importance of the matter to investors" and explicitly 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 agrees with incorporating concepts from the International Accounting Standards Board's (IASB's) project on Management Commentary and the Integrated Reporting Framework.

Comments on EFRAG's draft comment letter are requested by 25 July 2023. Further details are available in the press release and draft comment letter on the EFRAG website.