EFRAG cites the following reasons:

• The Conceptual Framework project is very important and will have a profound and overarching effect on the outcomes of future standard-setting processes. It is essential that the IASB's constituents have sufficient time to study the proposals in the ED.
• The IASB argued that a 150-day comment period would suffice as constituents would already be familiar with the content of the ED as it is based on the July 2013 Discussion Paper. However, EFRAG argues that there have been significant changes since then.
• In EFRAG’s view, the ED does not provide sufficient principle based guidance on important issues such as the selection of measurement bases and what should be reported in OCI. EFRAG expects that constituents might want to develop and provide suggestions on how to deal with these issues, which would take additional time.
• In some jurisdictions, the period available for debating the ED would be shortened by the time it takes to translate the proposals.
• The time available could also be reduced by the need to react to other documents issued by the IFRS Foundation for comment (the forthcoming Agenda Consultation and the IFRS Foundation Review on structure and effectiveness).

Please click for additional information and access to the letter sent to the IASB in the press release on the EFRAG website. More information on EFRAG's consultation document on the Conceptual Framework ED is available here.