In addition to proposals and comments on an advisory council, the proposed structure, due process matters, and the funding needed, the comment letter also discusses the cooperation with other standard setters and initiatives. Accountancy Europe notes, that it supports a “building block” approach to non-financial information (NFI) reporting standard setting: The base would be global standards for market transparency, achieved by the coordination, cooperation and consolidation of global NFI initiatives and additional “blocks” of EU NFI reporting standards could then be added to that, where necessary.

Under this scenario, Accountancy Europe notes, EFRAG’s role would be to endorse global NFI reporting standards in the EU and to develop the added “block” of EU NFI reporting standards important for the EU public policy objectives. The comment letter points out that international cooperation is the best way forward:

Therefore, we suggest EFRAG to collaborate with the IFRS Foundation, CDP, the Value Reporting Foundation, the Climate Disclosure Standards Board (CDSB) and the Global Reporting Initiative (GRI), to set the respective roles and task to avoid inefficiencies (e.g., output and funding) and to timely address the urgent issues at hand.

Please click to access the full comment letter on the Accountancy Europe website.