In its draft comment letter, EFRAG notes a number of issues that are considered to be prevalent in Europe and might deserve standard-setting activities. EFRAG believes the following issues should be of highest priority:
- the application of the SPPI test to sustainable finance products,
- the absence of recycling for FVOCI equity instruments,
- the treatment of equity-type instruments, and
- reporting on reverse factoring.
Comments on EFRAG's draft comment letter are requested by 14 January 2022. For more information, see the press release and the draft comment letter on the EFRAG website.