Deloitte comment letter on the proposed amendments to the IFRS Foundation Constitution

Published on: 30 Jun 2021

We have commented on the amendments to the IFRS Foundation Constitution the Trustees of the IFRS Foundation have proposed in order to enable the creation of a new sustainability standards board under the governance of the Foundation.

We commend and continue to support the IFRS Foundation Trustees for their ongoing efforts to adapt the IFRS Foundation’s institutional arrangements to support sustainability reporting standard-setting and we encourage the IFRS Foundation to amend the constitution now to anticipate the further components necessary to support sustainability reporting standard-setting, which would increase the IFRS Foundation’s flexibility to respond. We agree with many of the IFRS Foundation’s proposals, but we have some concerns about specific matters. These are in particular:

  • We recommend that the Constitution provides the structures necessary to ensure common ownership of fundamental elements that will be common to both Boards.
  • We disagree with the proposal of a simple majority threshold for the publication of an Exposure Draft or final ISSB Standard. We recommend having the same voting thresholds as those for the IASB.
  • We do not agree with the terminology proposed for the new board and its associated standards. We believe that it is fundamental that ‘reporting’ be included in both the Board’s name and its standards.

Please click to download our full comment letter below.


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