EFRAG calls for adequate EU representation, stable board sizes in IFRS Foundation Constitution review
EFRAG has published its Draft Comment Letter (DCL) on the IFRS Foundation's Exposure Draft Proposed Targeted Amendments to the IFRS Foundation Constitution, issued on 18 August 2026. Stakeholders are invited to submit comments on EFRAG’s DCL by 7 November 2026.
In the Draft Comment Letter, EFRAG recommends a fixed membership of at least 12 members for both the International Accounting Standards Board (IASB) and the International Sustainability Standards Board (ISSB). EFRAG considers the possibility of varying Board sizes of 8 to 12 members according to priorities and workload to be too broad, and suggests the Trustees should further clarify and define the criteria to be applied for any adjustment to the sizes of the Boards.
EFRAG also recommends maintaining the current allocation of three seats for Europe on each Board, with a distinction between seats allocated to the EU and the rest of Europe. It considers that at least two seats should be allocated to the EU, taking into account the EU's position as the world's third-largest economic bloc, the significance of its capital markets, and its 26% contribution to IFRS Foundation funding.
On other elements of the proposed amendments, EFRAG agrees with retaining Board member qualifications. It also agrees with the proposed voting arrangements for Boards with fewer than 12 members, as well as the possibility of a shortened workplan. EFRAG is, however, concerned about amendment that would allow some Board members to serve terms of less than five years.
EFRAG's detailed responses to the questions raised in the Exposure Draft are set out in the Annex accompanying the Draft Comment Letter.