EFRAG Calls for Greater Interoperability in ISSB’s Proposed SASB Amendments
EFRAG releases its Comment Letter to the Exposure Draft - Proposed Amendments to the (Sustainability Accounting Standards Board (SASB) Standards, and Exposure Draft - Proposed Amendments to the Industry-based Guidance on Implementing IFRS S2 published by the International Sustainability Standards Board (ISSB).
EFRAG welcomes the ISSB’s efforts to enhance the SASB Standards and acknowledges the significant progress made. The amendments represent an important step toward more consistent and decision-useful sustainability reporting at global level.
At the same time, EFRAG highlights several areas where further clarity and alignment would help ensure the amendments are practical and proportionate for preparers:
• Clarification of the practical meaning of ‘shall refer to and consider’: positioning SASB Standards as optional guidance to support materiality assessments
EFRAG recommends changing the wording from “shall” to “may” to avoid ambiguity and avoid reporting burden. The SASB Standards should function as a library of non-mandatory disclosures that help entities identify financially material information by highlighting likely material topics and metrics for each industry. This would support more relevant disclosures without creating new reporting obligations.
• Strengthening interoperability with other standards
EFRAG strongly supports closer alignment between SASB and the European Sustainability Reporting Standards (ESRS). While the proposed amendments move in this direction, certain provisions may still be difficult to reconcile with ESRS, EU law or other reporting frameworks. These inconsistencies could increase reporting complexity for companies operating in Europe.
• Ensuring proportional and implementable requirements
Some of the proposed metrics may be challenging to apply in practice due to data availability, sensitivity, or the level of granularity requested. EFRAG stresses that all datapoints should remain decision-useful, proportionate, and subject to materiality to avoid unnecessary burden for preparers.
• Clarifying the role of SASB in relation to IFRS S1 and S2
EFRAG encourages the ISSB to provide clearer guidance on how SASB topics and metrics relate to the “risks and opportunities” approach in IFRS S1 and S2, and to avoid unnecessary overlaps between the standards.
EFRAG also notes that further transparency on the ISSB’s roadmap, particularly regarding upcoming work on human capital and biodiversity, would help reduce uncertainty for companies planning their reporting processes.
Despite these challenges, EFRAG emphasises its strong commitment to continued collaboration with the ISSB to advance efficient interoperability: “We welcome the ISSB’s commitment to strengthening the SASB Standards,” said Chiara Del Prete, EFRAG SR TEG Chair. "Interoperability will be key to making these standards practical and effective for preparers. EFRAG looks forward to continued dialogue to advance global alignment.”
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