EFRAG Publishes its Comment Letter on the ISSB SASB Enhancement Consultation
EFRAG supports the enhancement of the SASB Standards and calls for greater consistency, reduced complexity, and enhanced interoperability across sustainability reporting standards.
EFRAG publishes its comment letter on the ISSB's Exposure Draft of Proposed Amendments to the SASB Standards and the IFRS S2 Industry-based Guidance relating to the Agricultural Products, Meat, Poultry & Dairy, and Electric Utilities & Power Generators industries.
In its comment letter, EFRAG welcomes the ISSB's continued efforts to enhance and maintain the SASB Standards. Building on feedback received through EFRAG's public consultation, EFRAG’s comment letter reflects the perspectives of European stakeholders and provides practical recommendations to improve consistency, reduce complexity, and strengthen interoperability with the European Sustainability Reporting Standards (ESRS) and other internationally recognised frameworks.
EFRAG’s key messages:
Reducing complexity and ambiguity in applying SASB standards. EFRAG encourages clear articulation of intended long-term reporting architecture and clear path forward for revision, which considers due process, feasibility of reporting, as well as alignment with sector-agnostic provisions of ISSB Sustainability Disclosure Standards.
Embedding interoperability by design. EFRAG recommends that interoperability considerations be integrated throughout the standard-setting process by systematically assessing alignment with ESRS and other recognised reporting frameworks before finalising amendments.
Avoiding de facto topical standards. The proposed amendments introduce a high proportion of sector-agnostic disclosures. EFRAG notes that this could unintentionally anticipate future topical standards and therefore encourages a clearer distinction between sector-agnostic and industry-specific disclosures.
Building on previous recommendations. EFRAG reiterates that the recommendations made in its 2025 comment letter remain relevant and encourages the ISSB to ensure that SASB and ISSB Sustainability Disclosure Standards are fully complementary while avoiding unnecessary overlaps.
What’s next?
The feedback received by the ISSB will inform the finalisation of the proposed enhancements for the three SASB industry standards. EFRAG will continue engaging with the ISSB to promote greater interoperability between the SASB Standards and the ESRS, supporting globally consistent sustainability reporting while addressing the needs of European preparers and users.