EFRAG's draft comment letter (DCL) on ISSB ED on SASB internationalisation and Taxonomy updates

​​EFRAG is consulting and asks for comments by 10 July 2023 on its draft comment letter in response to the ISSB ED on Internationalisation of SASB Standards and SASB Standards Taxonomy updates.Stakeholders can provide inputs to EFRAG's preliminary answers by way of an online survey that can be accessed here. Alternatively, EFRAG accepts comment letters submitted by using the Express your views page on EFRAG's website.Comments should be submitted by 10 July 2023.

​The ISSB is asking for views on its proposed methodology to enhance the international applicability of the SASB Standards without substantially changing the structure or original intent of the content. The ISSB is also seeking views on future amendments to the SASB Standards Taxonomy aligning it with the proposed methodology for enhancing the international applicability of SASB Standards.

In its draft comment letter EFRAG generally agrees that the proposed methodology would improve the international applicability of the SASB standards but points to the following improvements that could be made: i) keeping an acceptable comparability level when working with national references and ii) the ratification status of international references.

EFRAG considers the proposed methodology a reasonable transition approach, pending a more extensive standard setting activity to enhance the SASB Standards, as done for S2 Climate. In particular, EFRAG considers that there is room for further improvements of the SASB standards beyond the internationalisation of these standards. For example by requiring contextual narrative disclosures.

EFRAG requests the ISSB to develop a gap analysis between the SASB standards and sustainability reporting frameworks developed more recently or which are being developed. The results of this gap analysis should then serve as a basis for updates to the SASB standards.

EFRAG agrees to update the SASB XBRL Taxonomy to reflect the amended SASB standards accordingly, as suggested. EFRAG invites the ISSB to work with EFRAG on an harmonisation of the sector specific digital XBRL taxonomies of the ESRS and ISSB standards.

The comment letter can be found here. Comments are requested no later than 10 July 2023.