Public Comment Analysis
Open for general feedback
The Conceptual Framework document details the principles, objectives, assumptions, and definitions that guide SASB’s thinking and approach to Standard-setting/revising. The Conceptual Framework project will clarify and strengthen these core principles and concepts that govern SASB’s Standards.
SASB’s Conceptual Framework document was published in February of 2017 and does not reflect SASB’s updated mission statement, nor does not reflect SASB’s global reach, and the document contains outdated assumptions, definitions, and data.
- Phase 1 - Initial Research
- Phase 2 - Stakeholder Consultation
- Phase 3 - Post-Consultation Analysis
- Phase 4 - Exposure Draft Development
- Phase 5 - Public Comment Period
- Phase 6 - Public Comment Analysis
- Phase 7 - Completed
The Conceptual Framework public comment period ended on December 31, 2020, and SASB’s Standards Board is currently considering all public comments.
SASB’s Standards Board will consider all public comments submitted and conduct deliberations based on the comments received. At that time, the Standards Board may pursue further revisions of the Conceptual Framework or may approve the exposure draft as is. Upon the approval of the Conceptual Framework by the Standards Board, the approved version will supersede the 2017 version of the Conceptual Framework.
Published Documents & Supplemental Materials
Register for the webinar “Conceptual Framework & Rules of Procedure Public Comment Period Launch,” September 10, 2020, 7am-8am PST
Public Comments on the Proposed Changes to the SASB Conceptual Framework and Rules of Procedure
January 3-9, 2021
December 27, 2020-January 2, 2021
- Quit Nukes, 12-29-2020
- Itaú Unibanco, 12-30-2020
- Korede Ologun, 12-30-2020
- Society for Corporate Governance, 12-31-2020
- Anglo American, 12-31-2020
- Arabesque, 12-31-2020
- California Public Employees Retirement System, 12-31-2020
- Rights CoLab, 12-31-2020
- CFA Institute, 12-31-2020
December 20-26, 2020
- Deloitte Touche Tohmatsu Limited, 12-21-2020
- KPMG, 12-21-2020
- PricewaterhouseCoopers LLP, 12-21-2020
- Tobacco Free Portfolios, 12-21-2020
- American Bankers Association, 12-22-2020
- Bank of America, 12-23-2020
- Financial Executives International’s CCR, 12-23-2020
- Institute of Management Accountants, 12-23-2020
- Verizon, 12-24-2020
December 13-19, 2020
- EAGLE Certification Group, 12-16-2020
- International Corporate Governance Network, 12-17-2020
- Douglas Hileman, 12-19-2020
November 29-December 5, 2020
November 22-28, 2020
November 15-21, 2020
November 8-14, 2020
November 1-7, 2020
September 6-12, 2020
August 30-September 5, 2020
Board Materials & Decisions
Board Meeting Outcomes
- Staff presented a status update on a project intended to refresh the SASB Conceptual Framework, with a particular focus on two proposed revisions that may articulate the Standards Board’s core principles more clearly without substantively altering them.
- Staff noted pervasive and ongoing market confusion regarding the term “materiality,” which was clearly reflected in the public comments received on an exposure draft of the Conceptual Framework issued in late 2020. The Board discussed potential opportunities to improve the language used in the Conceptual Framework to clarify how the Standards Board has always viewed the concept of materiality while also aligning more closely with financial standard setters such as the International Accounting Standards Board (IASB).
- Additionally, staff noted consistent market feedback, including public comment letters, which has indicated that the “fundamental tenets” outlined in the Conceptual Framework may be more appropriate to include in the Standards Board’s Rules of Procedure. The Board expressed general agreement that the fundamental tenets – evidence based, market informed, industry specific, and transparent – are more accurately framed as characteristics of the standard-setting due process rather than as concepts that guide decision making. However, several Board members noted potential opportunities to strengthen how industry-specificity – and related concepts, such as business model and activities – are captured in other areas of the Conceptual Framework.
- Staff will incorporate the Board’s views into its next steps, including developing a working draft of the Conceptual Framework with proposed updates, and will continue to engage with the IFRS Foundation’s Technical Readiness Working Group to ensure appropriate alignment with international standard-setting efforts.
- Staff presented a summary of the public comments SASB received on the Conceptual Framework and Rules of Procedure exposure drafts, which were available on SASB’s website for public comment from August 28-December 31, 2020. The purpose of the session was to facilitate the Standards Board’s understanding of the public comments SASB received.
- Comments discussed by the Standards Board and staff included financial materiality, the characteristics for topic and metrics selection, the potential for additional detail and clarity, and considerations related to the IASB Conceptual Framework for Financial Reporting.
- Next steps include continuing the analysis of all comments, additional market consultations, and reconvening as a project team to establish an effective plan moving forward.
- The Board discussed four main topics relating to the Conceptual Framework and Rules of Procedure, which serve as key governing documents for SASB’s standard-setting work: 1) the complementary relationship between the Conceptual Framework and Rules of Procedure documents; 2) the potential removal of the six Guiding Principles within the Rules of Procedure
and subsequent replacement with a reference to the tenets and objectives detailed within the Conceptual Framework; 3) The potential addition of “transparency” as a tenet within the Conceptual Framework; 4) the revision of the criteria for topic and metric selection.
- The Board discussed and staff emphasized that revisions to the Conceptual Framework and Rules of Procedure will not substantively alter SASB’s core principles or the process through which standard-setting is carried out, but rather will focus on how those principles and processes are articulated.
- The next steps for the projects consist of staff continuing to draft revisions to the Conceptual Framework and Rules of Procedure based on views expressed by Board members. Staff plans to present proposed exposure drafts of both documents for the Board’s review in August 2020.
- Staff provided an update to the Board on the Rules of Procedure and Conceptual Framework Projects, which were approved by the Board in the September 2019 Board meeting.
- The staff update and Board discussion centered on the status of the respective projects, progress to date, next steps, and key milestones.
- No decisions that materially alter the project scope or objectives were made by the Board.
- The board discussed a new project on SASB’s Conceptual Framework.
For a full list of past and upcoming Standards Board meetings, as well as associated materials, please visit our Board Meetings Calendar & Archive.
The staff has prepared this summary for informational purposes only. Any Standards Board decisions are tentative and do not change current accounting. Official positions of SASB are determined only after extensive due process and deliberations.