Comment Letter Archive

Founded in 1946, the Society is a professional membership association of approximately 3,800 corporate and assistant secretaries, in-house counsel, outside counsel, and other governance professionals who serve approximately 1,600 entities, including 1,000 public, private, and nonprofit organizations of almost every size and industry. Our organization has more than 75 years of experience empowering professionals to shape and advance corporate governance within their organizations, in part through providing the knowledge and tools they need to advise their boards and executive management on corporate governance; regulatory and legal developments; and sustainability issues, including sustainability-related governance, risk management, and disclosure.  

We have a robust track record of constructive engagement with regulators and other standard setters on climate and other sustainability-related legal frameworks. For example:  

• We and our members have engaged, and plan to continue to engage, with the European Commission in relation to its 26 February 2025 Omnibus proposals, having submitted a member-informed position paper to EU officials in advance of the release of the proposals, which we plan to update in response to the specific proposals for further engagement with the Commission this summer. 
• We and our members have engaged with the IFRS Foundation (which has representation among our membership) in conjunction with the ISSB exposure drafts on climate-related and general sustainability-related disclosures, and continue to engage with the IFRS Foundation on its initial standards as well as the ISSB’s biodiversity, ecosystems, and ecosystem services (BEES) and human capital standards research projects.
• We engaged extensively with the US Securities and Exchange Commission in connection with its climate disclosure rulemaking, providing a detailed comment letter with seasoned insights and robust quantitative data that was cited more than 100 times in the SEC’s final rule.
• We are currently engaging with California policy makers on the state’s climate disclosure laws and regulations, which has encompassed, among other things, our creation of an approximately 60member working group to shape and support with qualitative and quantitative data the Society’s feedback to the California Air Resource Board’s Information Solicitation to inform the implementation of the state’s climate disclosure legislation.  

In this context, we are delighted to provide our perspective to EFRAG with respect to the revision and simplification of the existing European Sustainability Reporting Standards. Please note that the attached reflects our response to the online questionnaire submitted to EFRAG on 5 May, 2025, with the addition of a response to the General Assessment question, which exceeded the questionnaire’s character limit and thus could not be included in our submission.

Thank you for considering the Society’s input.  

Respectfully submitted,  
Randi Val Morrison 
General Counsel & Chief Knowledge Officer