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EFRAG published its draft comment letter in response to the IASB Agenda Consultation 2011. Comments are invited by 15 November 2011.

EFRAG recommends the IASB to:

Introduce a ‘period of calm’. A ‘period of calm’ will allow for time to ensure that IFRS is applied consistently in all relevant jurisdictions and entities.
Focus during the ‘period of calm’ on:
- Conceptual Framework issues (including performance reporting);
- post-implementation reviews, surveys of existing financial reporting practice and other research activities that help prepare evidence-based agenda proposals; and
- projects where an urgent need and/or a solution that is likely to improve financial reporting have been demonstrated.
Consult on agenda proposals where there is evidence supporting that improvement is needed and the benefits of the improvement justify the implementation efforts.
Limit the number of projects to be included on the IASB agenda.
Make proper use of research, but do not allocate more resources to areas such as Integrated Reporting than what is necessary to monitor the development.

During EFRAG’s consultation period, EFRAG will perform additional outreach activities, details of which will be announced in due course.