Stakeholder engagement in the development of sustainability standards. Evidence from EFRAG and ISSB comment letters

Purpose: This study compares stakeholder engagement in the sustainability standard-setting processes conducted by the European Financial Reporting Advisory Group (EFRAG) and the International Sustainability Standards Board (ISSB). Drawing on stakeholder theory, lobbying theory, and institutional logics, the study examines how different governance models - multi-stakeholder versus investor-orientedshape the language, tone, and thematic focus of comment letters submitted during public consultations. Methodology: We analyse all comment letters submitted in the EFRAG consultation on the ESRS and in the ISSB consultations on IFRS S1 and IFRS S2, using Natural Language Processing (NLP) techniques – including sentiment analysis and topic modelling – to identify linguistic and thematic patterns in stakeholder feedback. Findings: The analysis reveals distinct engagement dynamics across the two consultations. EFRAG submissions display a more balanced sentiment and broader thematic orientation, while ISSB feedback emphasises financial materiality and comparability. These differences are consistent with the contrasting institutional orientations of the two standard setters. Originality: This is the first large-scale comparative study of stakeholder engagement in EFRAG and ISSB consultations, integrating NLP techniques with established theoretical perspectives to show how institutional context shapes stakeholder discourse. Practical implications: The findings suggest that differences in institutional orientation influence the type of stakeholder input received during standard-setting processes. These insights are relevant to ongoing debates on interoperability between EFRAG and the ISSB, as understanding how institutional contexts shape stakeholder discourse may inform future coordination efforts.