Comment Letter on Proposed Targeted Amendments to the IFRS Foundation Constitution

Response identity

EMJ LIFE HOLDINGS PTE. LTD. issued this public comment letter on 24 August 2026 in response to the IFRS Foundation Exposure Draft Proposed Targeted Amendments to the IFRS Foundation Constitution. The response is presented from the perspective of a Singapore-based institutional technology company working on structured evidence, standards interoperability and machine-readable governance infrastructure.

Response in brief

The letter supports the objective of aligning the Constitution with a smaller and more flexible board structure while maintaining credible global standard-setting. It agrees with the proposed board-size range and geographical minimums, subject to public explanation whenever a board operates below the normal lower bound. It supports retaining the principal full-time and part-time provisions together with annual board-specific reporting on collective skills, jurisdictional experience and effective capacity. It also agrees with the proposed voting formula and other targeted amendments, with transparent consequential updates to the Due Process Handbook and continued protection of public technical deliberation.

Question 1: board size and geographical distribution

The response agrees with the proposed eight-to-twelve-member range and geographical minimums, while distinguishing the normal operating range from exceptional continuity arrangements. It recommends public explanations for operation below eight members and annual disclosure of board-specific composition, skills and effective capacity.

Question 2: full-time and part-time membership

The response supports retaining the existing principle without adding fixed quotas. It recommends transparent disclosure of temporary imbalances, their anticipated duration and corrective steps, while assessing each board separately according to mandate and workload.

Question 3: voting requirements

The response agrees in principle with the proposed voting formula and continuity floor. It recommends public visibility of affirmative votes, abstentions and applicable thresholds, together with a redline or consequential-amendment matrix for the Due Process Handbook.

Question 4: other amendments

The response supports the express Basis for Conclusions requirement, flexible IASB work-plan periods, clarified Managing Executive Director provisions and removal of temporary ISSB-establishment provisions. It recommends disclosure when board service exceeds eight years, continued predictability of agenda consultation and preservation of the IASB and ISSB technical independence.

Evidence boundary

The record owner identifies this as a submitted public consultation response. The supplied five-page PDF does not include a separate portal transmission receipt. Publication here preserves the complete letter and does not imply acceptance, adoption or endorsement by the IFRS Foundation, its Trustees, the IASB or the ISSB.