The European Financial Reporting Advisory Group has published a draft comment letter opposing broad flexibility to reduce the size of the International Accounting Standards Board and the International Sustainability Standards Board. It recommends fixed membership of at least 12 for each board and clearer criteria for any adjustment to board size. The group also calls for the current allocation of three European seats on each board to be retained, with at least two assigned to the European Union and a distinction maintained between the EU and the rest of Europe. It supports retaining existing board member qualifications, proposed voting arrangements for boards with fewer than 12 members and the option of a shortened workplan, but raises concerns about allowing some members to serve terms of less than five years.