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Deloitte comment letter on the SME Implementation Group draft Q&As (third batch)

Published on: 16 Nov 2011

Deloitte's IFRS Global Office has submitted a letter of comment to the SME Implementation Group on its Third batch of SME Implementation Group questions and answer documents.

In the comment letter, we re-iterate our concern over whether the level of SME Implementation Group's due process applied to the Q&As is appropriate and consistent with other similar activities at the IFRS Foundation and IASB. As regards the Q&As included in this batch of documents we question their appropriateness for the following reasons:

  • We are not convinced that the issues are areas in which we consider that the IFRS for SMEs lacks clarity such that inconsistent implementation is likely to occur in the absence of a Q&A.
  • We do not consider publication of a high volume of draft Q&As (nine since February 2011) to be in keeping with the Board's plan for periodic updating of the IFRS for SMEs. We believe that unless issues are clearly urgent, widespread and likely to result in significant divergence in practice they should be addressed through the next omnibus exposure draft of the IFRS for SMEs rather than by producing a continuous stream of new guidance.

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