Deloitte's IFRS Global Office has submitted a letter of comment to the SME Implementation Group regarding Draft Q&A Section 11, Issue 1: Fallback to IFRS 9 Financial Instruments and Draft Q&A Section 30, Issue 1: Recycling of cumulative exchange differences on disposal of a subsidiary.
In the comment letter, we are concerned about the appropriateness of these draft Q&As for the following reasons:
- both draft Q&As seek to restrict entities from adopting certain accounting policies which may be permitted, or indeed required, following the Board’s comprehensive review of the IFRS for SMEs. We do not believe that requiring a change in accounting policy which may be reversed within the next 2-3 years is useful to either preparers or users of the financial statements of SMEs; and
- we do not consider publication of a high volume of draft Q&As (11 since February 2011) to be in keeping with the Board’s plan for periodic updating of the IFRS for SMEs. As such, we welcome the commitment made in the November 2011 IFRS for SMEs Update to issue few, if any, further Q&As before the next comprehensive review of the IFRS for SMEs.
In addition, we are concerned about the due process applied to the Q&As and whether it is consistent with other IASB or IFRS Foundation activities.
All of our past comment letters are here.