For his detailed analysis, Mr Sampers drew on the summary report of the EU and on further analysis of in­di­vid­ual responses to the con­sul­ta­tion that were made public by the EU. The focus of his research was on the IFRS-re­lated questions in the con­sul­ta­tion.

Mr Sampers noted that stake­hold­ers from 23 Member States and 25 third countries submitted 338 responses with 82% of the responses being from or­gan­i­za­tions and companies, 9% from public au­thor­i­ties and international or­gan­iza­tions and 9% from private in­di­vid­u­als. In this context, Mr. Sampers es­pe­cially noted the high number of responses from private in­di­vid­uals that would show that stake­hold­ers were really concerned about de­vel­op­ments. He also noted the high number of responses from Germany.

In dis­cussing the responses to in­di­vid­ual questions, Mr. Sampers noted the confusing design of certain elements of the con­sul­ta­tion document that led to some false positives and con­tra­dic­tory answers and that only allowed ad­di­tional comments in case of support for what seemed to be the EC Com­mis­sion's pre­lim­i­nary view. He sum­marized the following insights:

• Regarding the question of whether the EU should be able modify the content of IFRSs on adoptions, the majority of re­spon­dents was clearly against "carve-ins", however, clear regional dif­fer­ences became obvious with 75% of re­spon­dents in France sup­port­ing the pos­si­bil­ity of carve-ins against only 15% in Germany, the UK and the Nether­lands doing so.
• A clear majority of re­spon­dents (68%) is convinced that the EU en­dorse­ment process is ap­pro­pri­ate to ensure that IFRS do not pose an obstacle to broader EU policy ob­jec­tives such as sus­tain­abil­ity and long-term in­vest­ments. This cor­re­lates with the answers to the question of how the EU could ensure that IFRS do not pose an obstacle to sus­tain­abil­ity and long-term in­vest­ments, where only 11% of re­spon­dents believed the pos­si­bil­ity of mod­i­fi­ca­tions to IFRS was needed to ensure this.
• On the question of whether an EU conceptual framework should underpin the IFRS en­dorse­ment process, the answer was clearly negative, however, a sur­pris­ing number (not a majority, though) supported adopting the IASB's Conceptual Framework for use in the EU. (Dis­cussing this point, par­tic­i­pants made clear that adopting a pro­nounce­ment that is not binding for the IASB would lead to a legally difficult situation, es­pe­cially since some of the IASB's standards are not aligned with the Conceptual Framework. Therefore, outright adoption would not seem to be an option.)

Overall, Mr Samper's pre­sen­ta­tion showed that it can be concluded that there is little support for changes to the current en­dorse­ment process and for the in­tro­duc­tion of an ability for Europe to modify the content of IFRS. This is in line with the overall summary in the EC Com­mis­sion's summary of responses which stated that the EU framework overall brings added value, is effective and relevant for achieving its ob­jec­tives and is coherent.

Mr. Sampers kindly gave Deloitte per­mis­sion to make his pre­sen­ta­tion slides available on IAS Plus. They can be accessed here.