Disclosure Initiative: Targeted Standards-level Review of Disclosures – Guidance for the Board (Agenda Paper 11A)

Background

At its meetings in May, June and July 2018, the IASB developed a draft framework to use when it develops and drafts disclosure objectives and requirements. This framework is designed to:

• (a) help the IASB develop effective disclosure objectives that encourage preparers to exercise judgement when deciding what to disclose;
• (b) improve the process by which the IASB develops the content of disclosure objectives and requirements, by:
  • i. Introducing consideration of disclosure proposals earlier in the standard-setting process
  • ii. Placing significant focus on the needs of users of financial statements and other stakeholders
  • iii. Effectively leveraging internal resources, such as the knowledge and expertise of the IFRS Taxonomy team
  • iv. Encouraging the IASB to communicate more effectively with stakeholders.

Staff analysis

The papers summarise the draft framework in three steps. Additional details are in our summaries of the relevant papers:

• a. Step 1: Setting disclosure objectives (see May 2018 Agenda Paper 11B)
• b. Step 2: Developing the content of disclosure requirements (see June 2018 Agenda Paper 11C)
• c. Step 3: Drafting of the disclosure objectives and requirements (see July 2018 Agenda Paper 11C).

The draft guidance reflects the decisions made by the IASB in the meetings noted above. The staff will test the guidance by drafting new disclosure requirements for IFRS 13 Fair Value Measurements and IAS 19 Employee Benefits.

Staff recommendation

That the Board approve the draft guidance.

Board discussion

All Board members expressed that they were happy with the guidance as drafted by the staff with the caveat that this was for testing purposes and was not the Board committing to use the wording proposed.

Some Board members expressed concern over what was meant by ‘testing’ and whether this would include analysis on disclosures once published. The staff clarified that testing would involve outreach with investors and other stakeholders and the drafting of an Exposure Draft in relation to the two Standards being tested. At this stage it is too early to conclude on whether the testing would go beyond this stage.

It was further confirmed that the guidance would only be used for the two proposed Standards at this stage and not directly in the development of other new Standards.

One Board member expressed concern that there was no mention of considering commercial sensitivity when preparing disclosures and thought that the staff should consider including this as a potential consideration for preparers.  Additionally, they requested more detailed guidance on what the Board should consider in the cost vs. benefit analysis when drafting disclosure requirements in the future.

A few Board members expressed concern around the order of the objectives and suggested that the overall objective should be considered first, followed by specific objectives and circling back to the main overall objective as a catch-all.

One Board member asked staff to distinguish clearly in the guidelines which work related to the Board and which work was for the project team and to make the wording in the guidelines more flexible on the level of understanding the Board must have.

Board decisions

The Board voted unanimously in favour of the proposed guidance.