ED/2011/6 is a re-exposure of the IASB and FASB's proposals in ED/2010/6 Revenue from Contracts with Customers (2010 ED).

In general, EFRAG welcomes the changes made to the 2010 ED, and notes that many of its concerns expressed in relation to the 2010 ED have now been solved. However, EFRAG disagrees with the proposals to:

• limit the onerous test to performance obligations satisfied over a period of time greater than one year
• perform the onerous test at a performance obligation level
• offset advances received against contract assets in all circumstances
• only being able to allocate contingent amount to one or all performance obligations within a contract
• require a list of specific disclosure requirements in IAS 34 Interim Financial Reporting
• include only sales-based variable consideration in the special requirements for when to recognise revenue related to licence agreements of intellectual property

The draft comment letter also raises a number of other concerns.

Comments on the letter are invited by 9 March 2012. The draft comment letter can be downloaded via the press release on EFRAG's website.