Our key comments include:  

• We would like to see guidance around whether entities must adopt the Further and Higher Education SORP if they are able to early adopt Financial Reporting Standard 102 (FRS 102) or whether they can continue to apply the requirements of the existing SORP.
• We suggest that the Operating and Financial Review (OFR) should be renamed as the “Strategic Report” to bring it in line with the new strategic report required for large and medium-sized charitable companies and that the contents and headings of the proposed OFR are aligned with the strategic report where possible.
• We disagree that in all cases, sabbatical leave should be accounted for as a long-term employee benefit where the liability would be recognised over the relevant period of service.  We highlight that in some situations, sabbatical leave may be accounted for as a short-term employee benefit.  We would like clarification over this point.
• Although we agree with the proposal to not permit the accrual model for government grants we note that this approach “will result in significant changes, potentially changing previously recognised surpluses into deficits, and reducing the comparability with prior year financial statements”.  We note “this could encourage the presentation of non-GAAP measures where the non-GAAP measures would revert back to the accruals model”.    
• We challenge whether disclosure of one total remuneration figure for the senior management team as a whole provides much useful information to users of the financial statements, given that remuneration bandings are already disclosed and that senior management teams within different higher education institutions can differ significantly in size.

A number of further improvements are highlighted in our comment letter such as aligning the terminology used within the SORP to that used within FRS 102 and recommending an explicit reference to the FRC guidance on going concern within the SORP. 

Further comments and a full response to all questions raised in the invitation to comment are contained within the full comment letter.