EFRAG welcomes the publication of DP/2014/2 Reporting the Financial Effects of Rate Regulation and supports the IASB's decision to initially examine a generic type of rate regulation called 'defined rate regulation'. However, EFRAG stresses that the DP can only represent a starting point in the discussion:

As the project progresses, we believe the IASB will need to consider in which circumstances an entity's right to recover an agreed amount of revenue and obligations to perform certain activities creates enforceable rights and obligations that should be recognised in financial statements.

EFRAG also believes that the IASB may need to consider whether it should widen the scope of a potential future standard to require disclosures of the effects of rate regulation other than those where assets and liabilities are recognised.

EFRAG generally supports the accounting approach of developing specific IFRS accounting requirements to defer or accelerate the recognition of a combination of costs and revenue but "remains open" to a 'cost deferral approach' should further work of the IASB show that it might produce relevant information.

Comments on the draft comment letter are due by 31 December 2014. It is available on the EFRAG website.