The proposals set out a new standard on interim reporting for entities that apply FRS 102 in their annual financial statements. The proposed standard is based on IAS 34, the international standard on interim reporting and will replace the existing ASB Statement 'Half-yearly financial reports'

Our key comments are as follows:  

• we agree that the ASB Statement on Preliminary Announcements is now of little practical use and can be withdrawn without replacement;
• we agree with the proposal to replace the ASB Statement: Half-yearly Financial Reports with a pronouncement based on IAS 34 but with necessary amendments to enable it to work within the context of UK accounting standards.  However, we believe that the proposed draft FRS 104 deviates more than necessary from the text of IAS 34 and that greater consistency would be preferable; and
• we question whether it is appropriate to badge the document as a Financial Reporting Standard given the complications that will arise because it will not be an ‘accounting standard’ for legal purposes. 

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