For his detailed analysis, Mr Sampers drew on the summary report of the EU and on further analysis of individual responses to the consultation that were made public by the EU. The focus of his research was on the IFRS-related questions in the consultation.
Mr Sampers noted that stakeholders from 23 Member States and 25 third countries submitted 338 responses with 82% of the responses being from organisations and companies, 9% from public authorities and international organisations and 9% from private individuals. In this context, Mr Sampers especially noted the high number of responses from private individual that would show that stakeholders were really concerned about developments. He also noted the high number of responses from Germany.
In discussing the responses to individual questions, Mr Sampers noted the confusing design of certain elements of the consultation document that led to some false positives and contradictory answers and that only allowed additional comments in case of support for what seemed to be the EC Commission's preliminary view. He summarised the following insights:
- Regarding the question of whether the EU should be able modify the content of IFRSs on adoptions, the majority of respondents was clearly against "carve-ins", however, clear regional differences became obvious with 75% of respondents in France supporting the possibility of carve-ins against only 15% in Germany, the UK and the Netherlands doing so.
- A clear majority of respondents (68%) is convinced that the EU endorsement process is appropriate to ensure that IFRS do not pose an obstacle to broader EU policy objectives such as sustainability and long-term investments. This correlates with the answers to the question of how the EU could ensure that IFRS do not pose an obstacle to sustainability and long-term investments, where only 11% of respondents believed the possibility of modifications to IFRS was needed to ensure this.
- On the question of whether an EU conceptual framework should underpin the IFRS endorsement process, the answer was clearly negative, however, a surprising number (not a majority, though) supported adopting the IASB's Conceptual Framework for use in the EU. (Discussing this point, participants made clear that adopting a pronouncement that is not binding for the IASB would lead to a legally difficult situation, especially since some of the IASB's standards are not aligned with the Conceptual Framework. Therefore, outright adoption would not seem to be an option.)
Overall, Mr Samper's presentation showed that it can be concluded that there is little support for changes to the current endorsement process and for the introduction of an ability for Europe to modify the content of IFRS. This is in line with the overall summary in the EC Commission's summary of responses which stated that the EU framework overall brings added value, is effective and relevant for achieving its objectives and is coherent.
Mr Sampers kindly gave us permission to make his presentation slides available on IAS Plus. They can be accessed here.