Most importantly, EFRAG believes that the effective date of IFRS 17 should be postponed to 1 January 2023, however, early application should be permitted so that companies can apply the standard before that date. The comment letter notes:

EFRAG welcomes the IASB’s decision to defer the effective date of IFRS 17. However, EFRAG disagrees with 1 January 2022 as the effective date. EFRAG considers that 1 January 2023 is a realistic effective date, with early application permitted.

Other than that, EFRAG is supportive of many of the changes proposed, even though the comment letter mentions several remaining concerns.  EFRAG also expresses its appreciation for the consideration of the topics identified in its letter sent to the IASB in September 2018. EFRAG believes that two issues warrant further consideration:

• EFRAG believes that the annual cohort requirement leads to unnecessary costs in some fact patterns. EFRAG recommends that the IASB consider developing an appropriate solution for them, reflective of the reporting objectives of the level of aggregation requirements and of their economic characteristics.
• EFRAG remains concerned about implementation challenges faced by preparers when applying the modified retrospective approach and encourages the IASB to confirm in the main text of the final standard that the use of estimates is allowed, including those needed to approximate the missing information.

Please click to access the press release and the final comment letter on the EFRAG website.