UK Endorsement Board secretariat publishes final comment letter on IASB’s Post-implementation Review of IFRS 10, IFRS 11 and IFRS 12

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28 May, 2021

The UK Endorsement Board (UKEB) secretariat has published its final comment letter on the International Accounting Standard Board’s (IASB's) Request for Information on its post-implementation review of IFRS 10 'Consolidated Financial Statements', IFRS 11 'Joint Arrangements' and 'IFRS 12 Disclosure of Interests in Other Entities' (the Standards).

The UKEB secretariat's final response has been informed from stakeholder roundtables and interviews, desk-based reviews of annual reports and public consultation on its draft response.  It concludes that the Standards have achieved their objectives and the objectives of them set by the IASB when issued and are working effectively overall.  The UKEB secretariat makes some recommendations in a few areas where it believes that the 'application of the Standards can be significantly improved'.  These are:


  • Review the requirement to disclose why an investment entity is classified as such when it meets the investment entity criteria but does not exhibit the typical characteristics.
  • Review the application guidance for identifying investment entities to ensure it results in appropriate outcomes for all types of investment fund.
  • Require investment entities to consolidate those intermediate subsidiaries which are investment entities to improve visibility at group level of assets and liabilities held by those subsidiaries.
  • Additional guidance to improve consistency and comparability in accounting for acquiring a controlling interest in a single-asset entity


  • Include principle-based guidance from IFRIC’s March 2015 Update on the assessment of other facts and circumstances.
  • Include additional guidance in the Standard to address any diversity of practice relating to the interaction of IFRS 11 with IFRS 15 and IFRS 16.


  • Review the extent to which disclosures for unconsolidated structured entities have proved useful as an indicator of potential risk.
  • Consider including guidance on the level of aggregation and disaggregation of disclosures on interests in other entities as part of its Primary Financial Statements project.
  • Consider including enhanced disclosures for subsidiaries with material non-controlling interests.

The final comment letter and further information is available on UKEB website.

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