The Draft Comment Letter supports the principles contained in the ED but highlights the following points:

• consultation with stakeholders has identified concerns about the practical application of the ED's proposals including issues on comparability, the impact on digital financial reporting, the application of judgement and issues of audit and enforceability.
• the UKEB has reservations about supporting the amendments to IFRS 13 and IAS 19 without first understanding whether the guidance described in the ED will be adopted and applied to other existing or future IASB standards.  The UKEB highlights "if the methodology is not used elsewhere, it will lead to inconsistent principles for disclosures being applied within IFRS, with the risk of confusing preparers and users and possibly resulting in inconsistent application".
• the UKEB recommends that the IASB first considers all feedback relating to the proposed approach to disclosure to determine how and when this will be used for existing and future standards. Once that decision has been reached, it recommends that the IASB re-expose the amendments to IFRS 13 or IAS 19.  The UKEB comments that this will help resolve its concern that it is difficult to support changes to these standards without understanding whether the proposed guidance will be applied to other standards.

Comments are requested by 01 November 2021. The draft comment letter and separate invitation to comment are available on the UKEB website.

UKEB also published a survey to gather stakeholder feedback on the changes to disclosure proposed in IASB’s ED/2021/3 Disclosure Requirements in IFRS Standards – A Pilot Approach. The survey is open until 12 November 2021.The Survey can be accessed here.