EFRAG draft comment letter on the IASB's proposed new reduced disclosure IFRS

  • EFRAG (European Financial Reporting Advisory Group) (dk green) Image

01 Oct, 2021

The European Financial Reporting Advisory Group (EFRAG) has issued a draft comment letter on the IASB exposure draft ED/2021/7 'Subsidiaries without Public Accountability: Disclosures'.

In the draft comment letter, EFRAG "cautiously" supports the proposals of the exposure draft, but raises some concerns and provides some suggestions. EFRAG:

  • suggests that the key principles proposed by the IASB should encompass cost-benefit considerations;
  • highlights the risks of not considering the existing disclosure requirements in full IFRSs when there are no recognition and measurement differences between the IFRS for SMEs and full IFRSs;
  • suggests that the reasoning for the exceptions is improved;
  • suggests considering the interaction between the disclosure requirements of this exposure draft and the disclosure requirements of the exposure draft Disclosure Requirements in IFRS Standards – A Pilot Approach;
  • considers that the application of a full set of disclosure requirements for IFRS 17 Insurance Contracts can be burdensome and costly for eligible subsidiaries; and
  • suggests a number of additional disclosures that it considers relevant for users of financial statements.

Comments on EFRAG's draft comment letter are requested by 26 January 2022. For more information, see the press release and the draft comment letter on the EFRAG website.

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