UKEB final comment letter on the IASB's ED on 'Disclosure Requirements in IFRS Standards — A Pilot Approach (Proposed amendments to IFRS 13 and IAS 19)

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21 Dec 2021

The UK Endorsement Board (UKEB) has published its final comment letter on the International Accounting Standard Board's (IASB's) ED/2021/3 Disclosure Requirements in IFRS Standards – A Pilot Approach ("the ED").

In its final comment letter the UKEB supports the IASB's efforts to make financial statement disclosure more useful and effective.  The comment letter, which has been informed from the UKEB's own analysis and stakeholder feedback, recommends a hybrid approach which would retain the use of the objectives and user information proposed in the ED but would require some amendments to the other ED proposals in order to address practical difficulties identified by stakeholders.  The comment letter highlights a number of challenges with the proposals in the ED including: 

  • stakeholder concerns about the practical application of the ED's proposals, in particular the possible consequences of removing the mandatory disclosure regime altogether.  The UKEB suggests that this would create challenges for some preparers as well as for auditors and regulators.
  • concerns identified through feedback that not all stakeholders are currently in a position to successfully transition to the ED's purely objectives-based approach 'without adverse consequences'.  In this regard the UKEB suggests that the IASB consider the path to improved disclosure as a journey with multiple milestones.

On the proposed hybrid approach the UKEB believes that that approach would enable the establishment of the principle that disclosures should be based on user needs but also will achieve many of the IASB's proposals.  It also provides a number of comments in relation to the ED proposals relating to IFRS 13 Fair Value Measurement and IAS 19 Employee Benefits.

The final comment letter and the feedback statement are available on the UKEB website.

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