In May 2023, the IASB issued a RFI seeking comments from stakeholders to identify whether the impairment requirements in IFRS 9 Financial Instruments provide information that is useful to users of financial statements; whether there are requirements that are difficult to implement and may prevent the consistent implementation of the standard; and whether unexpected costs have arisen in connection with applying or enforcing the standard.

The UKEB welcomes the opportunity to provide comments on the IASB's RFI.

The final comment letter, which has been informed from in-house research, consultation with the UKEB advisory groups, and feedback received during stakeholder roundtables and interviews, considers that the IFRS 9 impairment requirements generally are working as intended and ensure more timely recognition of expected credit losses than under IAS 39 Financial Instruments: Recognition and Measurement.  Whilst the comment letter highlights a number of areas of significant concern identified by UK stakeholders that may be addressed by standard setting or similar activities, it does highlight that no 'fatal flaws' have been identified from its outreach activities.

The comment letter identifies where additional application guidance in the Standard would be helpful due to the complexity of some of the requirements and their application to a range of very different types of entities.  Some areas raised in the comment letter the UKEB suggests would be best addressed via IASB -led education initiatives in an effort to drive enhanced international comparability.   

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