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Deloitte comment letter on ED/2009/6 'Management Commentary'

Published on: 01 Mar 2010

We believe that management commentary is an important element of financial reporting and provides decision-useful information to the users. The recent financial crisis has highlighted that users benefit from explanatory information in addition to the financial statements which helps evaluate an entity’s financial position, financial performance and cash flows. We are supportive of the Board establishing high-level principles to facilitate comparability amongst entities reporting under IFRSs and to enhance the usefulness of their financial reporting.

We agree with the IASB that the status of any final document should be that of non-mandatory guidance. However, for the avoidance of any doubt, we suggest that the IASB should clarify that an entity’s ability to claim compliance with IFRS in its financial statements does not depend on following this non-mandatory guidance on management commentary (BC 46 of the ED could imply otherwise).

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