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Deloitte comment letter on the FRC consultation on changes to FRS 102 to reflect recent changes in IFRS

Published on: 22 Dec 2016

We have published our comment letter on the Financial Reporting Council’s (FRC’s) consultation on changes to FRS 102 to reflect recent changes in IFRS.

The Consultation, which was published in September 2016, contains proposals to update Financial Reporting Standard (FRS) 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland to reflect recent changes in International Financial Reporting Standards (IFRSs).

We agree with the overall concept of keeping UK GAAP broadly aligned with IFRS but also would highlight the need to balance stability with improvement, as is set out in the proposed amendments to the principles for developing succinct financial reporting standards for the UK and Ireland. We believe it is important to be able to demonstrate how any proposed amendments to UK and Ireland financial reporting standards are in line with this principle. Bearing this in mind we believe the Phase I Financial Reporting Exposure Draft (“FRED”) should focus on incremental improvements arising from the experience of stakeholders in applying FRS 102.

We agree that it is useful to consider and discuss the proposed more fundamental changes currently proposed to be effective from 1 January 2022. However we feel that publishing detailed proposals in 2017 would be premature when there is currently no practical experience of how UK listed companies have implemented the requirements of IFRS 9 Financial Instruments and IFRS 16 Leases.

The full comment letter can be downloaded below.


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