We have responded to the IASB exposure draft ED/2019/4 Amendments to IFRS 17, which was published by the IASB in June 2019 to address concerns and implementation challenges that were identified after IFRS 17 Insurance Contracts was published in 2017.

We welcome the responsiveness of the IASB in addressing with this ED the issues that have been identified since the publication of IFRS 17 through the Transition Resource Group’s discussion and the IASB outreach activities.

We are generally supportive of the proposals in the ED, however, we provide recommendations in a number of areas where we believe these proposals could be improved.

• The proposal to define investment–return services in insurance contracts without direct participation features using the approach in the ED appears rule-based. We propose a principle-based approach that uses existing concepts in IFRS 17.
• We believe that the scope of the proposed amendment to reinsurance contracts held should be extended to all types of reinsurance contracts held.
• We also appreciate the Board’s efforts to address stakeholder concerns around the applicability of the risk mitigation option. While we do not disagree with the proposed amendment to extend the application of the risk mitigation option to reinsurance contracts held, we think a better solution could be achieved by extending the scope of the variable fee approach to reinsurance contracts held.
• We note the continuing attention of stakeholders with regard to the complexity of applying the existing requirements in the context of contracts that present those characteristics referred to as “mutualisation”.

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