We have commented on the IASB's exposure draft ‘Subsidiaries without Public Accountability: Disclosures’ published in July 2021.

We agree with the objective of the draft Standard which responds to requests from stakeholders and expect that the draft Standard will significantly reduce the cost of preparing financial statements applying IFRS Standards for subsidiaries of parents that report using these standards.  We agree that the Standard should only be available to subsidiaries that do not have public accountability. However, in addition to the requirement to meet the definition of an entity without public accountability proposed in the draft Standard, we suggest that an entity would be permitted to apply the draft Standard only if all of its owners, including those not otherwise entitled to vote, and outsiders for which the entity holds assets in a fiduciary capacity have been informed about, and do not object to, the entity applying the draft Standard. We also agree with the proposal to limit the scope to subsidiaries of a parent that produces consolidated financial statements available for public use that comply with IFRS Standards and with the approach taken to developing the proposed disclosure requirements using the IFRS for SMEs Standard as a starting point and generally agree with the proposed disclosures that result from the application of this approach.

Please click to download our full comment letter below.

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