Deloitte comment letter on the IASB’s request for information on the post-implementation review of IFRS 9
We have commented on the IASB’s Request for Information – Post-implementation Review IFRS 9 Financial Instruments Impairment.
We believe that the impairment requirements of IFRS 9 have generally worked well and overall have met the IASB’s objective of more timely recognition of credit losses, resulting in users of financial statements being provided with useful information.
Our observations on the PIR are limited to topics related to the application of the impairment requirements where we believe improvements could be made to achieve greater comparability and to strengthen the Standard, for example by incorporating guidance from the IFRS Transition Resource Group for Impairment of Financial Instruments. These topics include the impact from guarantee contracts on the measurement of expected credit loss (“ECL”), certain aspects related to the presentation of ECL, and the interaction between ECL and modification accounting.
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