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Deloitte view on the IIRC's integrated reporting proposals

  • Deloitte Comment Letter Image

Jul 19, 2013

We have published our comment letter on the International Integrated Reporting Council (IIRC) Consultation Draft of its proposed 'International Integrated Reporting Framework'. We support the IIRC in its efforts to develop the framework, seeing its development as timely as annual reports are getting longer and "the story of an organisation’s value proposition can often be lost in all that information".

Our comment letter includes the following points:

  • We agree that Integrated Reporting responds to a demand from market participants for better information, but note that it is not clear what role an integrated report plays in relation to existing financial, sustainability, and corporate governance reports, and that it would not replace these reports
  • We agree that an integrated report should aim to become a primary communication document, telling the value creation story, rather than being compliance-focused. We think that flexibility in Integrated Reporting is critical to foster innovation
  • We agree that the primary audience for integrated reports should be providers of financial capital in order to support their financial capital allocation assessments, but note it would be useful for the Framework to acknowledge explicitly that providers of financial capital are rarely a homogeneous group, allowing companies flexibility to meet the information needs of various types of providers of financial capital
  • We believe a better and clearer articulation is required in the Framework on how materiality for an integrated report is distinct from materiality for other reports such as financial reports, and how to handle the tension between application of materiality and achieving conciseness
  • We are of the view that the Framework should contain only the objectives, concepts and principles and minimum content elements for an integrated report in order to allow for experimentation and believe it would be premature to portray it as a reporting standard at this stage
  • We agree that the ability to obtain independent third party assurance on the information presented will be of utmost importance to the integrity and credibility of an integrated report, and believe that an international standard or applicable assurance guidance specific to Integrated Reporting will be required.

Click for the full comment letter.

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