Analysis of Comment Letters on the Discussion Paper

The staff summarised the comments received. For a comprehensive comment letter analysis please refer to the Observer notes available from the IASB website.

In general a majority of the respondents agreed to the proposals in the Discussion Paper. However, with regard to the question whether entities should be required to include Management Commentary (MC) in their financial reports to assert compliance with IFRSs 61% of the respondents addressing this issue thought that MC should not be mandatory. Some respondents raised the concern that MC lacks the same degree of objectivity as financial statement information. Others noted that important consequences for the audit will arise since the audit of MC poses significant challenges compared to an audit of financial statements.

With regard to the audit implications one Board member pointed out that in Germany MC is part of the audit and that it has been proofed to be auditable.

Other issues like objectivity, essential contents and the form of guidance were briefly discussed but no majority views became apparent.

By a majority of 12 votes the Board decided to go forward with this project and directed the staff to prepare an Agenda Proposal.