Disclosure Initiative: Targeted Standards-level Review of Disclosures

Date recorded:

Comment period (Agenda Paper 11)

The purpose of this paper was to ask the Board if it would like to extend the comment period for the Exposure Draft Disclosure Requirements in IFRS Standards — A Pilot Approach (ED) in light of feedback received from stakeholders.


The Board published the ED on 25 March 2021 with a 210-day comment period ending on 21 October 2021. Since March 2021, Board members and staff have conducted education and outreach activities relating to the ED. The feedback provided directly to the Board during the June 2021 meeting of the Accounting Standards Advisory Forum (ASAF) indicates that the comment deadline of 21 October 2021 might be insufficient to obtain input from a wide range of stakeholders and, in particular, to gather adequate evidence from fieldwork with preparers in their jurisdictions and discuss that evidence with other stakeholders.

Staff analysis

The staff’s analysis highlights that the potential benefits of the proposals can only be realised if the Board receives high quality, constructive feedback on the proposals.  It also notes that giving stakeholders sufficient time to fully consider the significant new thinking in the proposals is necessary in order to receive such feedback, particularly as the proposals, if finalised, would represent a fundamental change to the way that the Board develops disclosure requirements.

The staff’s analysis also considers the length of the extension, taking into account both the feedback received during the ASAF meeting and other consultations ending around that time.

Staff recommendation

The staff recommended that the Board extend the comment period for the ED to around 290 days, such that it finishes on 12 January 2022.

Board discussion

The Vice-Chair noted that although she has had concerns around the length of the comment period, she would support the recommendation to extend it in this case, in order to ensure there is sufficient time to receive stakeholders’ feedback on this important consultation. However, she highlighted that the messaging to stakeholders should make it clear that extending the comment period is the exception rather than the norm, as comment periods should normally be aligned with the Due Process Handbook.

Other Board members agreed with the Vice-Chair’s comments and shared her concerns around ensuring that extending the comment period is not the norm going forward but noted that there would be various reasons to support the extension in this instance.

A Board member noted that there has been a significant volume of consultation documents published by the Board in the last year. The proposals in the ED around the new disclosure requirements focus on behavioural change, which stakeholders might need additional time to fully comprehend and there have been differing views on the proposals. In light of these factors, the Board member would, hence, support the staff’s recommendation.

Another Board member highlighted that this project is in substance split into two parts, namely the principles being proposed and the field testing, with stakeholders likely needing more time in order to successfully go through the latter part and provide high quality feedback and responses to the proposals. Hence, the Board member understands why an extension would be warranted due to the nature of this project, even though the Board member would have been very reluctant to support an extension on different projects.

Another Board member pointed out that the issue the proposals are seeking to address is broader than improving the required disclosures under IAS 19 and IFRS 13 and it will affect many other Standards and future standard-setting as well, therefore that Board member would agree with the staff recommendation.

The Chairman highlighted that when the Board is setting comment periods in the future, consideration should be given to which aspects of a project determine the comment period (e.g. answering a conceptual question versus fieldwork, effect analysis etc., which might take a longer time) and whether the different aspects could be separated in order for work on a project to be carried out efficiently, whilst still gathering high quality feedback.

Board decision

All Board members supported the staff recommendation, with the Board members voting to extend the comment period on the ED to 290 days.

The Vice Chair suggested that the staff add an observation around the considerations regarding the Board’s reluctance to extend comment periods unless there are unusual circumstances.

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