Comment letter period (Agenda Paper 15)

In October 2020, the Board gave the staff permission to ballot the Exposure Draft (ED) to revise Practice Statement 1 Management Commentary. The Board normally allows 120 days for an ED. However, given the current pandemic environment, in addition to forthcoming consultations from the IFRS Foundation (IFRSF) Trustees on the IFRSF Constitution, the staff considered a longer period. On the other hand, having a longer comment period could delay the urgently needed revision of the Practice Statement.

The staff therefore asked the Board whether they prefer a 120-day comment period or a longer comment period, and if yes, how long.

Board discussion

The Chairman noted that some ASAF members had commented that the project is not a priority in their jurisdictions as they already had very detailed guidance. However, in the Chairman’s view, the principles-based character of the document and the high-level recommendations would fit into many existing frameworks. It will therefore be very valuable even for regions that already have detailed guidance.

One Board member said that rather than specifying the number of days for the comment period, she would set it in a way that avoids overlap with other projects. In her view, the ideal end of the comment period would be between end of September and end of October. This was echoed by other Board members.

All Board members voted in favour of this proposal, i.e. to select the comment period in a way that would avoid clashes with other consultations. The Board will vote in a future meeting on the exact length of the comment period when the publication date is known.