Work plan

Date recorded:

Timing of consultation documents (Agenda Paper 8)


Stakeholders are still coping with the challenges from the pandemic and are experiencing capacity constraints due to the volume of consultation documents published or shortly forthcoming and other engagements on projects outside a formal consultation.

The staff therefore asked the Board whether they agree to increase the comment period for:

  • The already published ED Regulatory Assets and Regulatory Liabilities from 150 days to 180 days
  • The forthcoming ED Targeted Standards-level Review of Disclosures from 180 days to 270 days
  • The forthcoming Request for Information on the Third Agenda Consultation from 120 days to 180 days

The staff did not see any need at this point to increase the comment period for other published or forthcoming consultation documents.

Board discussion

The staff informed the Board that three members of the Accounting Standards Advisory Forum (ASAF) noted in the March ASAF meeting that an extension of the comment period for the agenda consultation would be welcome given the current circumstances, while one ASAF member did not see an added benefit of a longer comment period.

Regarding Management Commentary, the staff are monitoring the publication of the upcoming Trustees consultation on a change to the constitution with regard to sustainability reporting. The ED for Management Commentary might have to be delayed to avoid publication at the same time as the Trustees consultation.

The Vice-Chair found the proposed extension of the Targeted Standards-level Review of Disclosures ED too long given that the previously agreed 180 days already exceed the standard comment period for an ED by 60 days. She would agree to a comment period of 210 days, which would give the staff a chance to bring back a comment letter analysis before the end of 2021. The Chairman and another Board member noted that a comment period beyond 180 days for any ED would be excessive.

Many Board members echoed these comments. One Board member noted that in her jurisdiction, preparers are not asking for extensions. She said that to grant extensions, she would like to know how the extra time will be used by preparers. If an extension will be needed to get better comments, she would agree to it, but she would want to avoid blanket extensions. One Board member asked whether the Targeted Standards-level Review of Disclosures ED would need more field work by the staff than other EDs, which was confirmed by the staff. The field work requires a degree of education as the ED proposes a new way of thinking. This would be a sequenced approach which needs more time than it would for other EDs.

Some Board members said that their outreach revealed that stakeholders are overwhelmed with consultations and need an extension to be able to respond properly.

The Chair called a vote on the staff recommendation with the modification of extending the Targeted Standards-level Review of Disclosures ED to 210 days, instead of 270 days. 11 of the 13 Board members voted in favour.

Correction list for hyphenation

These words serve as exceptions. Once entered, they are only hyphenated at the specified hyphenation points. Each word should be on a separate line.