The ED was issued on 11 October 2007 proposing miscellaneous amendments to 25 IFRSs. Our letter expresses concern that "it is not clear what are regarded by the Board as minor amendments and how such amendments are distinguished from 'major' amendments. We are concerned that this lack of clarity might lead to changes to IFRSs that would better be dealt with as part of the normal due process, i.e. separate exposure of the amendments. Although we acknowledge that the Annual Improvements document is subject to due process as set out in the IASB's Due Process Handbook we are concerned that the level of scrutiny may be less for Annual Improvements than it would be for amendments exposed on a stand-alone basis." Click for More Information about the ED. Here is an excerpt from our letter:

We believe that several of the proposed amendments are major amendments to IFRSs and should be exposed as separate documents because the proposed amendments either change or challenge important principles in IFRSs or have consequences beyond the situation the amendment is aiming to address.... In our opinion the following proposed amendments in the exposure draft could not be considered 'minor': the requirement of additional disclosures if an entity is not able/willing to apply IFRSs in full in IAS 1 Presentation of Financial Statements the proposed deletion of guidance for classification of leases of land in IAS 17 Leases the proposed replacement of the term 'fall due' in IAS 19 Employee Benefits the change in the accounting treatment for property under construction/development in IAS 40 Investment Property

Click to view Comments on the IASB Exposure Draft of Proposed Improvements to IFRSs (PDF 224k). Our past comment letters are Here.