Comments on the 165-page proposal are due 19 February 2009. The Roadmap sets forth several milestones that, if achieved, could lead to the required use of IFRS by US issuers in 2014. The milestones include:
- Improvements in accounting standards based on the latest IASB-FASB MOU (the commission cites revenue recognition and financial statement presentation as two projects that, when completed should 'improve financial reporting significantly')
- Accountability and funding of the IASC Foundation
- Improvement in the ability to use interactive data for IFRS reporting
As part of the Roadmap, the Commission is proposing to permit early use of IFRS by a limited number of US issuers where this would enhance the comparability of financial information to investors. Only an issuer whose industry uses IFRS as the basis of financial reporting more than any other set of standards would be eligible to elect to use IFRS, beginning with filings in 2010.
| TABLE OF CONTENTS OF THE SEC'S PROPOSED IFRS ROADMAP |
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- I. OVERVIEW
- II. THE ROLE OF IFRS IN THE US CAPITAL MARKETS
- A. The Promise of Global Accounting Standards
- 1. The Global Nature of Today's Capital Markets
- 2. Potential for IFRS as the Global Accounting Standard
- B. Past Policy Considerations Regarding IFRS
- III. A PROPOSED ROADMAP TO IFRS REPORTING BY US ISSUERS
- A. Milestones to be Achieved Leading to the Use of IFRS by US Issuers
- 1. Improvements in Accounting Standards
- 2. Accountability and Funding of the IASC Foundation
- 3. Improvement in the Ability to Use Interactive Data for IFRS Reporting
- 4. Education and Training
- 5. Limited Early Use of IFRS Where This Would Enhance Comparability for US Investors
- 6. Anticipated Timing of Future Rulemaking by the Commission
- 7. Implementation of the Mandatory Use of IFRS
- B. Other Areas of Consideration
- 1. The Roles of Financial Information
- 2. Accounting Systems, Controls and Procedures
- 3. Auditing
- 4. Considerations of IFRS and the IASB's Standard Setting Process
- a. State of IFRS
- b. Relationship to the Accounting Standard Setting Process
- IV. PROPOSAL FOR THE LIMITED EARLY USE OF IFRS WHERE THIS WOULD ENHANCE COMPARABILITY FOR US INVESTORS
- A. Eligibility Requirements
- B. Staff Letter of No Objection to the Use of IFRS
- C. Transition
- D. Alternative Proposals for US GAAP Information
- 1. Proposal A - Reconciled Information Pursuant to IFRS 1
- 2. Proposal B - Supplemental US GAAP Information
- 3. Discussion of Proposals A and B
- V. DISCUSSION OF PROPOSED AMENDMENTS
- A. The Use of IFRS Financial Statements in Commission Filings by Eligible Issuers
- 1. Proposed Amendments to Rule 4-01 of Regulation S-X
- 2. Proposed Definition of 'IFRS Issuer'
- B. Application
- 1. Article 13 of Regulation S-X
- 2. Proposed Clarifying Amendments with Respect to References to IFRS as Issued by the IASB
- C. Proposed Amendments to Item 10(e) of Regulation S-K and Regulation G
- D. Related Disclosure and Financial Reporting Issues
- 1. Selected Financial Data
- 2. Market-Risk and the Safe Harbor Provisions
- 3. Disclosure of First-Time Adoption of IFRS in Form 10-K
- 4. Other Considerations Relating to IFRS and US GAAP Guidance
- E. Financial Statements of Other Entities under Regulation S-X
- 1. Application of the Amendments to Rules 3-05, 3-09 and 3-14
- a. Significance Testing
- b. Separate Historical Financial Statements of Another Entity Provided under Rule 3-05, 3-09 or 3-14
- 2. Financial Statements Provided under Rule 3-10
- 3. Financial Statements Provided under Rule 3-16
- F. Pro Forma Financial Statements Provided under Article 11
- G. Industry Specific Matters
- 1. Disclosure Pursuant to Industry Guides
- 2. Disclosure from Oil and Gas Companies under FAS 69
- H. Application of the Proposed Amendments to Other Forms, Rules and Schedules
- 1. Application of Proposed Amendments to Exempt Offerings
- 2. References to FASB Pronouncements in Form 8-K
- 3. Application of IFRS to Tender Offer and Going-Private Rules
- VI. GENERAL REQUEST FOR COMMENTS
- VII. PAPERWORK REDUCTION ACT
- A. Background
- B. Burden and Cost Estimates Related to the Proposed Amendments
- C. Request for Comment
- VIII. COST-BENEFIT ANALYSIS
- A. Proposal for Early Use of IFRS by US Issuers
- 1. Expected Benefits
- 2. Expected Costs
- B. Proposal A: Reconciled Information Pursuant to IFRS 1
- 1. Expected Benefits
- 2. Expected Costs
- C. Proposal B: Supplemental US GAAP Information
- 1. Expected Benefits
- 2. Expected Costs
- IX. REGULATORY FLEXIBILITY ACT CERTIFICATION
- X. CONSIDERATION OF IMPACT ON THE ECONOMY, BURDEN ON COMPETITION AND PROMOTION OF EFFICIENCY, COMPETITION AND CAPITAL FORMATION
- XI. PROPOSED AMENDMENTS TO THE CODIFICATION OF FINANCIAL REPORTING POLICIES
- XII. STATUTORY BASIS AND TEXT OF PROPOSED AMENDMENTS
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