We recognise that accounting for employee benefits has been the subject of criticism for failing to provide a clear indication of the obligation of sponsoring entities towards their employees under long-term defined benefits plans and for the failure of IAS 19 to provide a proper model to account for certain types of plan (mainly certain cash balance plans). We share many of these concerns. However, while we appreciate the desire of the IASB to address the most pressing of these issues, we are concerned that the DP's proposals go beyond the changes that should be introduced via a short-term project. In particular, we strongly discourage the Board from proceeding with its proposal to redefine employee benefit schemes into defined benefits promises and contribution-based promises. As we explain in our detailed comments, the changes proposed would have far reaching consequences and would introduce inconsistencies in accounting for plans that are similar in substance. Further we note that contribution-based promises are not clearly defined and we are not sure we understand exactly what the measurement approach is for contribution-based promises as proposed in the DP and how it differs from other measurement approaches currently used in IFRS.

Finally, while we generally support the Board's proposal to eliminate the option to defer recognition of changes in defined benefit assets and obligation, the elimination of this approach cannot be addressed without proper resolution of the issues linked to the presentation of these changes. Accordingly, we believe that the implementation of this proposal should be timed to coincide with the revised Standard dealing with the presentation of financial performance.