We comment on improvements to IFRSs ED

  • Deloitte Comment Letter Image

24 Nov 2009

Deloitte Touche Tohmatsu has submitted comments on IASB Exposure Draft ED2009/11 Improvements to IFRSs, which was published 26 August 2009. The ED proposes improvements to eleven IFRSs, mostly mandatory for 2011 but several earlier.

While we support the IASB's improvements process, we have 'serious concerns regarding the quality and drafting of the 2009 amendments' and about inconsistencies between some of the proposed improvements and decisions on current agenda projects. Our view, in summary:

We welcome the IASB's continuing process to deal with certain amendments to IFRSs in an efficient and effective manner. Nonetheless, we have serious concerns regarding the quality and drafting of the 2009 amendments, as there is not always consistency between the Board's intentions as expressed in the introduction, the Basis of Conclusions and the actual wording of the amendment. This is particularly so with respect to the proposed changes to IAS 1, IAS 27, IAS 34, and IAS 40, in which the proposed amendments go beyond the Board's stated intentions and have more widespread consequences than indicated in the introduction or Basis for Conclusions. We also question whether such potentially wide-reaching amendments are within the scope of the annual improvements process.

We are also concerned that some of the proposed amendments and their implications appear to be in conflict with other projects on the Board's agenda. This is particularly the case with the proposed amendments to IAS 27. This apparent conflict is confusing for the Board's constituents, and we would strongly encourage the Board to ensure consistency between projects on its agenda and the annual improvements even if this means delaying an improvement.

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