In general, we question the appropriateness of these draft Q&As for the following reasons:

• as noted in paragraph BC75 of the IFRS for SMEs, local bodies, such as legislators and regulators, are best placed to judge how the concept of public accountability is viewed in their jurisdictions; and
• in determining the scope of the IFRS for SMEs, the Board decided upon a conceptual criterion. These draft Q&As could be read as adding rules to the concept.

We also question whether the level of SME Implementation Group's due process applied to the Q&As is appropriate and consistent with other similar activities at the IFRS Foundation and IASB. The Group's Terms of Reference and Operating Procedures were not subject to public comment, a regrettable deficiency that may impact the legitimacy of the product of the Group's deliberations. As the Q&As are considered IFRS related documents and are associated with the IASB, we believe that the due process steps followed in the development of an IFRIC Interpretation which include discussion and voting in a public meeting, public consultation on agenda items and positive approval of an Interpretation by the Board should be followed for these and any future Q&As.

In addition, we note that Draft Q&A 2011/03 seeks to interpret a term ('traded in a public market') which exists in full IFRSs (IFRS 8, IAS 27 and IAS 33). We do not consider it appropriate for a Q&A on the IFRS for SMEs to address an issue which applies to other IFRSs as such guidance will, whether it is intended to or not, be interpreted as being applicable to those IFRSs. ...