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Deloitte comment letter on IASB's annual improvements proposals

  • Deloitte Comment Letter Image

05 Sep 2011

Deloitte's IFRS Global Office has submitted a letter of comment on IASB Exposure Draft ED/2011/2 Improvements to IFRSs.

We welcome the IASB's continuing efforts to deal with certain amendments to IFRSs in an efficient and effective manner and are pleased to note that the proposed amendments address discrete areas where differences in interpretation or possible conflicts between IFRSs have been identified.

The following is an excerpt from the letter:

We are generally in agreement with the intentions of the proposed amendments, but are concerned that some amendments (in particular, those to IFRS 1 First-time Adoption of International Financial Reporting Standards) may have unintended consequences. These unintended consequences arise principally from ambiguous drafting which... include inconsistencies between the Basis of Conclusions and the actual wording of the amendment.

In addition, we note that the amendments introduce a number of terms (for example, 'required comparative period' and 'additional comparative information') for which a formal definition is not provided. This could also contribute to a lack of clarity over the scope and effect of the proposed amendments. The use of clearly defined terms will become more important as IFRSs are applied in new jurisdictions as terms in common use in one jurisdiction may be unfamiliar in another and also because any lack of clarity is likely to be exacerbated upon translation of IFRSs into another language.

Comments on ED/2011/2 close on 21 October 2011. Click for our Comment Letter on ED/2011/2 (PDF 42k).

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