In an opening statement before commenting directly on the IOSCO proposals, FEE expresses support for improvements in corporate reporting and stresses that non-GAAP measures play an important role as they can improve the communication between the entity and its stakeholders as long as they are reported in a transparent and unbiased manner. Nevertheless, FEE "identifies that there is a lack of coordination between market oversight bodies and regulators on one hand and the IASB on the other hand, which leads to a high degree of divergence in practice. FEE expressly references the ESMA consultation on alternative performance measures, but recently also the IFAC has issued guidance on supplementary financial measures. FEE states:

We believe that the International Accounting Standards Board (“IASB”) should also be involved in the reporting of Non-GAAP Measures in the context of financial reporting. Some IFRSs currently include guidance on how an entity can present Non-GAAP Measures within its financial statements. Therefore, [...] FEE suggests all the market oversight bodies and regulators (international, regional and national) to work with the IASB in order to develop a common comprehensive framework on Alternative Performance Measures/Non-GAAP measures.

The IASB has a disclosure initiative on its agenda that is split into several smaller projects. The project on principles of disclosure considers information that should be included in a complete set of financial statements and the presentation of non-IFRS information and comparative information. A discussion paper is currently expected in the second quarter of 2015. 

Please click for the FEE comment letter, which also contains detailed comments on the IOSCO proposals, on the FEE website.