The IASB published its DP for comment on 28 June 2018. Final comments are due to the IASB by 7 January 2019.

While EFRAG supports changes to IAS 32 Financial Instruments: Presentation, in its draft comment letter, EFRAG explains several "reservations" it has about the amendments proposed in the DP. These reservations include:

• the balance of costs and benefits of the information provided by the attribution approaches;
• separate presentation in the statement of financial position and statement of financial performance of derivatives, embedded derivatives and hybrids;
• accounting for standalone derivatives to extinguish an equity instrument consistently with a compound instrument;
• the proposed removal of the foreign currency rights issue exemption;
• classification changes for financial instruments that do not raise concerns in practice.

The draft comment letter also discusses new terminology introduced by the IASB's DP:

EFRAG acknowledges that a better articulation of IAS 32’s underlying principles could be an effective way to improve the consistency, clarity and completeness of the requirements and would require new terminology. However, new terminology would also require preparers and auditors to reconsider a wide range of past classification decisions. Accordingly, this approach, while addressing various interpretive issues, will also cause some disruption, create additional costs for preparers and risks the emergence of new issues and uncertainties.

The letter also asks that the IASB consider accounting for all standalone and embedded derivatives and derivative assets and liabilities under the scope of IFRS 9.

Comments on EFRAG's draft comment letter are requested by 3 December 2018. For more information, see the press release and the draft comment letter on the EFRAG website. EFRAG has also released a four minute video introducing the draft comment letter.