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Second Deloitte response to ad personam mandate on non-financial reporting standard setting

06 Jan 2021

The Deloitte firms in the European Union have responded to the consultation document on the ad personam mandate on potential need for changes to the governance and funding of EFRAG in the context of possible changes to non-financial reporting by companies.

We reiterate that we support actions in favour of global initiatives because the issues to be addressed are global issues and need global solutions. Businesses have global supply and value chains, face global risks and have global investors. Most importantly, issues such as climate change and achieving the UN Sustainable Development Goals require international solutions.

With respect to the Consultation document:

  • We are supportive of the proposals in relation to EFRAG’s new mission and due process as described in the document.
  • We support retaining the current infrastructure and role for the financial reporting.
  • We support the idea of an enlarged General Assembly that covers all EFRAG’s activities.
  • We support the proposals for an EFRAG (Supervisory) Board, which would look after the governance and administration of the overall organisation, as well as the oversight of all the EFRAG bodies.
  • We support the financial reporting and non-financial reporting Boards having the ultimate decision-making powers on financial reporting and non-financial reporting issues respectively.
  • For non-financial reporting, to the extent that EFRAG is entrusted with standard-setting activities, the non-financial reporting Board is likely to require enhanced technical competences, as compared to the current EFRAG Board.
  • Collecting the views of EU Member States /national public authorities on non-financial reporting will be important.
  • With respect to the EU institutions and agencies, we suggest their participation in an observer capacity with speaking rights, at each level of the EFRAG organisation, where this would be relevant.
  • With respect to the representation of the private sector and civil society, we are strongly in favour of a public-private partnership for EFRAG.
  • We support close involvement and/or cooperation between EFRAG and the identified key international non-financial reporting standard-setting organisations.
  • To enable the EFRAG structure to achieve its possible mission for non-financial reporting standard-setting successfully, it will need additional competent operational resources at the EFRAG staff level.
  • Finally, considering the proposed governance structure and the need for long-term finance, as well as the fact that the objective would be to possibly develop non-financial reporting standards, our view is that the European Commission and the Member States should provide the majority of the funding.

Please click to download our full comment letter here.

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Hyperinflationary economies - updated IPTF watch list available

06 Jan 2021

IAS 29 'Financial Reporting in Hyperinflationary Economies' defines and provides general guidance for assessing whether a particular jurisdiction's economy is hyperinflationary. But the IASB does not identify specific jurisdictions. The International Practices Task Force (IPTF) of the Centre for Audit Quality (CAQ) monitors the status of 'highly inflationary' countries. While it monitors the status of highly inflationary countries for the purposes of applying US GAAP, its criteria for identifying such countries are similar to those for identifying 'hyperinflationary economies' under IAS 29.

The IPTF's discussion document for the 10 November 2020 meeting is now available and states the following view of the Task Force:

Countries with three-year cumulative inflation rates exceeding 100%:

  • Argentina
  • Iran
  • Lebanon
  • South Sudan
  • Sudan
  • Venezuela
  • Zimbabwe

Countries with projected three-year cumulative inflation rates exceeding 100%:

  • Suriname

Countries where the three-year cumulative inflation rates had exceeded 100% in recent years:

There are no countries in this category for this period.

Countries with recent three-year cumulative inflation rates exceeding 100% after a spike in inflation in a discrete period:

There are no countries in this category for this period.

Countries with projected three-year cumulative inflation rates between 70% and 100% or with a significant (25% or more) increase in inflation during the current period

  • Angola
  • Haiti
  • Liberia
  • Yemen

The IPTF also notes that there may be additional countries with three-year cumulative inflation rates exceeding 100% or that should be monitored which are not included in the analysis as the necessary data is not available. An example cited is Syria.

The full list, including exact numbers, detailed explanations of the calculation of the numbers, and observations of the Task Force is available on the CAQ website.

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Year in review — 2020

30 Dec 2020

2020 was another successful year for the IAS Plus family with over 13 million page views. We've devoted significant resources to bring you comprehensive coverage of all things IFRS (two news item per day on average) and broader financial reporting and other relevant topics and are pleased that our readers appreciate our efforts.

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IFRS 17 adoption progresses around the world

30 Dec 2020

China, the second largest insurance market in the world, has decided to adopt IFRS 17 over a three year transition period. Saudi Arabia has adopted the IFRS 17 amendments issued in June 2020 and India is consulting on the adoption of them.

The Ministry of Finance of the People's Republic of China has issued CAS 25 (revised) to be part of the IFRS-converged accounting standards for Chinese entities (Chinese Accounting Standards or CAS). The text of the new regulation is converged with IFRS 17 as issued by the IASB except for the mandatory effective date that is staggered over two stages: 1 January 2023 for all Chinese listed insurers and 2026 for all other Chinese insurers. The Chinese text of CAS 25 (revised) is available here.

The Saudi Organization for Certified Public Accountants (SOCPA) has adopted Amendments to IFRS 17 that the IASB issued in June 2020 to address concerns and implementation challenges that were identified after IFRS 17 Insurance Contracts was published in 2017. The SOCPA adoption also includes Extension of the Temporary Exemption from Applying IFRS 9 (Amendments to IFRS 4). Announcements in Arabic regarding the adoption of the IFRS 17 amendments and the IFRS 4 amendments are available on the SOCPA website.

On 24 December 2020, the Institute of Chartered Accountants of India (ICAI) issued for comment an exposure draft of amendments to Ind AS 117 Insurance Contracts that is intended to keep the IFRS-converged accounting standards for Indian entities (Indian Accounting Standards or Ind AS) aligned with IFRSs as issued by the IASB. Comments can be submitted by 24 January 2021. Following receipt of any comments, the ICAI will issue the amended Ind AS 117 for the Ministry of Corporate Affairs to consider its inclusion in the legally mandated Ind AS. The press release on the ICAI website offers access to the exposure draft.

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Season's greetings

24 Dec 2020

We wish all our readers a healthy and happy festive season and all the best for the New Year!

We look forward to seeing you again after the holidays and to continue to be your preferred accounting website in 2021.

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IOSCO responds to the IFRS Foundation's sustainability consultation

24 Dec 2020

The International Organization of Securities Commissions (IOSCO) has submitted its response to the IFRS Foundation's consultation on sustainability reporting.

IOSCO sees an urgent need to improve the completeness, consistency and comparability of sustainability reporting and notes:

Together, the IFRS Foundation’s consultation and a parallel collaborative initiative of an alliance of sustainability reporting organizations can further efforts to facilitate comparable high-quality international standards that provide the content that capital markets need, within a transparent standard-setting architecture with a robust and inclusive governance structure.

IOSCO also believes that robust sustainability reporting standards, interconnected with financial reporting standards, would also support audit and assurance – enhancing the market’s trust in sustainability disclosures, and laying the foundations for mandatory corporate reporting on sustainability internationally.

Please click to access the full comment letter on the IOSCO website.

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FSB responds to the Trustees' sustainability consultation

22 Dec 2020

The Financial Stability Board (FSB) has submitted a comment letter on the IFRS Foundation Trustees’ consultation paper on sustainability reporting published in September 2020.

The FSB supports the recommended approach by the Trustees of the IFRS Foundation to initially focus on standards for climate-related financial disclosures, as an important initiative to promote globally consistent disclosures and avoiding fragmentation. The FSB strongly encourages the IFRS Foundation to build on the work of the TCFD, by using the TCFD’s recommendations as the basis for standards for climate-related financial disclosures.

The FSB notes that the TCFD recommendations set out a comprehensive framework that has been developed by, and is directly responsive to the needs of, users and preparers of financial filings across a range of financial and non-financial sectors around the world. They have attracted widespread support from users and preparers.

In its comment letter, the FSB also strongly encourages other national or regional authorities that are developing requirements or guidance for climate-related disclosures to consider using the TCFD recommendations as the basis. Such consistency in approach would help to avoid the risk of market fragmentation, both across jurisdictions, and between requirements and guidance being developed today and international standards that may be introduced in the future.

Please click to access the full comment letter on the FSB website.

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EFRAG draft comment letter on the IASB's proposed amendment to IFRS 16

22 Dec 2020

The European Financial Reporting Advisory Group (EFRAG) has issued a draft comment letter on the IASB exposure draft ED/2020/4 'Lease Liability in a Sale and Leaseback (Proposed amendment to IFRS 16)'.

The proposed amendment aims at clarifying how a seller-lessee should apply the subsequent measurement requirements in IFRS 16 Leases to the lease liability that arises in a sale and leaseback transaction.

EFRAG supports the proposals in the exposure draft as they provide practical guidance on an area not currently addressed by IFRS 16 while relying on existing measurement principles. However, EFRAG encourages the IASB to reconsider the matter more broadly as part of the future post-implementation review of IFRS 16.

Comments on EFRAG's draft comment letter were originally requested by 21 February 2021; however, to allow more time for stakeholders to provide their view, the comment deadline has been extended to 23 March 2021. For more information, see the press release and the draft comment letter on the EFRAG's website.

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We comment on the SASB’s proposed conceptual framework and rules of procedure

21 Dec 2020

We have published our comment letter on the SASB’s exposure draft 'Proposed Changes to the SASB Conceptual Framework and Rules of Procedure'.

We support the Board’s initiative to review these two documents to ensure that they describe clearly the concepts on which SASB Standards are based and the procedures that the organisation follows when developing, issuing and maintaining a SASB Standard. We believe it is important that SASB take this opportunity to ensure maximum alignment of both the SASB Conceptual Framework and the Rules of Procedure with global best practice (in particular the corresponding documents of the IFRS Foundation), in order to facilitate moves towards global sustainability standard setting. We therefore recommend that SASB now moves to adopt the approach set out in the recent joint paper.

Download the full comment letter here.

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IASB issues podcast on latest Board developments (December 2020)

21 Dec 2020

The IASB has released a podcast featuring IASB Chair Hans Hoogervorst and IASB Vice-Chair Sue Lloyd discussing deliberations at the December 2020 IASB meeting.

The podcast discusses:

  • Primary financial statements;
  • Comprehensive review of the IFRS for SMEs;
  • Maintenance and consistent application;
  • Subsidiaries that are SMEs;
  • Financial instruments with characteristics of equity; and
  • Post-implementation review of IFRS 9

The podcast (15 minutes) can be accessed through the press release on the IASB website.

The detailed notes taken by Deloitte observers at the meeting are available here.

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