The letter explores the benefits of integrated reporting in the context of continuing concern about streamlining of existing reporting and the broadening of reporting beyond pure financial reporting, but notes concerns about entity's preparedness to move to an integrated thinking and reporting model:

In today’s business environment, there is general agreement that various aspects of the current business reporting framework need to be streamlined. As well, there is increased demand for environmental, social and governance information that has the potential to affect investment decisions to be better integrated and connected in one external report, instead of using today’s separate reporting strands. In our view, however, few organizations currently have sufficiently integrated and robust systems and processes or an integrated thinking mindset necessary to generate a reliable integrated report

On the issue of demand for integrated reporting, the letter note "we see little evidence, at least in Canada, that providers of financial capital are demanding an integrated report" and "there will need to be clearly demonstrated capital allocation benefits to encourage widespread voluntary adoption".

In terms of the IIRC's expectations of finalising the proposals by the end of 2013 , the letter suggests the IIRC's pilot programme should be a key driver of the finalisation process, which may warrant a delay:

The concept of an integrated report as proposed by the IIRC is both new and complex. Accordingly, we are pleased that the IIRC has established a pilot program for both preparers and investors. The current workplan, however, calls for version 1 of the Framework to be published in December 2013, and for the pilot program to conclude in September 2014. There is much to be learned from the pilot program about issues with the Framework and how it can best be applied. Therefore, to maximize these insights, we believe the pilot program should be extended beyond September 2014. As well, we believe version 1 of the Framework should not be published until the pilot program is complete, to enable revisions to the draft Framework to consider everything learned from the pilot

The letter also outlines various other concerns about the IIRC's proposals, including such matters as the prescriptive nature of some terminology used, the level of detail required in integrated reports, a need for a more integrated discussion of 'capitals', whether the 'business model' concept should be defined, potential confusion on the definition and application of 'materiality', and the interaction with statutory reporting.

CPA Canada was formed at the beginning of 2013 by the Canadian Institute of Chartered Accountants (CICA) and The Society of Management Accountants of Canada (CMA Canada), which are currently undergoing the final phases of unification. The comment letter effectively represents the views of both antecedent organisations.

Click for access to the comment letter (link to CICA website).