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Deloitte comment letter on Request for Views 'Effective Dates and Transition Methods'

Published on: 31 Jan 2011

We strongly support the issuance of the Request for Views to assist the Board in understanding the expected time and effort involved in adopting future IFRSs. The unprecedented level of standard setting makes these types of outreach activities critical to ensuring that the Board’s various constituency groups can appropriately manage the expected significant changes to IFRSs.

Given the significance and scope of the projects that are the subject of the Request for Views, we believe that the Board’s implementation plan needs to incorporate flexibility due to the diversity of the constituency groups which are likely to be affected and to serve the different needs of constituents, both in respect of differences between constituency groups and differences within constituency groups due to size, industry and territory. Without flexibility, the needs of some constituents will not be addressed, thus jeopardising the quality of financial information produced. The Board should aim for an approach which facilitates orderly implementation of these changes by all constituents with the objective of high quality financial information based on robust data as this is in the best interests of all its constituents, including auditors. We therefore recommend that the Board sets a mandatory effective date that is far enough into the future while allowing entities to adopt standards early. Such an approach would give the necessary flexibility for entities to adopt either a single date or a sequential approach.

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