Deloitte comment letters (IASB/IFRIC/IFRSF)

Deloitte comment letters (resource)

A key part of due process is constituent feedback. This page provides quick access to Deloitte comment letters on key proposals from the International Accounting Standards Board (IASB), IFRS Interpretations Committee, IFRS Foundation, and related organisations.

Related Publications

Deloitte comment letter on the IASB's proposal to extend the practical relief regarding COVID-19-related rent concessions

24 Feb 2021

We support the extension of the availability of the practical expedient so that it applies to rent concessions that affect payments originally due on or before 30 June 2022 instead of 30 June 2021, for the reasons stated in the basis of conclusions on the exposure draft. We also agree with the proposed effective date and transition provisions.

Deloitte comment letter on tentative agenda decision on configuration or customisation costs in a cloud computing arrangement (IAS 38)

15 Feb 2021

We have commented on the IFRS Interpretations Committee's publication in the December 2020 IFRIC Update of the tentative decision not to take onto the Committee’s agenda the request for clarification on accounting for costs of configuring or customising the supplier’s application software in a Software as a Service (SaaS) arrangement.

Deloitte comment letter on tentative agenda decision on classification of debt with covenants as current or non-current (IAS 1)

15 Feb 2021

We have commented on the IFRS Interpretations Committee's publication in the December 2020 IFRIC Update of the tentative decision not to take onto the Committee’s agenda the request for clarification on whether an entity has a right to defer settlement of a liability for at least 12 months after the reporting period when the right to defer is subject to specified conditions.

Deloitte comment letter on tentative agenda decision on attributing benefit to periods of service (IAS 19)

15 Feb 2021

We have commented on the IFRS Interpretations Committee's publication in the December 2020 IFRIC Update of the tentative decision not to take onto the Committee’s agenda the request for clarification about the periods of service to which an entity attributes benefit for a particular defined benefit plan.

Deloitte comment letter on tentative agenda decision on hedging variability in cash flows due to real interest rate (IFRS 9)

15 Feb 2021

We have commented on the IFRS Interpretations Committee's publication in the December 2020 IFRIC Update of the tentative decision not to take onto the Committee’s agenda the request for clarification on the application of hedge accounting requirements in IFRS 9 when the risk management objective is to ‘fix’ the cash flows in real terms.

Deloitte comment letter on discussion paper on goodwill

21 Dec 2020

We support the Board’s initiative to assess whether information provided to investors on business combinations can be improved, including by setting clearer disclosure objectives. However, we are not convinced that the proposals in the discussion paper would result in disclosures that provide more useful information to users of the financial statements. Also, we do not support the preliminary view of the Board not to reintroduce amortisation of goodwill. Finally, without the reintroduction of goodwill amortisation, we strongly diagree with the proposal to remove the requirement to perform a quantitative impairment test every year.

Deloitte comment letter on the Trustees' sustainability consultation

01 Dec 2020

We stress that the scale of the challenges and the increasing momentum from all stakeholders for a global solution for sustainability reporting standards make the undeniable case for immediate action and consequently, support the IFRS Foundation’s proposal to establish a global sustainability standard-setter alongside the IASB and under the governance and oversight of the IFRS Foundation.

Deloitte comment letter on the tentative agenda decision on sale and leaseback in a corporate wrapper

24 Nov 2020

We agree that the IFRS Interpretations Committee’s conclusions as laid out in the agenda decision reflect the requirements of IFRS 10 and IFRS 16 in relation to the specific fact pattern presented therein. However, we strongly suggest that in addition to this decision the Board takes on a broader project to address the treatment of the sale of corporate wrappers, in particular when, if ever, these should be accounted for as sales of assets rather than subsidiaries.

Deloitte comment letter on the comprehensive review of the IFRS for SMEs

23 Oct 2020

We have commented on the IASB’s Request for Information Comprehensive Review of the IFRS for SMEs Standard, which was published by the IASB on 28 January 2020.

Deloitte comment letter on general presentation and disclosures

30 Sep 2020

We have commented on the IASB’s exposure draft ‘General Presentation and Disclosures’ which was published by the IASB on 17 December 2019.

Deloitte comment letter on tentative agenda decision on supply chain financing arrangements — reverse factoring

29 Sep 2020

We have commented on the IFRS Interpretations Committee's publication in the June 2020 IFRIC Update of the tentative decision not to take onto the Committee’s agenda the request for clarification on how to present liabilities to which reverse factoring arrangements relate and what information is required to be disclosed in relation to these arrangements in the financial statements.

Deloitte comment letter on the IASB's proposed amendments to defer the effective date of recent IAS 1 amendments Image

Deloitte comment letter on the IASB's proposal to defer the effective date of recent IAS 1 amendments

03 Jun 2020

We have commented on IASB exposure draft ED/2020/3, "Classification of Liabilities as Current or Non-Current – Deferral of Effective Date," which was published by the IASB on 4 May 2020. The ED proposes to defer the effective date of the January 2020 amendments to IAS 1 by one year.

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Deloitte comment letters (IASB/IFRIC/IFRSF)

Related Publications

Deloitte comment letter on the IASB's proposal to extend the practical relief regarding COVID-19-related rent concessions

Deloitte comment letter on tentative agenda decision on configuration or customisation costs in a cloud computing arrangement (IAS 38)

Deloitte comment letter on tentative agenda decision on classification of debt with covenants as current or non-current (IAS 1)

Deloitte comment letter on tentative agenda decision on attributing benefit to periods of service (IAS 19)

Deloitte comment letter on tentative agenda decision on hedging variability in cash flows due to real interest rate (IFRS 9)

Deloitte comment letter on discussion paper on goodwill

Deloitte comment letter on the Trustees' sustainability consultation

Deloitte comment letter on the tentative agenda decision on sale and leaseback in a corporate wrapper

Deloitte comment letter on the comprehensive review of the IFRS for SMEs

Deloitte comment letter on general presentation and disclosures

Deloitte comment letter on tentative agenda decision on supply chain financing arrangements — reverse factoring

Deloitte comment letter on the IASB's proposal to defer the effective date of recent IAS 1 amendments

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Correction list for hyphenation