7.0 Disclosure Requirements in IFRS Standards A Pilot Approach

Executive Summary

Purpose of the paper

This paper provides the Board with a draft Project Initiation Plan (PIP) and draft Comment Letter for the IASB's ED/2021/3 Disclosure Requirements in IFRS Standards – A Pilot Approach’ for discussion and approval. The IASB's ED was published on 25 March 2021. The comment deadline is 21 October 2021, though we note the IASB Board meeting on 21 July will consider extending the deadline to 12 January 2022. Should the deadline be extended a modified PIP will be re-presented to the Board.

Summary of the Issue

This IASB ED seeks to address the “disclosure problem” and proposes four actions:

1. Creates Guidance for IASB's use when developing and drafting disclosure requirements. This proposes to largely replace mandatory disclosure items with an objectives-based regime.
2. Applies this Guidance to IFRS 13 Fair Value Measurement and proposes amendments to this standard developed by using the new Guidance.
3. Applies this Guidance to IAS 19 Employee Benefits and proposes amendments to this standard developed by using the new Guidance.
4. Proposes consequential amendments to IAS 34 Interim Financial Reporting and IFRIC 17 Distribution of Non-cash Assets to Owners.

Decisions for the Board

The Board is asked to approve the draft PIP (based on IASB's currently approved deadline) and draft Comment Letter.

Recommendation

We recommend the Board approves the draft PIP and draft Comment Letter.

Appendices

1. Draft PIP: Disclosure Requirements in IFRS Standards – A Pilot Approach
2. Draft Comment Letter: Disclosure Requirements in IFRS Standards – A Pilot Approach

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Appendix 1: Draft Project Initiation Plan: Disclosure Requirements in IFRS Standards – A Pilot Approach

Overview

1SI/2019/685(5)(b) ² requires the UKEB to be responsible for “participating in and contributing to the development of a single set of international accounting standards.” The proposed project contributes to this work.

2The IASB's Exposure Draft ED Disclosure Requirements in IFRS Standards – A Pilot Approach ³ ("the Disclosure Pilot") seeks to address the “the disclosure problem" of financial statements containing irrelevant information, insufficient relevant information, ineffective communication of the information provided and a checklist approach to disclosure used by some entities.

3This project forms part of IASB's Disclosure Initiative, a portfolio of projects exploring how to improve the effectiveness of disclosures in financial reporting. The IASB's ED was published on 25 March 2021 and the comment deadline is 21 October 2021.

4The ED proposes four actions.

1. Creates Guidance for IASB to use when developing and drafting disclosure requirements. This proposes to largely replace mandatory disclosure items with an objectives-based regime where entities can provide disclosure that satisfies the disclosure objectives.
2. Applies this Guidance to IFRS 13 Fair Value Measurement and proposes amendments to this standard developed using the new Guidance.
3. Applies this Guidance to IAS 19 Employee Benefits and proposes amendments to this standard created using the new Guidance
4. Proposes consequential amendments to IAS 34 Interim Financial Reporting and IFRIC 17 Distribution of Non-cash Assets to Owners.

5The ED notes that in addition to the proposed amendments to IFRS 13 and IAS 19, the guidance may potentially be used in the future development of new standards and changes to existing IFRS standards.

6Given the importance placed on disclosure by users of financial statements, the ED's proposals are expected to affect a large number of UK stakeholders, including IFRS preparers, users, auditors and relevant regulators. Ensuring the IASB has the opportunity to consider views of UK stakeholders during the standard's development is key to minimising new concerns being identified during the endorsement and adoption assessment process

Objective of the project

7As noted above this project forms part of IASB's Disclosure Initiative, a portfolio of projects exploring how to improve the effectiveness of disclosures in financial reporting. It seeks to address the “the disclosure problem” of financial statements containing too much irrelevant information, not enough relevant information, ineffective communication of the information provided and some entities taking a checklist approach to disclosure.

8The ED aims to improve the IASB's approach to developing and drafting disclosure requirements in IFRS standards and to help stakeholders improve the usefulness of disclosures for the primary users of financial statements.

The Guidance for IASB

9To achieve the above the ED creates Guidance for IASB to use when developing and drafting disclosure requirements.

10IASB identified a number of barriers to better disclosure based on stakeholder feedback and considered ways to addressing these which would also potentially help improve the disclosure problem. Those barriers and IASB's proposed remedies are as follows:

1. Stakeholders have said to IASB that the easiest way to achieve compliance can be to apply disclosure requirements like a checklist. To remedy this IASB propose that companies to comply with disclosure objectives that can only be met by applying judgement.
2. Stakeholders have said to IASB that complying with high volumes of prescriptive requirements does not leave time to apply materiality judgements. To remedy this IASB proposes minimising the requirements to disclose particular items of information, thus removing a perceived compliance burden.
3. Preparers may not always understand why information is useful, and therefore find it difficult to make effective judgements regarding its disclosure. To remedy this IASB proposes to engage users earlier in the standard setting process, set objectives based on user needs, and explain to preparers how the users are likely to use the information provided.

11The proposed Guidance would lead to mandatory lists of disclosure items in accounting standards being replaced with:

1. Overall disclosure objectives – these describe the overall information needs of investors for a particular IFRS Standard and require companies to provide information in the Notes sufficient to meet these needs.
2. Specific disclosure objectives – these describe the detailed information needs of investors within an IFRS Standard. These include an explanation of what investors may do with the information. Companies are required to provide information in the Notes sufficient to ensure these needs are met.
3. Items of information – provide examples of items of information a company may disclose to satisfy each disclosure objective. In some cases providing this information will be mandatory. These are intended to help companies apply judgement and determine how to satisfy particular disclosure objectives.

12IASB then proceeded to applying the disclosure Guidance to IFRS 13 and IAS 19 with the twin aims of: improving the usefulness of disclosures of financial statements prepared applying those standards; and testing and improving the proposed Guidance itself.

Amendments to IFRS 13 and IAS 19

13The IASB's application of the proposed Guidance to IFRS 13 and IAS 19 results in the lists of mandatory disclosure items in these Standards being replaced with a General Objective, a number of Specific Objectives, descriptions of how users are likely to use the information, and multiple lists of Items of Information.

14The amendments to IFRS 13 and IAS 19 (and consequential changes to IAS 34 and IFRIC 17) arising from this exercise form part of the exposure draft and may be finalised as amendments to these standards when this consultation is finalised.

Consequences of finalising the ED

15If the proposals in the ED are finalised in full then:

1. The proposed amendments to IFRS 13 and IAS 19 (and consequential changes to IAS 34 and IFRIC 17) would be enacted with immediate effect;
2. The proposed Guidance will be used in standard setting activities in future; and
3. The proposed Guidance may be applied to amend other existing IFRS Standards, subject to the normal due process for amendment to a Standard.

Initial identification of issues

16Our initial desk-based review of the standard and feedback from user, preparer, auditor and regulator roundtables has identified the following initial issues with the proposals.

Comparability

17A tension between relevance and comparability arises under these proposals. Companies may disclose different information to meet the same disclosure objective depending on their circumstances. This may result in relevant disclosure but may make comparability between companies more challenging.

Digital reporting

18Reduced consistency in disclosure may make it more difficult for users of digital reporting (or their models which consume financial data) to draw meaningful comparisons between companies and ensure that complete data sets have been received due to the lack of uniformity in reporting.

Application of judgement

19IASB identified that some companies currently struggle to make good judgements and apply materiality correctly when considering disclosure. The proposals increase reliance on judgement, which may exacerbate this problem.

20The Items of Information (some of which are mandatory) continue to be visually presented in a checklist style in the test standards. Behavioural change is complex and it is possible this this may encourage companies who prefer to use a “safe” checklist approach to use the Items of Information in this manner, which would not achieve the desired change.

Audit & enforceability

21The auditability of the proposals needs to be considered. In addition, companies will need to consider their processes to make Boards and Audit Committees comfortable with judgement-based disclosures compared to the previous perceived “safe” lists of mandatory disclosure.

22Regulators will need to ensure the proposals are satisfactory for their needs, and adapt their processes not to query disclosure only because it is different to that of similar companies, if the overall disclosure objectives are met. Regulators have told us working with an objectives based regime can be successful, but is resource intensive. Scaling this approach across more standards has resourcing implications for both regulators and companies. Some stakeholders have suggested that a company's assessment of materiality may need to be disclosed to allow regulators to adequately assess the completeness and effectiveness of reporting.

IFRS 13 amendments

23Based on our initial analysis we do not support the proposed amendments to IFRS 13. We understand that IFRS 13 was chosen for the disclosure pilot as it provided a good example of a standard requiring a high level of materiality judgement. However, we note that the PIR of IFRS 13 concluded that the information required by IFRS 13 is useful to users of financial statements. Further, stakeholders consulted by IASB during this project confirmed that “fair value measurement disclosures applying IFRS 13 generally contain information that meets the needs of users of financial statements”. (BC 59). Given the significant amount of change and consultation in recent months we cannot support significant amendments to a disclosure regime that stakeholders say is working adequately.

Context of amendments

24Based on our initial analysis we have reservations about supporting amendments to either IFRS 13 or IAS 19 without first understanding whether the Guidance described in the ED will be adopted and applied to other IASB projects. If the methodology is not used elsewhere, it will lead to inconsistent principles for disclosures being applied within IFRS.

Key planning assumptions, constraints and timeline

Comment deadline and resource capacity

25IASB comment deadline for this project is 21 October 2021. IASB will consider a request to extend this deadline to 12 January 2022 when it meets on 21 July 2021. Should the deadline be extended we expect to revise this workplan such that the comment letter to IASB is submitted for approval to the December board meeting rather than the October board meeting. The additional time would be used to offer a wider range of field testing dates to increase the appeal of field testing to potential volunteer companies, and to extend the public consultation on the draft comment letter. Any material revisions to the plan would be re-presented to the Board.

26We have commenced activities related to this project and will provide stakeholders a longer than usual comment period to maximise responses in what is a very busy consultation period for both UKEB and our stakeholders.

Assumptions

27We have made the following assumptions in developing this project plan:

1. The work will be combination of desk based analysis and outreach with stakeholders.
2. That a draft comment letter will be presented for Board approval at the 20 July meeting. The draft comment letter will be open to stakeholder comment for a longer than usual period of six-eight weeks to allow stakeholders the maximum time to engage prior to a final comment letter being presented to the Board at the 28 October 2021 meeting (this is later than the IASB comment deadline of 15 October 2021). .
3. IASB will accept a slightly late Comment letter. The IASB project team have already been advised of the timeline for the UKEB project.

Outreach

UK stakeholders

28The ED approach to disclosure is likely to impact a wide range of stakeholders including users and preparers of financial statements, auditors and relevant regulators. To ensure feedback is received from each these communities we have leveraged the recent Agenda Consultation roundtables to also obtain feedback on the ED. These views will be used to inform our draft comment letter, which provides stakeholders a further opportunity for feedback. During the period that the draft comment letter is open to consultation, we plan further interviews with UK regulators and will conduct further individual stakeholder interviews as opportunities arise.

29In addition to the roundtables and draft comment letter, we propose to create a series of educational videos produced jointly with IASB exploring key elements of the proposals. The purpose of these is to educate UK stakeholders and to raise awareness of the proposals and the opportunity to comment.

30We will advertise for volunteers to participate in IASB's field test exercise, and to the extent UK volunteers participate, will conduct this as a joint exercise with IASB. Due to the timing of the field testing, we expect low stakeholder engagement due to half-year reporting commitments and the number of other consultations taking place concurrently in the UK. Should IASB extend their reporting deadline this may improve preparers ability to participate, but this is unlikely to be known until after the IASB July board meeting.

International stakeholders

31We are already in touch with the IASB's project team and have plans in place to record a joint series of educational videos on the ED, which will be hosted on the UKEB website.

32EFRAG issued its draft comment letter on the IASB's ED on 11 May 2021 and has a comment deadline of 15 October 2021. The Australian Accounting Standards Board (AASB) issued its draft comment letter in April 2021 and has a comment deadline of 16 August 2021. We plan to reach out to the both project teams to understand their key areas of concern. We also aim to reach out to the staff of the Accounting Standards Board of Canada (AcSB) and as we understand from previous conversations that the proposals in the ED are of particular interest to them. This outreach should help us obtain further insight into those jurisdictions' views of the requirements proposed in the ED and whether there are overlaps with UK views.

33Outreach work is planned to occur between June and late September.

Project closure

34Consistent with the proposals in the draft Due Process Handbook, the Feedback statement should be approved by the board at the same time as the comment letter.

Project timeline

35The proposed high-level project timeline is as follows:

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Appendix 2: Invitation to Comment: Exposure Draft ED/2021/3 Disclosure Requirements in IFRS Standards – A Pilot Approach (Proposed Amendments to IFRS13 and IAS 19).

Dr. Andreas Barckow Chairman International Accounting Standards Board 7 Westferry Circus Canary Wharf London E14 4HD

[Date]

Dear Dr Barckow

Invitation to Comment: Exposure Draft ED/2021/3 Disclosure Requirements in IFRS Standards – A Pilot Approach (Proposed Amendments to IFRS13 and IAS 19).

The UK Endorsement Board (UKEB) is responsible for endorsement and adoption of IFRS for use in the UK and therefore is the UK's National Standard Setter for IFRS. The UKEB also leads the UK's engagement with the IFRS Foundation (Foundation) on the development of new standards, amendments and interpretations. This letter is intended to contribute to the Foundation's due process. The views expressed by the UKEB in this letter are separate from, and will not necessarily affect the conclusions in, any endorsement and adoption assessment on new or amended International Accounting Standards undertaken by the UKEB.

We welcome the opportunity to contribute to the debate on disclosure in financial statements. Our work has included in-house research and some initial outreach at our stakeholders' roundtables. Our work on these matters continues and will inform our final comment letter. Our high-level comments from our initial work is as follows:

1We support IASB in its ongoing efforts to make financial statement disclosure more useful and effective. We see merit in the principles-based approach to disclosure described in the Exposure Draft (“ED”) that uses objectives to replace lists of mandatory disclosure.

2However, initial consultation with stakeholders has identified concerns about the practical application of the ED's proposals, including issues of comparability, the impact on digital financial reporting, the application of judgement and issues of audit and enforceability. More information on these issues can be found in appendix 1.

3We do not support the proposed amendments to IFRS 13. We note that both the Post Implementation Review (PIR) and stakeholders consulted by IASB during this project confirmed that the fair value measurement disclosures generally contain information which meets the needs of users. Given the significant amount of change and consultation in recent months we cannot support significant amendments to a disclosure regime that stakeholders say is working adequately. This is discussed further at paragraph A19 of appendix 1.

4Furthermore, we have reservations about supporting amendments to either IFRS 13 or IAS 19 without first understanding whether the Guidance described in the ED will be adopted and applied to other IASB projects. If the methodology is not used elsewhere, it will lead to inconsistent principles for disclosures being applied within IFRS.

If you have any questions about this response please contact the project team at [email protected]

Yours sincerely

Pauline Wallace Chair UK Endorsement Board

The proposed Guidance

Overall and Specific Disclosure Objectives and the Disclosure Problem

A1We support IASB in its ongoing efforts to make financial statement disclosure more effective and useful. We see merit in the principles-based approach to disclosure described in the Exposure Draft (“ED”) that uses objectives to replace lists of mandatory disclosure. We can see that well defined objectives, both general objectives addressing the standard in its entirety, and specific objectives to address specific areas of the standard can be helpful in explaining the need for the information, which will assist companies in applying judgement to disclosure.

A2We particularly welcome the inclusion in the specific objectives of a statement describing users' expected use of the disclosed information. This provides valuable information to assist preparers, auditors and regulators in applying judgement as to what should be included and excluded from the disclosure process. These ideas support IASB's objective to ensure financial statements contain more relevant information and reduce irrelevant information.

Describing Items of Information to promote the use of judgement

A3We find the drafting throughout the ED to be sufficiently clear in its use of prescriptive and non-prescriptive language to be able to differentiate between mandatory and non-mandatory requirements. It is also clear that judgement should be applied to meet the objectives.

Other Comments on the Proposed Guidance

A4Paragraphs BC27-BC56 discuss the proposed process to develop specific disclosure objectives based on understanding users' needs. However the scope of the project is restricted to primary users (BC Table 4) and the list of parties to be consulted appears to consist primarily of investors (paragraph BC36). The term “investor” is also used instead of "user" in many of the IASB supporting materials to this project. We believe this creates the risk that objectives may not meet the needs of primary users as defined in the Conceptual Framework, which are existing and potential investors, lenders and other creditors.. We recommend that the needs of other primary users such as lenders and other creditors are explicitly scoped into the Guidance as groups to be consulted during the development of new disclosures. We further note that user needs may change over time and we suggest the Guidance include a mechanism to periodically consider this and make necessary adjustments.

A5One further consideration for the proposed process to develop specific disclosures is co-ordination with the proposed International Sustainability Standards Board (ISSB), as its activities develop. Whilst the exact nature of the financial statement disclosures that may underpin the ISSB's standards will not become certain for some time, it is important that IASB builds in sufficient flexibility during the development of this project to accommodate any overlaps that arise later down the line.

A6An important important consideration is whether the proposed Guidance is to be adopted for other future or existing standards. For example, if IASB following feedback from this consultation decide not to proceed with the proposed Guidance for other standard setting purposes, we would not support IFRS 13 or IAS 19 being changed in line with these proposals. If the methodology is not used elsewhere, it will lead to inconsistent principles for disclosures being applied within IFRS.

A7We are concerned that the potential amendments to IFRS 13 and IAS 19 are presented as an exposure draft and could proceed to finalisation after this consultation. We do not agree that sufficient rationale has been presented to justify the proposed changes to IFRS 13. This is discussed further at A19 below. By bundling the proposed guidance (future impact) and proposed changes to IFRS 13 and IAS 19 (immediate impact) into a single exposure draft, labelled as a “pilot approach” we question whether stakeholders have sufficient awareness of the significance and immediacy of the changes arising from the IFRS 13 and IAS 19 proposals. We recommend that when the consultation closes IASB consider the degree of stakeholder feedback on the specific detail of the IFRS 13 and IAS 19 proposals to determine whether these proposals would benefit from re-exposure prior to finalisation.

Increased Application of Judgement

A8We have a number of practical concerns regarding the proposals. If the objectives of the project are to be achieved it is important that the proposals will work in practice and be effective in bringing about change. We highlight these concerns below, and are seeking feedback from stakeholders as to their likely impact on the Disclosure Pilot and its objectives.

Comparability

A9Initial outreach with users indicates support for the proposals as they believe the benefits of more relevant disclosure outweigh the potential comparability issues arising from disclosures that are highly tailored to company circumstances or that may changes year-on-year as company circumstances change. They expect teething problems when companies first implement the new approach, but they expect that a commonality of practice will emerge within industries. They note that identifying the correct list of mandatory items will be important, and we recommend IASB consider this when assessing the results of field testing. We will continue to seek feedback from users during the consultation period to ensure users are willing to accept potentially decreased comparability in financial statement disclosure.

Digital Financial Reporting

Taxonomy

A10Stakeholder feedback suggests the current taxonomy can be challenging to apply with gaps and subjective judgements required to tag financial statements. There is a danger that this current situation is further exacerbated in an environment where disclosures are less consistent. We recommend IASB's field testing considers the implications for the new proposals and whether any solutions can be found to help mitigate the risks identified by our stakeholders above

Other Digital Reporting Matters

A11While BC48-49 acknowledge that the project team has worked with the taxonomy team on matters such as application challenges and tagging, the ED does not address the relationship between the proposed disclosure changes and the IASB's future vision for digital reporting and data use. The UKEB draft comment letter on the IASB's agenda consultation recommends IASB allocate more resource to digital reporting as it is anticipated that digital consumption of financial information will become more prevalent. We recommend that IASB explain clearly how the proposed disclosure changes align to their digital strategy prior to introducing change to the disclosure regime. This should also be incorporated into the proposed Guidance as a criteria for the future design and drafting of disclosure.

Application of judgement

A12Companies are already required to apply judgement and disclose all material information in financial statements under IAS 1 and yet the checklist approach persists. While the objectives approach provides further information to assist preparers and auditors in applying the necessary judgement, the risk remains that preparers with sufficient resources continue to present judgement-based disclosure while those lacking resource prefer to create a new checklist, possibly using the optional Items of Information as a basis to do so. We encourage the IASB to ensure companies with different size characteristics are included in the field tests.

A13In addition, preparers will face challenges under the proposed regime in providing sufficient rationale to auditors, Boards and Audit Committees on the judgements they make about information included or excluded from the disclosures under the new regime. However, the additional information on user needs and the use of objective may assist "middle ground” preparers transition to applying a more judgement-based approach. An additional way of nudging companies to avoid the checklist approach may be to present the Items of Information in a visual format which does not resemble a checklist.

A14We intend to seek further feedback from stakeholders during the consultation period on these matters.

Audit and enforceability

A15Providing clear objectives and information about how users expect to use the information is likely to enhance the ability to make good audit judgements.

A16Auditors may, however, experience similar challenges to those described for preparers at A12 and A13 above. Initial outreach with the audit community suggests these proposals are seen as conceptually a step in the right direction, but that application may be challenging, given the safety provided by a checklist approach. We recommend that audit firms are included in the proposed field tests of IFRS 13 and IAS 19 so that potential issues for both preparers and their audit firms can be identified and addressed.

A17IASB note in BC 191 that today auditors “ask only whether an entity has provided the specific piece of information the Standard requires" but under the proposals will need to apply judgement not just to the content of the disclosure, but to the "communication effectiveness of information disclosed”. This appears a more complex and time-consuming process. We recommend that a sufficiently long lead time be allowed for any proposed changes to IFRS 13 and IAS 19 arising from this project to allow audit firms to address the resource and skills consequences of such a change.

A18Regulators are also key to the success of these proposals. Some have suggested that a company's assessment of materiality may need to be disclosed to allow regulators to adequately assess the completeness and effectiveness of reporting. Regulators have told us that ensuring high quality of disclosure with an objectives-based regime is resource intensive. Recent experience working with IAS 1 has shown good results when working with well resourced preparers, auditors and regulatory teams. However, scaling this approach to cover a wider number of standards may exceed available regulatory resources, and add to the regulatory burden of smaller preparers, such as AIM listed companies. This could also impact international comparability as regulatory resources and funding vary by jurisdiction. We recommend IASB work with regulators in different jurisdictions to conduct an impact assessment of the proposals.

The proposed amendments to IFRS 13

A19We do not support the proposed amendments to IFRS 13. We understand that IFRS 13 was chosen for the disclosure pilot as it provided a good example of a standard requiring a high level of materiality judgement. However, we note that the PIR of IFRS 13 concluded that the information required by IFRS 13 is useful to users of financial statements. Further, stakeholders consulted by IASB during this project confirmed that “fair value measurement disclosures applying IFRS 13 generally contain information that meets the needs of users of financial statements”. (BC 59). Given the significant amount of change and consultation in recent months we cannot support significant amendments to a disclosure regime that stakeholders say is working adequately.

A20If IASB chooses to continue to develop these proposals we ask that the following points are considered. Our general comments in paragraphs A1 – A18 also apply to the proposed amendments to IFRS 13.

A21Whilst the proposed changes to IFRS 13 appear workable we encourage IASB to undertake field testing as we believe it is key to identifying any potential issues. Field tests should include examples of both large and small companies.

A22Some disclosure requirements appear to be disproportionate. Paragraphs 118-121 describe proposed disclosures for assets and liabilities measured at amortised cost but for which fair value in disclosed in the notes. Paragraph 121 suggest that, while not mandatory, "a description of the nature, risks and other characteristics of the classes of assets and liabilities.....this information can be provided by cross reference to where that information is disclosed elsewhere in the financial statements.” This final requirement, particularly as it relates to the risks of fair value measurement, is in addition to existing requirements but also appears to be beyond the scope of what is discussed in BC 98-100. We interpret this to mean that, subject to materiality, disclosures of fair value valuation risk for items carried at fair value, and items carried at amortised cost for which fair value is disclosed in the notes should be the same.

A23Providing the same level of detail for fair value measurement risk for amortised cost assets as fair value assets appears disproportionately burdensome as companies are less likely to undertake the same level of fair value risk and sensitivity testing for amortised cost assets as they are for assets recorded at fair value. Smaller organisations with no or few fair value assets may not have the resources to do this. We recommend this requirement be removed, or if this was not IASB's intention that the drafting be clarified to reflect this.

A24The following example illustrates the point. Consider a bank with a large portfolio of vanilla Loans to Customers, which is recorded at amortised cost. Disclosure of the fair value of this portfolio is currently required by paragraph 25 of IFRS7 and would typically include less information about the risk to fair value measurement than that suggested above. Assuming the portfolio is material disclosure under the old/new regime might appear as follows.

Vanilla Loans to Customers – Amortised Cost

* disclosed in some cases

The proposed amendments to IAS 19

A25Our general comments in paragraphs A1 – A18 also apply to the proposed amendments to IAS 19.

A26Our initial analysis suggests these proposals are in line with the new disclosure guidance described in the ED, and appear workable though potentially burdensome. [This is an initial view - stakeholders please see Question 9 in the Invitation to Comment].

A27Due to the large number of UK companies that will be affected by the proposed changes to IAS 19, and the range of benefits covered by this disclosure we believe that field testing with a diverse range of companies will be important to identify any potential issues, and we encourage IASB in their plans to do so.

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