ECA - Amendments to the Classification and Measurement of Financial Instruments

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``` UK End Endorsement Board

March 2025

The UKEB does not accept any liability to any party for any loss, damage or costs howsoever arising, whether directly or indirectly, whether in contract, tort or otherwise from any action or decision taken (or not taken) as a result of any person relying on or otherwise using this document or arising from any omission from it.

© 2025 All Rights Reserved

Introduction

Purpose

1The purpose of this Endorsement Criteria Assessment (ECA) is to determine whether the Amendments to IFRS 9 and IFRS 7–Amendments to the Classification and Measurement of Financial Instruments (the Amendments) issued by the International Accounting Standards Board (IASB) in May 2024 meet the UK's statutory requirements for adoption as set out in Regulation 7 of Statutory Instrument 2019/685[^1] (SI 2019/685).

2The Amendments have an effective date of 1 January 2026 with earlier application permitted.

3The UKEB actively influenced the development of the Amendments. This included submitting a Final Comment Letter on 19 July 2023[^2] in response to the IASB's Exposure Draft Amendments to the Classification and Measurement of Financial Instruments—Proposed amendments to IFRS 9 and IFRS 7[^3].

Background to the Amendments

4Section 2 in this ECA provides a brief description of the Amendments.

Scope of the adoption assessment

5The Amendments make changes to the mandatory parts of IFRS 9 Financial Instruments and IFRS 7 Financial Instruments: Disclosures. These changes to the mandatory parts of the standards form part of the UKEB's adoption assessment.

6UK-adopted international accounting standards comprise only the mandatory[^4] sections of standards[^5]. The amendments to the Implementation Guidance of IFRS 7, and to the Bases for Conclusions of IFRS 9 and IFRS 7 are not adopted by the Board and are not considered in this ECA.

7The Amendments include an amendment to IFRS 19 Subsidiaries without Public Accountability: Disclosures which will be considered for adoption at a future date as part of the UKEB's assessment work for the adoption of IFRS 19 as a whole. Accordingly, the amendments to IFRS 19 have not been considered as part of this adoption.

8If IFRS 19 is endorsed for use in the UK the effective date will be set out in the relevant adoption statement.

Structure of the assessment

9The UKEB's analysis is presented in the following sections:

  1. Section 1: describes UK statutory requirements for adoption of new or amended international accounting standards; and
  2. Section 2: discusses how the Amendments meet the criteria in Section 1.

Do the Amendments lead to a significant change in accounting practice?

10A standard adopted by the UKEB under Regulation 6 of SI 2019/685 that it considers is likely to lead to a 'significant change in accounting practice', is subject to the requirements in paragraph 3 of Regulation 11 of SI 2019/685 that the UKEB:

  1. carry out a review of the impact of the adoption of the standard; and
  2. publish a report setting out the conclusions of the review no later than 5 years after the date on which the standard takes effect (being the first day of the first financial year in respect of which it must be used)".

11Section 2 of the ECA discusses whether the Amendments lead to a significant change in accounting practice and concludes that they do not.

Section 1: UK statutory requirements for adoption

UK statutory requirements

1.1Paragraph 1 of Regulation 7 of SI 2019/685 requires that an international accounting standard only be adopted if:

  1. the standard is not contrary to either of the following principles—
    1. an undertaking's accounts must give a true and fair view of the undertaking's assets, liabilities, financial position and profit or loss;
    2. consolidated accounts must give a true and fair view of the assets, liabilities, financial position and profit or loss of the undertakings included in the accounts taken as a whole, so far as concerns members of the undertaking;
  2. the use of the standard is likely to be conducive to the long term public good in the United Kingdom; and
  3. the standard meets the criteria of understandability, relevance, reliability and comparability required of the financial information needed for making economic decisions and assessing the stewardship of management."

1.2This ECA assesses the criteria above in the following order:

  1. Whether the Amendments meet the criteria of relevance, reliability, understandability and comparability required of the financial information needed for making economic decisions and assessing the stewardship of management (Regulation 7(1)(c)).
  2. Whether the Amendments are not contrary to the principle that an entity's accounts must give a true and fair view (Regulation 7(1)(a)).
  3. Whether use of the Amendments is likely to be conducive to the long term public good in the UK (Regulation 7(1)(b)). Regulation 7(2) of SI 2019/685 includes specific areas to consider for this assessment. They are:
    1. whether the Amendments are likely to improve the quality of financial reporting;
    2. the costs and benefits that are likely to result from the use of the Amendments; and

iii. whether the Amendments are likely to have an adverse effect on the economy of the UK, including on economic growth.

Relevance, Reliability, Understandability and Comparability[^6]

1.3Information is relevant if it is capable of making a difference in the decision- making of users[^7] or in their assessment of the stewardship of management. The information may aid predictions of the future, confirm or change evaluations of the past, or both.

1.4Financial information is reliable if, within the bounds of materiality, it:

  1. can be depended on by users to represent faithfully what it either purports to represent or could reasonably be expected to represent;
  2. is complete; and
  3. is free from material error and bias.

1.5Financial information should be readily understandable by users with a reasonable knowledge of business and economic activities and accounting, and a willingness to study the information with reasonable diligence.

1.6Information is comparable if it enables users to identify and understand similarities in, and differences among, items. Information about an entity should be comparable with similar information about other entities and with similar information about the same entity for another period.

1.7In conducting the overall assessment against the technical accounting criteria, the UKEB is required to adopt an absolute, rather than a relative, approach. This means that this assessment is an absolute one against the criteria (do the Amendments provide information that is understandable, relevant, reliable and comparable?) rather than a relative one (do the Amendments provide information that is more understandable, relevant, reliable and comparable than current, or any other, accounting?). When an assessment of any individual aspect or requirement of the Amendments uses comparative language (e.g. 'enhances comparability'), this does not mean that the objective is to reflect a real comparison in relative terms. Instead, the objective is to explain that any individual aspect or requirement of the Amendments has the potential to 'enhance' one or more of the qualitative characteristics. Consideration of whether the Amendments are likely to improve the quality of financial reporting is separate from this assessment and is included within the UK long term public good assessment in Section 2.

True and fair view assessment

1.8As noted above, the first adoption criterion set out in Regulation 7(1) of SI 2019/685 requires that an international accounting standard can be adopted only if:

"[....] the standard is not contrary to either of the following principles—

an undertaking's accounts must give a true and fair view of the undertaking's assets, liabilities, financial position and profit or loss;

consolidated accounts must give a true and fair view of the assets, liabilities, financial position and profit or loss of the undertakings included in the accounts taken as a whole, so far as concerns members of the undertaking; [....]”

1.9For the sake of brevity, the UKEB refers to the assessment against this endorsement criterion as 'the true and fair view assessment' and to the principles set out in Regulation 7(1)(a) as the ‘true and fair principle'. However, these abbreviated expressions do not imply that the assessment has considered anything other than the full terms of the endorsement criterion set out above.

1.10The duty of the UKEB under Regulation 7(1)(a) is to determine generically, before a standard is applied to a set of accounts, whether that standard is 'not contrary' to the true and fair principle. In other words, it is an ex-ante assessment. The UKEB has therefore considered whether the Amendments contain any requirement that would prevent accounts prepared using the Amendments from giving a true and fair view.

1.11The approach is to determine whether the Amendments are not contrary to the true and fair principle in respect of any of the specific items identified in Regulation 7(1)(a) (namely, the assets, liabilities, financial position and profit or loss) in the context of the preparation of the accounts as a whole. A holistic approach has been taken to this assessment, considering the impact of the Amendments taken as a whole, including their interaction with other UK-adopted international accounting standards.

1.12For the purposes of the assessment, the UKEB considers the requirement in paragraph 15 of IAS 1 Presentation of Financial Statements for financial statements to 'present fairly the financial position, financial performance and cash flows of an entity' to be equivalent to the Companies Act 2006 requirement for accounts to give a true and fair view.

1.13This assessment is separate from the duty of directors under section 393(1) of the Companies Act 2006, which requires directors to be satisfied that a specific set of accounts gives a true and fair view of an undertaking's or group's assets, liabilities, financial position and profit or loss.

Adoption decision

1.14Section 2 of this ECA discusses how the Amendments meet the statutory endorsement criteria set out in this Section 1.

1.15On the basis of these assessments the UKEB concludes that the Amendments meet the statutory endorsement criteria. The UKEB is therefore of the view that it will adopt the Amendments to IFRS 9 and to IFRS 7 for use in the UK.

2. Section 2: Description and assessment of the Amendments

Title and issue date of final amendments

2.1Amendments to IFRS 9 and IFRS 7—Amendments to the Classification and Measurement of Financial Instruments, issued on 30 May 2024.

Origin

2.2The Amendments were a response to feedback received by the IASB in relation to:

  1. The potential effect on financial liabilities of a Tentative Agenda Decision made by the IFRS Interpretations Committee regarding the treatment of cash received by electronic transfer as settlement for a financial asset.
  2. Certain matters arising from the Post implementation Review of IFRS 9 Classification and Measurement (PIR) including:
    1. Application of the requirements for assessing contractual cash flow characteristics to financial assets with environmental, social and governance (ESG) linked features.
    2. Clarification of the application of the contractual cash flow assessment to contractually linked instruments.
    3. Disclosure of fair value changes for equity instruments presented at fair value in other comprehensive income.

2.3Proposed amendments to address these matters were provided in the Exposure Draft Amendments to the Classification and Measurement of Financial Instruments—Proposed amendments to IFRS 9 and IFRS 7 (the ED). The IASB made changes to the ED proposals in response to stakeholder feedback prior to issuing the final Amendments.

Effective date and transition

2.4The Amendments are effective for annual reporting periods commencing on or after 1 January 2026. Early application is permitted. It is also permitted to apply early only the Amendments to the requirements for the classification of financial assets (and associated disclosures) without applying the other Amendments to the standards.

2.5The Amendments to IFRS 9 are to be applied retrospectively. However, entities are not required to restate prior periods to reflect the application of the Amendments.

Consequential amendments

2.6The Amendments do not give rise to consequential amendments to other standards.

Assessment of the UK statutory requirements for adoption

Technical accounting criteria assessment

2.7For clarity of analysis, the technical accounting criteria assessment of the Amendments will be considered in three sections as follows:

  1. IFRS 9 - Recognition and derecognition.
  2. IFRS 9 - Classification of financial assets.
  3. IFRS 7 - Disclosures.

2.8For the purposes of this analysis the terms relevance, reliability, understandability and comparability are as described in paragraphs 1.3 - 1.6 of this document.

A. Amendments to IFRS 9 – Recognition and derecognition

What has changed?
The new paragraph B3.1.2A provides clarification of the date of initial recognition or derecognition of financial assets and financial liabilities.
Financial assets
The recognition and derecognition criteria for financial assets in paragraph B3.1.2A are consistent with the existing requirements of IFRS 9 paragraphs 3.1.1 and 3.2.3. Including these concepts in the Application Guidance provides additional context and clarity to that guidance. However, as this change reflects the concepts already present in paragraphs 3.1.1 and 3.2.3 this aspect of the Amendments is not considered further in the following analysis.
Financial liabilities
Recognition
Paragraph B3.1.2A states that the entity shall recognise a financial liability on the date on which the entity becomes party to the contractual provisions of the instrument. This is consistent with the existing requirement at IFRS 9 paragraph 3.1.1. Including these concepts in the Application Guidance provides additional context and clarity to that guidance. However, as this change reflects the concepts already present in paragraph 3.1.1 this aspect of the Amendments is not considered further in the following analysis.
Derecognition
Paragraph B3.1.2A provides clarification that the point of derecognition for financial liabilities is the settlement date. It explains that the settlement date is the date on which the liability "is extinguished because the obligation specified in the contract is discharged or cancelled or expires”, or in some other way qualifies for derecognition. This explanation is consistent with the existing requirement in IFRS 9 paragraphs 3.3.1 and 3.3.2, therefore the introduction of the term settlement date acts as a clarification of existing requirements, rather than creating new requirements.
The new paragraphs B3.3.8 – B3.3.10 describe a new alternative to the use of settlement date for the derecognition of financial liabilities settled in cash using an electronic payment system. In such cases the liability may be deemed to be discharged, and hence derecognised, if it meets certain criteria including:
  • the entity issued a payment instruction which resulted in the entity having no practical ability to withdraw, stop or cancel the payment;
  • the entity has no practical ability to access the cash to be used for payment; and
  • the settlement risk of the payment system is insignificant.
If the alternative is used, it shall be applied to all payments made using that payment system.
Relevance and reliability Technical criteria assessment
The clarification that settlement date should be used for the derecognition of financial liabilities is relevant to decisions made by users, as it provides information to allow users to understand the outstanding liabilities and the cash position of the entity.
Derecognising the liability only when it is extinguished creates reliable information as it reflects the underlying economics of the transaction.
The new alternative permits derecognition of liabilities at a different time to the settlement date, for payments made using an electronic payment system that meet certain criteria. This is a practical expedient that acknowledges that electronic payments are typically quicker and have different characteristics than traditional payment methods. For example, when using a payment system with low settlement risk, once the payment instruction is sent and the funds can longer be accessed nor the payment cancelled, the liability can in effect be viewed as discharged. The qualifying criteria in paragraph 3.3.8 act to ensure that derecognition does not take place while the payment is still uncertain. This therefore also results in relevant information that allows users to understand the outstanding liabilities and cash position of the entity.
Understandability Continuing to recognise a financial liability until such time as it is extinguished by being paid, cancelled or it expires aligns with when a user would expect a liability to be extinguished. Hence the clarification that this criterion be used for derecognition helps ensure the presentation of information that is understandable for users.
The criteria for the application of the alternative to settlement date helps clarify the timing of derecognition for liabilities settled using electronic cash payments.
Comparability The clarification highlights that derecognition should take place at settlement date. This clarity will reduce diversity in practice, resulting in greater consistency in financial reporting, and improve its comparability.
However, the Amendments have also introduced an alternative method, with a different point of derecognition when using electronic cash payments which meet certain criteria. This means certain entities could derecognise the liability at different times, depending on whether or not the alternative method is used. Practices could also vary within entities, if some payment systems used qualify for the alternative method while others do not.
The introduction of the alternative might create a risk to consistency, and therefore comparability. However:
  1. fails to meet the criteria for one entity, it should fail for all
entities, mitigating risks of inconsistency.
  • As these requirements affect the accounts only for
  • transactions which take place a few days prior to reporting
    period end, any inconsistency arising from use of the
    alternative may, in many cases, be immaterial.
  • The alternative applies only to financial liabilities. A liability
  • settled via electronic payment may be derecognised prior to the
    cash being received and accounted for by the payee. However,
    within organisations, application of a consistent policy will
    allow for comparability over time.
  • This difference in timing between financial assets and financial
  • liabilities may impact intra-group transactions. However, such
    groups typically have access to the necessary information on
    when the cash was both paid and received, to ensure the
    individual entity and group accounts accurately reflect the
    underlying transaction and that practical challenges on
    consolidation can be overcome. ```