Due Process Compliance Statement - Post-Implementation Review of IFRS 16 Leases

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Publication date
30 October 2025
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The International Accounting Standards Board (IASB) published its Request for Information (RFI) for the Post-implementation Review (PIR) of IFRS 16 Leases1 on 17 June 2025. The IASB comment period ended on 15 October 2025.

Influencing process

Project preparation

Step Mandatory / optional2 Metrics or evidence UKEB Secretariat comments
Added to UKEB technical work plan [Due Process Handbook (Handbook) 4.30] Mandatory Project included in the UKEB published technical work plan Complete: The PIR of IFRS 16 Leases was included in the UKEB technical work plan published in October 2024 as active monitoring and as an active influencing project from June 2025.
Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, A1 to A2 and A12 to A14] Mandatory Project initiation plan (PIP) draft with project outline (background, scope, project objective) and approach for influencing (key milestones and timing) Complete: The Secretariat included mandatory milestones for the project and considered, as appropriate, other milestones and activities. The PIP was approved at the 26 June 2025 Board meeting.
Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, A1 to A2 and A12 to A14] Mandatory Outreach plan for stakeholders and communication approach outlined Complete: The PIP (referred to above) included the outreach plan and approach.
Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, A1 to A2 and A12 to A14] Mandatory Resources allocated Complete: One project director supported and overseen by one senior project director, with communications and economics team support.
Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, A1 to A2 and A12 to A14] Mandatory Assessment of whether to set up an ad-hoc advisory group Complete: Taking a proportionate approach, an ad-hoc advisory group was not considered necessary due to the limited scope nature of the project.
Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, A1 to A2 and A12 to A14] Mandatory Assessment of whether PIP required updating Complete: We monitored this throughout the project, the nature and scope of which remained as proposed in the original PIP.
Project Initiation Plan (PIP) [Handbook 5.4 to 5.8, A1 to A2 and A12 to A14] Mandatory UKEB Board public meeting held to approve PIP Complete: The PIP was approved at the 26 June 2025 Board meeting.
Education sessions [Handbook 4.10] Optional Board provided with education sessions Complete: The Board was provided with an education session on 24 June 2025.

Desk-based research

Step Mandatory / optional2 Metrics or evidence UKEB Secretariat comments
Desk-based research [Handbook 5.9 and A3] Optional Review of relevant documentation Complete: The Secretariat has reviewed:
  • the IASB's work on the PIR;
  • other standard-setters' views; and
  • accounting manuals and press releases for guidance and illustrative examples.

Outreach

Draft Comment Letter (DCL)

Step Mandatory / optional2 Metrics or evidence UKEB Secretariat comments
Outreach activities [Handbook 5.10 to 5.12 and A4 to A8] Mandatory Evidence of consultation Complete: Due to the limited scope nature of the project, consultation activities were focused consultation with advisory groups and on obtaining responses to the Draft Comment Letter (DCL). The UKEB received two comment letters. One comment letter received was published on the UKEB website while the other one was not published as the stakeholder requested that the letter was not made publicly available. However, it was made available to UKEB members.
DCL published for comment (mandatory unless impracticable) [Handbook paragraphs 5.13 to 5.17 and A4(d)] Mandatory Comment period set for responses to DCL Complete: The DCL was published for consultation for 45 days on 25 July 2025 (comment period deadline: 8 September 2025).
DCL published for comment (mandatory unless impracticable) [Handbook paragraphs 5.13 to 5.17 and A4(d)] Mandatory Review and approval at a UKEB public meeting Complete: The DCL was reviewed and approved at the Board meeting on 26 June 2025 subject to revision after the meeting. The revision was approved by the Chair.

Project finalisation and project closure

Step Mandatory / optional2 Metrics or evidence UKEB Secretariat comments
Final Comment Letter (FCL) [Handbook paragraph 5.18 and A4(d)] Mandatory Public responses to DCL considered and published on website Complete: The UKEB received two comment letters one of which was published on the UKEB website while one letter was not published as the stakeholder requested that the letter was not made publicly available. However, the letter was made available to UKEB members. All responses were assessed, reflected as appropriate in the FCL and summarised in the Feedback Statement.
Final Comment Letter (FCL) [Handbook paragraph 5.18 and A4(d)] Mandatory FCL approved by the UKEB in public meeting Complete: The FCL was presented to the Board for approval on 25 September 2025. The Board approved the FCL subject to suggested amendments. The revision was approved by the Chair.
Final Comment Letter (FCL) [Handbook paragraph 5.18 and A4(d)] Mandatory FCL submitted to the IASB and posted on UKEB website Complete: The FCL was submitted to the IASB and posted on the UKEB website on 15 October 2025.
Feedback Statement [Handbook 5.19 to 5.22 and A9 to A11] Mandatory Feedback Statement approved for publication by the UKEB in a public meeting Complete: A draft of the Feedback Statement was presented for approval to the Board at its 25 September 2025 public meeting. The Board approved the draft Feedback Statement, subject to editorial changes.
Feedback Statement [Handbook 5.19 to 5.22 and A9 to A11] Mandatory Feedback Statement published on the UKEB website Complete: The final Feedback Statement was published on the UKEB website on 15 October 2025.
Due Process Compliance Statement (DPCS) [Handbook 5.23 to 5.26 and A12 to A14] Mandatory DPCS approved by the UKEB in public meeting Complete: A draft DPCS was presented for approval to the Board at its 25 September 2025 public meeting.
Due Process Compliance Statement (DPCS) [Handbook 5.23 to 5.26 and A12 to A14] Mandatory DPCS published on the UKEB website Complete: The final DPCS was presented for noting at the Board's 30 October 2025 meeting. Completed: The final DPCS was published on the UKEB website after the 30 October 2025 Board meeting.

Ongoing communications

Step Mandatory / optional2 Metrics or evidence UKEB Secretariat comments
Public Board meetings [Handbook 4.10] Mandatory UKEB public meetings held to discuss technical project The Board received an overview of the project in June 2025. The Board approved the PIP at its meeting on 26 June 2025, DCL at its meeting on 15 July 2025 and FCL at its meeting on 25 September 2025.
Secretariat papers [Handbook 4.20] Mandatory Board meeting papers posted and publicly available usually no later than 5 working days before a Board meeting. The UKEB's meeting papers were published on the UKEB website 5 working days before the public meetings. Meeting minutes and recordings were made publicly available via the UKEB website.
Project webpage [Handbook 4.25(b)] Mandatory Project webpage contains a project description with up-to-date information on the project. Complete: The project webpage has been updated regularly on a timely basis.
Subscriber Alerts [Handbook 4.24] Optional Evidence that subscriber alerts have occurred Complete: Subscribers were alerted via email 5 days before each Board meeting, with links to the agenda, papers and the option to dial in to observe the discussion.
News Alerts [Handbook 4.24] Optional News Alert to announce publication of key documents Complete: News Alerts and LinkedIn posts calling for comments were published on the following dates:
  • 25 July 2025 (both)
  • 25 July 2025 (both)
  • 3 September 2025 (News Alert)
  • 4 September 2025 (LinkedIn post)
A News Alert announcing publication of the Feedback Statement was published on 16 October 2025.

Conclusion

This project complies with the applicable due process steps, as set out in the December 2022 Handbook.


Footnotes


  1. IASB Request for Information on the Post-implementation Review of IFRS 16 Leases. ↩

  2. In accordance with the Due Process Handbook. ↩↩↩↩↩