8 UKEB Research Consultation

20 November 2025 Agenda Paper 8

Executive Summary

Purpose of the paper

The UKEB will be seeking stakeholder feedback on its research topics for the 2026 / 2027 period which is a component of the UKEB's overall Regulatory Strategy (2025–28). An Invitation to Comment (ITC) will be issued in December 2025.

Summary of the Issue

Feedback from on the UKEB's Regulatory Strategy (2025-2028) highlighted that stakeholders wanted more information on how the UKEB prioritises projects and opportunity to comment on the proactive research projects is chooses.

Decisions for the Board

Recommendation

The Board approve the [Draft] Research Consultation ITC.

Appendices

Appendix A: UKEB Research Consultation – [Draft] Invitation to Comment

Appendix A: UKEB Research Consultation – [Draft] Invitation to Comment

Call for comments: UKEB Research Consultation

Deadline for completion of this Invitation to Comment: Close of business, XXXX Please submit to: [email protected]

UK Endorsement Board

The UK Endorsement Board (UKEB) is responsible for the endorsement and adoption of IFRS for use in the UK and is, therefore, the UK's National Standard Setter for IFRS. The UKEB also leads the UK's engagement with the IFRS Foundation on the development of new accounting standards, amendments and interpretations.

Objectives and context

The UKEB is seeking stakeholder feedback on its research topics for 2026/2027 period as a component of the UKEB's overall Regulatory Strategy (2025-28)¹.

Who should respond to this Invitation to Comment?

Stakeholders with an interest in the quality of accounts prepared in accordance with IFRS Standards.

How to respond to this Invitation to Comment

Please download this document, answer any questions on which you would like to provide views, and return it to [email protected] by close of business on XXXX.

Your details

Name: Click or tap here to enter text. Email address: Click or tap here to enter text.

Are you responding:

If responding on behalf of an organisation,

Name of organisation: Click or tap here to enter text.

Please select what best describes you:

If your response was ‘Other', please describe: Click or tap here to enter text.

Is your organisation a listed entity?

Would you be content for UKEB to contact you by email if we wished to discuss some of your responses?

Use of Large Language Models.

Privacy and other policies

The data collected through submitting this document will be stored and processed by the UKEB. By submitting this document, you consent to the UKEB processing your data for the purposes of influencing the development of and adopting IFRS for use in the UK. For further information, please see our Privacy Statements and Notices and other Policies (e.g. Consultation Responses Policy and Data Protection Policy)².

The UKEB's policy is to publish on its website all responses to formal consultations issued by the UKEB unless the respondent explicitly requests otherwise. A standard confidentiality statement in an e-mail message will not be regarded as a request for non-disclosure. If you do not wish your signature to be published, please provide the UKEB with an unsigned version of your submission. The UKEB prefers to publish responses that do not include a personal signature. Other than the name of the organisation/individual responding, information contained in the “Your Details” document will not be published. The UKEB does not edit personal information (such as telephone numbers, postal or e-mail addresses) from any other response document submitted; therefore, only information that you wish to be published should be submitted in such responses.

Research topics

For background and context for the research topics one to three below, please refer to the Annex of this document.

Question One: Accounting for Intangible Assets

Do you agree with the proposed approach of the UKEB:

• continuing to develop an understanding of what information is most useful for stakeholders;
• developing a principle-based framework; and
• considering potential connectivity issues with IFRS S2 Climate-related Disclosures?

Please provide an explanation for your response and as well as any alternative suggestions.

Question Two: Carbon and Other Environmental Credits

Do you agree with the proposed approach of the UKEB:

• documenting the current schemes, disclosures and approaches adopted in the UK;
• considering potential principles-based accounting treatments; and
• assessing any potential connectivity implications for the financial statements from IFRS S2 Climate-related Disclosures?

Please provide an explanation for your response and as well as any alternative suggestions.

Question Three: Fundamental issues or gaps with IFRS

Are there IFRS Accounting Standards that need to be developed or require fundamental revisions to ensure they continue to remain relevant in the contemporary business environment? Can you suggest a principle-based approach to address the issues you have identified?

Please provide an explanation for your response and any principles-based approaches that could address them.

Question Four: relative priority of research topics

Please indicate your view of the priority of research topics (1 Highest to 5 Lowest) considering their pervasiveness, feasibility, relevance to the UK and urgency. Please also add any alternative topics in the response box below the table.

Please provide an explanation for your ranking and a detailed description of any alternative topics.

Question Five: Any Other Comments

The UKEB welcomes any other feedback on this overall consultation.

Annex: Context and background for research topics

Context

1Research supports the UKEB's influencing and adoption activities and help to fulfil the Board's thought leadership guiding principle.

2The research will have a problem-solving orientation relating to current issues with international accounting standards as well as ad hoc research. Ad hoc research may relate to topics such as cost of capital, the UKEB's Post Implementation Review (PIR) of IFRS 17 Insurance Contracts or further work related to Rate-regulated activities.

3At the Accounting Standards Advisory Forum (ASAF) meeting in October 2025, the IASB Chair noted that, in addition to the two projects currently on the IASB project reserve list (Pollutant Pricing Mechanisms and Operating Segments), the IASB had become aware that Hyperinflation and Cryptocurrencies were also urgent and high priority topics for some stakeholders. These four topics are likely to be of interest to the IASB in the near to medium term.

4As part of the IASB's Third Agenda Consultation the UKEB conducted outreach on Operating Segments and Hyperinflation. It was concluded³ that UK stakeholders considered Operating Segments to be a low priority. They also considered that Hyperinflation was neither prevalent nor acute for UK IFRS reporters (even those with subsidiaries in inflationary economies).

5The UKEB considers that Pollutant Pricing Mechanisms (PPMs) and Intangible Assets (including Cryptocurrencies) will be of most relevance to UK stakeholders in the near to medium term.

6The UKEB has capacity to focus on two major research projects in addition to ad-hoc research requirements. Given its limited resources and the potential relevance to UK listed companies, the UKEB has decided not to undertake proactive research on either Operating Segments or Hyperinflation, at this time.

Background for research topics

Accounting for Intangible Assets (Question 1 above)

7The IASB is currently in the research phase of an Accounting for Intangibles project and has indicated that it will undertake research through the remainder of 2025 and finalise the project direction in 2026. The UKEB sees an opportunity to support this work and encourage the IASB to develop a principles-based approach to accounting for intangible assets.

8Intangible assets are a significant part of the UK economy and will play an important role in future economic growth. Appropriate accounting plays key role in providing decision useful information about these items to users of financial statements.

9In anticipation, the UKEB initiated its own research project focused on understanding UK stakeholders' views and gathering evidence about the UK intangibles landscape⁴,⁵,⁶.

10In the 2026/27 timeframe the UKEB could continue to build on its intangibles research, including the case study-based research carried out in 2025/26. The research could build on the findings from engaging stakeholders on the intangibles case studies.

11The research could also identify potential interactions with IFRS S2 Climate-related Disclosures (IFRS S2) in relation to climate-related opportunities and elements of relevant ISSB research projects could also be explored with stakeholders.

12This work would provide the UKEB with a body of evidence to support its engagement with, and influencing of, the IASB with their intangibles research and highlight opportunities to embed principle-based solutions in future international standard setting.

13To complement the current UKEB case study-based research the UKEB could:

a) Continue to develop a detailed understanding of what information is most useful through engagement with UK stakeholders, including users of financial information.

b) Develop a conceptual, principle-based framework to support standard-based solutions to address current accounting challenges with intangible assets.

Carbon and Other Environmental Credits (Question 2 above)

14In response to feedback on the IASB's Third Agenda Consultation, the IASB added a Pollutant Pricing Mechanisms (PPM) project to their reserve list. Since then, the prevalence of these schemes and the diversity in practice in accounting for them has increased.

15The IASB met in January 2025⁷ to discuss whether to promote a project on PPMs from its reserve list to its Workplan. The IASB decided to defer the decision until the Fourth Agenda Consultation, which has since been deferred by a year.

16The UKEB's engagement with this project to date has been limited but included participation in an IASB PPM survey in March 2024⁸. The UKEB provided the IASB with a summary view of the type of schemes, examples of financial statement disclosures and the range of accounting treatments used in the UK and encouraged the IASB to activate the project.

17PPMs or Carbon and Other Environmental Credits are expected to play an important role in managing UK listed companies' efforts to address climate change and the transition to a net zero economy. Appropriate accounting plays key role in providing decision useful information about these items to users of financial statements.

18In anticipation of the IASB activating a project on PPMs and given the deferral of starting the IASB's Fourth Agenda Consultation, the UKEB could undertake descriptive research, focusing on identifying the extent and nature of Carbon and Other Environmental Credits utilised by UK listed companies, and the different accounting treatments adopted.

19The research could also explore with stakeholders' potential connections with the financial statements in relation to disclosures required under IFRS S2 in relation to carbon credits.

20This work would provide an evidence base to support future Board discussions. Even if the IASB does not undertake a standalone project, the evidence gathered would be likely to be relevant to future discussions on intangible assets and provisions.

21To complement the IASB considerations the UKEB could:

a) Document the range of environmental credit schemes in the UK, the extent and nature of financial statement disclosures and the range of accounting treatments adopted in listed entities.

b) Consider potential principles-based accounting treatments for environmental credits.

c) Assess any potential connectivity implications on the financial statements from carbon credit disclosure requirements in IFRS S2 Climate-related Disclosures.

Fundamental gaps or issues in IFRS Accounting Standards (Question 3 above)

22UKEB discussions in June 2025⁹ on its approach to the IASB's Fourth Agenda Consultation noted an opportunity to take a wide view across the IFRS Accounting Standards to identify any current or emerging significant issues that are not addressed or inadequately addressed. This project would be an opportunity to consider principle-based, as opposed to narrow-scope, solutions to these challenges.

23Are there IFRS Accounting Standards that need to be developed or require fundamental revisions to ensure they continue to remain relevant in the contemporary business environment? Can you suggest a principle-based approach to address the issues you have identified?

Thank you for completing this Invitation to Comment

Please submit this document by close of business on XXX to: [email protected]

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