Response 1 - PwC

Paul Lee Chair UK Endorsement Board 6th Floor 10 South Colonnade London E14 4PU

26 January 2026

Dear Paul

I am responding on behalf of PricewaterhouseCoopers LLP to your invitation to comment on the Draft Endorsement Criteria Assessment (DECA) of IFRS 19 Subsidiaries without Public Accountability: Disclosures.

We continue to support globally consistent standards and encourage endorsement of international accounting standards, without any regional modifications and carve-outs where possible.

Overall, we support the endorsement of IFRS 19. However, we have raised to the UKEB and the FRC the interaction of IFRS 19 with section 407 of the Companies Act in the past and continue to think this is something that should be explored. Section 407 does not allow a UK subsidiary to apply a different GAAP to the parent's individual accounts unless there are 'good reasons' to do so, or the parent uses IFRS in both its consolidated and individual accounts. This will potentially restrict the availability of IFRS 19 for UK subsidiaries of a UK parent that reports under FRS 101, compared to it being available for UK subsidiaries of an overseas parent, unless that parent can demonstrate there are 'good reasons' for reporting in that way. Similarly, it will also prevent the parent from using FRS 101 in its individual accounts if it wanted to use IFRS 19 in its UK subsidiaries.

While we do not consider this a reason to withhold UK endorsement of IFRS 19, it is disappointing that the issue was not explored in the DECA, including that 'good reasons' for using different frameworks might exist. Alternatively, the FRC could add a further 'interpretation' to FRS 100, explaining that IFRS 19 can be applied by a UK subsidiary if a UK parent applies FRS 101 because there are good reasons for doing so. The 'good reasons' could be that the legislators did not know about IFRS 19 when section 407 was written, because it is de-regulatory and because it removes discrimination against being a UK parent. Adding such an 'interpretation' would remove the need and cost of UK groups having to perform their own analysis.

Nevertheless, we support the adoption of the IFRS 19 Subsidiaries without Public Accountability: Disclosures, as proposed in the DECA. Our responses to the questions in the Invitation to Comment are 'yes'.

If you have any questions in relation to this letter please do not hesitate to contact me.

Yours sincerely

Head of UK Corporate Reporting Services PricewaterhouseCoopers LLP

PricewaterhouseCoopers LLP, 1 Embankment Place, London WC2N 6RH T: +44 (0) 20 7583 5000, F: +44 (0)20 7822 4652, www.pwc.co.uk PricewaterhouseCoopers LLP is a limited liability partnership registered in England with registered number OC303525. The registered office of PricewaterhouseCoopers LLP is 1 Embankment Place, London WC2N 6RH. PricewaterhouseCoopers LLP is authorised and regulated by the Financial Conduct Authority for designated investment business.