Response 2 - Grant Thornton UK LLP

Commercial in Confidence

Paul Lee Chair UK Endorsement Board Submitted via email: [email protected]

Grant Thornton UK LLP 8 Finsbury Circus London EC2M 7EA T +44 (0)20 7383 5100

12 February 2026

Dear Paul

Response to Invitation to Comment on the Draft Endorsement Criteria Assessment of IFRS 19 Subsidiaries without Public Accountability: Disclosures

Grant Thornton UK LLP welcomes the opportunity to respond to the UK Endorsement Board's invitation to comment on the Draft Endorsement Criteria Assessment of IFRS 19 Subsidiaries without Public Accountability: Disclosures.

Grant Thornton is one of the world's leading organisations of independent assurance, tax and advisory firms. We are an adviser that delivers technical expertise and a personal, proactive and agile service that goes beyond. Grant Thornton UK LLP is part of a global network that employs 76,000 people in over 150 countries.

We advocate a single set of globally consistent financial reporting standards. Therefore, we are in full agreement with the endorsement of IFRS 19 Subsidiaries without Public Accountability: Disclosures. Our detailed responses to the invitation to comment are attached.

Yours sincerely

12/2/2026

Partner

Grant Thornton UK LLP is a limited liability partnership registered in England and Wales: No.OC307742. Registered office: 8 Finsbury Circus, London EC2M 7EA. A list of members is available from our registered office. Grant Thornton UK LLP is authorised and regulated by the Financial Conduct Authority. Grant Thornton UK LLP is a member firm of Grant Thornton International Ltd (GTIL). GTIL and the member firms are not a worldwide partnership. Services are delivered by the member firms. GTIL and its member firms are not agents of, and do not obligate, one another and are not liable for one another's acts or omissions. Please see grantthornton.co.uk for further details.

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Deadline for completion of this Invitation to Comment:

Close of business, 26 February 2026

Please submit to: [email protected]

Introduction

The objective of this Invitation to Comment is to obtain input from stakeholders on the endorsement and adoption of IFRS 19 Subsidiaries without Public Accountability: Disclosures, published by the International Accounting Standards Board (IASB) in May 2024¹. IFRS 19 is a new voluntary reduced disclosure standard. It has an effective date of 1 January 2027 with earlier application permitted (subject to the UKEB's adoption for use in the UK). The information collected from this Invitation to Comment is intended to help with the endorsement assessment.

UK endorsement and adoption process

The requirements for UK adoption are set out in Statutory Instrument 2019/685².

The powers to formally adopt international accounting standards for use in the UK were delegated to the UK Endorsement Board in May 2021³.

Who should respond to this Invitation to Comment?

Stakeholders with an interest in the quality of accounts prepared in accordance with IFRS Accounting 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 26 February 2026.

Brief responses to individual questions are welcome, as well as comprehensive responses to all questions.

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)⁴.

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.

Assessment against endorsement criteria

Our draft assessment [tentatively] concludes that:

• IFRS 19 meets the criteria of relevance, reliability, understandability and comparability required of the financial information needed for making economic decisions and assessing the stewardship of management, as required by SI 2019/685 (see Regulation 7(1)(c));
• application of IFRS 19 is not contrary to the principle that an entity's accounts must give a true and fair view as required by SI 2019/685 (see Regulation 7(1)(a)); and
• that IFRS 19 is likely to be conducive to the long term public good in the UK, as required by SI 2019/685 (see Regulation 7(1)(b)), having considered:
  • whether it will generally improve the quality of financial reporting;
  • the costs and benefits that are likely to result from its use; and
  • whether it is likely to have an adverse effect on the economy of the UK, including on economic growth.

Our draft assessment also concludes that IFRS 19 is not likely to lead to a significant change in accounting practice and, therefore, does not meet the criteria for a post-implementation review under Regulation 11 in SI 2019/685.

Our assessment is set out in Sections 2–5 of the [Draft] ECA.

Questions

Technical accounting criteria assessment

1. Do you agree that the technical accounting criteria assessment considers the main key aspects? (please select one option)

2. Please include any comments you may have in response to question 1:

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3. Do you agree with the draft assessment of IFRS 19 against the technical accounting criteria? (please select one option)

4. Please include any comments you may have in response to question 3:

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UK long term public good assessment

5. Do you agree with the initial overall assessment of the costs likely to arise from the implementation of IFRS 19? (please select one option).

6. Please include any comments you may have in response to question 5 including, if applicable, any costs that may have been omitted from the analysis:

Para 3.18 of the Draft Endorsement Criteria Assessment (DECA) cost-benefit analysis section refers to the fact IFRS 19 is a voluntary standard, and therefore suggests that only entities who considered the benefits of adoption to be greater than the costs would apply the standard. However, we note that UK subsidiaries of international groups may be required by the group to prepare accounts under IFRS 19 on the basis of a cost benefit analysis for the group as a whole, rather than based on a cost benefit analysis for the UK subsidiary itself. Nevertheless, given we are not aware of any evidence that there would be a significant number of entities for whom this would be the case, and we understand that this was not raised as a concern in feedback from preparers at the time of writing the DECA, we do not think this should prevent endorsement of the standard. On the basis the standard is voluntary, we would expect the benefits across all UK entities/ groups adopting to outweigh the costs. We note that para 3.49 of the DECA refers to familiarisation costs of entities applying IFRS 19. In addition, there is likely to be a familiarisation cost to UK entities considering adopting IFRS 19 but ultimately determining that the costs do not outweigh the benefits. These preparers will still incur the cost of the time spent analysing the disclosures required by IFRS 19 versus the disclosures required by FRS 101 or FRS 102 (and the measurement differences) in order to understand what the costs and benefits are likely to be. This cost would mainly be incurred at the point IFRS 19 is initially endorsed in the UK but would continue to be a cost for new entities or groups, or entities whose circumstances change. While we do not think this should prevent adoption of IFRS 19, we note that this cost could to some extent be reduced if publicly available educational materials are provided at the point of endorsement of the standard, for example a document giving a line by line comparison between the disclosure requirements of FRS 101 and IFRS 19, and a high level summary of other amendments made to IFRS in FRS 101.

7. Do you agree with the initial overall assessment of the benefits likely to arise from the implementation of IFRS 19? (please select one option).

8. Please include any comments you may have in response to question 7 including, if applicable, any benefits that may have been omitted from the analysis:

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9. Do you agree with the draft assessment that IFRS 19 is likely to be conducive to the long term public good in the UK? (please select one option)

10. Please include any comments you may have in response to question 9 including, if applicable, any economic effects that have been omitted from the analysis:

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11. In our [Draft] ECA, we described a set of users who may use the financial statements of subsidiaries without public accountability. Do you agree that the UKEB has not overlooked any user category that could be substantially affected by the reduced disclosure requirements of IFRS 19? (please select one option).

12. Please include any comments you may have in response to question 11:

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Company Law interaction

13. IFRS 19 provides a definition of “public accountability" to set the scope for a subsidiary's eligibility to voluntarily apply the Standard. The IFRS 19 definition differs from the definitions of “public interest entity” and “public interest company” set out in Part 16 of the Companies Act 2006, which relate to audit. As the definitions in the Act do not relate to reporting under UK-adopted international accounting standards, do you agree that this issue is not relevant to the UKEB's endorsement assessment of IFRS 19? Please see paras 19 – 21 of the [Draft] ECA Executive Summary for further detail.

14. If you disagree, please provide the rationale for your answer to question 13:

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True and fair view assessment

15. Do you agree with the draft assessment that IFRS 19 is not contrary to the true and fair view requirement? (please select one option)

16. Please include any comments you may have in response to question 15:

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Is IFRS 19 likely to lead to a significant change in accounting practice?

17. Do you agree with the tentative assessment in the [Draft] ECA that IFRS 19 is not likely to lead to a significant change in accounting practice? (please select one option):

18. Please provide your rationale for the answer to Question 17—namely, the reasons for concluding whether or not IFRS 19 is likely to lead to a significant change in accounting practice:

IFRS 19 could have a significant impact on certain UK entities choosing to adopt it, depending on the previous regime/accounting standard adopted, and the nature of the entity (for example some entities might see a significant increase in disclosure requirements, changes in measurement requirements, or a new requirement to present a cashflow statement). However, given IFRS 19 does not change IFRS recognition and measurement or presentation principles, and only removes disclosure requirements, it does not introduce requirements that are new to the UK financial reporting regime as a whole, as it removes disclosures from IFRS rather than modifying or adding to requirements. As noted in the DECA, this is a voluntary standard which will be available only to a subset of UK entities and is not expected to have widespread use in the UK given the existence of FRS 101 (and FRS 102). We therefore agree that it does not meet the criteria of leading to a significant change in accounting practice.

Other comments

19. Do you have any other comments on the [Draft] ECA you would like to add?

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Response generation

20. Did you/your organisation use a large language model (e.g. Chat GPT, Microsoft Copilot) to create any part of your/its response (response to this Invitation to Comment or a comment letter you are submitting as part of your response)?

21. If you answered yes to Question 20, please specify which model and what prompt(s) you used for the large language model.

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Thank you for completing this Invitation to Comment

Please submit this document by close of business on 26 February 2026 to: [email protected]

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