Response 6 - RSM UK

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Paul Lee Chair UK Endorsement Board 8th Floor 125 London Wall London EC2Y 5AS

RSM UK Tax and Accounting Limited 25 Farringdon Street London EC4A 4AB United Kingdom T +44 (0)20 3201 8000 rsmuk.com

Submission by email to: [email protected]

23 February 2026

Dear Paul,

On behalf of RSM, a leading audit, tax and consulting firm to the UK middle market, we are pleased to comment on the UK Endorsement Board (UKEB) Draft Endorsement Criteria Assessment of IFRS 19 Subsidiaries without Public Accountability: Disclosures.

We support the endorsement of IFRS 19 for use in the UK. Endorsement of the standard potentially allows multinational groups to use a consistent reduced-disclosure framework across eligible subsidiaries in different jurisdictions, subject of course to other jurisdictions adopting the standard too, where adoption is necessary. (We note that EFRAG has already submitted its final recommendation to the EC for adoption.)

We would also like to mention that we support the continued availability of FRS 101. For many UK-centric groups, FRS 101 remains the most proportionate option (since it has fewer disclosures and provides exemption from the cash flow statement). We therefore see IFRS 19 as an alternative to, not a replacement for, FRS 101.

We would encourage the final ECA to avoid describing FRS 101 and IFRS 19 as "conceptually similar": they achieve proportionality through very different routes. IFRS 19 is based on the disclosure requirements of the IFRS for SMEs, with some additional disclosures to accommodate the wider scope of IFRS 19, whereas FRS 101 is based on full IFRS disclosures with extensive reductions, and this difference in approach has practical implications for users.

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RSM UK Corporate Finance LLP, RSM UK Legal LLP, RSM UK Restructuring Advisory LLP, RSM UK Risk Assurance Services LLP, RSM UK Risk Assurance Services LLP, RSM UK Audit LLP, RSM UK Consulting LLP and RSM UK Creditor Solutions LLP and RSM UK Creditor Solutions LLP are limited liability partnerships registered in England and Wales, with registered numbers OC325347, OC402439, OC325349, OC389499, OC325348, OC325350, OC397475 and OC390886 respectively. RSM UK Employer Services Limited, RSM UK Tax and Accounting Limited and RSM UK Management Limited are registered in England and Wales with numbers 6463594, 6677561 and 3077999 respectively. All limited companies and limited liability partnerships are registered at 6th Floor, 25 Farringdon Street, London, EC4A 4AB. The UK group of companies and LLPs trading as RSM is a member of the RSM network. RSM is the trading name used by the members of the RSM network. Each member of the RSM network is an independent accounting and consulting firm which practises in its own right. The RSM network is not itself a separate legal entity in any jurisdiction. RSM UK Legal LLP is authorised and regulated by the Solicitors Regulation Authority, reference number 626317.

We would be pleased to respond to any questions the Board or its staff may have about any of our response. If you have any questions or comments, please do not hesitate to contact Danielle Stewart, OBE on [email protected]

Yours faithfully,

RSM UK Tax and Accounting Limited

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Appendix

Technical accounting criteria assessment

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

Yes	No
	X

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

We agree that the exceptions based approach adopted is appropriate and that the UKEB's technical accounting criteria assessment adequately covers the key aspects of IFRS 19, addressing areas where disclosure reductions could have the greatest impact on user decision making.

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

Yes	No
X

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

We agree with the conclusion that IFRS 19 meets the criteria of relevance, reliability, understandability and comparability.

In our view, the disclosure requirements retained in IFRS 19 continue to provide users of eligible subsidiaries' financial statements, for example, parent entities and lenders, with decision-useful information

UK long term public good assessment

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

Yes	No
X

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

We agree that the UKEB's qualitative approach to assessment of implementation costs is appropriate, as preparers report not having started detailed assessment of the impact. We also agree that the voluntary nature of IFRS 19 means that entities are unlikely to apply the Standard unless they assess that the benefits of adopting the standard outweigh the costs.

We also agree that costs will vary depending on the accounting framework previously applied, the degree of centralisation of group reporting, and the geographical spread of the group. The assessment appropriately recognises that one-off transition costs are likely to be more significant for subsidiaries moving from UK GAAP than for those already reporting under IFRS

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

Yes	No
X

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

We agree with the assessment that IFRS 19 offers potential benefits to preparers, particularly groups with international operations. Where full IFRS is currently applied to local accounts of subsidiaries internationally, the benefit of being able to apply the same approach to reduced disclosures everywhere, including in the UK, will inevitably outweigh the extra costs of having to prepare a cash flow statement and extra disclosures in the UK financial statements.

9Do 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)

Yes	No
X

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

We agree that IFRS 19 is likely to be conducive to the long-term public good in the UK. The Standard supports consistency in financial reporting within IFRS groups, and potentially reduces international reporting burdens, as described in response to Q8 above.

Non-endorsement could reduce flexibility for UK subsidiaries of overseas IFRS groups.

11In 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).

Yes	No
X

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

We agree with the UKEB's identification of the primary users of eligible subsidiaries' financial statements. In our experience, lenders, group entities and non-controlling shareholders are the most relevant users, and these users are typically able to request additional information when required. We do not consider that other user groups would be materially disadvantaged by the reduced disclosures in IFRS 19

Company Law interaction

13IFRS 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.

Yes	No
X

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

N/A

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True and fair view assessment

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

Yes	No
X

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

We agree with the conclusion that IFRS 19 is not contrary to the true and fair view requirement. As IFRS 19 does not alter recognition or measurement and retains key disclosures necessary to understand an entity's financial position, performance and cash flows, we do not believe it would prevent IFRS 19-compliant financial statements from giving a true and fair view.

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

17Do 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):

Yes	No
X

18Please 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:

We agree that IFRS 19 is unlikely to lead to a significant change in accounting practice. The Standard is voluntary and relates to disclosure-only, and therefore does not affect how transactions are recognised, measured or presented.

Other comments

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

We support the UKEB's overall approach and conclusions. We note that uptake of IFRS 19 in the UK may be limited in practice due to the continued availability and attractiveness of FRS 101 for UK subsidiaries.

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Response generation

20Did 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)?

Yes	No
	X

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

N/A

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Response 6 - RSM UK

File information

Appendix

Technical accounting criteria assessment

UK long term public good assessment

Company Law interaction

True and fair view assessment

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

Other comments

Response generation