8 IASB General Update

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19 March 2026
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Executive Summary

Project Type
Influencing
Project Scope
Various
Purpose of the paper
This paper provides the Board with an update on projects the Secretariat is currently monitoring. As agreed with the Board, the Secretariat monitors projects being undertaken by the IASB. This is to inform the Board about the progress and decisions being made by the IASB on active projects. Discussion by the Board may also help inform interactions with international standard setter meetings, including the IASB's Accounting Standards Advisory Forum (ASAF), of which the UKEB is a member.
Summary of the Issue
Topics addressed in this paper include topics discussed by the IASB at its February 2026 meeting and topics to be discussed at the March 2026 ASAF meeting.

Topics for discussion

  • IFRS Foundation Due Process Handbook
  • Post-implementation Review of IFRS 16 Leases
  • Equity Method

Topics for noting

  • Post-implementation Review of IFRS 9—Hedge Accounting
  • Financial Instruments with Characteristics of Equity
  • List of IASB projects
Decisions for the Board
Topics for discussion IFRS Foundation Due Process Handbook (Appendix A)
1. Does the Board have any comments on the enhanced proposals to raise as key messages at the ASAF meeting?
Post-implementation Review of IFRS 16 Leases (Appendix B)
1. Do Board Members have any feedback in relation to the UKEB's key messages for ASAF relating to topics discussed at the IASB's February 2026 meeting?
2. Do Board Members have any views on the stakeholder proposals on reducing ongoing costs of applying IFRS 16 (Question 4 of RFI)?
3. Do Board Members have any views on areas stakeholders identified where additional clarity could improve consistency and reduce diversity in practice (Question 2 of RFI – Usefulness of information resulting from lessees' application of judgement)?
Equity Method (Appendix C)
1. Do Board Members have any feedback in relation to the concerns of Japanese and Chinese stakeholders?
2. Do Board Members have any feedback in relation to the UKEB's key messages for the ASAF meeting?
Topics for noting
Do Board members have any comments or questions on the topics for noting?
Recommendation
N/A
Appendices
Appendix A: IFRS Foundation Due Process Handbook Appendix B: Post-implementation Review of IFRS 16 Leases Appendix C: Equity Method Appendix D: Post-implementation Review of IFRS 9—Hedge Accounting Appendix E: Financial Instruments with Characteristics of Equity Appendix F: List of IASB Projects

Appendix A: IFRS Foundation Due Process Handbook

Project Stage IFRS Foundation Research Exposure Draft Redeliberation Final DPH Published
UKEB Monitoring Influencing Monitoring -
UKEB project page
UKEB Final Comment Letter (published 28 March 2025)
IFRS Foundation project page

Purpose

A1The purpose of this paper is to seek Board Member views ahead of feedback to the IFRS Foundation Trustees' Exposure Draft (ED) Proposed Amendments to the IFRS Foundation's Due Process Handbook being discussed at the IASB's Accounting Standards Advisory Forum (ASAF) meeting, in March 2026.

A2The project update to be presented to ASAF summarises discussions of the Due Process Oversight Committee (DPOC) at its meeting on 3 March 2026, including:

a) stakeholder feedback to the ED consultation; and[^1]

b) further enhancements to the IFRS Foundation Due Process Handbook (the Handbook) made in response to the feedback.[^2]

Background

A3On 19 December 2024, the Trustees of the IFRS Foundation published the ED proposing amendments to the Handbook.

A4Primarily, amendments were proposed to reflect the creation of the International Sustainability Standards Board (ISSB) and ensure it formally applies the IFRS Foundation's due process to its operations. However, the proposed amendments also include enhancements and clarifications to the Handbook, based on the Foundation's recent experiences (for example, of post-implementation reviews).

UKEB Comment Letter

A5At its February 2025 meeting, the Board agreed to respond to the ED on the basis that the IFRS Foundation's due process has a direct impact on how the UKEB carries out its own statutory functions, including compliance with its own due process requirements.

A6Given the limited scope of the ED's proposals, the Board agreed to publish a high-level document on the UKEB website, setting out the key issues proposed for inclusion in the UKEB's Comment Letter, instead of a Draft Comment Letter. This document was also approved for circulation to the members of the UKEB advisory and working groups, via email, for their comments and views.

A7The UKEB's Final Comment Letter was submitted to the IFRS Foundation Trustees on 28 March 2025.

ASAF presentation from IFRS Foundation

A8The project update to be presented at ASAF provides the context for the Handbook's update, a summary of the consultation responses and proposals for further clarifications and enhancements to proposals in the ED.

A9The table below provides an overview of proposals in the ED, the recommendations in the UKEB Final Comment Letter and the main changes from the ED proposed.

A10In addition to the topics covered by the IFRS Foundation Trustees' consultation on the proposed amended Due Process Handbook, the UKEB proposed additional consideration be given to how the two boards analyse the likely costs and benefits of new requirements on affected parties, as well as the wider economic effects.

Question for the Board
1. Does the Board have any comments on the enhanced proposals to raise as key messages at the ASAF meeting?

Next steps

A11The UKEB Secretariat will observe the March ASAF meeting and provide an update on the discussion to the Board in due course.

Clarifying and enhancing proposals in the Exposure Draft

1. Due process for the SASB Standards and the SASB Standards Taxonomy

Proposals in the Exposure Draft
Add Appendix setting out SASB Standards due process. Retain process approved in 2022: amendments discussed in private with SASB Board Adviser Group, issued for 120 day consultation, and presented to ISSB for ratification.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED: * Urged the Foundation to apply the full due process to the SASB Standards and SASB Standards Taxonomy, if the long-term intent is for them to be required, or required in effect, rather than voluntary, or educational material. * Advised that, for the development and ratification of the SASB standards to meet the criteria of public accountability, discussions should be public and there should be transparency around appointments to the Board Adviser Group.
IFRS Foundation Staff: further proposed changes
Some respondents expressed concern with the lower level due process and the perceived lack of transparency, the size of the Board Adviser Group, the status of the SASB Standards, and the ISSB's intentions for them. The following further changes to the Handbook are proposed: * Retaining proposals relating to due process as SASB Standards are illustrative materials, but clarifying their difference in the text and specifying that if the status of SASB Standards changes so that entities are required to apply them, the SASB Standards would be subject to the full ISSB due process. * Highlighting similarities with the ISSB due process and the overarching responsibility of the ISSB for SASB Standards. * Specifying size of the Board Adviser Group is the maximum permitted by paragraph 3.43 of the Handbook. * Adding a section specifying Board Adviser Group can develop discussion papers for the ratification and publication by the ISSB.

2. Reflecting connectivity

Proposals in the Exposure Draft
Reflect aim for two boards' to work together, specifically: include the objective from the IFRS Foundation's Constitution of 'complementary sets of IFRS Standards'; reflect new processes (e.g. joint board meetings); and, add a due process step for boards to consider steps taken to develop compatible Standards, avoiding inconsistencies and conflicts with the other board's Standards.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED broadly supported the proposals to formalise connectivity in the Handbook and proposed the following additional changes: * Strengthening the objective so that it would be for the boards to ‘develop IFRS Standards that connect, where appropriate'.[^3] * Including a requirement for opportunities and risks relating to connectivity to be considered at the start of the standard setting process. * Requiring work plan consultations reflect the boards' formal and public assessment of the connectivity of proposed projects.
IFRS Foundation Staff: further proposed changes
Respondents generally welcomed the proposals but made suggestions to further foster connectivity. The following further changes to the Handbook are proposed: * Clarifying that Standards are intended to work well together but can be applied separately from each other, and alongside other parties' materials (para 1.1). * Requiring boards to consider whether to align the timing of their work plan consultations (after para 4.3). * Requiring board consideration of possible interactions with the other board's Standards when evaluating adding a standard-setting project to the work plan (after para 5.4).

3. Post-implementation reviews (PIR)

Proposals in the Exposure Draft
Clarify objective of a PIR is to assess whether effects of applying the requirements are as intended. Emphasise it is not a standard-setting project and clarify possible outcomes. Specify timing of a PIR – when sufficient information is available to assess the effects of new requirements. Clarify process for deciding whether matters arising from PIR warrant further action and, if so, how prioritised.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED: * Recommended the focus of PIRs be on whether the Standard has met its intended objective and whether the cost benefit analysis was accurate. * Recommended the Handbook specify that implementation and interpretation issues be reserved for consideration by a Transition Resource Group, or IFRIC, as relevant. * Recommended a backstop completion period be introduced for PIRs to ensure they are not deferred indefinitely.
IFRS Foundation Staff: further proposed changes
Responses were mixed and raised several issues, responded to by the following further proposed changes to the Handbook: * Refining the explanation of PIR objective by specifying that the basis of a PIR assessment is 'the objective of the Standard' (para 6.50) and that the PIR's objective is whether the Standard continues to work as intended (para 6.51). Amend para 6.52 to remove suggestion that application questions are linked to the objective of a PIR. * Amending para 6.53 to remove reference to application questions and insert a new paragraph setting out mechanisms for identifying and addressing application questions outside a PIR. * Clarifying PIR timing by specifying it is expected to begin within five years of the effective date of the new requirements, and requiring a board wishing to defer a PIR to explain its decision to the DPOC and indicate when the PIR will start (para 6.55). * Amending para 6.62 to remove suggestion that a board will only consider 'fatal flaws' or 'fundamental questions' during a PIR. Removing prioritisation guidance, which was unnecessarily detailed and potentially confusing. * Updating para 6.64 to clarify that the project summary and feedback summary will include the rationale for the board's conclusions.

4. Interpretations Committee (IFRIC)

Proposals in the Exposure Draft
Clarify term 'widespread effect' in criteria used by IFRIC to consider need for a standard-setting project, with ‘widespread effect' meaning the circumstance or transaction is prevalent and there is diversity in application.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED: * Recommended that “prevalence” was further defined e.g. by reference to the number and size of entities, relevant sizes of jurisdictional capital markets etc. * Proposed that IFRIC be able to recommend standard-setting if, after implementation of a Standard, the required accounting is leading to unintended or poor accounting outcomes.
IFRS Foundation Staff: further proposed changes
Respondents generally supported the proposed clarification but suggested further enhancements. The following further changes to the Handbook are proposed: * Clarifying 'widespread effect' (para 5.17):
  1. The Interpretations Committee assesses the need for a standard-setting project based on whether: The matter has widespread effect – that is:
    1. the circumstance or transaction is prevalent, or is expected to be prevalent; and
    2. there is diversity, or expected diversity, in the application of IFRS Accounting Standards that has, or is expected to have, a material effect on those affected.
* Codifying existing practice that IFRIC can report additional information to the IASB when confirming its decision (para 8.2). * Codifying the process for maintaining agenda decision when it issues new Standards (para 8.5) and acknowledging that the IASB can ask IFRIC to consider updating agenda decisions which would have been withdrawn to reflect new or amended requirements (para 5.14).

Including the due process for the ISSB in the Handbook

Proposals in the Exposure Draft
Specify throughout the Handbook that the ISSB is subject to the same due process requirements as the IASB.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED was supportive of the proposals.
IFRS Foundation Staff: further proposed changes
None – All respondents agreed the two boards should have the same due process. However, if there is a need for any difference that should be clearly identified and the rationale explained. Respondents expressed concern over the use ‘financial reporting' to cover both financial statements and sustainability-related disclosures but, as the terminology comes from the Conceptual Framework, it is to be retained to avoid confusion.

Conceptual Framework

Proposals in the Exposure Draft
Specify the due process for maintaining the Conceptual Framework to avoid the suggestion that future amendment would be made by the IASB alone.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED did not comment on this issue.
IFRS Foundation Staff: further proposed changes
None – respondents proposed developing a conceptual framework for sustainability standards, but it is not the Handbook's role to address future strategy or whether the ISSB will have a conceptual framework; its role is to specify the process for amending or developing a conceptual framework.

IFRS Interpretations Committee

Proposals in the Exposure Draft
Reflect that the formal remit of the Interpretations Committee in the Constitution relates to the Accounting Standards.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED: * Recommended the IFRS Foundation confirm whether an Interpretations Committee will be established to consider questions relating to the interpretation of ISSB Standards.
IFRS Foundation Staff: further proposed changes
None – respondents highlighted there was no equivalent body for ISSB Standards, but the role of the project is not to determine whether an equivalent body should be created to support the ISSB. IFRS Foundation staff recommend the Trustees initiate discussions about ISSB long-term strategy for supporting its Standards and whether an additional body may be required.

Minor improvements to IFRS Standards

Proposals in the Exposure Draft
Retire the term 'annual improvements’. Refer to packages of minor improvements instead.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED did not comment on this issue.
IFRS Foundation Staff: further proposed changes
Minor – respondents were generally supportive but suggested defining ‘minor' and allowing a 120-day comment period unless approved by the DPOC. The due process already requires boards to use their judgment in relation to whether an improvement is 'minor' but the words 'minor or narrow-scope changes' to be added for clarification. The board will be able to consider whether improvements require more than a 90 day comment period.

Other materials to support application of IFRS Standards

Proposals in the Exposure Draft
Change 'educational material' to 'material to support application of IFRS Standards' and specify due process for materials developed with third parties.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED did not comment on this issue.
IFRS Foundation Staff: further proposed changes
Minor – respondents expressed concern about the due process of previously published materials and suggested clarifying differences between the status of the various materials. Further amendments proposed to clarify materials produced by the Foundation and those produced and maintained by third party organisations; and whether materials are ‘mandatory' or 'non-mandatory'.

Other targeted amendments

Proposals in the Exposure Draft
Targeted amendments proposed to twelve other areas where small enhancements and clarifications were made, including, inter alia:
  1. requiring the DPOC to review the due process a board follows before a major new IFRS Standard or Amendment is issued;
  2. allowing surveys to be used to collect responses to formal consultations; and,
  3. explaining how boards may build on the work of other standard-setters.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED: * Recommended consideration of the re-exposure requirements which do not currently include consultation with stakeholders. The UKEB recommended paragraph 6.30 require the board to consider stakeholder feedback, including from consultative groups, before making a final decision on re-exposure.
IFRS Foundation Staff: further proposed changes
Minor – respondents were generally supportive of the proposals. Respondents additional proposals would go beyond the scope of the ED and require wider consultation. Surveys being a supplementary method to responding to formal consultations to be clarified. ISSB to undertake due process to amend IFRS S2 in the event of GHG Protocol Corporate Standard being updated. No change proposed in relation to re-exposure criteria as para 6.30 states that re-exposure is more likely if changes to an ED would require a significant change from current practice.

Appendix B: Post-implementation Review of IFRS 16 Leases

Project Stage IASB Research / Pipeline Discussion Paper Redeliberation Exposure Draft Redeliberation Final Standard Post Implementation Review UKEB Research / Influencing Research / Monitoring Influencing Influencing Monitoring Endorsement Influencing UKEB Post Implementation Review
UKEB project page
UKEB Final Comment Letter (published 16 October 2025)
IASB Next Milestone: Project completion

Purpose

B1The purpose of this paper is:

a) To ask for Board Members' views on the key messages the UKEB plans to raise at the March 2026 Accounting Standards Advisory Forum (ASAF) meeting. At that meeting the IASB will seek ASAF members' views on the IASB's discussions at its January, February and March 2026 meetings relating to the feedback received on the Post-implementation Review (PIR) of IFRS 16 Leases.

b) To provide the Board with an overview of:

i. the final batch of feedback the IASB received on its Request for Information: IFRS 16 Leases (RFI), following the IASB's February 2026 meeting; and

ii. the IASB staff's update to their review of academic literature related to IFRS 16.

Background

B2In June 2025, the IASB published its RFI, to seek stakeholders' views on the requirements in IFRS 16, with a comment period ending on 15 October 2025. The UKEB's final comment letter (FCL) to the IASB was submitted on 15 October 2025. The IASB received 122 responses to the RFI and held 35 outreach events.

B3IASB staff continued providing the IASB with their summary of feedback received on the RFI, with the final aspects brought to the IASB's meeting on 25 February 2026.

February 2026 IASB meeting

B4The IASB discussed the following papers at its February 2026 meeting:

a) Feedback summaries on the following aspects of the RFI:

i. Potential improvements to future transition requirements.[^1]

ii. Other matters.[^2]

b) Academic literature review - update.[^3]

B5The IASB did not make any tentative decisions.

B6Annex 1 provides:

a) a high-level overview of the feedback received by the IASB on its RFI and of the views expressed by the UKEB in its FCL; and

b) an overview of the academic literature review update provided by the IASB staff.

UKEB views

B7For those aspects on which the UKEB expressed views in its FCL, the UKEB's views generally align with the feedback the IASB discussed during its February 2026 meeting.

March 2026 ASAF meeting

IASB staff's objective

B8The IASB plan to bring a project update and seek views from ASAF members on the IASB's discussions at its January, February and March 2026 meetings relating to the feedback received on the PIR of IFRS 16.

B9Staff papers[^4] for the March 2026 IASB meeting were only available from 16 March 2026. Therefore, the IASB ASAF paper provides only a summary of feedback and stakeholders' suggestions for reducing ongoing costs (Question 4 of RFI) and enhancing the usefulness of information resulting from lessees' application of judgement (Question 2 of RFI)[^5]. An overview of the ASAF paper is provided for the Board below:

a) On reducing ongoing costs, stakeholders recommended that the IASB consider:

i. Reducing the frequency with which lessees are required to remeasure lease liabilities.

ii. Allowing lessees to retain the existing discount rate when remeasuring lease liabilities for reassessments and lease modifications.

iii. Permitting the use of simplified discount rate approaches, such as a risk-free rate, a group or parent rate, or any readily obtainable borrowing rate.

iv. Expanding the scope of existing recognition exemptions.

v. Removing or streamlining selected disclosure requirements.

b) On the usefulness of information resulting from application of judgement, stakeholders generally supported the principles-based approach but identified areas where additional clarity could improve consistency and reduce diversity in practice. In particular, stakeholders suggested that the IASB:

i. Provide further guidance and illustrative examples on key judgements, including assessing the ‘reasonably certain' threshold for lease term and interpreting 'genuine variability' when identifying in-substance fixed payments.

ii. Clarify the requirements for determining the incremental borrowing rate and the treatment of variable lease payments.

iii. Introduce more specific disclosure requirements on significant judgements and assumptions - such as disclosures of weighted-average discount rates and methodologies applied - to enhance transparency and comparability.

iv. Consider simplifying or clarifying areas where judgement is currently viewed as unclear or overly complex.

UKEB Key messages

B10The Board was supportive of the Secretariat's proposed key messages relating to IASB discussions in January 2026 as set out in the Agenda Paper 9B of the UKEB's February 2026 meeting. These key messages included a comment that any proposed changes to simplify specific areas to mitigate ongoing costs for preparers should be carefully considered and weighed against the expected changes in benefits to users. Possible simplifications to consider include:

a) Streamlining discount rate requirements, for example by permitting use of a lessee's obtainable borrowing rate instead of the incremental borrowing rate.

b) Revising the low-value and short-term exemptions to reduce their perceived rule-based nature and enable a more principles-based, materiality-driven approach.

B11In addition to the key messages proposed in the January 2026 UKEB meeting, the Secretariat's preliminary view about key messages to convey at the ASAF meeting on the matters discussed at the IASB's February 2026 meeting is:

a) The IASB's feedback aligns with the UKEB's view that the transition requirements generally worked well, preparers valued the simplifying practical expedient, though the lack of full retrospective application may have led some users to continue adjusting back to IAS 17 figures.

b) The UKEB has not been made aware of pervasive concerns in the UK relating to applying IFRS 16 with IFRS 9 for rent concessions.

c) Stakeholder feedback to the IASB broadly agreed with the UKEB's earlier views on IFRS 15. However, many still find aspects of IFRS 16 unclear, especially when deciding whether a sale has occurred in sale and leaseback transactions. They also point to challenges around renewal options and situations where only part of an asset is leased back. In response, targeted clarifications to IFRS 16, potentially drawing on IFRS 15 guidance, could help improve consistency.

d) The UKEB has not been made aware of any specific issues in the UK around applying the partial gain or loss recognition requirements.

e) The UKEB has not identified any other significant matters relevant to the assessment of the effects of IFRS 16.

Questions for the Board
1. Do Board Members have any feedback in relation to the UKEB's key messages for ASAF relating to topics discussed at the IASB's February 2026 meeting?
2. Do Board Members have any views on the stakeholder proposals on reducing ongoing costs of applying IFRS 16 (Question 4 of RFI)?
3. Do Board Members have any views on areas stakeholders identified where additional clarity could improve consistency and reduce diversity in practice (Question 2 of RFI – Usefulness of information resulting from lessees' application of judgement)?

Next steps

B12At future meetings, the IASB will discuss its actions in response to the feedback received. More specifically, at its March 2026 meeting, the IASB will discuss staff analysis and recommendations on whether to take any actions in response to stakeholders' feedback about:

a) ongoing costs for lessees of applying the measurement requirements in IFRS 16; and

b) usefulness of information resulting from lessees' application of judgement.

B13The Secretariat will provide a verbal update to the Board at its March 2026 meeting of the IASB's March 2026 meeting to assist the Board in finalising the key messages to convey at the upcoming ASAF meeting.

B14The IASB expects to publish a project report and feedback statement before the end of 2026.

B15The Secretariat will continue to monitor the IASB discussions and update the Board as necessary.

Annex 1: Overview of feedback received by IASB against UKEB views in FCL and academic literature review update

Stakeholder feedback to IASB and UKEB FCL

1The table below provides an overview of the feedback received by the IASB against the views provided by the UKEB in its FCL.

Question 5: Potential improvements to future transition requirements
Stakeholder feedback to the IASB
Many stakeholders commented on Question 5 and, of these, most considered the transition requirements in IFRS 16 to strike an appropriate balance between reducing preparer costs and providing useful information to users. Some respondents observed that permitting multiple transition options reduced comparability. Stakeholders also offered recommendations for future standard-setting. Most of those commenting specifically on multiple transition options supported retaining flexibility, while a smaller number raised concerns about allowing more than one transition approach.
UKEB FCL
The IASB's feedback is consistent with the UKEB’s FCL, which included the following views:
  1. The UKEB is not aware of any significant concerns with the transition requirements.
  2. Preparers appreciated the practical expedient available on transition as it simplified the accounting at transition date. However, it is possible that not requiring full retrospective application contributed to some users adjusting back to IAS 17 numbers.
Question 6.1: Applying IFRS 16 with IFRS 9 Financial Instruments rent concessions
Stakeholder feedback to the IASB
Many respondents to Question 6.1- particularly standard-setters, preparers, accountancy bodies and accounting firms - said there remains insufficient clarity on how a lessee distinguishes between a lease modification under IFRS 16 and an extinguishment of a lease liability under IFRS 9 when accounting for forgiven lease payments. Stakeholders reported resulting diversity in practice. Views were mixed on how frequently rent concessions occur, but most respondents said guidance would be helpful given the potential for such concessions to re-emerge. Some noted that the 2024 Annual Improvements clarified the consequences of extinguishment under IFRS 9, but said a broader question remains about distinguishing extinguishment from modification. Most stakeholders recommended that the IASB develop guidance to reduce diversity, offering differing views on whether rent concessions should generally be treated as lease modifications or extinguishments. A few stakeholders suggested the IASB consider factors such as the unit of account, the reasons for the concession, and whether forgiven amounts relate to past or future payments. One firm noted that its guidance permits an accounting policy choice between IFRS 16 and IFRS 9.
UKEB FCL
The UKEB stated that it is aware of the IFRIC suggestion and acknowledges that there could be diversity in practice. However, the UKEB has not been made aware of pervasive concerns with applying IFRS 16 with IFRS 9 to rent concessions in the UK.
Question 6.2: Applying IFRS 16 with IFRS 15 Revenue from Contracts with Customers when assessing whether the transfer of an asset in a sale and leaseback transaction is a sale
Stakeholder feedback to the IASB
Many respondents to Question 6.2 - mainly standard-setters and some accounting bodies, preparers and firms - said it is often difficult to assess whether the transfer of an asset in a sale and leaseback transaction qualifies as a sale under IFRS 15, noting that IFRS 15 was not designed with such transactions in mind. Some preparers, however, reported no significant difficulties, either because such transactions are infrequent or because they consider IFRS 16 sufficiently clear. Several stakeholders reported diversity in judgements regarding the transfer of control in specific circumstances, particularly where renewal options cover substantially all of the asset's remaining economic life, only part of an asset is leased back, a repurchase option exists, revenue is recognised over time, or the lessee is involved in specifying an asset pre-construction. Many respondents asked the IASB to provide guidance or examples for these scenarios, clarify how control criteria apply to sale and leaseback transactions, or provide decision tools to support consistent application. A few suggested more prescriptive requirements - similar to those in FASB Topic 842 - both for assessing whether a sale has occurred and for determining whether a lessee controls an asset during construction.
UKEB FCL
The UKEB stated that its view remains broadly consistent with its response to the IASB's Post-implementation Review of IFRS 15 Revenue from Contracts with Customers (see Final Comment Letter – Post-Implementation Review of IFRS 15 Revenue from Contracts with Customers). However, some stakeholders said that aspects of IFRS 16 lack sufficient clarity to support consistent judgement, leading to diversity in practice - particularly in assessing whether the transfer of an asset in a sale and leaseback transaction qualifies as a sale. Areas identified include:
  1. renewal options: uncertainty about whether renewal options that extend the lease for (substantially) all of the asset's remaining economic life should be treated consistently with economically similar purchase options; and
  2. unit of account: uncertainty when only part of an asset is leased back.
The UKEB considers that targeted amendments to IFRS 16 - either clarifying the existing requirements or incorporating relevant guidance from IFRS 15 paragraph 38 - could help address these concerns.
Question 6.3: Applying IFRS 16 with IFRS 15 to gain or loss recognition in a sale and leaseback transaction
Stakeholder feedback to the IASB
Many respondents to Question 6.3 - across standard-setters, accounting bodies, preparers and firms - said that restricting the gain or loss in a sale and leaseback transaction provides useful information because it reflects the economic substance of the transaction, considers linked arrangements together, and reduces structuring opportunities. However, many noted that applying the partial gain or loss model is complex and costly, requiring significant judgement, intricate calculations, and additional challenges where variable lease payments not based on an index or rate are involved. Some suggested practical expedients, further guidance on measuring lease liabilities (including where variable payments depend on an index or rate), and reconsideration of inconsistencies with other lease liability measurement requirements. A smaller group - primarily from Asia-Oceania and some global firms - disagreed with restricting gains or losses. They said the approach is inconsistent with IFRS 15, reduces comparability with Topic 842, introduces complexity that obscures performance, creates inconsistencies in accounting for variable lease payments, and diverges from lessor accounting in IFRS 16. These stakeholders recommended an approach aligned with Topic 842, recognising gains or losses in full when a sale occurs and excluding variable payments not based on an index or rate from lease liabilities.
UKEB FCL
The UKEB has not been made aware of any specific issues around applying the partial gain or loss recognition requirements.
Question 6.4: Other matters relevant to the assessment of the effects of IFRS 16
Stakeholder feedback to the IASB
Lessor accounting Some stakeholders - mainly standard-setters, accounting bodies, preparers and firms - raised concerns about the limited guidance for lessors in IFRS 16 compared with the detailed lessee requirements. A few noted diversity in practice on matters such as remeasurement of the net investment in the lease, applying IFRS 9 impairment, accounting for unguaranteed residual values, and recognising operating lease income when collectability is uncertain. These stakeholders suggested the IASB provide additional requirements or guidance. A small number also raised concerns about specific requirements, including separating lease and non-lease components (particularly in real estate), accounting by intermediate lessors for variable payments, principal-agent considerations in subleases, and the interaction between manufacturer/dealer lessor requirements and IFRS 15. Determining the scope of IFRS 16 and identifying a lease Some stakeholders highlighted challenges in determining whether a contract contains a lease, including assessing who directs the use of an asset, whether substitution rights are substantive (including in circular-economy arrangements), and how to treat complex power purchase agreements. Others said it remains unclear whether cloud computing, digital infrastructure or similar arrangements fall within IFRS 16, IAS 38 Intangible Assets or service contract guidance. A few also raised concerns about distinguishing in-substance purchases from leases. Most asked the IASB to provide clearer guidance or examples. Corporate wrappers Some stakeholders asked the IASB to clarify how IFRS 16 interacts with IFRS 10 when a subsidiary (or single-asset entity) is sold and its assets leased back. They said it is unclear whether to apply IFRS 10 Consolidated Financial Statements or IFRS 15 to the control assessment and whether to recognise a full or partial gain. Although the IASB has included this issue in its maintenance pipeline, some urged it to be addressed sooner. A few offered differing views on whether IFRS 10, IFRS 16, or a combination should apply. Other matters A small number of respondents raised concerns about: * recognition patterns for lease-related expenses, including double-counting issues and mismatches for intermediate lessors; * usefulness and consistency of requirements for variable lease payments not based on an index or rate; * the application of IAS 21 The Effects of Changes in Exchange Rates and IAS 29 Financial Reporting in Hyperinflationary Economies; * lack of guidance on subleases, non-cash consideration, maintenance, lease deposits, VAT, separating non-lease components, impairment of right-of-use assets, and interactions with IFRS 11 Joint Arrangements, IFRS 3 Business Combinations and IFRS 5 Non-current Assets Held for Sale and Discontinued Operations, * whether to require reconciliations of movements in right-of-use assets and lease liabilities. A few stakeholders commented on costs for entities outside the IFRS for SMEs Standard, and some expressed concerns about PIR timing - suggesting earlier reviews and greater use of the IFRS Interpretations Committee and transition resource groups.
UKEB FCL
The UKEB has not identified any other significant matters relevant to the assessment of the effects of IFRS 16.

Academic literature review update

2At its March 2025 meeting the IASB discussed an overview of the academic literature relevant to the PIR of IFRS 16. During its February 2026 meeting, the IASB staff presented a summary of the additional academic literature relevant to the PIR of IFRS 16, identified since the initial review.

3The feedback included the following:

a) Recent academic evidence indicates that IFRS 16 has had significant effects on entities' financial statements and key ratios, with impacts differing by sector. Studies also observed continued diversity in how entities present and explain lease-related impacts in practice.

b) Research from one jurisdiction suggested that early compliance with IFRS 16 disclosure requirements was moderate and higher among entities audited by Big Four firms.

c) Several studies found that IFRS 16 improved the usefulness of lease information for users, including evidence of enhanced investment and financing decisions and reduced share-price-crash risk for lease-intensive entities.

d) Findings on comparability were mixed: some studies reported improved transparency and comparability, while others found that differences between IFRS 16 and Topic 842 can influence user judgements and increase information-processing costs.

e) Evidence on real effects showed operational impacts—such as system changes and implementation costs—alongside improvements in internal controls and decision-making. Some studies also indicated increases in leasing activity, reduced capital expenditure and debt financing, and improved investment efficiency following implementation.

Appendix C: Equity Method

Project Stage IASB Research / Pipeline Discussion Paper Redeliberation Exposure Draft Redeliberation Final Standard Post Implementation Review UKEB Research / Influencing Research / Monitoring Influencing Influencing Monitoring Endorsement Influencing UKEB Post Implementation Review
UKEB project page
UKEB Final Comment Letter (published 16 December 2024)
IASB Next Milestone: Decide Project Direction (expected March 2026)

Purpose

C1The purpose of this paper is:

a) To provide an update on the IASB's deliberation at its February 2026 meeting on the proposal in the Exposure Draft (ED) Equity Method of Accounting IAS 28 Investments in Associates and Joint Ventures (revised 202x) relating to impairment of an investment.

b) To ask for Board Members' views on the key messages the UKEB plans to raise at the March 2026 Accounting Standards Advisory Forum (ASAF) meeting, on the proposal in the ED relating to recognition of full gains and losses on transactions with associates and joint ventures (JVs).

Background

C2In September 2024, the IASB published its ED, which aimed to:

a) clarify and add to the requirements in IAS 28 to answer application questions about how to apply the equity method of accounting;

b) reorder the requirements in a more logical and consistent way to help companies with the application of the Standard i.e. improve the understandability; and

c) improve the disclosure requirements in IFRS 12 Disclosure of Interests in Other Entities and IAS 27 Separate Financial Statements to complement the proposed amendments to IAS 28.

C3The UKEB undertook a ‘light touch' approach in responding to the ED and is not aware of pervasive or material concerns for the UK arising from the proposals. Therefore, the UKEB supported the proposals in the ED, but did not comment on each specific proposal.

C4In May 2025, the IASB discussed feedback it received on the ED. The Board received an update at its September 2025 meeting[^6].

C5In September 2025, the IASB commenced its deliberations of the ED proposals. The Board has received regular updates, on IASB's decisions/tentative decisions[^7]. A summary of those decisions in the project plan and on redeliberating the proposals in the ED to date can be found in Appendix A of the March 2026 IASB Staff agenda paper 13.

C6According to the IASB's published workplan, the IASB is expected to decide on the project direction in March 2026.

IASB February 2026 meeting

Impairment of an investment

C7At its February 2026 meeting, the IASB continued its redeliberation of the proposals in the ED and discussed impairment of an investment. A summary of the ED proposal, other background information and tentative decisions on the topic discussed at the meeting are presented in Annex 1 of this paper.

Transaction with associates and JVs

C8At that meeting, the IASB continued to redeliberate the ED proposal that an investor recognises in full any gains or losses that result from transactions with its associates and JVs, due to concerns it received from some stakeholders in some jurisdictions.

C9At its October 2025 meeting, the IASB had decided to undertake further work:

a) to understand the concerns of respondents who said the proposals could increase opportunities for earnings management; and

b) to understand whether enhancing disclosures or adding guidance might resolve these concerns.

C10The IASB discussed feedback from further stakeholder meetings on the ED proposal[^8]. The overall messages from the stakeholder meetings were:

a) All groups of Japanese and Chinese meeting participants strongly disagree with the proposal. Investment in associates is pervasive in their jurisdictions and is an important feature of how entities conduct their business[^9]. Their main concerns are:

i. It will increase earnings management opportunities which will lead to significant distortions in profits and losses and result in a presentation that is less aligned with the business model of investors in associates and JVs.

ii. It is inconsistent with the fundamental principle that an investor recognises its share of the investee's financial performance based on its ownership interest.

iii. It is a fundamental change without undertaking a fundamental review of the equity method. The inconsistency between IAS 28 and IFRS 10 Consolidated Financial Statements does not justify the need for such a fundamental change because sales of businesses to an associate are relatively infrequent.

b) Whilst these transactions are captured by IAS 24 Related Party Disclosures, some regulators stressed the need for greater transparency, as preparers often disclose minimal information under the existing requirements. Regulators asked for enforceable specific disclosure requirements, such as the rationale for a transaction and how transactions are priced.

c) Discussion with some European preparers, about the concerns of Japanese and Chinese stakeholders, did not change those preparers' support for the ED proposal. The European preparers continue to support the ED proposal, citing the IASB's cost-benefit assessment of the proposals.

March 2026 ASAF meeting

Transactions with associates and joint ventures

C11The IASB will seek feedback on this specific topic at the forthcoming ASAF meeting at the end of March 2026.

C12In February 2026, the Secretariat provided the Board with an update on this topic (for noting)[^10]. That paper set out details of this ED proposal, the IASB's rationale, a summary of ED feedback received, and further outreach being undertaken by the IASB. As noted in that paper, the UKEB supported the proposals in the ED, but did not comment on the specific ED proposals in its comment letter.

C13To inform UKEB views to be shared at the forthcoming ASAF meeting, the Secretariat started to undertake outreach with UKEB Advisory Groups (AGs), specifically investors[^11], regarding the concerns expressed by some of the IASB's stakeholders in some jurisdictions and provided feedback in that paper.

C14The Secretariat has continued to seek feedback from other UKEB AGs[^12]. This paper provides the Board with an update on outreach with Accounting firms and Institutes and Preparers, and details the specific questions that the IASB staff will be asking at the forthcoming ASAF meeting, along with the Secretariat's suggested UKEB key messages.

IASB staff's objective

C15At the March 2026 ASAF meeting, the IASB will seek ASAF members' views on two aspects of the feedback received from its further work undertaken on the ED proposal:

a) the implications of the ED proposals for users of financial statements[^13]; and

b) the ability of an investor in an associate or JVs to obtain information from its associates/JVs for the application of the requirements in IAS 28 in preparing consolidated financial statements[^14].

C16In particular, ASAF members will be asked the following questions:

Questions for ASAF members
1. Is there evidence from your jurisdiction that users of financial statements focus on:
  1. profit or loss attributable to shareholders of the parent entity for the reporting period; or
  2. group operating profit or loss for the year in consolidated financial statements (including if disclosures on segment performance and other voluntary disclosures use profit or loss attributable to shareholders of the parent entity)?
2. IFRS 12 requires an entity to provide a reconciliation of the summarised information presented about a JV or associate to the carrying amount of that investment in the statement of financial position. In your jurisdiction, as part of this reconciliation, do entities disclose information about restricted gains and losses?
  1. if such information is disclosed, how do users of financial statements use this information?
  2. if such information is not disclosed, do you think the information would be useful to users of financial statements?
3. In restricting gains and losses on transactions with associates and JVs (when applying IAS 28) we (the IASB staff) understand:
  1. some entities adjust the income from equity accounted investments;
  2. other entities adjust the line-item in the income statement (such as revenue and cost of sales).
What, if any, is the prevailing practice in your jurisdiction? 4. Do investors in associates and JVs in your jurisdiction find it difficult to obtain information from its JVs or associates to comply with the requirements in IAS 28? If so, what are the challenges in accessing that information?

UKEB Advisory Groups feedback

UKEB Preparer Advisory Group (PAG)

C17PAG members supported the ED proposal to recognise gains and losses in full because:

a) it resolves the inconsistency between IAS 28 and IFRS 10 Consolidated Financial Statements; and

b) upfront full recognition of gains and losses is simpler, as it eliminates the need to track the unrecognised portion of gains and losses that is deferred under the current requirements in IAS 28.

C18When questioned whether, in response to feedback on the ED, additional disclosures on 'upstream' transactions or the rationale for transactions and their pricing, for either associates or JVs, could be a way forward to help users understand transactions, PAG members raised the following concerns:

a) Providing this information would be burdensome for preparers, particularly for those companies with a significant number of JVs and associates.

b) Challenges include completeness and timeliness of obtaining the necessary information from associates and JVs for any additional disclosures, given that a company does not have control over associates and JVs.

c) Detailed disclosures on transactions with associates and JVs are provided at the request of the regulator. However, the benefits of this information for users are questionable.

C19Other key points raised were:

a) Applying full recognition of gains and losses retrospectively would lead to some initial costs, but ongoing costs are not expected to increase.

b) Materiality would apply and therefore the impact of the ED proposal is not expected to be significant for most companies, as associates and JVs are not material.

UKEB Accounting Firms and Institutes Advisory Group (AFIAG)

C20Similar to PAG members, AFIAG members supported the ED proposal because it is simpler and less burdensome than the recognition currently required by IAS 28 to restrict gains and losses. Other key points raised by AFIAG members were:

a) Applying the current requirements in IAS 28 is challenging for companies in some circumstances.

b) Concerns raised by some respondents to the ED proposal on the potential for earnings management were acknowledged but not shared by AFIAG members.

c) AFIAG members noted that there are different views in practice on whether the equity method is a measurement method or a one-line consolidation.

d) AFIAG members observed that companies, in general, do not disclose information about restricted gains and losses as part of the IFRS 12 requirements for an entity to provide a reconciliation of the summarised information presented about a JV or associate to the carrying amount of that investment in the statement of financial position.

UKEB Key messages

C21The Secretariat's preliminary view about UKEB key messages to convey at the ASAF meeting is:

a) There are merits in the ED proposal i.e. simpler and less costly to apply for preparers. Users also noted that the current partial recognition requirements in IAS 28 add 'noise' when gains are deferred and reversed over time.

b) Feedback received indicates that, in general, companies in the UK do not disclose information about restricted gains and losses, currently recognised under IAS 28, as they tend not to be material.

c) At times it is challenging for preparers to gather complete and timely information from their associates and JVs, given that they do not exercise control.

d) Whilst users have indicated that the ED proposal may provide an opportunity for earnings management, it is considered that the risk of manipulation is likely to be limited in most cases, due to lack of materiality.

e) Calls for additional disclosures appear to be arising from regulators who are concerned about compliance, rather than a deficiency in the standard. Additional disclosures should not be needed given the existing disclosure requirements for related-party transactions under IAS 24. The UKEB understands that a preparer would consider the requirements in IAS 24 with due regard to the materiality (nature/magnitude) of the information, given the disclosure requirements under IAS 1 Presentation of Financial Statements paragraphs 7 and 31.

Paragraph 7 of IAS 1 includes a definition of materiality.

Material:

Information is material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that the primary users of general-purpose financial statements make on the basis of those financial statements, which provide financial information about a specific reporting entity.

Materiality depends on the nature or magnitude of information, or both. An entity assesses whether information, either individually or in combination with other information, is material in the context of its financial statements taken as a whole.

Information is obscured if it is communicated in a way that would have a similar effect for primary users of financial statements to omitting or misstating that information. The following are examples of circumstances that may result in material information being obscured:

a) information regarding a material item, transaction or other event is disclosed in the financial statements but the language used is vague or unclear;

b) information regarding a material item, transaction or other event is scattered throughout the financial statements;

c) dissimilar items, transactions or other events are inappropriately aggregated;

d) similar items, transactions or other events are inappropriately disaggregated; and

e) the understandability of the financial statements is reduced as a result of material information being hidden by immaterial information to the extent that a primary user is unable to determine what information is material.

Assessing whether information could reasonably be expected to influence decisions made by the primary users of a specific reporting entity's general purpose financial statements requires an entity to consider the characteristics of those users while also considering the entity's own circumstances.

Many existing and potential investors, lenders and other creditors cannot require reporting entities to provide information directly to them and must rely on general purpose financial statements for much of the financial information they need. Consequently, they are the primary users to whom general purpose financial statements are directed. Financial statements are prepared for users who have a reasonable knowledge of business and economic activities and who review and analyse the information diligently. At times, even well informed and diligent users may need to seek the aid of an adviser to understand information about complex economic phenomena.

Extract from paragraph 31 of IAS 1:

An entity shall also consider whether to provide additional disclosures when compliance with the specific requirements in IFRS is insufficient to enable users of financial statements to understand the impact of particular transactions, other events and conditions on the entity's financial position and financial performance.

Questions for the Board
1. Do Board Members have any feedback in relation to the concerns of Japanese and Chinese stakeholders (see paragraph C10)?
2. Do Board Members have any feedback in relation to the UKEB's key messages for the ASAF meeting (see paragraph C21)?

Next steps

C22The IASB will continue redeliberating the ED proposals over the next few months, in line with the redeliberation plan outlined in paragraph 27 of Agenda Paper 13 for the IASB's June 2025 meeting.

C23The UKEB Secretariat will continue to monitor the IASB's redeliberation and tentative decisions and will continue to provide the Board with updates.

Annex 1: IASB's tentative decisions – February 2026

Impairment of an investment

Current requirements
Paragraph 40 of IAS 28 requires an investor to apply paragraphs 41A-41C of the Standard to determine whether there is any objective evidence that its net investment in an associate is impaired. If application of paragraphs 41A-41C indicates that its net investment might be impaired, paragraph 40 of IAS 28 requires the investor to test its net investment for impairment in accordance with IAS 36 Impairment of Assets. Among other things, paragraph 41C of IAS 28 states that “A significant or prolonged decline in the fair value of an investment in an equity instrument below its cost is also objective evidence of impairment".
Exposure Draft proposals
The ED proposed:
  1. to replace 'decline...below its cost' in paragraph 41C of IAS 28 with ‘decline...to less than its carrying amount';
  2. to remove the reference to a 'significant or prolonged' decline in fair value; and
  3. to add requirements to IAS 28 explaining that when the investor determines whether its net investment might be impaired, information about the fair value of the investment might be observed from the price paid to purchase an additional interest in the associate or received to sell part of the interest, or from a quoted market price for the investment.
UKEB Comment Letter
In its Comment letter, the UKEB supported the ED proposal.
IASB tentative decisions
In considering the feedback on the ED, the IASB decided to proceed with its ED proposals regarding impairment indicators. In addition to the ED proposals, the IASB also tentatively decided to:
  1. explain that a single, discrete event might not by itself indicate an impairment and that instead the combined effect of several events might indicate an impairment;
  2. clarify that the investor is required to consider observable information that comes to its attention when the investor determines whether its net investment in an associate might be impaired;
  3. clarify that for a publicly traded associate, the investor considers the quoted market price at the reporting date;
  4. not to move the impairment requirements from IAS 28 to IAS 36 Impairment of Assets[^15]; and
  5. not to consider two application issues[^16] relating to the reversal of an impairment loss.
UKEB Secretariat preliminary view
The IASB's tentative decisions are consistent with the ED proposals, with some additional clarifications. The UKEB final comment letter supported the ED proposals.

Appendix D: Post-implementation Review of IFRS 9—Hedge Accounting

Purpose of this paper

D1The purpose of this paper is to provide the Board with an update on the IASB's post-implementation review (PIR) of the hedge accounting requirements in IFRS 9 Financial Instruments, and some preliminary UKEB Secretariat desktop research on this topic.

Background

D2In December 2025, the IASB decided to start the PIR. At its February 2026 meeting, the IASB discussed the objective, activities and timeline for the first phase of the PIR.

IASB February 2026 Meeting

D3IASB staff presented a project plan[^17] for phase one of the PIR. Phase one includes initial outreach with the IFRS Foundation's IFRS Accounting Advisory Groups, meetings with other small groups of stakeholders, and a review of academic research. The purpose of the initial outreach is to inform the request for information which will be used to seek feedback from stakeholders. Phase two of the project will consider the feedback received in the public consultation.

D4The project plan sets out the objective of the PIR. This includes consideration of whether:

a) The objective of the hedge accounting requirements in IFRS 9 is being met. This objective is described in the paper as: 'to represent, in the financial statements, the effect of an entity's risk management activities that use financial instruments to manage exposures arising from particular risks that could affect profit or loss'[^18].

b) The benefits to users from the resulting information are broadly as expected.

c) The costs of applying some or all of the new requirements and auditing and enforcing their application are broadly as expected.

D5The project plan indicates that the IASB staff expect the overall PIR to take around 24 months to complete. The timeline for phase one includes outreach to consultative groups from March to May 2026. This includes the Accounting Standards Advisory Forum, the IFRS Interpretations Committee, the Capital Markets Advisory Committee and the Financial Instruments Consultative Group, all of which are scheduled in March 2026.

D6The IASB expect to publish the request for information in the second half of 2026, with a 120-day comment period.

UKEB Secretariat preliminary desktop research

D7The UKEB Secretariat has carried out preliminary desktop research into the prevalence of hedge accounting among listed entities in the UK. A text-based search of annual report filed in 2025 referring to the term "hedge” identified 328 companies. The Secretariat reviewed 111 of these annual reports and identified that 68 of the 111 applied hedge accounting.

D8The preliminary analysis of those applying hedge accounting indicates that:

a) Hedge accounting is used across a wide range of industries.

b) 72% of entities reviewed applied IFRS 9 hedge accounting, while 22% of entities continued to apply IAS 39 hedge accounting requirements. In 6% of entities it was not clear what policy was applied.

c) Among those entities that used hedge accounting, IFRS 9 hedge accounting was used in all sectors reviewed. The most extensive use of IFRS 9 hedge accounting among the entities surveyed was in Industrial Goods and Services.

d) The use of IAS 39 was most prevalent in Financial Services, Banks, and Customer Products and Services. The majority of entities reviewed in those sectors applying hedge accounting used IAS 39.

D9The UKEB Secretariat will continue to review the preliminary analysis to develop our understanding of the use of IFRS 9 hedge accounting among UK entities.

Next steps

D10The UKEB Secretariat will continue to monitor developments.

Appendix E: Financial Instruments with Characteristics of Equity

Purpose of this paper

E1The purpose of this paper is to provide the Board with an update on the IASB's redeliberation of certain proposals in the Exposure Draft Financial Instruments with Characteristics of Equity (ED).

Background

E2In November 2023, the IASB issued the ED which sought to clarify the classification requirements and principles of IAS 32 Financial Instruments: Presentation. The ED also included presentation and disclosure proposals in response to calls from users for “better information about the characteristics of financial liabilities and equity instruments that are not captured by classification alone, and about the amounts attributable to ordinary shareholders of an entity”[^19]. The UKEB issued its Final Comment Letter (FCL) in response to the ED in April 2024.

E3At its December 2025 meeting the IASB discussed initial feedback and project direction in relation to the 'fixed-for-fixed' proposals in the ED. At its February 2026 meeting, the IASB discussed and voted on possible refinements to the proposals in the ED to take account of stakeholder feedback.

IASB December 2025 Meeting

E4The ED proposed certain clarifications of when the 'fixed-for-fixed' condition in paragraph 16(b)(ii) of IAS 32 is met. These included introducing the concepts of 'preservation' and 'passage of time' adjustments.

E5The IASB staff reported mixed stakeholder feedback to the proposals[^20]. The papers noted that many stakeholders provided mixed views. While many respondents supported the efforts to provide additional guidance on particular practice questions, they disagreed with some proposals, or asked for further clarification or application guidance. Some stakeholders disagreed with the proposals, and considered them overly restrictive.

E6The UKEB FCL broadly welcomed the IASB proposals on the 'fixed-for-fixed' condition. However, the FCL recommended some clarifications to the proposed wording, and suggested that illustrative examples of both preservation and passage of time examples would be helpful. The UKEB also noted concerns that one illustrative example in the ED indicated that use of a benchmark interest rate in a contract would not meet the 'fixed-for-fixed' criteria, which would be a departure from current practice in the UK.

IASB February 2026 Meeting

E7IASB staff presented two papers[^21] to recommending finalising the ED proposals, subject to certain refinements. All thirteen IASB members tentatively voted in favour of the staff recommendations, which are summarised in the table below.

E8A number of the proposals appear to address concerns raised in the UKEB FCL, and to provide greater clarity in relation to the adjustments that would be permitted to meet the 'fixed-for-fixed' condition. In general, with the exception of the clarification relating to functional currency, these proposals would be expected to tighten the application of the 'fixed-for-fixed' criteria.

E9In relation to 'adjustments that are solely a function of time' IASB staff paper 5B explained that under the proposals contracts linked to benchmark interest rates would not be capable of meeting the 'fixed-for-fixed' condition, as they are not predetermined. This clarification would potentially represent a change to UK practice, as highlighted in the UKEB FCL.

1) The 'fixed-for-fixed' condition
Current requirements
IAS 32 requires derivatives to exchange a fixed amount of cash for a fixed number of own equity instruments to be classified as an equity instrument.
Exposure Draft Proposals
The ED proposed clarifying when the fixed-for-fixed condition is met, including where the amount of consideration exchanged for each of an entity's own equity instruments varies because of preservation or passage of time adjustments.
UKEB Comment Letter
The UKEB broadly welcomed the IASB proposals. However, the FCL also: * recommended clarifications to the guidance on passage of time and preservation adjustments; and * highlighted one illustrative example in the ED which suggested a change to existing UK practice for adjustments linked to benchmark interest rates.
IASB tentative decisions
The IASB tentatively decided to proceed with the proposed requirements in the ED, subject to minor drafting requirements and targeted improvements, including: * clarifying that a derivative meets the 'fixed-for-fixed' condition if there is a fixed amount of consideration, and either a fixed number of shares, or a fixed exchange ratio; * clarifying that when a group entity issues a derivative over shares in another group entity, the derivative could meet the 'fixed-for-fixed' condition in the consolidated accounts if the consideration amount is denominated in the functional currency of either entity; * replacing the term 'preservation adjustments' with 'adjustments that compensate the future holders of the equity instruments', and clarifying the circumstances in which such adjustments are consistent with the 'fixed-for-fixed' condition; and * replacing the term 'passage of time adjustments' with 'adjustments that are solely a function of time', and clarifying the circumstances in which such adjustments would be consistent with the 'fixed-for-fixed' condition.

Next steps

E10The IASB will continue to redeliberate the classification topics in the ED. The IASB staff presented an update to the project plan at the February meeting, with final amendments now expected in 2027, rather than the second half of 2026.

Appendix F: List of IASB projects

This Appendix provides a list of all active IASB projects[^22], including links to the IASB project page and where relevant, to the UKEB project page and any UKEB projects or comment letters. Items highlighted in grey are changed from the last report.

List of IASB projects
Introduction

This paper provides the Board with an update on projects the Secretariat is currently monitoring.

As agreed with the Board, the Secretariat monitors projects being undertaken by the IASB. This is to inform the Board about the Board about the progress and decisions being made by the IASB on active projects. Discussion by the Board may also help inform interactions with international standard setter meetings, including the IASB's Accounting Standards Advisory Forum (ASAF), of which the UKEB is a member.

Summary of the Issue
Topics addressed in this paper include topics discussed by the IASB at its February 2026 meeting and topics to be discussed at the March 2026 ASAF meeting.

Topics for discussion

  • IFRS Foundation Due Process Handbook
  • Post-implementation Review of IFRS 16 Leases
  • Equity Method

Topics for noting

  • Post-implementation Review of IFRS 9—Hedge Accounting
  • Financial Instruments with Characteristics of Equity
  • List of IASB projects
Decisions for the Board
Topics for discussion IFRS Foundation Due Process Handbook (Appendix A)

Project Type: Endorsement and adoption Project Scope: Significant

Executive Summary

Project Type
Influencing
Project Scope
Various
Purpose of the paper
This paper provides the Board with an update on projects the Secretariat is currently monitoring. As agreed with the Board, the Secretariat monitors projects being undertaken by the IASB. This is to inform the Board about the progress and decisions being made by the IASB on active projects. Discussion by the Board may also help inform interactions with international standard setter meetings, including the IASB's Accounting Standards Advisory Forum (ASAF), of which the UKEB is a member.
Summary of the Issue
Topics addressed in this paper include topics discussed by the IASB at its February 2026 meeting and topics to be discussed at the March 2026 ASAF meeting.

Topics for discussion

  • IFRS Foundation Due Process Handbook
  • Post-implementation Review of IFRS 16 Leases
  • Equity Method

Topics for noting

  • Post-implementation Review of IFRS 9—Hedge Accounting
  • Financial Instruments with Characteristics of Equity
  • List of IASB projects
Decisions for the Board
Topics for discussion IFRS Foundation Due Process Handbook (Appendix A)
1. Does the Board have any comments on the enhanced proposals to raise as key messages at the ASAF meeting?
Post-implementation Review of IFRS 16 Leases (Appendix B)
1. Do Board Members have any feedback in relation to the UKEB's key messages for ASAF relating to topics discussed at the IASB's February 2026 meeting?
2. Do Board Members have any views on the stakeholder proposals on reducing ongoing costs of applying IFRS 16 (Question 4 of RFI)?
3. Do Board Members have any views on areas stakeholders identified where additional clarity could improve consistency and reduce diversity in practice (Question 2 of RFI – Usefulness of information resulting from lessees' application of judgement)?
Equity Method (Appendix C)
1. Do Board Members have any feedback in relation to the concerns of Japanese and Chinese stakeholders?
2. Do Board Members have any feedback in relation to the UKEB's key messages for the ASAF meeting?
Topics for noting
Do Board members have any comments or questions on the topics for noting?
Recommendation
N/A
Appendices
Appendix A: IFRS Foundation Due Process Handbook Appendix B: Post-implementation Review of IFRS 16 Leases Appendix C: Equity Method Appendix D: Post-implementation Review of IFRS 9—Hedge Accounting Appendix E: Financial Instruments with Characteristics of Equity Appendix F: List of IASB Projects

Appendix A: IFRS Foundation Due Process Handbook

IFRS Foundation Research Exposure Draft Redeliberation Final DPH Published
UKEB Monitoring Influencing Monitoring -
UKEB project page
UKEB Final Comment Letter (published 28 March 2025)
IFRS Foundation project page

Purpose

A1The purpose of this paper is to seek Board Member views ahead of feedback to the IFRS Foundation Trustees' Exposure Draft (ED) Proposed Amendments to the IFRS Foundation's Due Process Handbook being discussed at the IASB's Accounting Standards Advisory Forum (ASAF) meeting, in March 2026.

A2The project update to be presented to ASAF summarises discussions of the Due Process Oversight Committee (DPOC) at its meeting on 3 March 2026, including:

a) stakeholder feedback to the ED consultation; and[^1]

b) further enhancements to the IFRS Foundation Due Process Handbook (the Handbook) made in response to the feedback.[^2]

Background

A3On 19 December 2024, the Trustees of the IFRS Foundation published the ED proposing amendments to the Handbook.

A4Primarily, amendments were proposed to reflect the creation of the International Sustainability Standards Board (ISSB) and ensure it formally applies the IFRS Foundation's due process to its operations. However, the proposed amendments also include enhancements and clarifications to the Handbook, based on the Foundation's recent experiences (for example, of post-implementation reviews).

UKEB Comment Letter

A5At its February 2025 meeting, the Board agreed to respond to the ED on the basis that the IFRS Foundation's due process has a direct impact on how the UKEB carries out its own statutory functions, including compliance with its own due process requirements.

A6Given the limited scope of the ED's proposals, the Board agreed to publish a high-level document on the UKEB website, setting out the key issues proposed for inclusion in the UKEB's Comment Letter, instead of a Draft Comment Letter. This document was also approved for circulation to the members of the UKEB advisory and working groups, via email, for their comments and views.

A7The UKEB's Final Comment Letter was submitted to the IFRS Foundation Trustees on 28 March 2025.

ASAF presentation from IFRS Foundation

A8The project update to be presented at ASAF provides the context for the Handbook's update, a summary of the consultation responses and proposals for further clarifications and enhancements to proposals in the ED.

A9The table below provides an overview of proposals in the ED, the recommendations in the UKEB Final Comment Letter and the main changes from the ED proposed.

A10In addition to the topics covered by the IFRS Foundation Trustees' consultation on the proposed amended Due Process Handbook, the UKEB proposed additional consideration be given to how the two boards analyse the likely costs and benefits of new requirements on affected parties, as well as the wider economic effects.

Question for the Board
1. Does the Board have any comments on the enhanced proposals to raise as key messages at the ASAF meeting?

Next steps

A11The UKEB Secretariat will observe the March ASAF meeting and provide an update on the discussion to the Board in due course.

Clarifying and enhancing proposals in the Exposure Draft

1. Due process for the SASB Standards and the SASB Standards Taxonomy

Proposals in the Exposure Draft
Add Appendix setting out SASB Standards due process. Retain process approved in 2022: amendments discussed in private with SASB Board Adviser Group, issued for 120 day consultation, and presented to ISSB for ratification.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED: * Urged the Foundation to apply the full due process to the SASB Standards and SASB Standards Taxonomy, if the long-term intent is for them to be required, or required in effect, rather than voluntary, or educational material. * Advised that, for the development and ratification of the SASB standards to meet the criteria of public accountability, discussions should be public and there should be transparency around appointments to the Board Adviser Group.
IFRS Foundation Staff: further proposed changes
Some respondents expressed concern with the lower level due process and the perceived lack of transparency, the size of the Board Adviser Group, the status of the SASB Standards, and the ISSB's intentions for them. The following further changes to the Handbook are proposed: * Retaining proposals relating to due process as SASB Standards are illustrative materials, but clarifying their difference in the text and specifying that if the status of SASB Standards changes so that entities are required to apply them, the SASB Standards would be subject to the full ISSB due process. * Highlighting similarities with the ISSB due process and the overarching responsibility of the ISSB for SASB Standards. * Specifying size of the Board Adviser Group is the maximum permitted by paragraph 3.43 of the Handbook. * Adding a section specifying Board Adviser Group can develop discussion papers for the ratification and publication by the ISSB.

2. Reflecting connectivity

Proposals in the Exposure Draft
Reflect aim for two boards' to work together, specifically: include the objective from the IFRS Foundation's Constitution of 'complementary sets of IFRS Standards'; reflect new processes (e.g. joint board meetings); and, add a due process step for boards to consider steps taken to develop compatible Standards, avoiding inconsistencies and conflicts with the other board's Standards.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED broadly supported the proposals to formalise connectivity in the Handbook and proposed the following additional changes: * Strengthening the objective so that it would be for the boards to ‘develop IFRS Standards that connect, where appropriate'.[^3] * Including a requirement for opportunities and risks relating to connectivity to be considered at the start of the standard setting process. * Requiring work plan consultations reflect the boards' formal and public assessment of the connectivity of proposed projects.
IFRS Foundation Staff: further proposed changes
Respondents generally welcomed the proposals but made suggestions to further foster connectivity. The following further changes to the Handbook are proposed: * Clarifying that Standards are intended to work well together but can be applied separately from each other, and alongside other parties' materials (para 1.1). * Requiring boards to consider whether to align the timing of their work plan consultations (after para 4.3). * Requiring board consideration of possible interactions with the other board's Standards when evaluating adding a standard-setting project to the work plan (after para 5.4).

3. Post-implementation reviews (PIR)

Proposals in the Exposure Draft
Clarify objective of a PIR is to assess whether effects of applying the requirements are as intended. Emphasise it is not a standard-setting project and clarify possible outcomes. Specify timing of a PIR – when sufficient information is available to assess the effects of new requirements. Clarify process for deciding whether matters arising from PIR warrant further action and, if so, how prioritised.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED: * Recommended the focus of PIRs be on whether the Standard has met its intended objective and whether the cost benefit analysis was accurate. * Recommended the Handbook specify that implementation and interpretation issues be reserved for consideration by a Transition Resource Group, or IFRIC, as relevant. * Recommended a backstop completion period be introduced for PIRs to ensure they are not deferred indefinitely.
IFRS Foundation Staff: further proposed changes
Responses were mixed and raised several issues, responded to by the following further proposed changes to the Handbook: * Refining the explanation of PIR objective by specifying that the basis of a PIR assessment is 'the objective of the Standard' (para 6.50) and that the PIR's objective is whether the Standard continues to work as intended (para 6.51). Amend para 6.52 to remove suggestion that application questions are linked to the objective of a PIR. * Amending para 6.53 to remove reference to application questions and insert a new paragraph setting out mechanisms for identifying and addressing application questions outside a PIR. * Clarifying PIR timing by specifying it is expected to begin within five years of the effective date of the new requirements, and requiring a board wishing to defer a PIR to explain its decision to the DPOC and indicate when the PIR will start (para 6.55). * Amending para 6.62 to remove suggestion that a board will only consider 'fatal flaws' or 'fundamental questions' during a PIR. Removing prioritisation guidance, which was unnecessarily detailed and potentially confusing. * Updating para 6.64 to clarify that the project summary and feedback summary will include the rationale for the board's conclusions.

4. Interpretations Committee (IFRIC)

Proposals in the Exposure Draft
Clarify term 'widespread effect' in criteria used by IFRIC to consider need for a standard-setting project, with ‘widespread effect' meaning the circumstance or transaction is prevalent and there is diversity in application.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED: * Recommended that “prevalence” was further defined e.g. by reference to the number and size of entities, relevant sizes of jurisdictional capital markets etc. * Proposed that IFRIC be able to recommend standard-setting if, after implementation of a Standard, the required accounting is leading to unintended or poor accounting outcomes.
IFRS Foundation Staff: further proposed changes
Respondents generally supported the proposed clarification but suggested further enhancements. The following further changes to the Handbook are proposed: * Clarifying 'widespread effect' (para 5.17):
  1. The Interpretations Committee assesses the need for a standard-setting project based on whether: The matter has widespread effect – that is:
    1. the circumstance or transaction is prevalent, or is expected to be prevalent; and
    2. there is diversity, or expected diversity, in the application of IFRS Accounting Standards that has, or is expected to have, a material effect on those affected.
* Codifying existing practice that IFRIC can report additional information to the IASB when confirming its decision (para 8.2). * Codifying the process for maintaining agenda decision when it issues new Standards (para 8.5) and acknowledging that the IASB can ask IFRIC to consider updating agenda decisions which would have been withdrawn to reflect new or amended requirements (para 5.14).

Including the due process for the ISSB in the Handbook

Proposals in the Exposure Draft
Specify throughout the Handbook that the ISSB is subject to the same due process requirements as the IASB.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED was supportive of the proposals.
IFRS Foundation Staff: further proposed changes
None – All respondents agreed the two boards should have the same due process. However, if there is a need for any difference that should be clearly identified and the rationale explained. Respondents expressed concern over the use ‘financial reporting' to cover both financial statements and sustainability-related disclosures but, as the terminology comes from the Conceptual Framework, it is to be retained to avoid confusion.

Conceptual Framework

Proposals in the Exposure Draft
Specify the due process for maintaining the Conceptual Framework to avoid the suggestion that future amendment would be made by the IASB alone.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED did not comment on this issue.
IFRS Foundation Staff: further proposed changes
None – respondents proposed developing a conceptual framework for sustainability standards, but it is not the Handbook's role to address future strategy or whether the ISSB will have a conceptual framework; its role is to specify the process for amending or developing a conceptual framework.

IFRS Interpretations Committee

Proposals in the Exposure Draft
Reflect that the formal remit of the Interpretations Committee in the Constitution relates to the Accounting Standards.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED: * Recommended the IFRS Foundation confirm whether an Interpretations Committee will be established to consider questions relating to the interpretation of ISSB Standards.
IFRS Foundation Staff: further proposed changes
None – respondents highlighted there was no equivalent body for ISSB Standards, but the role of the project is not to determine whether an equivalent body should be created to support the ISSB. IFRS Foundation staff recommend the Trustees initiate discussions about ISSB long-term strategy for supporting its Standards and whether an additional body may be required.

Minor improvements to IFRS Standards

Proposals in the Exposure Draft
Retire the term 'annual improvements’. Refer to packages of minor improvements instead.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED did not comment on this issue.
IFRS Foundation Staff: further proposed changes
Minor – respondents were generally supportive but suggested defining ‘minor' and allowing a 120-day comment period unless approved by the DPOC. The due process already requires boards to use their judgment in relation to whether an improvement is 'minor' but the words 'minor or narrow-scope changes' to be added for clarification. The board will be able to consider whether improvements require more than a 90 day comment period.

Other materials to support application of IFRS Standards

Proposals in the Exposure Draft
Change 'educational material' to 'material to support application of IFRS Standards' and specify due process for materials developed with third parties.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED did not comment on this issue.
IFRS Foundation Staff: further proposed changes
Minor – respondents expressed concern about the due process of previously published materials and suggested clarifying differences between the status of the various materials. Further amendments proposed to clarify materials produced by the Foundation and those produced and maintained by third party organisations; and whether materials are ‘mandatory' or 'non-mandatory'.

Other targeted amendments

Proposals in the Exposure Draft
Targeted amendments proposed to twelve other areas where small enhancements and clarifications were made, including, inter alia:
  1. requiring the DPOC to review the due process a board follows before a major new IFRS Standard or Amendment is issued;
  2. allowing surveys to be used to collect responses to formal consultations; and,
  3. explaining how boards may build on the work of other standard-setters.
UKEB Comment Letter
The UKEB Comment Letter in response to the ED: * Recommended consideration of the re-exposure requirements which do not currently include consultation with stakeholders. The UKEB recommended paragraph 6.30 require the board to consider stakeholder feedback, including from consultative groups, before making a final decision on re-exposure.
IFRS Foundation Staff: further proposed changes
Minor – respondents were generally supportive of the proposals. Respondents additional proposals would go beyond the scope of the ED and require wider consultation. Surveys being a supplementary method to responding to formal consultations to be clarified. ISSB to undertake due process to amend IFRS S2 in the event of GHG Protocol Corporate Standard being updated. No change proposed in relation to re-exposure criteria as para 6.30 states that re-exposure is more likely if changes to an ED would require a significant change from current practice.

Appendix B: Post-implementation Review of IFRS 16 Leases

IASB Research / Pipeline Discussion Paper Redeliberation Exposure Draft Redeliberation Final Standard Post Implementation Review
UKEB Research / Influencing Research / Monitoring Influencing Monitoring Endorsement Influencing UKEB Post Implementation Review
UKEB project page
UKEB Final Comment Letter (published 16 October 2025)
IASB Next Milestone: Project completion

Purpose

B1The purpose of this paper is:

a) To ask for Board Members' views on the key messages the UKEB plans to raise at the March 2026 Accounting Standards Advisory Forum (ASAF) meeting. At that meeting the IASB will seek ASAF members' views on the IASB's discussions at its January, February and March 2026 meetings relating to the feedback received on the Post-implementation Review (PIR) of IFRS 16 Leases.

b) To provide the Board with an overview of:

i. the final batch of feedback the IASB received on its Request for Information: IFRS 16 Leases (RFI), following the IASB's February 2026 meeting; and

ii. the IASB staff's update to their review of academic literature related to IFRS 16.

Background

B2In June 2025, the IASB published its RFI, to seek stakeholders' views on the requirements in IFRS 16, with a comment period ending on 15 October 2025. The UKEB's final comment letter (FCL) to the IASB was submitted on 15 October 2025. The IASB received 122 responses to the RFI and held 35 outreach events.

B3IASB staff continued providing the IASB with their summary of feedback received on the RFI, with the final aspects brought to the IASB's meeting on 25 February 2026.

February 2026 IASB meeting

B4The IASB discussed the following papers at its February 2026 meeting:

a) Feedback summaries on the following aspects of the RFI:

i. Potential improvements to future transition requirements.[^1]

ii. Other matters.[^2]

b) Academic literature review - update.[^3]

B5The IASB did not make any tentative decisions.

B6Annex 1 provides:

a) a high-level overview of the feedback received by the IASB on its RFI and of the views expressed by the UKEB in its FCL; and

b) an overview of the academic literature review update provided by the IASB staff.

UKEB views

B7For those aspects on which the UKEB expressed views in its FCL, the UKEB's views generally align with the feedback the IASB discussed during its February 2026 meeting.

March 2026 ASAF meeting

IASB staff's objective

B8The IASB plan to bring a project update and seek views from ASAF members on the IASB's discussions at its January, February and March 2026 meetings relating to the feedback received on the PIR of IFRS 16.

B9Staff papers[^4] for the March 2026 IASB meeting were only available from 16 March 2026. Therefore, the IASB ASAF paper provides only a summary of feedback and stakeholders' suggestions for reducing ongoing costs (Question 4 of RFI) and enhancing the usefulness of information resulting from lessees' application of judgement (Question 2 of RFI)[^5]. An overview of the ASAF paper is provided for the Board below:

a) On reducing ongoing costs, stakeholders recommended that the IASB consider:

i. Reducing the frequency with which lessees are required to remeasure lease liabilities.

ii. Allowing lessees to retain the existing discount rate when remeasuring lease liabilities for reassessments and lease modifications.

iii. Permitting the use of simplified discount rate approaches, such as a risk-free rate, a group or parent rate, or any readily obtainable borrowing rate.

iv. Expanding the scope of existing recognition exemptions.

v. Removing or streamlining selected disclosure requirements.

b) On the usefulness of information resulting from application of judgement, stakeholders generally supported the principles-based approach but identified areas where additional clarity could improve consistency and reduce diversity in practice. In particular, stakeholders suggested that the IASB:

i. Provide further guidance and illustrative examples on key judgements, including assessing the ‘reasonably certain' threshold for lease term and interpreting 'genuine variability' when identifying in-substance fixed payments.

ii. Clarify the requirements for determining the incremental borrowing rate and the treatment of variable lease payments.

iii. Introduce more specific disclosure requirements on significant judgements and assumptions - such as disclosures of weighted-average discount rates and methodologies applied - to enhance transparency and comparability.

iv. Consider simplifying or clarifying areas where judgement is currently viewed as unclear or overly complex.

UKEB Key messages

B10The Board was supportive of the Secretariat's proposed key messages relating to IASB discussions in January 2026 as set out in the Agenda Paper 9B of the UKEB's February 2026 meeting. These key messages included a comment that any proposed changes to simplify specific areas to mitigate ongoing costs for preparers should be carefully considered and weighed against the expected changes in benefits to users. Possible simplifications to consider include:

a) Streamlining discount rate requirements, for example by permitting use of a lessee's obtainable borrowing rate instead of the incremental borrowing rate.

b) Revising the low-value and short-term exemptions to reduce their perceived rule-based nature and enable a more principles-based, materiality-driven approach.

B11In addition to the key messages proposed in the January 2026 UKEB meeting, the Secretariat's preliminary view about key messages to convey at the ASAF meeting on the matters discussed at the IASB's February 2026 meeting is:

a) The IASB's feedback aligns with the UKEB's view that the transition requirements generally worked well, preparers valued the simplifying practical expedient, though the lack of full retrospective application may have led some users to continue adjusting back to IAS 17 figures.

b) The UKEB has not been made aware of pervasive concerns in the UK relating to applying IFRS 16 with IFRS 9 for rent concessions.

c) Stakeholder feedback to the IASB broadly agreed with the UKEB's earlier views on IFRS 15. However, many still find aspects of IFRS 16 unclear, especially when deciding whether a sale has occurred in sale and leaseback transactions. They also point to challenges around renewal options and situations where only part of an asset is leased back. In response, targeted clarifications to IFRS 16, potentially drawing on IFRS 15 guidance, could help improve consistency.

d) The UKEB has not been made aware of any specific issues in the UK around applying the partial gain or loss recognition requirements.

e) The UKEB has not identified any other significant matters relevant to the assessment of the effects of IFRS 16.

Questions for the Board
1. Do Board Members have any feedback in relation to the UKEB's key messages for ASAF relating to topics discussed at the IASB's February 2026 meeting?
2. Do Board Members have any views on the stakeholder proposals on reducing ongoing costs of applying IFRS 16 (Question 4 of RFI)?
3. Do Board Members have any views on areas stakeholders identified where additional clarity could improve consistency and reduce diversity in practice (Question 2 of RFI – Usefulness of information resulting from lessees' application of judgement)?

Next steps

B12At future meetings, the IASB will discuss its actions in response to the feedback received. More specifically, at its March 2026 meeting, the IASB will discuss staff analysis and recommendations on whether to take any actions in response to stakeholders' feedback about:

a) ongoing costs for lessees of applying the measurement requirements in IFRS 16; and

b) usefulness of information resulting from lessees' application of judgement.

B13The Secretariat will provide a verbal update to the Board at its March 2026 meeting of the IASB's March 2026 meeting to assist the Board in finalising the key messages to convey at the upcoming ASAF meeting.

B14The IASB expects to publish a project report and feedback statement before the end of 2026.

B15The Secretariat will continue to monitor the IASB discussions and update the Board as necessary.

Annex 1: Overview of feedback received by IASB against UKEB views in FCL and academic literature review update

Stakeholder feedback to IASB and UKEB FCL

1The table below provides an overview of the feedback received by the IASB against the views provided by the UKEB in its FCL.

Question 5: Potential improvements to future transition requirements
Stakeholder feedback to the IASB
Many stakeholders commented on Question 5 and, of these, most considered the transition requirements in IFRS 16 to strike an appropriate balance between reducing preparer costs and providing useful information to users. Some respondents observed that permitting multiple transition options reduced comparability. Stakeholders also offered recommendations for future standard-setting. Most of those commenting specifically on multiple transition options supported retaining flexibility, while a smaller number raised concerns about allowing more than one transition approach.
UKEB FCL
The IASB's feedback is consistent with the UKEB’s FCL, which included the following views:
  1. The UKEB is not aware of any significant concerns with the transition requirements.
  2. Preparers appreciated the practical expedient available on transition as it simplified the accounting at transition date. However, it is possible that not requiring full retrospective application contributed to some users adjusting back to IAS 17 numbers.
Question 6.1: Applying IFRS 16 with IFRS 9 Financial Instruments rent concessions
Stakeholder feedback to the IASB
Many respondents to Question 6.1- particularly standard-setters, preparers, accountancy bodies and accounting firms - said there remains insufficient clarity on how a lessee distinguishes between a lease modification under IFRS 16 and an extinguishment of a lease liability under IFRS 9 when accounting for forgiven lease payments. Stakeholders reported resulting diversity in practice. Views were mixed on how frequently rent concessions occur, but most respondents said guidance would be helpful given the potential for such concessions to re-emerge. Some noted that the 2024 Annual Improvements clarified the consequences of extinguishment under IFRS 9, but said a broader question remains about distinguishing extinguishment from modification. Most stakeholders recommended that the IASB develop guidance to reduce diversity, offering differing views on whether rent concessions should generally be treated as lease modifications or extinguishments. A few stakeholders suggested the IASB consider factors such as the unit of account, the reasons for the concession, and whether forgiven amounts relate to past or future payments. One firm noted that its guidance permits an accounting policy choice between IFRS 16 and IFRS 9.
UKEB FCL
The UKEB stated that it is aware of the IFRIC suggestion and acknowledges that there could be diversity in practice. However, the UKEB has not been made aware of pervasive concerns with applying IFRS 16 with IFRS 9 to rent concessions in the UK.
Question 6.2: Applying IFRS 16 with IFRS 15 Revenue from Contracts with Customers when assessing whether the transfer of an asset in a sale and leaseback transaction is a sale
Stakeholder feedback to the IASB
Many respondents to Question 6.2 - mainly standard-setters and some accounting bodies, preparers and firms - said it is often difficult to assess whether the transfer of an asset in a sale and leaseback transaction qualifies as a sale under IFRS 15, noting that IFRS 15 was not designed with such transactions in mind. Some preparers, however, reported no significant difficulties, either because such transactions are infrequent or because they consider IFRS 16 sufficiently clear. Several stakeholders reported diversity in judgements regarding the transfer of control in specific circumstances, particularly where renewal options cover substantially all of the asset's remaining economic life, only part of an asset is leased back, a repurchase option exists, revenue is recognised over time, or the lessee is involved in specifying an asset pre-construction. Many respondents asked the IASB to provide guidance or examples for these scenarios, clarify how control criteria apply to sale and leaseback transactions, or provide decision tools to support consistent application. A few suggested more prescriptive requirements - similar to those in FASB Topic 842 - both for assessing whether a sale has occurred and for determining whether a lessee controls an asset during construction.
UKEB FCL
The UKEB stated that its view remains broadly consistent with its response to the IASB's Post-implementation Review of IFRS 15 Revenue from Contracts with Customers (see Final Comment Letter – Post-Implementation Review of IFRS 15 Revenue from Contracts with Customers). However, some stakeholders said that aspects of IFRS 16 lack sufficient clarity to support consistent judgement, leading to diversity in practice - particularly in assessing whether the transfer of an asset in a sale and leaseback transaction qualifies as a sale. Areas identified include:
  1. renewal options: uncertainty about whether renewal options that extend the lease for (substantially) all of the asset's remaining economic life should be treated consistently with economically similar purchase options; and
  2. unit of account: uncertainty when only part of an asset is leased back.
The UKEB considers that targeted amendments to IFRS 16 - either clarifying the existing requirements or incorporating relevant guidance from IFRS 15 paragraph 38 - could help address these concerns.
Question 6.3: Applying IFRS 16 with IFRS 15 to gain or loss recognition in a sale and leaseback transaction
Stakeholder feedback to the IASB
Many respondents to Question 6.3 - across standard-setters, accounting bodies, preparers and firms - said that restricting the gain or loss in a sale and leaseback transaction provides useful information because it reflects the economic substance of the transaction, considers linked arrangements together, and reduces structuring opportunities. However, many noted that applying the partial gain or loss model is complex and costly, requiring significant judgement, intricate calculations, and additional challenges where variable lease payments not based on an index or rate are involved. Some suggested practical expedients, further guidance on measuring lease liabilities (including where variable payments depend on an index or rate), and reconsideration of inconsistencies with other lease liability measurement requirements. A smaller group - primarily from Asia-Oceania and some global firms - disagreed with restricting gains or losses. They said the approach is inconsistent with IFRS 15, reduces comparability with Topic 842, introduces complexity that obscures performance, creates inconsistencies in accounting for variable lease payments, and diverges from lessor accounting in IFRS 16. These stakeholders recommended an approach aligned with Topic 842, recognising gains or losses in full when a sale occurs and excluding variable payments not based on an index or rate from lease liabilities.
UKEB FCL
The UKEB has not been made aware of any specific issues around applying the partial gain or loss recognition requirements.
Question 6.4: Other matters relevant to the assessment of the effects of IFRS 16
Stakeholder feedback to the IASB
Lessor accounting Some stakeholders - mainly standard-setters, accounting bodies, preparers and firms - raised concerns about the limited guidance for lessors in IFRS 16 compared with the detailed lessee requirements. A few noted diversity in practice on matters such as remeasurement of the net investment in the lease, applying IFRS 9 impairment, accounting for unguaranteed residual values, and recognising operating lease income when collectability is uncertain. These stakeholders suggested the IASB provide additional requirements or guidance. A small number also raised concerns about specific requirements, including separating lease and non-lease components (particularly in real estate), accounting by intermediate lessors for variable payments, principal-agent considerations in subleases, and the interaction between manufacturer/dealer lessor requirements and IFRS 15. Determining the scope of IFRS 16 and identifying a lease Some stakeholders highlighted challenges in determining whether a contract contains a lease, including assessing who directs the use of an asset, whether substitution rights are substantive (including in circular-economy arrangements), and how to treat complex power purchase agreements. Others said it remains unclear whether cloud computing, digital infrastructure or similar arrangements fall within IFRS 16, IAS 38 Intangible Assets or service contract guidance. A few also raised concerns about distinguishing in-substance purchases from leases. Most asked the IASB to provide clearer guidance or examples. Corporate wrappers Some stakeholders asked the IASB to clarify how IFRS 16 interacts with IFRS 10 when a subsidiary (or single-asset entity) is sold and its assets leased back. They said it is unclear whether to apply IFRS 10 Consolidated Financial Statements or IFRS 15 to the control assessment and whether to recognise a full or partial gain. Although the IASB has included this issue in its maintenance pipeline, some urged it to be addressed sooner. A few offered differing views on whether IFRS 10, IFRS 16, or a combination should apply. Other matters A small number of respondents raised concerns about: * recognition patterns for lease-related expenses, including double-counting issues and mismatches for intermediate lessors; * usefulness and consistency of requirements for variable lease payments not based on an index or rate; * the application of IAS 21 The Effects of Changes in Exchange Rates and IAS 29 Financial Reporting in Hyperinflationary Economies; * lack of guidance on subleases, non-cash consideration, maintenance, lease deposits, VAT, separating non-lease components, impairment of right-of-use assets, and interactions with IFRS 11 Joint Arrangements, IFRS 3 Business Combinations and IFRS 5 Non-current Assets Held for Sale and Discontinued Operations, * whether to require reconciliations of movements in right-of-use assets and lease liabilities. A few stakeholders commented on costs for entities outside the IFRS for SMEs Standard, and some expressed concerns about PIR timing - suggesting earlier reviews and greater use of the IFRS Interpretations Committee and transition resource groups.
UKEB FCL
The UKEB has not been aware of any other significant matters relevant to the assessment of the effects of IFRS 16.

Academic literature review update

2At its March 2025 meeting the IASB discussed an overview of the academic literature relevant to the PIR of IFRS 16. During its February 2026 meeting, the IASB staff presented a summary of the additional academic literature relevant to the PIR of IFRS 16, identified since the initial review.

3The feedback included the following:

a) Recent academic evidence indicates that IFRS 16 has had significant effects on entities' financial statements and key ratios, with impacts differing by sector. Studies also observed continued diversity in how entities present and explain lease-related impacts in practice.

b) Research from one jurisdiction suggested that early compliance with IFRS 16 disclosure requirements was moderate and higher among entities audited by Big Four firms.

c) Several studies found that IFRS 16 improved the usefulness of lease information for users, including evidence of enhanced investment and financing decisions and reduced share-price-crash risk for lease-intensive entities.

d) Findings on comparability were mixed: some studies reported improved transparency and comparability, while others found that differences between IFRS 16 and Topic 842 can influence user judgements and increase information-processing costs.

e) Evidence on real effects showed operational impacts—such as system changes and implementation costs—alongside improvements in internal controls and decision-making. Some studies also indicated increases in leasing activity, reduced capital expenditure and debt financing, and improved investment efficiency following implementation.

Appendix C: Equity Method

IASB Research / Pipeline Discussion Paper Redeliberation Exposure Draft Redeliberation Final Standard Post Implementation Review
UKEB Research / Influencing Research / Monitoring Influencing Monitoring Endorsement Influencing UKEB Post Implementation Review
UKEB project page
UKEB Final Comment Letter (published 16 December 2024)
IASB Next Milestone: Decide Project Direction (expected March 2026)

Purpose

C1The purpose of this paper is:

a) To provide an update on the IASB's deliberation at its February 2026 meeting on the proposal in the Exposure Draft (ED) Equity Method of Accounting IAS 28 Investments in Associates and Joint Ventures (revised 202x) relating to impairment of an investment.

b) To ask for Board Members' views on the key messages the UKEB plans to raise at the March 2026 Accounting Standards Advisory Forum (ASAF) meeting, on the proposal in the ED relating to recognition of full gains and losses on transactions with associates and joint ventures (JVs).

Background

C2In September 2024, the IASB published its ED, which aimed to:

a) clarify and add to the requirements in IAS 28 to answer application questions about how to apply the equity method of accounting;

b) reorder the requirements in a more logical and consistent way to help companies with the application of the Standard i.e. improve the understandability; and

c) improve the disclosure requirements in IFRS 12 Disclosure of Interests in Other Entities and IAS 27 Separate Financial Statements to complement the proposed amendments to IAS 28.

C3The UKEB undertook a ‘light touch' approach in responding to the ED and is not aware of pervasive or material concerns for the UK arising from the proposals. Therefore, the UKEB supported the proposals in the ED, but did not comment on each specific proposal.

C4In May 2025, the IASB discussed feedback it received on the ED. The Board received an update at its September 2025 meeting[^6].

C5In September 2025, the IASB commenced its deliberations of the ED proposals. The Board has received regular updates, on IASB's decisions/tentative decisions[^7]. A summary of those decisions in the project plan and on redeliberating the proposals in the ED to date can be found in Appendix A of the March 2026 IASB Staff agenda paper 13.

C6According to the IASB's published workplan, the IASB is expected to decide on the project direction in March 2026.

IASB February 2026 meeting

Impairment of an investment

C7At its February 2026 meeting, the IASB continued its redeliberation of the proposals in the ED and discussed impairment of an investment. A summary of the ED proposal, other background information and tentative decisions on the topic discussed at the meeting are presented in Annex 1 of this paper.

Transaction with associates and JVs

C8At that meeting, the IASB continued to redeliberate the ED proposal that an investor recognises in full any gains or losses that result from transactions with its associates and JVs, due to concerns it received from some stakeholders in some jurisdictions.

C9At its October 2025 meeting, the IASB had decided to undertake further work:

a) to understand the concerns of respondents who said the proposals could increase opportunities for earnings management; and

b) to understand whether enhancing disclosures or adding guidance might resolve these concerns.

C10The IASB discussed feedback from further stakeholder meetings on the ED proposal[^8]. The overall messages from the stakeholder meetings were:

a) All groups of Japanese and Chinese meeting participants strongly disagree with the proposal. Investment in associates is pervasive in their jurisdictions and is an important feature of how entities conduct their business[^9]. Their main concerns are:

i. It will increase earnings management opportunities which will lead to significant distortions in profits and losses and result in a presentation that is less aligned with the business model of investors in associates and JVs.

ii. It is inconsistent with the fundamental principle that an investor recognises its share of the investee's financial performance based on its ownership interest.

iii. It is a fundamental change without undertaking a fundamental review of the equity method. The inconsistency between IAS 28 and IFRS 10 Consolidated Financial Statements does not justify the need for such a fundamental change because sales of businesses to an associate are relatively infrequent.

b) Whilst these transactions are captured by IAS 24 Related Party Disclosures, some regulators stressed the need for greater transparency, as preparers often disclose minimal information under the existing requirements. Regulators asked for enforceable specific disclosure requirements, such as the rationale for a transaction and how transactions are priced.

c) Discussion with some European preparers, about the concerns of Japanese and Chinese stakeholders, did not change those preparers' support for the ED proposal. The European preparers continue to support the ED proposal, citing the IASB's cost-benefit assessment of the proposals.

March 2026 ASAF meeting

Transactions with associates and joint ventures

C11The IASB will seek feedback on this specific topic at the forthcoming ASAF meeting at the end of March 2026.

C12In February 2026, the Secretariat provided the Board with an update on this topic (for noting)[^10]. That paper set out details of this ED proposal, the IASB's rationale, a summary of ED feedback received, and further outreach being undertaken by the IASB. As noted in that paper, the UKEB supported the proposals in the ED, but did not comment on the specific ED proposals in its comment letter.

C13To inform UKEB views to be shared at the forthcoming ASAF meeting, the Secretariat started to undertake outreach with UKEB Advisory Groups (AGs), specifically investors[^11], regarding the concerns expressed by some of the IASB's stakeholders in some jurisdictions and provided feedback in that paper.

C14The Secretariat has continued to seek feedback from other UKEB AGs[^12]. This paper provides the Board with an update on outreach with Accounting firms and Institutes and Preparers, and details the specific questions that the IASB staff will be asking at the forthcoming ASAF meeting, along with the Secretariat's suggested UKEB key messages.

IASB staff's objective

C15At the March 2026 ASAF meeting, the IASB will seek ASAF members' views on two aspects of the feedback received from its further work undertaken on the ED proposal:

a) the implications of the ED proposals for users of financial statements[^13]; and

b) the ability of an investor in an associate or JVs to obtain information from its associates/JVs for the application of the requirements in IAS 28 in preparing consolidated financial statements[^14].

C16In particular, ASAF members will be asked the following questions:

Questions for ASAF members
1. Is there evidence from your jurisdiction that users of financial statements focus on:
  1. profit or loss attributable to shareholders of the parent entity for the reporting period; or
  2. group operating profit or loss for the year in consolidated financial statements (including if disclosures on segment performance and other voluntary disclosures use profit or loss attributable to shareholders of the parent entity)?
2. IFRS 12 requires an entity to provide a reconciliation of the summarised information presented about a JV or associate to the carrying amount of that investment in the statement of financial position. In your jurisdiction, as part of this reconciliation, do entities disclose information about restricted gains and losses?
  1. if such information is disclosed, how do users of financial statements use this information?
  2. if such information is not disclosed, do you think the information would be useful to users of financial statements?
3. In restricting gains and losses on transactions with associates and JVs (when applying IAS 28) we (the IASB staff) understand:
  1. some entities adjust the income from equity accounted investments;
  2. other entities adjust the line-item in the income statement (such as revenue and cost of sales).
What, if any, is the prevailing practice in your jurisdiction? 4. Do investors in associates and JVs in your jurisdiction find it difficult to obtain information from its JVs or associates to comply with the requirements in IAS 28? If so, what are the challenges in accessing that information?

UKEB Advisory Groups feedback

UKEB Preparer Advisory Group (PAG)

C17PAG members supported the ED proposal to recognise gains and losses in full because:

a) it resolves the inconsistency between IAS 28 and IFRS 10 Consolidated Financial Statements; and

b) upfront full recognition of gains and losses is simpler, as it eliminates the need to track the unrecognised portion of gains and losses that is deferred under the current requirements in IAS 28.

C18When questioned whether, in response to feedback on the ED, additional disclosures on 'upstream' transactions or the rationale for transactions and their pricing, for either associates or JVs, could be a way forward to help users understand transactions, PAG members raised the following concerns:

a) Providing this information would be burdensome for preparers, particularly for those companies with a significant number of JVs and associates.

b) Challenges include completeness and timeliness of obtaining the necessary information from associates and JVs for any additional disclosures, given that a company does not have control over associates and JVs.

c) Detailed disclosures on transactions with associates and JVs are provided at the request of the regulator. However, the benefits of this information for users are questionable.

C19Other key points raised were:

a) Applying full recognition of gains and losses retrospectively would lead to some initial costs, but ongoing costs are not expected to increase.

b) Materiality would apply and therefore the impact of the ED proposal is not expected to be significant for most companies, as associates and JVs are not material.

UKEB Accounting Firms and Institutes Advisory Group (AFIAG)

C20Similar to PAG members, AFIAG members supported the ED proposal because it is simpler and less burdensome than the recognition currently required by IAS 28 to restrict gains and losses. Other key points raised by AFIAG members were:

a) Applying the current requirements in IAS 28 is challenging for companies in some circumstances.

b) Concerns raised by some respondents to the ED proposal on the potential for earnings management were acknowledged but not shared by AFIAG members.

c) AFIAG members noted that there are different views in practice on whether the equity method is a measurement method or a one-line consolidation.

d) AFIAG members observed that companies, in general, do not disclose information about restricted gains and losses as part of the IFRS 12 requirements for an entity to provide a reconciliation of the summarised information presented about a JV or associate to the carrying amount of that investment in the statement of financial position.

UKEB Key messages

C21The Secretariat's preliminary view about UKEB key messages to convey at the ASAF meeting is:

a) There are merits in the ED proposal i.e. simpler and less costly to apply for preparers. Users also noted that the current partial recognition requirements in IAS 28 add 'noise' when gains are deferred and reversed over time.

b) Feedback received indicates that, in general, companies in the UK do not disclose information about restricted gains and losses, currently recognised under IAS 28, as they tend not to be material.

c) At times it is challenging for preparers to gather complete and timely information from their associates and JVs, given that they do not exercise control.

d) Whilst users have indicated that the ED proposal may provide an opportunity for earnings management, it is considered that the risk of manipulation is likely to be limited in most cases, due to lack of materiality.

e) Calls for additional disclosures appear to be arising from regulators who are concerned about compliance, rather than a deficiency in the standard. Additional disclosures should not be needed given the existing disclosure requirements for related-party transactions under IAS 24. The UKEB understands that a preparer would consider the requirements in IAS 24 with due regard to the materiality (nature/magnitude) of the information, given the disclosure requirements under IAS 1 Presentation of Financial Statements paragraphs 7 and 31.

Paragraph 7 of IAS 1 includes a definition of materiality.

Material:

Information is material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that the primary users of general-purpose financial statements make on the basis of those financial statements, which provide financial information about a specific reporting entity.

Materiality depends on the nature or magnitude of information, or both. An entity assesses whether information, either individually or in combination with other information, is material in the context of its financial statements taken as a whole.

Information is obscured if it is communicated in a way that would have a similar effect for primary users of financial statements to omitting or misstating that information. The following are examples of circumstances that may result in material information being obscured:

a) information regarding a material item, transaction or other event is disclosed in the financial statements but the language used is vague or unclear;

b) information regarding a material item, transaction or other event is scattered throughout the financial statements;

c) dissimilar items, transactions or other events are inappropriately aggregated;

d) similar items, transactions or other events are inappropriately disaggregated; and

e) the understandability of the financial statements is reduced as a result of material information being hidden by immaterial information to the extent that a primary user is unable to determine what information is material.

Assessing whether information could reasonably be expected to influence decisions made by the primary users of a specific reporting entity's general purpose financial statements requires an entity to consider the characteristics of those users while also considering the entity's own circumstances.

Many existing and potential investors, lenders and other creditors cannot require reporting entities to provide information directly to them and must rely on general purpose financial statements for much of the financial information they need. Consequently, they are the primary users to whom general purpose financial statements are directed. Financial statements are prepared for users who have a reasonable knowledge of business and economic activities and who review and analyse the information diligently. At times, even well informed and diligent users may need to seek the aid of an adviser to understand information about complex economic phenomena.

Extract from paragraph 31 of IAS 1:

An entity shall also consider whether to provide additional disclosures when compliance with the specific requirements in IFRS is insufficient to enable users of financial statements to understand the impact of particular transactions, other events and conditions on the entity's financial position and financial performance.

Questions for the Board
1. Do Board Members have any feedback in relation to the concerns of Japanese and Chinese stakeholders (see paragraph C10)?
2. Do Board Members have any feedback in relation to the UKEB's key messages for the ASAF meeting (see paragraph C21)?

Next steps

C22The IASB will continue redeliberating the ED proposals over the next few months, in line with the redeliberation plan outlined in paragraph 27 of Agenda Paper 13 for the IASB's June 2025 meeting.

C23The UKEB Secretariat will continue to monitor the IASB's redeliberation and tentative decisions and will continue to provide the Board with updates.

Annex 1: IASB's tentative decisions – February 2026

Impairment of an investment

Current requirements
Paragraph 40 of IAS 28 requires an investor to apply paragraphs 41A-41C of the Standard to determine whether there is any objective evidence that its net investment in an associate is impaired. If application of paragraphs 41A-41C indicates that its net investment might be impaired, paragraph 40 of IAS 28 requires the investor to test its net investment for impairment in accordance with IAS 36 Impairment of Assets. Among other things, paragraph 41C of IAS 28 states that “A significant or prolonged decline in the fair value of an investment in an equity instrument below its cost is also objective evidence of impairment".
Exposure Draft proposals
The ED proposed:
  1. to replace 'decline...below its cost' in paragraph 41C of IAS 28 with ‘decline...to less than its carrying amount';
  2. to remove the reference to a 'significant or prolonged' decline in fair value; and
  3. to add requirements to IAS 28 explaining that when the investor determines whether its net investment might be impaired, information about the fair value of the investment might be observed from the price paid to purchase an additional interest in the associate or received to sell part of the interest, or from a quoted market price for the investment.
UKEB Comment Letter
In its Comment letter, the UKEB supported the ED proposal.
IASB tentative decisions
In considering the feedback on the ED, the IASB decided to proceed with its ED proposals regarding impairment indicators. In addition to the ED proposals, the IASB also tentatively decided to:
  1. explain that a single, discrete event might not by itself indicate an impairment and that instead the combined effect of several events might indicate an impairment;
  2. clarify that the investor is required to consider observable information that comes to its attention when the investor determines whether its net investment in an associate might be impaired;
  3. clarify that for a publicly traded associate, the investor considers the quoted market price at the reporting date;
  4. not to move the impairment requirements from IAS 28 to IAS 36 Impairment of Assets[^15]; and
  5. not to consider two application issues[^16] relating to the reversal of an impairment loss.
UKEB Secretariat preliminary view
The IASB's tentative decisions are consistent with the ED proposals, with some additional clarifications. The UKEB final comment letter supported the ED proposals.

Appendix D: Post-implementation Review of IFRS 9—Hedge Accounting

Purpose of this paper

D1The purpose of this paper is to provide the Board with an update on the IASB's post-implementation review (PIR) of the hedge accounting requirements in IFRS 9 Financial Instruments, and some preliminary UKEB Secretariat desktop research on this topic.

Background

D2In December 2025, the IASB decided to start the PIR. At its February 2026 meeting, the IASB discussed the objective, activities and timeline for the first phase of the PIR.

IASB February 2026 Meeting

D3IASB staff presented a project plan[^17] for phase one of the PIR. Phase one includes initial outreach with the IFRS Foundation's IFRS Accounting Advisory Groups, meetings with other small groups of stakeholders, and a review of academic research. The purpose of the initial outreach is to inform the request for information which will be used to seek feedback from stakeholders. Phase two of the project will consider the feedback received in the public consultation.

D4The project plan sets out the objective of the PIR. This includes consideration of whether:

a) The objective of the hedge accounting requirements in IFRS 9 is being met. This objective is described in the paper as: 'to represent, in the financial statements, the effect of an entity's risk management activities that use financial instruments to manage exposures arising from particular risks that could affect profit or loss'[^18].

b) The benefits to users from the resulting information are broadly as expected.

c) The costs of applying some or all of the new requirements and auditing and enforcing their application are broadly as expected.

D5The project plan indicates that the IASB staff expect the overall PIR to take around 24 months to complete. The timeline for phase one includes outreach to consultative groups from March to May 2026. This includes the Accounting Standards Advisory Forum, the IFRS Interpretations Committee, the Capital Markets Advisory Committee and the Financial Instruments Consultative Group, all of which are scheduled in March 2026.

D6The IASB expect to publish the request for information in the second half of 2026, with a 120-day comment period.

UKEB Secretariat preliminary desktop research

D7The UKEB Secretariat has carried out preliminary desktop research into the prevalence of hedge accounting among listed entities in the UK. A text-based search of annual report filed in 2025 referring to the term "hedge” identified 328 companies. The Secretariat reviewed 111 of these annual reports and identified that 68 of the 111 applied hedge accounting.

D8The preliminary analysis of those applying hedge accounting indicates that:

a) Hedge accounting is used across a wide range of industries.

b) 72% of entities reviewed applied IFRS 9 hedge accounting, while 22% of entities continued to apply IAS 39 hedge accounting requirements. In 6% of entities it was not clear what policy was applied.

c) Among those entities that used hedge accounting, IFRS 9 hedge accounting was used in all sectors reviewed. The most extensive use of IFRS 9 hedge accounting among the entities surveyed was in Industrial Goods and Services.

d) The use of IAS 39 was most prevalent in Financial Services, Banks, and Customer Products and Services. The majority of entities reviewed in those sectors applying hedge accounting used IAS 39.

D9The UKEB Secretariat will continue to review the preliminary analysis to develop our understanding of the use of IFRS 9 hedge accounting among UK entities.

Next steps

D10The UKEB Secretariat will continue to monitor developments.

Appendix E: Financial Instruments with Characteristics of Equity

Purpose of this paper

E1The purpose of this paper is to provide the Board with an update on the IASB's redeliberation of certain proposals in the Exposure Draft Financial Instruments with Characteristics of Equity (ED).

Background

E2In November 2023, the IASB issued the ED which sought to clarify the classification requirements and principles of IAS 32 Financial Instruments: Presentation. The ED also included presentation and disclosure proposals in response to calls from users for “better information about the characteristics of financial liabilities and equity instruments that are not captured by classification alone, and about the amounts attributable to ordinary shareholders of an entity”[^19]. The UKEB issued its Final Comment Letter (FCL) in response to the ED in April 2024.

E3At its December 2025 meeting the IASB discussed initial feedback and project direction in relation to the 'fixed-for-fixed' proposals in the ED. At its February 2026 meeting, the IASB discussed and voted on possible refinements to the proposals in the ED to take account of stakeholder feedback.

IASB December 2025 Meeting

E4The ED proposed certain clarifications of when the 'fixed-for-fixed' condition in paragraph 16(b)(ii) of IAS 32 is met. These included introducing the concepts of 'preservation' and 'passage of time' adjustments.

E5The IASB staff reported mixed stakeholder feedback to the proposals[^20]. The papers noted that many stakeholders provided mixed views. While many respondents supported the efforts to provide additional guidance on particular practice questions, they disagreed with some proposals, or asked for further clarification or application guidance. Some stakeholders disagreed with the proposals, and considered them overly restrictive.

E6The UKEB FCL broadly welcomed the IASB proposals on the 'fixed-for-fixed' condition. However, the FCL recommended some clarifications to the proposed wording, and suggested that illustrative examples of both preservation and passage of time examples would be helpful. The UKEB also noted concerns that one illustrative example in the ED indicated that use of a benchmark interest rate in a contract would not meet the 'fixed-for-fixed' criteria, which would be a departure from current practice in the UK.

IASB February 2026 Meeting

E7IASB staff presented two papers[^21] to recommending finalising the ED proposals, subject to certain refinements. All thirteen IASB members tentatively voted in favour of the staff recommendations, which are summarised in the table below.

E8A number of the proposals appear to address concerns raised in the UKEB FCL, and to provide greater clarity in relation to the adjustments that would be permitted to meet the 'fixed-for-fixed' condition. In general, with the exception of the clarification relating to functional currency, these proposals would be expected to tighten the application of the 'fixed-for-fixed' criteria.

E9In relation to 'adjustments that are solely a function of time' IASB staff paper 5B explained that under the proposals contracts linked to benchmark interest rates would not be capable of meeting the 'fixed-for-fixed' condition, as they are not predetermined. This clarification would potentially represent a change to UK practice, as highlighted in the UKEB FCL.

1) The 'fixed-for-fixed' condition
Current requirements
IAS 32 requires derivatives to exchange a fixed amount of cash for a fixed number of own equity instruments to be classified as an equity instrument.
Exposure Draft Proposals
The ED proposed clarifying when the fixed-for-fixed condition is met, including where the amount of consideration exchanged for each of an entity's own equity instruments varies because of preservation or passage of time adjustments.
UKEB Comment Letter
The UKEB broadly welcomed the IASB proposals. However, the FCL also: * recommended clarifications to the guidance on passage of time and preservation adjustments; and * highlighted one illustrative example in the ED which suggested a change to existing UK practice for adjustments linked to benchmark interest rates.
IASB tentative decisions
The IASB tentatively decided to proceed with the proposed requirements in the ED, subject to minor drafting requirements and targeted improvements, including: * clarifying that a derivative meets the 'fixed-for-fixed' condition if there is a fixed amount of consideration, and either a fixed number of shares, or a fixed exchange ratio; * clarifying that when a group entity issues a derivative over shares in another group entity, the derivative could meet the 'fixed-for-fixed' condition in the consolidated accounts if the consideration amount is denominated in the functional currency of either entity; * replacing the term 'preservation adjustments' with 'adjustments that compensate the future holders of the equity instruments', and clarifying the circumstances in which such adjustments are consistent with the 'fixed-for-fixed' condition; and * replacing the term 'passage of time adjustments' with 'adjustments that are solely a function of time', and clarifying the circumstances in which such adjustments would be consistent with the 'fixed-for-fixed' condition.

Next steps

E10The IASB will continue to redeliberate the classification topics in the ED. The IASB staff presented an update to the project plan at the February meeting, with final amendments now expected in 2027, rather than the second half of 2026.

Appendix F: List of IASB projects

This Appendix provides a list of all active IASB projects[^22], including links to the IASB project page and where relevant, to the UKEB project page and any UKEB projects or comment letters. Items highlighted in grey are changed from the last report.

List of IASB projects