Response 3 - Aviva

Call for comments on the Exposure Draft Amendments to the Fair Value Option for Investments in Associates and Joint Ventures

Deadline for completion of this Invitation to Comment:

Midday, Saturday 4 April 2026

Please submit to: [email protected]

Introduction

The objective of this Invitation to Comment is to obtain input from stakeholders on the UK Endorsement Board's (UKEB's) Draft Comment Letter (DCL) on the Exposure Draft (ED) Amendments to the Fair Value Option (IAS 28) published by the International Accounting Standards Board (IASB) on 19 February 2026. The IASB's comment period ends on 20 April 2026.

UK endorsement and adoption process

The UKEB is responsible for endorsement and adoption of IFRS for use in the UK and therefore is the UK's National Standard Setter for IFRS. The UKEB also leads the UK's engagement with the IFRS Foundation (Foundation) on the development of new standards, amendments and interpretations. This letter is intended to contribute to the IASB's due process. The views expressed by the UKEB in this letter are separate from, and will not necessarily affect the conclusions in, any endorsement and adoption assessment on new or amended International Accounting Standards undertaken by the UKEB.

Who should respond to this Invitation to Comment?

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

How to respond to this Invitation to Comment

Please download this document, answer any questions on which you would like to provide views, and return it together with the 'Your Details' form to [email protected] by midday on Saturday 4 April 2026

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

Privacy and other policies

The data collected through responses to this document will be stored and processed by the UKEB. By submitting this document, you consent to the UKEB processing your data for the purposes of influencing the development of and adopting IFRS for use in the UK. For further information, please see our Privacy Statements and Notices and other Policies (e.g. Consultation Responses Policy and Data Protection Policy)¹.

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

Questions

Scope of fair value option (IAS 28)

1The UKEB's draft comment letter (DCL) proposes rationalising the scope paragraph of the fair value option in IAS 28 to make it concise and principles-based. Do you agree with this position? Please explain why or why not.

We are supportive of the change; however, we suggest that the examples of types of entities that could have ‘investing in assets' as a main business activity is retained to provide more practical guidance to preparers, while making it clear that the list is non-exhaustive. E.g. “Examples of entities which could have a main business activity of investing in particular types of assets include a venture capital organisation, a mutual fund or a unit trust. This list is not exhaustive.” As a consequence of rationalising the scope in paragraph 18, paragraph 19 should also be updated to align with the revised wording.

2The UKEB's DCL raises a concern about ED paragraphs BC17 and BC 18, which refer to the ability to revoke the fair value option in IAS 28, as they do not relate to the scope of the fair value option in IAS 28. Do you agree with this position? Please explain why or why not.

BC17 and BC18 introduce the concept of the FV option being irrevocable, citing paragraph 18 of IAS 28. Both the current version and the ED of IAS 28 make no reference within para 18 to the irrevocable nature of the FV option, and therefore the BC as drafted is misleading. If the IASB intend to make the election explicitly irrevocable, this should be clearly outlined in the main body of the standard, but we believe that this decision is not within the intended scope of the current amendments.

In addition, the IAS 28 FV option as proposed in the ED is now linked to the specified main business activity of an entity under IFRS 18. We believe the IASB should separately consider, outside of the scope of these narrow scope amendments, how an entity should account for a change in circumstances where it no longer invests in joint ventures and associates as its main business activity.

3The IASB's Exposure Draft includes an alternative view supporting opening the fair value option in IAS 28 to all entities. This is addressed in Appendix A, paragraph A3 of the DCL. Do you have any comments on the alternative view or our view in relation to it, as set out in Appendix A, paragraph A3 of the DCL?

We have no comments regarding this matter.

Other

4The UKEB's DCL supports the proposed amendments in relation to the effective date and transition. Do you agree with this position? Please explain why or why not.

We are supportive of the effective date and transition, as this will allow entities to change their accounting policies on adoption of IFRS 18 on 1 January 2027.

5Do you have any other comments on the IASB's Exposure Draft or the UKEB's DCL you would like to share?

N/A

Response generation

6Did you/your organisation use a large language model (e.g. Chat GPT, Microsoft Copilot) to create any part of your/its response (response to this Invitation to Comment or a comment letter you are submitting as part of your response)?

7If you answered yes to Question 6, please specify which model and what prompt(s) you used for the large language model.

Thank you for completing this Invitation to Comment

Please submit this document by midday on Saturday 4 April 2026 to [email protected]

---