Feedback Statement - IFRS 19 Subsidiaries without Public Accountability Disclosures

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The UK Endorsement Board (UKEB) is the UK National Standard Setter for IFRS, responsible for the endorsement and adoption of international accounting standards, for use in the UK. The UKEB also leads the UK’s engagement with the IFRS Foundation on the development of new standards, amendments and interpretations.

Purpose of this Feedback Statement

This Feedback Statement presents the views of UK stakeholders received during the UKEB’s public consultation on the [Draft] Endorsement Criteria Assessment (ECA) of IFRS 19 Subsidiaries without Public Accountability: Disclosures and, where relevant, explains how the UKEB has addressed those views in the final ECA.

Description of IFRS 19

Overall

IFRS 19 Subsidiaries without Public Accountability: Disclosures was issued by the IASB in May 2024. Consequential amendments to IFRS 19 were issued in May 2024 and December 2024, and Amendments to IFRS 19 were issued in August 2025. The amended Standard is effective for annual reporting periods beginning on or after 1 January 2027, with earlier application permitted.

IFRS 19 is a new reduced disclosure IFRS Accounting Standard which aims to simplify the preparation of financial statements for eligible subsidiaries by reducing the required disclosures in their financial statements, compared with disclosure requirements in full IFRS Accounting Standards.

The IASB developed IFRS 19 in response to demand from stakeholders, particularly preparers, who requested that eligible subsidiaries with a parent that applies IFRS Accounting Standards in its consolidated financial statements should be permitted to apply IFRS Accounting Standards with reduced disclosure requirements.

IFRS 19 sets out the reduced disclosure requirements, which are organised by IFRS Accounting Standard.

Main Requirements

Aspect	Main Requirements
Scope	IFRS 19 is a voluntary standard. A subsidiary is eligible to apply IFRS 19 if: • it does not have public accountability; and • it has an ultimate or intermediate parent that produces consolidated financial statements that comply with IFRS Accounting Standards and are available for public use.
Definition of public accountability	An entity has public accountability if: • its debt or equity instruments are traded in a public market; or • it holds assets entrusted to it by its customers i.e. in a fiduciary capacity (for example, banks and insurance companies).
Disclosure requirements	IFRS 19 is a disclosure-only standard. An eligible subsidiary that applies the Standard does so by applying the recognition, measurement, and presentation requirements in other IFRS Accounting Standards and the reduced disclosure requirements in IFRS 19.
Statement of compliance	IFRS 19 is part of IFRS Accounting Standards. An eligible subsidiary applying IFRS 19 asserts its compliance with IFRS Accounting Standards and states that it has applied IFRS 19.

Stakeholder Feedback

Prior to publishing the [Draft] ECA, the Board gathered stakeholder feedback from all relevant stakeholder categories and incorporated it into the [Draft] ECA. Engagement included:

UKEB advisory group meetings (the Preparer Advisory Group, the Accounting Firms and Institutes Advisory Group and the Investor Advisory Group).
Targeted engagement (1:1 interviews) with preparers and users (principally bank lending departments).

Following publication of the [Draft] ECA, stakeholder engagement activities included:

Public consultation on the [Draft] ECA, which was published for consultation for 90 days, between 28 November 2025 and 26 February 2026.
Promotion of the IFRS 19 [Draft] ECA consultation through News Alerts, LinkedIn posts, the UKEB website and targeted emails to UK stakeholders.

UKEB Consultation on the Draft [ECA]

Nine formal responses from stakeholders were received.
Stakeholder submissions received were published on the UKEB website.
All stakeholder comments and views were considered in reaching the UKEB’s final assessment of IFRS 19.

Stakeholder type	Number of formal responses
Accounting firms	5
Professional body	1
Academic	1
Not-for-profit organisation	1
Individual	1
Total	9

The majority of respondents to the [Draft] ECA concurred with the UKEB’s assessment based on the adoption criteria in paragraph 1 of Regulation 7 SI 2019/685 and are supportive of the adoption of IFRS 19.

Detailed Assessment

Glossary

The remainder of this feedback statement makes use of the following acronyms and abbreviations:

TAC: Technical Accounting Criteria
LTPG: Long Term Public Good
True and Fair: True and Fair View Assessment
Sig. Change: Significant Change in Accounting Practice

Technical Accounting Criteria Assessment (Section 4)

UKEB Tentative Assessment	Stakeholder Views	UKEB Final Assessment
The [Draft] ECA tentatively concluded that IFRS 19 meets the criteria of relevance, reliability, understandability and comparability required of the financial information needed for making economic decisions and assessing the stewardship of management, as required by Regulation 7(1) of SI 2019/685.	Six respondents (four from accounting firms and a professional body, and one individual) agreed with the UKEB’s tentative conclusion in the [Draft] ECA. One respondent suggested the TAC focus on the differences in the disclosure requirements of IFRS 19 and the Financial Reporting Standard 101 Reduced Disclosure Framework (FRS 101). One respondent observed that paragraph 2.4 of the [Draft] ECA indicates that the overall assessment against the TAC adopts an absolute, rather than a relative, approach whilst paragraph 2.8 of the [Draft] ECA states this assessment focuses on whether the disclosure requirements in IFRS 19 will continue to meet the needs of the users of eligible subsidiaries’ financial statements. This respondent suggested amending the wording in the [Draft] ECA to avoid this inconsistency.	No further action. The TAC section of the ECA assesses the requirements of IFRS 19 on their own merit against the TAC set out in the legislation. Therefore, references to differences with FRS 101 are not relevant. The Board considered that no changes were necessary as there is no inconsistency between paragraphs 4.4 and 4.8 of the final ECA.
The [Draft] ECA tentatively concluded that IFRS 19 meets the criteria of relevance, reliability, understandability and comparability required of the financial information needed for making economic decisions and assessing the stewardship of management, as required by Regulation 7(1) of SI 2019/685.	A few respondents commented on the TAC and provided the feedback below: • Questioned whether the UKEB has a mandate under legislation to carry out this assessment. • Suggested moving the references to the Companies Act 2006, in this section of the [Draft] ECA, to a separate section along with other relevant legal issues. • Suggested that companies with intellectual property rights (IPR) holding subsidiaries should be required to expressly disclose their existence in the notes to the accounts or in an appendix.	The International Accounting Standards (Delegation of Functions) (EU Exit) Regulations 2021 (SI 2021/609) conferred statutory powers for the adoption of new or amended international accounting standards to the UKEB. This does not require explicit mention in the ECA. Regarding the comment on references to the Companies Act in this section of the ECA, the UKEB decided against including a separate section in the ECA on company law requirements. Therefore, no changes were made to address the comment. The additional disclosures requested for companies that hold IPR holding subsidiaries are not relevant to IFRS 19, which applies to subsidiaries only. Therefore, no changes were made to address this comment.
The [Draft] ECA tentatively concluded that IFRS 19 meets the criteria of relevance, reliability, understandability and comparability required of the financial information needed for making economic decisions and assessing the stewardship of management, as required by Regulation 7(1) of SI 2019/685.	A few respondents commented on Table 5 in paragraph 2.10 of the [Draft] ECA as follows: • Noted that IAS 41 Agriculture and IFRS 5 Non-current Assets Held for Sale and Discontinued Operations meet one of the criteria for identifying ‘key aspects’ of IFRS 19 i.e. both standards have led to a significant reduction in disclosures but have not been analysed separately against the technical accounting criteria. • Disagreed with the conclusion in Table 5 (paragraph 2.10 in the [Draft] ECA) that IFRS 19 does not lead to significant reduction in the disclosure requirements for IAS 19 Employee Benefits.	Table 5 in the ECA noted that the reduction in disclosure requirements for IAS 41 and IFRS 5 are unlikely to have a significant impact on the usefulness of UK entities’ financial statements for users and therefore do not meet the criterion in paragraph 4.6(a) of the ECA. The table was slightly amended to further add this explanation. Overall, around half of the disclosures under IAS 19 are not required by IFRS 19. However, the key disclosures remain. This supports the conclusion in Table 5 of the ECA that there is no significant reduction in disclosures. Therefore, no changes were made to address this comment.

UK Long Term Public Good Assessment (Section 5)

UKEB Tentative Assessment	Stakeholder Views	UKEB Final Assessment
The [Draft] ECA tentatively concluded that IFRS 19 is likely to be conducive to the long term public good in the UK as required by SI 2019/685 (see Regulation 7(1)(b)), having considered: • the costs and benefits that are likely to result from its use.	Out of the nine formal responses received, one disagreed with the LTPG assessment, and raised the following concerns: • Whether reducing preparers’ costs should be a legitimate concern to be considered when adopting a standard for use in the UK. • Whether the UKEB focused narrowly on lenders when conducting their assessment of direct benefits to users. • Whether the loss of information from the reduced disclosures is in the public interest.	The ECA was not amended for these comments because: • As noted in ECA (paragraph 5.44), IFRS 19 has the potential to deliver substantial cost savings to large UK groups with overseas subsidiaries. This was considered to be conducive to the LTPG in the UK. • The UKEB concluded that “the main external users of these financial statements are credit providers (e.g. bank lending departments) and non-controlling interests” (paragraph 5.22) after conducting extensive and balanced stakeholder engagement. • The UKEB has received no indication from stakeholders that IFRS 19 is likely to provide regulators with insufficient information (paragraph 5.57) or impede users’ decision-making (paragraph 5.58).
The [Draft] ECA tentatively concluded that IFRS 19 is likely to be conducive to the long term public good in the UK as required by SI 2019/685 (see Regulation 7(1)(b)), having considered: • the costs and benefits that are likely to result from its use.	One respondent (an accounting firm), which agreed with the UK LTPG assessment, made the following points: • The [Draft] ECA notes that only entities which considered the benefits of adoption to be greater than the costs would apply the Standard (paragraph 3.18). This respondent observed that UK subsidiaries of international groups may be required by the group to prepare accounts under IFRS 19 on the basis of a cost benefit analysis for the group as a whole, rather than based on a cost benefit analysis for the individual UK subsidiary. • Paragraph 3.49 of the [Draft] ECA refers to familiarisation costs of entities applying IFRS 19. This respondent argued that UK entities considering adopting IFRS 19 but determining that the costs do not outweigh the benefits, would still incur assessment costs.	Paragraph 5.35 of the ECA acknowledges that an international group may require its UK subsidiary to apply IFRS 19. Therefore, no changes were necessary to address this comment. In the ECA paragraph 5.59 (e) was added to clarify that: “Some entities (either groups or subsidiaries) may incur familiarisation costs when considering adopting IFRS 19 but ultimately determining that the costs do not outweigh the benefits.”

True and Fair View Assessment (Section 6)

UKEB Tentative Assessment	Stakeholder Views	UKEB Final Assessment
The [Draft] ECA tentatively concluded that IFRS 19 is not contrary to the true and fair view principle set out in Regulation 7(1) of SI 2019/685.	Out of the nine formal responses received, a not-for-profit organisation disagreed with the true and fair view assessment. The response observes that: • Financial performance is wholly subjective and is viewed from the perspective of an analyst. • True and fair are separate and ‘fair’ is secondary to “true”. • There is no mechanism to incorporate IFRS 19 into UK law.	These concerns relate to disagreement with the concept of the true and fair view rather than the assessment of IFRS 19 against the statutory criteria. Further, the mechanism for incorporating any new IFRS Accounting Standard into UK law is set out in legislation. Therefore, no changes were made to the “True and Fair View” assessment to address the respondent’s comments.

Is IFRS 19 likely to lead to a significant change in accounting practice? (Section 7)

UKEB Tentative Assessment	Stakeholder Views	UKEB Final Assessment
The [Draft] ECA concluded that IFRS 19 is not likely to lead to a significant change in accounting practice and does not meet the criteria for a post-implementation review under Regulation 11 in SI 2019/685.	Seven out of nine respondents agreed with the UKEB’s tentative conclusion that IFRS 19 is not likely to lead to a significant change in accounting practice for the reasons provided in Section 5 of the [Draft] ECA. Two respondents disagreed with the UKEB’s tentative conclusion, arguing that: • Because the UKEB is considering IFRS 19 for endorsement, and subsequent adoption for use in the UK, it indicates that the UKEB expects IFRS 19 to be used by a significant number of UK subsidiaries; • The assessment omits other key impacts of the standard, for example impacts on users of financial statements and benefits to the wider corporate group as well as the subsidiary entities applying IFRS 19; and • The Standard requires changes to the law and an explanation of how public interest would be maintained.	Paragraph 7.8 of the ECA noted that the UKEB does not expect a significant uptake of the Standard in the UK. Further, paragraph 3.35 of the ECA addresses the impact of the Standard for users. Therefore, no changes were needed to the “Significant Change” assessment to address these comments.

Other Significant Feedback

Stakeholder feedback	UKEB Final Response
IFRS 14 Regulatory Deferral Accounts An accounting firm suggested that the UK-endorsed version of IFRS 19 should clarify whether the disclosure requirements for IFRS 14 apply. Another respondent (an individual) had also observed that excluding IFRS 14 is inappropriate because the [Draft] ECA should assess IFRS 19 in its entirety. This respondent argued that the approach in the [Draft] ECA is tantamount to a carve-out which is only warranted in exceptional circumstances.	In the UK-adopted version of IFRS 19, the IFRS 14 reduced disclosures, set out in paragraphs 98–102, were enclosed in a box and shaded grey. A footnote was added to state that those disclosures are not applicable by entities applying the Standard under UK-adopted international accounting standards, as IFRS 14 has not been adopted for use in the UK. IFRS 14 does not form part of UK-adopted IAS and so cannot be considered as part of the UKEB’s adoption assessment of IFRS 19 (paragraph 2.7(c) of the ECA). This would not be considered a ‘carve-out’, as it is not an exercise of the power in Regulation 6(3) of SI 2019 No. 685.
Clarifying the eligibility criterion One respondent (an accounting firm) raised a concern on the eligibility criterion to apply IFRS 19. The concern relates to the reference to IFRS Accounting Standards in paragraph 7(c) of IFRS 19 and the respondent asked for clarification to assist subsidiaries on assessing their eligibility to use the Standard.	The UKEB agreed that the reference to IFRS Accounting Standards in paragraph 7(c) of IFRS 19 means UK-adopted IAS. The Adoption Statement confirms the definition of UK-adopted international accounting standards and references the relevant Statutory Instruments.

Stakeholder feedback

UKEB Final Response

IFRS 14 Regulatory Deferral Accounts
An accounting firm suggested that the UK-endorsed version of IFRS 19 should clarify whether the disclosure requirements for IFRS 14 apply. Another respondent (an individual) had also observed that excluding IFRS 14 is inappropriate because the [Draft] ECA should assess IFRS 19 in its entirety. This respondent argued that the approach in the [Draft] ECA is tantamount to a carve-out which is only warranted in exceptional circumstances.

In the UK-adopted version of IFRS 19, the IFRS 14 reduced disclosures, set out in paragraphs 98–102, were enclosed in a box and shaded grey. A footnote was added to state that those disclosures are not applicable by entities applying the Standard under UK-adopted international accounting standards, as IFRS 14 has not been adopted for use in the UK.

IFRS 14 does not form part of UK-adopted IAS and so cannot be considered as part of the UKEB’s adoption assessment of IFRS 19 (paragraph 2.7(c) of the ECA). This would not be considered a ‘carve-out’, as it is not an exercise of the power in Regulation 6(3) of SI 2019 No. 685.

Clarifying the eligibility criterion
One respondent (an accounting firm) raised a concern on the eligibility criterion to apply IFRS 19. The concern relates to the reference to IFRS Accounting Standards in paragraph 7(c) of IFRS 19 and the respondent asked for clarification to assist subsidiaries on assessing their eligibility to use the Standard.

The UKEB agreed that the reference to IFRS Accounting Standards in paragraph 7(c) of IFRS 19 means UK-adopted IAS. The Adoption Statement confirms the definition of UK-adopted international accounting standards and references the relevant Statutory Instruments.

Disclaimer

This Feedback Statement has been produced in order to set out the UKEB’s response to stakeholder comments received on the UKEB’s [Draft] Endorsement Criteria Assessment on the IASB’s IFRS 19 Subsidiaries without Public Accountability: Disclosures and should not be relied upon for any other purpose.

The views expressed in this Feedback Statement are those of the UK Endorsement Board at the point of publication.

Any sentiment or opinion expressed within this Feedback Statement will not necessarily bind the conclusions, decisions, endorsement or adoption of any new or amended IFRS by the UKEB.

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