Response 2 - QCA

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01 March 2022
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Quoted Companies Alliance 6 Kinghorn Street London EC1A 7HW T +44 (0)20 7600 3745 [email protected] www.theqca.com

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

[email protected]

Tuesday 1 March 2022

Dear UKEB colleagues,

Draft Regulatory Strategy 2022/23

We welcome the opportunity to respond to your Draft Regulatory Strategy 2022/23.

The Quoted Companies Alliance Accounting, Auditing and Financial Reporting Expert Group has examined the proposals and advised on this response from the viewpoint of small and mid-sized quoted companies. A list of Expert Group members can be found in Appendix A.

Overall, we consider the Draft Regulatory Strategy of the UK Endorsement Board to be reasonable and well-considered and the comments we have made are intended to embolden certain aspects of the strategy rather than object to them.

We look forward to working with the UKEB over the coming months,. Yours sincerely,

Tim Ward Chief Executive

The Quoted Companies Alliance is the independent membership organisation that champions the interests of small to mid-size quoted companies. A company limited by guarantee registered in England Registration Number: 4025481

We have the following comments to make regarding the following sections of the draft strategy, plan and budget.

Strategic objectives 2022/2025

We broadly agree with the UKEB's strategic objectives as set out in the draft document. However, we have the following comments to raise:

  • Regarding 3.2.1(a) (Influencing), it is the view of some of our membership that the UKEB could do more to demonstrate thought leadership in financial reporting standards from a UK perspective. It is their view that more needs to be done to take the lead in looking at different solutions to the IASB and IFRS than is currently the case.
  • Regarding 3.2.2 (b) (Adoption of standards for use in the UK), we agree with the aim to "conduct proportionate stakeholder engagement" and emphasise the importance of consulting with a variety of stakeholders of different sizes and complexities. This would help greatly in ensuring that the implications of implementation of standards have been properly considered, taking into account the relative impact of new standards on different entities. We would be happy to facilitate such engagement.

Appendix A

The Quoted Companies Alliance Accounting, Auditing and Financial Reporting Expert Group

Name Organisation
Rochelle Duffy (Chair) PKF Littlejohn LLP
Elisa Noble (Deputy Chair) BDO LLP
Edward Beale Western Selection PLC
Matthew Brazier Invesco Asset Management Limited
Anna Hicks Saffery Champness LLP
Mark Hodgkins Trackwise Designs PLC
Michael Hunt ReNeuron Group PLC
Clive Lovett Bilby PLC
Laura Mott Haysmacintyre
Giles Mullins Grant Thornton UK LLP
James Nayler Mazars LLP
Matthew Stallabrass Crowe UK LLP
Tom Stock Haysmacintyre
Helena Watson KPMG LLP
Peter Westaway Deloitte LLP