Feedback Statement - Post Implementation Review of IFRS 9 - Impairment

September 2023

The UK Endorsement Board (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 on the development of new standards, amendments and interpretations.

The comment letter to which this feedback statement relates forms part of those influencing activities and is intended to contribute to the IFRS Foundation'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.

Purpose of this feedback statement

This feedback statement presents the views of UK stakeholders received during the UKEB's outreach activities on the IASB's Post-implementation Review (PIR) of IFRS 9 Financial Instruments Impairment project and explains how the UKEB's Final Comment Letter addressed those views.

Outreach approach

The UKEB's outreach activities took place between February and September 2023 and were conducted to assist the UKEB in developing its Comment Letter.

The outreach approach was underpinned by the UKEB's guiding principles of thought leadership, transparency, independence and accountability.

Due to the project timeline, most of our outreach activities were performed in the early stages of the project and these stakeholder views were reflected in the UKEB draft comment letter.

Outreach activities included:

• meetings with preparers, users, accounting firms and regulators, including discussions with the UKEB Financial Instruments Working Group;
• a roundtable event with preparers; and
• public consultation on the UKEB's draft comment letter.

Two written responses to the UKEB's Invitation to Comment on its Draft Comment Letter were received. This is in addition to the stakeholder outreach statistics shown in the table.

All comments and views were considered in reaching the UKEB final views on the questions raised.

*The professional bodies/committees have multiple members, often representing a variety of stakeholder types.

The IASB's Post-implementation Review

The IASB has spilt its Post-implementation Review of IFRS 9 into three parts. This part of the review focuses on the impairment requirements of IFRS 9, together with the related disclosure requirements in IFRS 7 Financial Instruments: Disclosures.

The PIR assesses whether the standard is meeting its objectives, can be applied consistently, provides useful information to users, and implementation costs are as expected. The IASB's possible actions following the PIR are to:

1. produce educational materials;
2. conduct follow-up research work for possible standard setting; or
3. take no action

The IASB's Request for Information (Rfl) identified ten areas of the impairment requirements on which it was seeking feedback. The UKEB comment letter was responsive to UK stakeholder feedback and focused only on those areas where UK stakeholders expressed particular concerns.

1. IFRS 9's overall approach to impairment