Final Comment Letter published

Date: 27 May 2021

The UKEB Secretariat has published its response to the IASB’s Request for Information in its post-implementation review of IFRS 10, IFRS 11 and IFRS 12 (the Standards).

Following public consultation on its draft response, the UKEB Secretariat concludes that the Standards have achieved their overall objectives by introducing a principles-based approach to accounting for consolidation and joint arrangements.  The response includes some recommendations, limited to specific areas where the application of the Standards can be improved. These are:


1.           Review the requirement to disclose why an investment entity is classified as such when it meets the investment entity criteria but does not exhibit the typical characteristics.

2.           Review the application guidance for identifying investment entities to ensure it results in appropriate outcomes for all types of investment fund.

3.           Require investment entities to consolidate those intermediate subsidiaries which are investment entities to improve visibility at group level of assets and liabilities held by those subsidiaries.

4.           Develop guidance for accounting treatment of acquisition of a controlling interest in a single asset entity, since diverse practice exists in this area.


1.           Include principle-based guidance from IFRIC’s March 2015 Update on the assessment of other facts and circumstances.

2.           Include additional guidance in the Standard to address any diversity of practice relating to the interaction of IFRS 11 with IFRS 15 and IFRS 16.


1.           Review the extent to which disclosures for unconsolidated structured entities have proved useful as an indicator of potential risk.

2.           Consider including guidance on the level of aggregation and disaggregation of disclosures on interests in other entities as part of its Primary Financial Statements project.

3.           Consider including enhanced disclosures for subsidiaries with material non-controlling interests.