ACCA (the Association of Chartered Certified Accountants) is pleased to have this opportunity to comment on the financial reporting exposure draft (FRED) on the above subject, which was considered by ACCA's Financial Reporting Committee.
Question 1
The proposals set out in this FRED seek to implement the amendments made by the IASB from its annual improvements project, amendments arising from other changes made by the IASB to IFRSs, and amendments specific to FRS. Do you agree with the ASB proposals for the implementation of these changes to UK and Irish FRS? If not, please explain why.
Amendments from IASB improvements project
We generally support consequential amendments to UK and Irish standards in order to retain their converged status with IFRS. We also note that the ASB has rightfully, limited the number of amendments due to the current deliberations on the future of UK GAAP. We did not raise any specific concerns about the particular improvements to IFRS7 during the IASB's improvement deliberations and agree that they should be implemented into FRS.
Amendments from other changes made by the IASB to IFRSs
In our response to the ED proposing amendments to IAS24, we were overall supportive of the amendments. Incorporating these amendments will not only bring FRS8 in line with IAS24, but also with Company Law (which refers to IAS24). We support the proposed amendments.
Amendments arising from ASB's annual review of FRS
We also support the FRS specific amendments which clarify the exemption in FRS8 and extend the exemption from segmental disclosures for subsidiaries in SSAP25, as providers of capital are largely interested in the group's accounts.
Question 2
The ASB considers that the benefits of implementing the proposals in this FRED will outweigh the costs involved. Do you agree? If not, why not? It would be helpful if any significant costs that would arise on implementation of the proposals could be identified and quantified.
As noted above, we did not raise any specific concerns about these particular amendments to IFRS. In addition, we can see that many of the proposed improvements to FRS do offer additional guidance and clarification, and would be an improvement. As they are not significantly altering or adding to the requirements of current FRS, they would not be a major cost for preparers.