ACCA contributed to the ad-personam mandate of the EFRAG Board President Jean-Paul Gauzès on NFI reporting standard-setting. Following the feedback received, Jean-Paul Gauzès issued a consultation document on his proposals for the governance and funding of EFRAG should it be entrusted with a mandate for NFI standard-setting, to which ACCA also responded.
The objective of the mandate is to set out issues if EFRAG were to take on NFR standard setting. However, we would note that the problems of changing the existing EFRAG structure into one suitable to take on the new role may be very significant. It is possible that setting up a completely new body may be the better answer.
The advantages of doing so might include the clear separation of funding and staff resources between the IFRS function and the NFR function, without any questions of whether there had been a diversion of resources for one to the other or cross-subsidies. It would also leave the existing governance of EFRAG as it is. On the other hand, there might be some loss of co-ordination between financial reporting and NFR.
We set out our suggestions throughout the document in answer to the specific questions raised in the consultation. We are conscious that the revisions to non-financial reporting in Europe are not yet finalised, for example in terms of the scope of companies that will be required to comply, the topics to be covered and the balance between EU level and member state requirements. Some aspects of the structure may need to be adjusted to reflect the final form of the revision.
Too see the full responses please download the consultation response documents.