ACCA welcomes the opportunity to provide views in response to the exposure draft of the Practice Statement on Management Commentary. This has been done with the assistance of ACCA’s Global Forum for Corporate Reporting.
We support the revision of the Practice Statement as it is needed not only to address the current deficiencies in management commentary (as identified in para IN8), but also to reflect current developments in sustainability reporting standard-setting. Connectivity between financial information and sustainability information is vital, and the Practice Statement is central to providing this connectivity.
Given the significant interactions between this Practice Statement and the standards that the ISSB will produce, we would recommend that the IASB pauses further work on the Practice Statement until such time as when the ISSB is firmly established. In our view, it is appropriate to develop the Practice Statement in close collaboration with the ISSB, so that it can reflect and be informed by the development of future ISSB standards.