Our detailed response (in the appendix) has been prepared in conjunction with our member companies.
We very much welcome that the IASB is addressing this topic. Whilst we have many comments to the Exposure Draft, we are appreciative that the IASB is taking concrete steps to address specific stakeholder needs, and is engaging preparers and other stakeholders in this discussion. We would be more than happy to further contribute to this topic in due course.
Summary of key points from our comments on the Exposure Draft:
- We agree that it is reasonable not to define supplier finance arrangements.
- We believe that the IASB should differentiate the disclosures requirements for “active programs” (that is, actively managed as alternative credit facilities) and “passive programs”.
- We see unintended consequences in providing the information in 44H in instances where supplier financing programs are designed for a purpose other than actively managing credit facilities.
- We are of the view that IFRS 9 guidance on recognition and derecognition of financial liabilities, including the existing disclosure requirements highlighted by the December 2020 IFRIC Agenda Decision, should be sufficient to (i) ensure that the presentation of trade payables on the face of the Financial Statements is not misleading for the users, and (ii) provide the right information about the risks related to these programs.
- There is a risk that some of the information to be disclosed may not be provided timely and consistently, and the management of the entity may have no control on the quality and completeness of the information.
- The disclosure may be misleading for users of financial statements who may disproportionately weigh the importance of payment due dates in determining whether the financial liability should continue to be recognised as a trade payable, or extinguished/reclassified as financial debt.
- We agree that it is beneficial to provide information about non-cash changes in liabilities arising from financing activities.
Please find our detailed comments in relation to the specific questions raised in the Exposure Draft in the appendix.