Dear Sir or Madam,

SwissHoldings, the Swiss Federation of Industrial and Services Groups in Switzerland, represents 61 Swiss groups, including most of the country’s major industrial and commercial enterprises. We are pleased to provide comments on the exposure draft on Subsidiaries without Public Accountability: Disclosures.

Our association welcomes the proposed introduction of the new and simplified standard for subsidiaries without public accountability. It will reduce the administrative burden as well as costs for financial reporting for said preparers. However, we would like to encourage the IASB to reconsider the scope and broaden it to all entities without public accountability.

We provide our comments in relation to the specific questions raised in the ED following the position of BUSINESSEUROPE in the annex.

If you require any further information upon these matters, please do not hesitate to contact us.

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