We do not support the proposed amendments as they currently stand. This is for the same reasons articulated by Martin Edelmann in his Alternative View (AV1-AV3 of the ED), and also as set out in more detail in the appendices to this letter.
It appears to us that the IASB is addressing a perceived problem about the application of judgement with a legislative remedy. We would dispute that there is such a significant (or material) problem with Accounting Policy disclosures; and we suggest that a more appropriate response would be to issue further Implementation Guidance and Illustrative Examples so as to help preparers apply their judgment, rather than issuing additonal requirements to try and legislate for good judgement.
Moreover in these proposals the IASB is missing the opportunity to promote better understanding of IFRS in markets where there are other financial reporting regimes (such as Switzerland) and in emerging markets. Users of financial information do not have such a good understanding of IFRS as the proposals imagine, and the financial statements of preparers do educate and inform
the financial community about IFRS generally and create best practice.
Comment Letter on the Exposure Draft ED/2019/6 “Disclosure of Accounting Policies – Proposed amendments to IAS1 and IFRS Practice Statement 2”
