As the IAIS pointed out in submissions on the Financial Instruments Exposure Draft in September 2009 and the Insurance Contracts Exposure Draft in November 2010, the IAIS believes that it is crucial that the effective dates of the two standards are aligned for insurers. Having different adoption dates could lead to accounting mismatch or to the need to change accounting methodologies in close succession unless a practical transition is provided for insurers.
In general, the IAIS agrees with the IASB’s proposal to make IFRS 9 mandatory for annual periods beginning on or after 1 January 2015, in order that this date may coincide with the effective date of Insurance Contracts.
The IAIS's view here is contingent upon the insurance contract project deliberations being finalised with sufficient time available to ensure implementation of an insurance standard in 2015. The IAIS applauds the IASB for the progress it has made on both the insurance contracts and financial instruments projects, but notes a concern that these projects still appear some way from conclusion. As a consequence, considerable effort may be required if the Board is to finalise these standards, particularly on insurance accounting and impairment, while also allowing adequate time for implementation by preparers in time for adoption on 1 January 2015.
In the event of the IASB determining that the effective dates of IFRS 9 and the eventual insurance contracts standard are likely to diverge, the IAIS would seek to discuss further with the IASB how the challenges that this would bring for insurers might be resolved.
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