20 February 2014

FEE comments on IPSASB's consultations on EDs 48, 49 and 53

IPSASB-ED-48 - Separate Financial Statements

FEE has reviewed the changes in terminology between this ED and its donor Standard, IAS 27, and agrees that the revised terminology better represents the position of public sector bodies.

FEE has considered the IPSASB’s decision to replace references to IFRS 9 Financial Instruments contained in IAS 27 with references to the IPSASs dealing with financial instruments. As the IPSASB has not yet considered the applicability to the public sector of this standard, and also in view of the fact that the IASB’s proposed amendments to this standard are not complete, FEE agrees with the IPSASB’s decision to remove references to it in this ED.

FEE also agrees with the proposal that if an investment entity measures its investments in a controlled entity at fair value through surplus or deficit in its consolidated accounts it should also account for those investments in the same way in its separate financial statements.

Full comment letter

IPSASB-ED-49 - Consolidated Financial Statements

FEE has reviewed the changes in terminology between this ED and its donor Standard, IFRS 10, and agrees that the revised terminology better represents the position of public sector bodies.

FEE has considered the IPSASB’s decision to replace references to IFRS 9 Financial Instruments contained in IAS 27 with references to the IPSASs dealing with financial instruments. As the IPSASB has not yet considered the applicability to the public sector of this standard, and also in view of the fact that the IASB’s proposed amendments to this standard are not complete, FEE agrees with the IPSASB’s decision to remove references to it in this ED.

Likewise, FEE also agrees with the IPSASB’s decision to replace references with IFRS 5, Non-current Assets Held for Sale and Discontinued Operations, with those of relevant IPSASs on the grounds that IPSASB has not yet considered this standard for applicability to the public sector.

Full comment letter

IPSASB-ED-53 - First-Time Adoption of Accrual Basis International Public Sector Accounting Standards

FEE strongly supports IPSASB’s programme which helpfully combines IFRS converged IPSASs on matters which are common to both private and public sectors.

FEE believes that a three year exemption period is appropriate and should provide an adequate length of time for most public sector bodies to adequately deal with the issues arising from the transition to accruals accounting.

A three-year exemption period should, in FEE´s view, permit first-time adopters to implement systems and obtain information sufficient for them to produce financial statements complying with the accruals IPSASs including the provision of comparative information. FEE presumes that bodies planning to make the move to accruals accounting would have started the necessary preliminary work well in advance of preparing their first set of transitional IPSAS financial statements.

Additionally, any issues with, for example, obtaining historical cost information for assets and liabilities held for a long time by the bodies are unlikely to be resolved by any reasonable extension of the exemption period. For these reasons, FEE does not support any further extension of the three-year exemption period.

Full comment letter

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