16 July 2013

FEE's comment letter to IIRC on the international integrated reporting framework

FEE commends the IIRC for the significant achievement of issuing the Draft Framework and recognises that redesigning the direction and focus of corporate reporting is a journey. Making the step towards integrated thinking and integrated reporting takes time; the Draft Framework is an important and laudable milestone in this process.

The IIRC is strongly encouraged in advancing the Draft Framework and in engaging all stakeholders, including policymakers, regulators, and private sector entities, in creating a shared vision on integrated reporting.

FEE supports the IIRC’s objective of gaining as much practical experience with the Draft Framework as possible, such as provided by the Pilot Programme and Emerging Integrated Reporting Database. The lessons learnt from the Pilot Programme will be instrumental in further developing the Draft Framework. When the final Framework is instated, it is expected this will need to be reviewed and updated periodically, depending on the practical experiences with integrated reporting.

FEE fully endorses the way in which integrated reporting is currently being developed, by largely drawing on stakeholders' involvement and gaining practical experience. FEE is convinced that, at least for the time being, integrated reporting should continue to be market driven instead of being mandated by public authorities. Legislation on this matter could in fact hinder such promising evolution and stifle innovation. However, it is necessary to involve public authorities as stakeholders in developing integrated reporting as regulators can be influential in promoting the widespread acceptance and use of integrated reporting or in removing obstacles to the application or adoption of integrated reporting.

In FEE's view, it is very useful that the IIRC has chosen to focus integrated reporting in the first instance on the information needs of providers of financial capital. This pragmatic approach aids in making the Draft Framework operational. FEE fully agrees with the Draft Framework’s recognition (Paragraph 1.7) that integrated reporting benefits all stakeholders who are interested in an organisation’s ability to create value over time. The IIRC is encouraged to investigate further how information needs of other stakeholders align with, or differ from, those of providers of financial capital.

FEE also finds the principles of integrated reporting useful for reports prepared by not-for-profit organisations and the public sector, as well as reports prepared for specific stakeholder groups. In such reports, different materiality considerations may apply.

Full comment letter

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