EFRAG issued this letter in draft form for a short public consultation, running for no more than 10 days. EFRAG has received more than 20 comment letters from a variety of stakeholders: banking and insurance industries, accounting profession, user representative organisations, national standard-setters and ESMA. EFRAG has also heard from other observers on the EFRAG Board, ECB, EBA and EIOPA, having the benefit of the participation of their representatives in the meetings. In this public consultation, stakeholders have reaffirmed views they had expressed when providing comments on EFRAG´s draft endorsement advice in the course of the summer:
(a) Bringing a solution to the insurance issue should not be a cause of delay of endorsement of IFRS 9; in particular a swift endorsement process of IFRS 9 is critical for the banking industry;
(b) The solution should ideally be found in amendments to IFRS issued by the IASB; and
(c) All companies in Europe, including those involved in insurance activities, need clarity as a matter of urgency on how and when they have to apply IFRS 9.
EFRAG cannot yet make a formal assessment because the IASB’s requirements in their precise formulation are not yet available. Once they are available, EFRAG will need to run its full due process.
EFRAG is very pleased that the IASB is constructively progressing options to address the issues EFRAG has highlighted in its endorsement advice to the EC. However, uncertainty exists as to whether the IASB will provide an appropriate remedy when it makes its final decisions on the matter. These decisions will be made at the earliest in 6 to 9 months from now.
Hence, as of the date of this letter, EFRAG is not in a position to amend its previous recommendation that “all businesses other than those carrying out insurance activities are required to account for their financial instruments in compliance with IFRS 9 in 2018 and businesses carrying out insurance activities are permitted to do so in compliance with IFRS 9 from the same date”.
The IASB is expected to issue an ED in December 2015 that will propose two optional approaches to assist entities that issue insurance contracts until the new insurance contracts standard is issued:
(a) The “deferral approach”. Under this approach, the application of IFRS 9 would be deferred until 1 January 2021 at the latest and eligible entities would apply IAS 39 Financial Instruments: Recognition and Measurement. An eligible entity would be one whose predominant liabilities arise from insurance contracts within the scope of IFRS 4 Insurance Contracts.
(b) The “overlay approach”. Under this approach, IFRS 9 would be applied from 1 January 2018 in the balance sheet and the effect on profit or loss arising from the application of IFRS 9 to insurance activities would be reported in other comprehensive income. All entities issuing contracts in the scope of IFRS 4 would have the option to follow this approach, in particular those entities which would fail the predominance test supporting the use of the deferral approach, e.g. conglomerates including insurance activities.
Full press release
Full comment letter
© EFRAG - European Financial Reporting Advisory Group
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