25 November 2015

EBA, ESMA, FEE, FRC, IFAC: Comment letters on the IASB Conceptual Framework for Financial Reporting

EBA

The EBA would welcome further assessment by the IASB on the impact of the removal of the probability threshold in conjunction with the application of the proposed recognition criteria in ED on the type and amounts of assets and liabilities to be recognised compared to the current standards.

The EBA agrees with the high-level provisions provided in the ED concerning the statement of profit or loss. However, the EBA would encourage the IASB to continue working on developing a conceptual basis which addresses the definition and the purpose of the statements of profit or loss and other comprehensive income, and the conditions under which recycling should occur, in order to guide the development of future IFRS, even if the EBA also acknowledges the difficulties in doing so. Having an adequate conceptual basis may avoid future discussions when setting new Standards and it may also help users assessing the financial performance of an entity.

EBA´s full comment letter

ESMA

ESMA strongly supports the aim of the IASB’s Conceptual Framework project to improve financial reporting by providing a clear and comprehensive set of updated concepts. ESMA welcomes the ED as it provides a number of updated concepts underpinning IFRS financial reporting. In particular, ESMA is of view that the ED provides welcomed changes and clarifications to the existing Conceptual Framework in areas such as elements of financial statements and their recognition. Furthermore, ESMA welcomes the proposed guidance on reporting entity, derecognition and the role of business activities in financial reporting.

ESMA´s full comment letter

FEE

FEE supports the IASB’s project as FEE understands the importance of the Conceptual Framework for Financial Reporting in the future development of IFRS. A complete, updated and robust framework would assist the IASB in its standard setting process, preparers in selecting accounting policies, users of financial statements and other constituents to better understand and comprehend the principles of IFRS, including the external auditors.

FEE expresses its disappointment that the IASB has not conceptually defined cash flows and consequently the cash flow statement and the link of the cash flow statement to the statement(s) of financial performance and financial position. 

FEE´s full comment letter

FRC

The FRC has called on the IASB to reconsider its proposed Conceptual Framework so that it properly reflects the importance of stewardship, prudence and reliability, which it describes as cornerstones of the Framework. 
The FRC’s comments are made in its response to the IASB’s ED on its Conceptual Framework.  This identifies principles for the IASB to use when it develops and revises IFRSs.

FRC´s full comment letter

IFAC

IFAC commends the IASB on its efforts in reactivating the Framework project, and recommends a number of additional conceptual areas for consideration including in regard to business models, and financial performance. IFAC also provides specific comments and recommendations regarding several areas in the ED including stewardship, prudence, definitions of assets and liabilities, measurement bases, and presentation and disclosure.

IFAC´s full comment letter

IASB´s ED/2015/3 3 'Conceptual Framework for Financial Reporting'

IASB´s ED/2015/4 'Updating References to the Conceptual Framework'