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IFRS 4 Phase II will not, however, be ready by the implementation date for IFRS 9 in 2018. Consequently, insurers are concerned that they will have to implement IFRS 9 on a temporary basis and then alter it again, at considerable cost, when IFRS 4 Phase II is implemented later.
The letter also pointed out that if IFRS 9 and IFRS 4 Phase II need to be implemented separately it will cause significant confusion, both for users and investors.
While a potential European solution has been put forward to allow insurers to implement the two standards together, the letter points out that a global solution is needed, so asks EFRAG to push the International Accounting Standards Board (IASB) to develop such a solution.