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EFRAG agrees with most proposals in the ED but it believes that the proposed amendment to IFRS 1 is unnecessary. Furthermore, this proposed amendment puts into question the purpose annual improvements should serve.
In addition, EFRAG believes that the IASB should refrain from making amendments to the bases for conclusions of standards, unless it wishes to correct outright errors.
In EFRAG's view, amendments to bases for conclusions cannot take the place of actual standard-setting. Furthermore, EFRAG would like to note that such amendments do not form part of the standards themselves and hence do not affect IFRS as endorsed in the EU.
EFRAG is finally asking its constituents if they believe that the IASB should address any further amendments to IFRS 3 before commencement of its planned post-implementation review of the standards.