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This feedback statement describes the main comments received by EFRAG in response to its draft comment letter and how these comments were considered by EFRAG in finalising its comment letter to the IASB.
The majority of respondents agreed with EFRAG’s overall tentative position on the ED. However, three respondents did not support EFRAG’s draft comment letter as they did not think that the IASB should proceed with the proposed amendments.
Two of these respondents considered that the IASB should not proceed with the ED mainly because they did not agree with the proposal in paragraph 22(d) to require an explanation of consistency of information and did not think the remaining proposals were necessary or useful. One of these respondents did not support amending IFRS 8 before the debates on the IASB’s Principles of Disclosure Discussion Paper and Primary Financial Statements project were finalised. Another respondent was not convinced that the proposed amendments provide solutions for the issues that have been identified and considered that the proposed amendments are likely to create new implementation issues.
Role and function of the Chief Operating Decision Maker (CODM)
Seven respondents explicitly agreed with EFRAG’s view that the proposed amendment would clarify the description and the role of the CODM. The remaining respondents either did not think the amendments were necessary (because they are not aware of any difficulties or expressed different views on some aspects of the function of the CODM or sought additional clarifications on the proposed description.
Explanation of why segments differ, definition of annual reporting package and aggregation criteria
All but three respondents supported EFRAG’s position and disagreed with the IASB proposal, with some strongly disagreeing. Overall, the main reason for disagreement was that IFRS 8 is not the appropriate place for addressing the problem of segment information provided outside the financial statements. Two of the three respondents that did not support the EFRAG position supported the IASB proposal and one respondent did not object to the proposed amendment.
Disclosure of segment information in addition to that regularly reviewed by, or regularly provided to, the CODM
Most respondents supported EFRAG’s tentative position. However, two respondents disagreed with the proposal and therefore did not support EFRAG’s tentative position.
Restate segment information for all interim periods presented earlier
Most respondents supported EFRAG’s tentative position.