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PensionsEurope welcomes the opportunity to comment on the IFRS consultation regarding the developing disclosure requirements and proposed amendments to IFRS 13 and IAS 19. PensionsEurope believes that the note disclosures with regards to pension plans are already very comprehensive in current annual financial statements. Most of the information disclosed in the notes covers already the proposed disclosure objectives. For this reason, it is unclear, how the new concept should better meet the users' needs. Furthermore, PensionsEurope believes that any structured disclosure process needs checklists to decide which information will not be provided due to materiality reasons. Therefore, a checklist approach has its advantages. You can read our answer and explanation here