How we responded to feedback on the 2013 Discussion Paper In developing the Exposure Draft Conceptual Framework for Financial Reporting, the IASB considered feedback received on the 2013 Discussion Paper A Review of the Conceptual Framework for Financial Reporting. The following table summarises: the suggestions in the 2013 Discussion Paper; the feedback received on those suggestions; 1 and how the IASB has responded to that feedback. Suggestion in 2013 Discussion Paper Feedback received How the IASB responded Introduction—Purpose and status of the Conceptual Framework Purpose The Discussion Paper suggested that: the primary purpose of the Conceptual Framework should be to assist the IASB by identifying concepts that the IASB will use when developing and revising Standards. the Conceptual Framework may also assist parties other than the IASB to: o understand and interpret existing IFRSs; and o develop accounting policies when no Standard or Interpretation specifically applies to a particular transaction or event. some aspects of the Conceptual Framework should be for the IASB only. 1 Many disagreed that the IASB should be identified as the primary user of the Conceptual Framework. They argue that this understates the importance of the Conceptual Framework to other parties. Some respondents disagreed with the suggestion that some aspects of the Conceptual Framework should be for the IASB only. They pointed out that preparers sometimes need to refer to the Conceptual Framework. Some respondents expressed the view that the Discussion Paper was not sufficiently aspirational, because in some areas it described the judgements the IASB will have to make The IASB agrees with those respondents who argued that the status of the Conceptual Framework suggested in the Discussion Paper understated the importance of the Conceptual Framework. Hence, the Exposure Draft now proposes that the purpose of the Conceptual Framework is to: assist the IASB to develop Standards; assist preparers to develop consistent accounting policies when no Standard applies to a particular transaction or event, or when a Standard allows a choice of accounting policy; assist all parties to understand and interpret the Standards. Agenda papers 10A–10M presented at the March 2014 IASB meeting provide a more detailed summary of the feedback received. 1|Page Suggestion in 2013 Discussion Paper Feedback received How the IASB responded when setting Standards and, in their view, did not examine fundamental concepts. The Exposure Draft does not propose that aspects of the Conceptual Framework should be for the IASB only.2 The IASB is of the view that the Conceptual Framework should be a practical tool that will help when developing Standards. An aspirational document of the type suggested by some respondents would be unlikely to fulfil this role. Status The Discussion Paper suggested that: the Conceptual Framework is not a Standard and does not override any Standard. in rare cases, in order to meet the overall objective of financial reporting, the IASB may decide to issue a new or revised Standard that conflicts with an aspect of the Conceptual Framework. In such cases, the IASB would describe the departure from that aspect of the Conceptual Framework, and the reasons for it, in the Basis for Conclusions on that Standard. 2 Many respondents agreed that the Conceptual Framework is not a Standard and should not override any Standard. Although a few respondents disagreed, many stated that the IASB should be permitted to depart from the Conceptual Framework. The IASB has carried forward from the Discussion Paper the suggested status of the Conceptual Framework. Hence, the Exposure Draft states that: the Conceptual Framework is not a Standard and does not override Standards. in a limited number of cases, the IASB may depart from aspects of the Conceptual Framework if that is needed to meet the overall objective of financial reporting. If the IASB does so, it will explain the departure in the Basis for Conclusions on the Standard in question. The Basis for Conclusions on the Exposure Draft notes that only the IASB when setting Standards would be able to rebut the presumption proposed in the Exposure Draft that an item of income or expenses should be included in the statement of profit or loss, because IAS 1 prohibits the inclusion of items of income and expenses in OCI when no Standard permits or requires this. 2|Page Suggestion in 2013 Discussion Paper Feedback received How the IASB responded Chapter 1—The objective of general purpose financial reporting and Chapter 2—Qualitative characteristics of useful financial information3 Approach In 2010, the IASB revised two Chapters of the Conceptual Framework, dealing with: the objective of financial reporting; and the qualitative characteristics of useful financial information. The Discussion Paper stated that the IASB did not intend to fundamentally reconsider those two chapters. Many respondents stated that the IASB should reconsider aspects of these Chapters. In particular, respondents suggested that: the objective of financial reporting should refer to stewardship more prominently; an explicit reference to prudence should be reintroduced; the Conceptual Framework should describe the role of substance over form in financial reporting; reliability should be reintroduced as a qualitative characteristic of useful financial information; the IASB should consider changes to the description of the primary user group; and the Conceptual Framework should discuss how to avoid unnecessary complexity. In response to these comments, the IASB now proposes to make a number of changes to these Chapters. The Exposure Draft proposes: to give more prominence, within the discussion of the objective of financial reporting, to the importance of providing information needed to assess management’s stewardship of the entity’s resources; to reintroduce an explicit reference to prudence (described as caution under conditions of uncertainty) and clarify that prudence is important for achieving neutrality; to state explicitly that a faithful representation represents the substance of an economic phenomenon rather than merely representing its legal form. In response to concerns raised that reliability is no longer identified as a qualitative characteristic, the IASB proposes to clarify 3 The ‘Chapters’ referred to in this document are the Chapters in the 2015 Exposure Draft The Conceptual Framework for Financial Reporting. 3|Page Suggestion in 2013 Discussion Paper Feedback received How the IASB responded that measurement uncertainty is one factor that can make information less relevant. Hence, there is a trade-off between the level of measurement uncertainty and other factors that make information relevant. Other aspects of the qualitative characteristic of reliability are very similar to aspects of the Exposure Draft’s description of the qualitative characteristic of faithful representation. Hence the IASB thinks it is unnecessary to reintroduce the term reliability. The IASB continues to believe that existing and potential investors lenders and other creditors have the most critical and immediate need for financial information. Hence the IASB proposes not to change the description of the primary user group. The IASB believes that the proposed Conceptual Framework will provide it with all the tools it will need to enable it to address concerns about complexity by considering whether the information required by a particular Standard is understandable and whether the benefits of providing that information justify the costs. Hence the IASB proposes not to add a discussion of complexity to the Conceptual Framework. 4|Page Suggestion in 2013 Discussion Paper Feedback received How the IASB responded Materiality The Discussion Paper suggested no changes to the existing description of materiality. It stated that this description is clear. Many respondents agreed with that statement. However, some suggested amendments or clarifications. The Exposure Draft proposes no amendments to the concept of materiality, except to clarify the reference to users. The IASB will consider suggestions made by respondents for amendments and clarifications in its Disclosure Initiative.4 Chapter 3—Financial statements and reporting entities Going concern Some respondents: The Discussion Paper identified three expressed concern that the Discussion situations in which the going concern Paper appeared to downplay the assumption is relevant (when measuring assets importance of the going concern concept; and liabilities, when identifying liabilities and suggested that additional disclosures about when making disclosures about the entity). going concern are needed; asked for additional guidance on going concern (including clarification of the time horizon) and on the link between going concern and notions such as ‘practically unconditional’ and ‘no realistic alternative’ discussed in the guidance on the definition of a liability; and requested guidance on financial statements 4 In response to concerns that the Discussion Paper downplayed the importance of the going concern assumption, the Exposure Draft clarifies that going concern should continue to be treated as an underlying assumption. The Exposure Draft proposes the following guidance on the interaction between the going concern assumption and the liability definition: if a present obligation could be avoided only by liquidating the entity or ceasing trading, the entity has a liability; an entity does not have a liability for a The Disclosure Initiative is a collection of implementation and research projects aimed at improving disclosure in IFRS financial reporting. 5|Page Suggestion in 2013 Discussion Paper Feedback received that are prepared when an entity is not a going concern. How the IASB responded transfer that would be required only if the entity is liquidated or ceases trading. The IASB does not believe that further guidance on the going concern assumption is needed. The IASB has no plans to produce a Standard on financial statements of entities that are not a going concern. The needs of users of such financial statements may depend significantly on local legal requirements governing the liquidation. Reporting entity Because the IASB had previously issued a Discussion Paper and Exposure Draft on the reporting entity, the Conceptual Framework Discussion Paper did not address the reporting entity. A few respondents to the Conceptual Framework Discussion Paper stated that there is no need for a separate reporting entity chapter: a broad description of a reporting entity would be sufficient. The Reporting Entity Exposure Draft: described a reporting entity and its features; proposed that the boundary of a reporting entity should be determined by control; stated that unconsolidated financial statements might provide useful information if they were presented In response to the Reporting Entity Exposure Draft: some noted that the IASB has no authority to determine who must, should or could prepare financial statements; many agreed that an entity controlling one or more entities should prepare consolidated financial statements; 6|Page The IASB believes that the Conceptual Framework needs to describe the reporting entity. Instead of describing who must, should or could prepare financial statements, the Exposure Draft simply describes a reporting entity as an entity that chooses, or is required, to present general purpose financial statements. The Exposure Draft also discusses the boundary of a reporting entity and notes that the boundary can be determined either by Suggestion in 2013 Discussion Paper together with consolidated financial statements; stated that combined financial statements might provide useful information about entities under common control. Feedback received How the IASB responded direct control only (resulting in unconsolidated financial statements) or by both direct and indirect control (resulting in consolidated financial statements). It notes that, in general, consolidated financial statements are more likely to provide useful information to users of financial statements than unconsolidated financial statements. some suggested that the IASB should permit entities to present unconsolidated financial statements in a separate document from the consolidated financial statements or without preparing consolidated financial statements at all; many welcomed a discussion of combined financial statements but disagreed with restricting their use to entities under common control. The Exposure Draft no longer requires unconsolidated financial statements to be presented together with the consolidated financial statements. Instead the Exposure Draft proposes that entities that choose or are required to present unconsolidated financial statements should disclose how users may obtain the consolidated financial statements. The IASB has modified the discussion on combined financial statements. The Exposure draft now states that if two or more entities that do not have a parent-subsidiary relationship prepare financial statements, those financial statements are referred to as combined financial statements. 7|Page Suggestion in 2013 Discussion Paper Feedback received How the IASB responded Perspective The Discussion Paper did not discuss the perspective from which financial statements are presented (entity perspective or propriety perspective). Some respondents to the Discussion Paper stated that the Conceptual Framework should discuss the perspective from which financial statements are presented. The Exposure Draft proposes that financial statements should be prepared from the perspective of the reporting entity as a whole. Chapter 4—The elements of financial statements Definitions of assets and liabilities The Discussion Paper suggested that the definitions of assets and liabilities should be amended to confirm more explicitly that: an asset (or a liability) is the underlying resource (or obligation), rather than the ultimate inflow (or outflow) of economic benefits; and an asset (or a liability) must be capable of generating inflows (or outflows) of economic benefits. Those inflows (or outflows) need not be certain. Consequently, the Discussion Paper suggested the following definitions: an asset is a present economic resource controlled by the entity as a result of past events. a liability is a present obligation of the entity to transfer an economic resource as a result of past events. an economic resource is a right, or other 8|Page Many respondents agreed with the focus on the The Exposure Draft proposes to use the right or obligation. definitions suggested in the Discussion Paper, but with two changes to the definition of an Many respondents agreed that the reference to economic resource: ‘expected’ in the existing definitions should be to use the phrase ‘has the potential to’ replaced with ‘capable’. However: rather than ‘capable’. This term, together some found the term ‘capable’ unclear; and with the proposed supporting guidance, is intended to clarify that no probability some expressed the view that an explicit threshold is intended. This reflects the probability threshold should be retained in IASB’s view that assets and liabilities can either the definitions of assets and liabilities exist even when there is only a low or the recognition criteria. probability of a flow of economic benefits. to delete ‘or other source of value’. The Some respondents felt that ‘other source of value’ was too vague. IASB proposes instead to explain that the notion of a ‘right’ encompasses not just legal rights but also access that an entity controls in other ways, for example by keeping know-how secret. The Exposure Draft clarifies that when there is only a low probability of an inflow or Suggestion in 2013 Discussion Paper Feedback received source of value, that is capable of producing economic benefits. Rights approach The Discussion Paper suggested defining an economic resource (and, hence, an asset) as a right. For example, for a physical object (such as a building), the asset is not the underlying physical object but a bundle of rights to obtain the economic benefits generated by the building. outflow of economic benefits, recognising an asset or liability may in some cases not provide relevant information. Although many respondents supported the idea that an economic resource is a right, some felt that some items are best viewed as physical objects rather than as a bundle of rights. The Exposure Draft adopts the same approach as the Discussion Paper. Many respondents agreed that the definition of a liability should include at least some obligations that are conditional on an entity’s future actions (ie they agreed with the IASB’s The Exposure Draft proposes that the definition of a present obligation should reflect Approach 2. Hence, it proposes that an entity has a present obligation to transfer The Discussion Paper noted that in many cases, the bundle of rights over a physical object (such as a building) will still often be: accounted for as a single item; and described in the financial statements as the physical object, if a more precise description is not needed. Present obligation The Discussion Paper discussed three approaches to identifying a present obligation, which must have arisen from past events: Approach 1: a present obligation must be 9|Page How the IASB responded The IASB notes that ownership of a physical object arises only because of rights conveyed by law. Furthermore, full legal ownership of a physical asset differs from the right to use an asset for 99 per cent (or 50 per cent or even 1 per cent) of its useful life, but although those rights differ in their extent, they do not differ fundamentally in nature—they are all rights of one kind or another. Hence, the Exposure Draft proposes defining an economic resource as a right. Nevertheless, consistently with the Discussion Paper the Exposure Draft notes that describing the set of rights as a physical object will often provide the most concise, clear and understandable information. Suggestion in 2013 Discussion Paper strictly unconditional. Approach 2: a present obligation must be practically unconditional. Approach 3: a present obligation may be conditional on the entity’s future actions. Feedback received How the IASB responded rejection of Approach 1). However, views were mixed on whether the IASB should adopt Approach 2, Approach 3 or some hybrid of those approaches. an economic resource if both: the entity has no practical ability to avoid the transfer; and the obligation has arisen from past events; in other words the entity has received the economic benefits, or conducted the activities, that establish the extent of its obligation. The IASB tentatively rejected Approach 1. However, it did not reach a preliminary view in favour of either Approach 2 or Approach 3. The IASB rejected Approach 1 because restricting obligations to those that are strictly unconditional would be unlikely to provide useful information to users of financial statements. The IASB rejected Approach 3 because the term ‘obligation’ implies that there must be some limit on the entity’s ability to avoid the transfer of an economic resource. Executory contracts The Discussion Paper described the rights and obligations that arise under executory contracts. Many respondents stated that the guidance on executory contracts needed further development. The IASB has refined the discussion of executory contracts. The Exposure Draft states that: an executory contract creates a single asset or single liability; and is an asset if the terms of the exchange are favourable, and is a liability if the terms of the exchange are unfavourable. The IASB proposes that the Conceptual 10 | P a g e Suggestion in 2013 Discussion Paper Feedback received How the IASB responded Framework should not provide explicit guidance on the measurement of executory contract assets and liabilities. Thus, the measurement guidance proposed for all assets and liabilities would also apply to such assets and liabilities. As noted in the Exposure Draft, if an executory contract is measured at historical cost, it is measured at zero (and, hence, is not recognised) unless it is onerous. Equity The Discussion Paper suggested that: the Conceptual Framework should retain the existing definition of equity as the residual interest in the assets of the entity after deducting all its liabilities. the IASB should use the definition of a liability to distinguish liabilities from equity instruments. an entity should: o update the measure of classes of equity claim at the end of each reporting period. o recognise updates to those measurements in the statement of changes in equity, as a transfer of wealth between classes of equity 11 | P a g e Many respondents supported retaining the existing definition of equity, and using the suggested definition of a liability (or a similar definition) to distinguish liabilities from equity instruments. However, some respondents expressed concerns about such an approach. The IASB is not proposing any changes to the definitions of a liability, or of equity, to address the problems that arise when classifying instruments with characteristics of both liabilities and equity. The IASB will further explore how to distinguish between liabilities and equity in its research project on Many respondents also supported presenting or Financial Instruments with Characteristics of disclosing additional information on the effects Equity. of different classes of equity claims; however, many expressed reservations about the Consequently, the Exposure Draft does not suggestion to update the measurement of discuss presentation or disclosure about classes of equity claim and to highlight the classes of equity claims, measurement of results using an enhanced statement of changes equity claims, or the use of a statement of in equity. changes in equity. Suggestion in 2013 Discussion Paper Feedback received How the IASB responded Many respondents stated that there is no need to change the definitions of income or expenses (except to align them with the revised definitions of assets and liabilities). The Exposure Draft proposes changes to the definitions of income and expenses to align them with the proposed definitions of assets and liabilities. The proposed definitions are as follows: Income is increases in assets or decreases in liabilities that result in increases in equity, other than those relating to contributions from holders of equity claims. Expenses are decreases in assets or increases in liabilities that result in decreases in equity, other than those relating to distributions to holders of equity claims. claim. if an entity has issued no equity instruments, it may be appropriate to treat the most subordinated class of instruments as if it were an equity claim. Definitions of income and expenses The Discussion Paper briefly discussed possible changes to the definitions of income and expenses resulting from the suggested changes to the definitions of assets and liabilities. However, a few respondents suggested that the IASB should not define income and expenses solely in terms of changes in asset and liabilities. Although the Exposure Draft still defines income and expenses in terms of changes in assets and liabilities, it emphasises that information about financial performance is just as important as information about financial position. 12 | P a g e Suggestion in 2013 Discussion Paper Feedback received How the IASB responded Unit of account The Discussion Paper suggested that the unit of account will normally be decided when the IASB develops Standards and that in selecting the unit of account, the IASB should consider the qualitative characteristics of useful information. Many respondents agreed with the suggestions in the Discussion Paper. However, some stated that the Conceptual Framework should include more guidance on determining the unit of account. They did not indicate what sort of guidance would be helpful. Although the IASB still thinks that the unit of account will normally be decided when it develops Standards, the Exposure Draft proposes guidance on: possible units of account; and factors to consider when determining the unit of account. Some respondents read the Discussion Paper as setting a presumption that all assets and liabilities should be recognised. They disagreed with such a presumption. Others disagreed with the implication that only the IASB when developing Standards could decide that an asset or liability should not be recognised. The Exposure Draft proposes an even-handed approach to recognition with neither a presumption that all assets or liabilities should be recognised nor a presumption that they should be recognised only if they meet stringent criteria. Instead, the Exposure Draft proposes criteria based on the qualitative characteristics of useful financial information and on the cost constraint. Some respondents agreed that the recognition criteria should refer to relevance and faithful representation. However, some suggested that it would be clearer and more straightforward to retain probability and reliability of The supporting guidance identifies some circumstances when those criteria might not be met including: some cases when it is uncertain whether an asset or liability exists; Chapter 5—Recognition and derecognition Recognition The Discussion Paper suggested that an entity should recognise all its assets and liabilities, unless the IASB decides when developing Standards that an entity need not, or should not, recognise an asset or a liability because: recognising the asset (or the liability) would provide users of financial statements with information that is not relevant or is not sufficiently relevant to justify the cost; or no measure of the asset (or the liability) would result in a faithful representation of both the asset (or the liability) and the changes in the asset (or the liability), even if all necessary descriptions and 13 | P a g e Suggestion in 2013 Discussion Paper explanations are disclosed. Feedback received How the IASB responded measurement as explicit recognition criteria. some cases when the asset or liability is unlikely to result in future flows of economic benefits; and some cases when the level of measurement uncertainty is so high that the measurement has little relevance and no other relevant measure is available or can be obtained. In response to the feedback received, the Exposure Draft no longer proposes that decisions about recognition should be restricted to the IASB. Derecognition The Discussion Paper suggested that an entity should derecognise an asset or a liability when it no longer meets the recognition criteria. However, for cases in which an entity retains a component of an asset or a liability, the IASB should determine, when developing or revising particular Standards how the entity would best portray the changes that resulted from the transaction. 14 | P a g e Respondents were split on the approach to be used for derecognition. Some suggested a control-based approach to recognition. Others suggested an approach based on an assessment of risks and rewards. The Exposure Draft describes the approaches available and the factors to consider, in deciding at a Standards level how to represent faithfully both: the assets and liabilities (if any) retained after the transaction that led to the derecognition; and the change in the entity’s assets and liabilities as a result of the transaction. Suggestion in 2013 Discussion Paper Feedback received How the IASB responded Although many respondents agreed with the overall approach to measurement suggested in the Discussion Paper some respondents suggested that the measurement section of the Discussion Paper: was underdeveloped. Consequently, the IASB should delay issuing any proposals on measurement and undertake additional research; and included too much Standards-level detail. Because the lack of guidance on measurement is a serious gap in the existing Conceptual Framework, the IASB proposes not to delay issuing its proposals on measurement. Chapter 6—Measurement Approach The Discussion Paper discussed: how the objective of financial reporting and the qualitative characteristics of useful financial information influence decisions about measurement; three categories of measurement bases; and how to identify an appropriate measurement basis and the implications of the suggested approach for particular types of assets and liabilities. The Exposure Draft focuses on: measurement bases, the information that they provide and their advantages and disadvantages; and the factors to consider when selecting a measurement basis. The IASB agreed with those respondents who suggested that the measurement section contained too much Standards-level detail. Hence, the IASB has removed some of the detailed guidance included in the Discussion Paper on implications for particular types of assets and liabilities. Mixed measurement The Discussion Paper suggested that a single measurement basis for all assets and liabilities may not provide the most relevant information for users of financial statements. 15 | P a g e Although a few respondents to the Discussion Paper suggested that the Conceptual Framework should advocate the use of a single measurement basis, nearly all of those who Consistently with the feedback received, the Exposure Draft does not advocate a single measurement basis for all assets and liabilities. It states that consideration of the Suggestion in 2013 Discussion Paper Measurement bases The Discussion Paper grouped measures into three categories: Cost-based measures; Current market prices including fair values; and Other cash-flow-based measures. Feedback received How the IASB responded commented on this issue agreed that a single measurement basis for all assets and liabilities may not provide the most relevant information for users of financial statements. objective of financial reporting, of the qualitative characteristics of useful information and of the cost-benefit constraint is likely to result in the selection of different measurement bases for different assets, liabilities and items of income and expense. A few respondents stated that they found the discussion of three different categories of measures confusing. Others stated that the Conceptual Framework should identify only two measurement categories: cost-based measures and current measures. The IASB agreed with those respondents who suggested that the discussion of three different categories of measures was confusing. Hence, the Exposure Draft describes the following measurement bases: historical cost measurement bases; and current value measurement bases including fair value, value in use and fulfilment value. Cash-flow-based measurements are described as measurement techniques used to estimate measurements made on one of the measurement bases described. 16 | P a g e Suggestion in 2013 Discussion Paper Factors to consider when selecting a measurement basis The Discussion Paper suggested that: when selecting which measurement basis to use for a particular item, the IASB should consider what information that measurement basis will produce in both the statement of financial position and the statement(s) of profit or loss and OCI. the relevance of a particular measure will depend on how investors, creditors and other lenders are likely to assess how an asset or a liability of that type will contribute to future cash flows. Consequently, the selection of a measurement basis: o for a particular asset, should depend on how that asset contributes to future cash flows; and o for a particular liability, should depend on how the entity will settle or fulfil that liability. the number of different measurement bases used should be the smallest number necessary to provide relevant information. Unnecessary measurement changes should be avoided and necessary measurement changes should be explained. the benefits of a particular measurement 17 | P a g e Feedback received How the IASB responded Many respondents to the Discussion Paper: agreed with the guidance on selection of a measurement basis; and suggested that consideration of the business model concept could help in selecting a measurement basis. The Exposure Draft develops the suggestions in the Discussion Paper. It discusses how the qualitative characteristics of useful financial information affect the selection of a measurement basis. In particular, the Exposure Draft proposes that: when selecting a measurement basis it is important to consider the information that measurement basis will produce in both the statement of financial position and the statement(s) of financial performance; information provided by the financial statements can be made more relevant by considering: o how that asset or liability contributes to future cash flows. This will depend in part on the nature of the business activities conducted by the entity; and o the characteristics of the asset or liability. the level of measurement uncertainty associated with a measurement basis is one of the factors that affects the relevance of the information provided by that measurement basis. Some respondents to the Discussion Paper disagreed with the suggestion that the number of different measurement bases used should be the smallest number necessary to provide relevant information. They stated that there should not be an artificial limit on the number of measurement bases used. Suggestion in 2013 Discussion Paper Feedback received How the IASB responded basis to users of financial statements need to be sufficient to justify the cost. as with all other areas of financial reporting, the cost constraint affects the selection of a measurement basis. The Exposure Draft no longer states that the number of different measurement bases used should be the smallest number necessary to provide useful information. Instead it states that, in general, the greater the number of measurement bases used in a set of financial statements, the more complex (and hence, less understandable) the resulting information will be. Chapter 7—Presentation and disclosure (General guidance) Objectives The Discussion Paper suggested that: the objective of primary financial statements is to provide summarised information about recognised assets, liabilities, equity, income, expenses, changes in equity, and cash flows that have been classified and aggregated in a manner that is useful to users of financial statements in making decisions about providing resources to the entity. the objective of the notes to the financial statements is to supplement the primary 18 | P a g e Most respondents expressed broad support for these suggestions. However, some questioned whether it is necessary to have separate objectives of the primary financial statements and the notes. The Exposure Draft does not identify primary financial statements, nor does it propose separate objectives for particular parts of the financial statements (other than to describe the purpose of the statement of profit or loss). The IASB considers that such definitions and objectives are best considered in Standards-level projects (eg the Disclosure Initiative). However, the IASB considers that setting an objective for the financial statements as a Suggestion in 2013 Discussion Paper Feedback received financial statements by providing additional useful information about: o the assets, liabilities, equity, income, expenses, changes in equity, and cash flows of the entity; and o how efficiently and effectively the entity’s management and governing board have discharged their responsibilities to use the entity’s resources. Scope The Discussion Paper suggested that: forward-looking information should be required in financial statements only if it provides relevant information about the assets and liabilities that existed at the end of, or during, the reporting period. financial statement should include information about the risks arising from an entity’s recognised and unrecognised assets and liabilities. 19 | P a g e How the IASB responded whole would clarify their scope and, hence, the Exposure Draft proposes the following objective for the financial statements: To provide information about an entity’s assets, liabilities, equity, income and expenses that is useful to users of financial statements in assessing the prospects for future net cash inflows to the entity and assessing management’s stewardship of the entity’s resources. Some respondents to the Discussion Paper: stated that the suggested description of forward-looking information is too narrow and could result in useful information being excluded from the financial statements (for example, information about non-adjusting post-balance sheet events). Others stated that the description would be too broad. expressed a concern that a requirement to provide information about risks could be understood to include almost any type of information, including information that would be best placed outside the financial statements. The Exposure Draft proposes to retain the description of forward-looking information that should be included in financial statements. In response to concerns raised, it clarifies that information about non-adjusting post-balance sheet events is not forward-looking information and is included in the financial statements if such information is necessary to meet the proposed objective of financial statements. The Exposure Draft retains the Discussion Paper’s suggestion that financial statements should include information about the risks arising from an entity’s recognised and unrecognised assets and liabilities because Suggestion in 2013 Discussion Paper Feedback received How the IASB responded the IASB believes that such information contributes to meeting the proposed objective of financial statements. Presentation and disclosure as communication tools The Discussion Paper discussed: classification, aggregation and offsetting in financial statements; presentation and disclosure objectives in Standards; and communication principles that the IASB should consider when it sets presentation and disclosure requirements in Standards. Although there was broad support for the suggestions in the Discussion Paper, many respondents expressed the view that it included too much Standards-level detail. The IASB agreed with the feedback received and, hence, the proposals in the Exposure Draft focus on high-level principles instead of Standards-level guidance. The Exposure Draft proposes guidance on: how presentation and disclosure can be used as communication tools; classification and aggregation of amounts included in the financial statements; and using presentation and disclosure principles to promote the effective and efficient communication of information. Chapter 7—Presentation and disclosure (Information about financial performance) Overall approach The Discussion Paper reviewed approaches to reporting income and expenses in the statement of profit or loss and other comprehensive income (OCI). Some respondents expressed the view that the discussion of financial performance and the reporting of income or expenses in OCI: requires more thought and analysis; simply codified existing practice; is a Standards-level topic. The IASB believes that conceptual guidance on reporting financial performance (including the use of OCI) is urgently needed. The proposals in the Exposure Draft build on the suggestions in the Discussion Paper. In developing those proposals, the IASB has 20 | P a g e Suggestion in 2013 Discussion Paper Feedback received How the IASB responded considered the use of OCI in existing Standards. However, it has not sought to justify existing practice. Describing the statement of profit or loss The Discussion Paper suggested: that the Conceptual Framework should require a total or subtotal for the statement of profit or loss; that the statement of profit or loss should be treated as a default location for income and expense; and how to decide which items of income or expense should be reported in the statement of profit or loss and which should be reported in other comprehensive income (OCI). 21 | P a g e Many respondents: argued that profit or loss is the primary measure of performance and should be given prominence in the Conceptual Framework; agreed that profit or loss should be presented as a total or subtotal; and stated that profit or loss (and/or financial performance) should be defined or described. However, there were few suggestions, and no consensus, about how this should be done. The IASB’s previous work on presentation and disclosure has lead it to conclude that it is not possible to define or precisely describe in the Conceptual Framework when an item of income or expense should be included in the statement of profit or loss. Hence, instead of defining profit or loss the Exposure Draft: states that income or expenses included in the statement of profit or loss are the primary, but not the only, source of information about an entity’s financial performance for the period; proposes a presumption that all income and expenses will be included in the statement of profit or loss; but states that in some circumstances the relevance of the information in profit or loss could be enhanced if income or expenses arising from a remeasurement of an asset or liability is reported outside the statement of profit or loss (in OCI). Suggestion in 2013 Discussion Paper Feedback received How the IASB responded Recycling The Discussion Paper suggested that the Conceptual Framework should permit or require at least some OCI items to be reclassified subsequently (‘recycled’) into the statement of profit or loss. Many respondents to the Discussion Paper supported recycling for some or all items included in OCI. However, there was no consensus about which items to recycle and when. The Exposure Draft proposes a rebuttable presumption that income or expenses included in OCI would subsequently be recycled to profit or loss. This is consistent with the idea that the statement of profit or loss is the primary source of information about an entity’s performance for the period. Most respondents agreed with the suggested approach to capital and capital maintenance. The IASB proposes to leave the existing descriptions and discussion of capital and capital maintenance in the Conceptual Framework largely unchanged. Chapter 8—Capital and capital maintenance The IASB suggested keeping the existing descriptions and discussion of capital and capital maintenance in the Conceptual Framework largely unchanged until it undertakes a project on accounting for high inflation. 22 | P a g e Suggestion in 2013 Discussion Paper Feedback received How the IASB responded Many respondents: agreed that the business model has a role to play in financial statements. However, there were mixed views on whether it is fundamental to financial reporting or should play a more limited role; and suggested the IASB should define or provide additional guidance on the business model. However, others noted that other parties have defined the business model, for different purposes. They suggested that the IASB would cause confusion if it adopted a different definition, tailored to be suitable for accounting. To avoid confusion with how the term ‘business model’ is used by other parties, the Exposure Draft does not use that term. It refers instead to ‘how an entity conducts its business activities’. Other issues Business model The Discussion Paper did not define the business model concept. However, the IASB suggested that financial statements can be made more relevant if the IASB considers how an entity conducts its business activities when developing new Standards. A few respondents suggested that the IASB should identify long-term investment as a particular type of business activity (or business model), and develop specific measurement and presentation requirements for entities conducting that business activity 23 | P a g e The IASB believes that the nature of an entity’s business activities affects different aspects of financial reporting differently. Thus, the Exposure Draft discusses the effect of an entity’s business activities separately for each area affected, rather than providing a single over-arching description of those effects. The IASB believes that: the Exposure Draft contains sufficient discussion of the effect of an entity’s business activities for the IASB to reach appropriate standard-setting decisions for any kind of business activity, including long-term investment; and there is no need for the Conceptual Framework to contain specific decisions on any particular type of business activity. Suggestion in 2013 Discussion Paper Transition and effective date The Discussion Paper stated that once the IASB finalises the revised Conceptual Framework, it will start using it immediately. The Discussion Paper did not suggest any other guidance on transition and effective date. Effects analysis The Discussion Paper stated that a revised Conceptual Framework will not necessarily lead to changes to existing IFRSs. Any proposal to change an existing Standard or 24 | P a g e Feedback received How the IASB responded Some respondents stated that the Conceptual Framework should include transition guidance, particularly for those preparers who use the Conceptual Framework to develop and select accounting policies when no specific Standard applies. The IASB agreed with those respondents who suggested that the Conceptual Framework should include transition guidance. Hence, the Exposure Draft proposes that: the IASB and the IFRS Interpretations Committee should apply the revised Conceptual Framework immediately after its publication; a transition period of approximately 18 months should be allowed for entities that use the Conceptual Framework to develop and select accounting policies when no specific Standard applies. Early application should be permitted; and no additional guidance on transition should be provided in the revised Conceptual Framework. Consequently, IAS 8 Accounting Policies, Changes in Accounting Estimates and Errors would govern any changes in accounting policy arising from an application of the revised Conceptual Framework. Some respondents to the Discussion Paper stated that the IASB should analyse the potential effect of a revised Conceptual Framework on existing Standards. In particular, The Basis for Conclusions accompanying the Exposure Draft: explains that the Conceptual Framework Suggestion in 2013 Discussion Paper Feedback received Interpretation would need to go through the IASB’s normal due process (including a formal decision to add the project to the IASB’s agenda). the IASB should identify any inconsistencies between the revised Conceptual Framework and the Standards. How the IASB responded Timetable The Discussion Paper stated that the Conceptual Framework should be revised without delay. Setting a tight but achievable deadline means that the IASB will focus on those changes that will provide clear and significant improvements to the existing Conceptual Framework. 25 | P a g e Some respondents to the Discussion Paper supported the IASB’s decision to set a tight timetable for the project. However, many of those who commented expressed the view that the IASB should spend more time developing robust concepts. does not override existing Standards or Interpretations; explains the implications of the proposed changes to the Conceptual Framework including the fact that the IASB will not necessarily change existing Standards or Interpretations as a result of changes that it makes to the Conceptual Framework; and describes possible inconsistencies between the existing Standards and the Conceptual Framework Exposure Draft. The IASB will not finalise the revised Conceptual Framework until it is satisfied that enough work has been done and that its due process has provided sufficient input. Nevertheless, the IASB continues to believe that significant improvements to the existing Conceptual Framework can and should be made on a timely basis. Hence the IASB aims to complete its revisions to the Conceptual Framework in 2016.