EXHIBIT I
CONSEJO MEXICANO PARA LA INVESTIGACIÓN Y DESARROLLO DE
NORMAS DE INFORMACIÓN FINANCIERA (CINIF)
RESPONSES FROM CINIF TO THE ELEVEN QUESTIONS INCLUDED IN
THE INVITATION FOR COMMENTS RECEIVED FROM THE IASB IN THE
EXPOSURE DRAFT OF THE PROPOSED IFRS FOR SMEs
Question 1 – Stand-alone document
1. In the text of the question it is stated that “...the IASB focused on the types of
transactions and other events and conditions typically encountered by SMEs with
about 50 employees. For such entities, the proposed IFRS is intended to be a
stand alone document, with minimal cross-references to full IFRSs”. In the
paragraphs in Section 1 of the ED there is no mention or reference to such
number of employees.
2. It should be considered that in many countries SMEs include many non-publicly
accountable entities with great volumes of operations and hundreds and even
thousands of employees. For these types of entities the definition of SME stated
in Section 1 of the ED is obviously improper.
3.
IFRS for SMEs cannot be considered an independent or stand-alone document
since in many of its paragraphs cross-references are made to the complete IFRSs
requiring its application, as it is the case in the following twenty four paragraphs:
7.9, 10.4, 11.1, 13.5, 14.10, 14.11, 15.5, 16.13, 17.16, 17.23, 19.15, 19.20, 23.3
(b), 24.4, 24.5, 25.4, 29.2, 29.3, 30.21, 31.1, 34.1, 35.1 (a), 37.1, 37.2. These
requirements for the application of standards stated in the full IFRSs will force
the issuers, auditors and users of the financial statements of SMEs to have
knowledge and training in both the full IFRSs and the IFRS for SMEs. Shall this
be the case, then the adoption of the IFRS for SMEs will not simplify the
accounting rules for SMEs but will make such rules more complex.
4. For the reasons discussed above we have concluded that only one set of financial
standards should exist, applicable to all kind of entities regardless of type or size.
The difference between SMEs and publicly accountable entities should not be
made based on the financial accounting standards to apply but only in the
disclosure requirements. Thus, SMEs should be subject to less disclosure
requirements than those required as mandatory for publicly accountable entities.
Question 2 – Recognition and measurement simplifications that the Board adopted
Our responses to this question are included in our detailed comments listed in Exhibit 2.
1
Question 3 – Recognition and measurement simplifications that the Board
considered but did not adopt
We concur with the position adopted by IASB.
Question 4 – Whether all accounting policy options in full IFRSs should be available
to SMEs
All options stated in the full IFRSs for general application should be also permitted to
SMEs. In our opinion there should not be accounting policy options for SMEs different
to those stated in the full IFRSs. We suggest that the disclosure requirements for SMEs
be reduced to those considered to be strictly necessary for such entities.
Question 5 – Borrowing costs
We do not concur with the proposal because a lack of comparability is generated. See our
comments in Section 24, Exhibit 2.
Question 6 – Topics not addressed in the proposed IFRS for SMEs
As stated in our response to Question 1 we consider that no cross-references to full
IFRSs should be made if IFRS for SMEs is to be considered and independent and stand
alone document. As such all standards considered necessary for SMEs should be
included in the text of the IFRS for SMEs thus making unnecessary for the user the need
to consult another set of rules.
Question 7 – General referral to full IFRSs
We do not consider adequate the requirements in paragraphs 10.2 – 10.4. See our
comments to Questions 1 and 6.
Question 8 – Adequacy of guidance
We recommend the inclusion of more guidance. Also, we suggest that guidance should
be included in each corresponding Section of the IFRS for SMEs. The inclusion in the
guidance of examples of financial statements of service, commercial, and manufacturing
entities would be helpful to SMEs.
Question 9 – Adequacy of disclosures
The Section of Disclosure Requirements in the (Draft) IFRSs for SMEs Section by
Section should be omitted since it is just a copy of the disclosure requirements stated in
the corresponding paragraphs of each Section. Our suggestions for additional or reduction
of disclosure requirements for SMEs are included in Exhibit 2.
2
Question 10 – Transition guidance
We have no comments. We concur with Section 38 of the IFRS for SMEs.
Question 11 – Maintenance of the IFRS for SMEs
We consider inadequate the approach of maintenance adopted in the ED of IFRS for
SMEs which in our opinion should be updated whenever a new IFRS or IFRIC is issued
and not every other year. Doing so may represent the untimely recognition by SMEs of
new and significant accounting developments that may have significant effects on such
entities.
3