Australian Government Department of Finance and Deregulation SUMMARY OF SIGNIFICANT CHANGES TO THE FINANCE MINISTER’S ORDERS FOR FINANCIAL REPORTING (INCORPORATING POLICY AND GUIDANCE) AND PRIMA FORMS OF FINANCIAL STATEMENTS APPLYING TO 2011-12 The purpose of this document is to provide entities with an overview of the significant changes to the Finance Minister’s Orders for Financial Reporting (FMOs) and PRIMA Forms of Financial Statements. Additionally, it offers guidance to assist entities in identifying which of these changes may constitute a change in accounting policy, as required by AASB 108 Accounting Policies, Changes in Accounting Estimates and Errors, and thus might require disclosure (whilst considering materiality and the entity’s own circumstances). Reference Change in accounting policy1 Changes Finance Minister’s Orders General Amended – throughout the document: o sections containing guidance on changes applicable for the first time in 2010-11 (e.g. to Australian Accounting Standards (AAS)) have either been removed or condensed; o divisions have been reworked to improve readability by grouping related sections under subheadings; o where required, paragraphs have been moved to more appropriate divisions or levels (e.g. from policy to black letter or guidance); and o guidance not relevant to the preparation of financial statements has been removed. No impact. 1 Disclaimer: These changes have been assessed by Finance as likely to constitute a change in accounting policy in accordance with the principles of AASB 108 Accounting Policies, Changes in Accounting Estimates and Errors to assist entities in preparing and presenting their financial statements. However, entities will need to consider whether the changes actually constitute a change in accounting policy for their own individual circumstances then work through the potential reporting implications whilst considering materiality. Hence, not all of the likely changes in accounting policy might apply to an entity or require disclosure. ■ Added or new section ■ Amended, clarified or moved ■ Removed Page 1 Replaced most specific references to Financial Management and Accountability Act 1997 (FMA Act) agencies and Commonwealth Authorities and Companies Act 1997 (CAC Act) authorities with references to the defined term entities in order to ensure items are reported consistently by all Commonwealth entities where relevant. Impact: when determining whether an accounting treatment or disclosure is relevant, entities must consider the substance of the transaction and/or circumstances (i.e. if you have it, you report it and disclose in full). For example, references to agency have been replaced with entity in Divisions 100 – 104 to ensure all Commonwealth entities to which these requirements apply prepare appropriation disclosures on a consistent basis. Information which is inconsistent with the philosophy of the Finance Minister’s Orders (FMOs) has been removed. The philosophy of the FMOs being that: o it will not duplicate or re-state accounting standards; o they are not a “training tool”; o they should be logically arranged; and they should be written as close to “plain English” as is feasible for a technical document. No impact. 1 Legislative Authority Clarified the scope and source of authority of the FMOs. Amended division to reflect the move to a single legislative instrument titled Finance Minister’s Orders (Financial Statements for reporting periods ending on or after 1 July 2011) for all entities covered by the FMOs. No impact. 2 Content, Philosophy and Structure Added sections on content and philosophy of the FMOs, which set out the principles adhered to when preparing the FMOs and PRIMA Forms of Financial Statements (PRIMA Forms). No impact. 4 Definitions Replaced the defined terms administered items and departmental items with administered and departmental respectively, as the previous terms already had a specific meaning under the Appropriation Acts. Moved the following definitions from other divisions: o appropriations for payment to CAC Act bodies (from Division 100); o commitments (from Division 81); and o heritage and cultural assets (from Division 37). Replaced the defined term responsible agency with responsible entity. ■ Added or new section ■ Amended, clarified or moved ■ Removed Page 2 Removed the following definitions which are defined elsewhere (i.e. in AAS, legislation, Government policy or guidance): o drawdown; o FinanceBriefs; o Portfolio Budget Statements; o redundancy; o reimbursement; o reserves; o revaluation; o special account; o special appropriations; and o standing appropriations. Added definition of Public Non-Financial Corporations. No impact. 8 Authoritative Requirements Added guidance clarifying the legal meaning of the phrase ‘have regard to’ in relation to the status of FinanceBriefs, Accounting Guidance Notes (AGNs), etc. Impact: While the ‘have regard to’ principle is well established, the FMOs now clarify that entities must take principles in FinanceBriefs, etc. into consideration as a fundamental element in decision making. In rare circumstances where entities are of the view that key principles should not be applied, they must be able to demonstrate why and document their reasoning. 9 Financial Reporting Structure and Form 10 Simplified reporting Added new requirement for not-for-profit entities to disclose their basis of operations in accordance with paragraph 8(b) of AASB 1054. Impact: all entities must disclose whether they operate on a forprofit or not-for-profit basis. Removed division – provisions moved to other relevant divisions where appropriate. No impact. 13 Rounding off Clarified that section 13.2 is subject to the exceptions in sections 13.3 to 13.5. No impact. 15 Departmental and Administered Items: Classification and Reporting Clarified that all special public money is neither departmental nor administered, including money held in trust, which is a subset of special public money. See also changes to Division 120. No impact. ■ Added or new section ■ Amended, clarified or moved ■ Removed Page 3 16 Exemptions from this Schedule Added section 16.4 to black letter to clarify that even where granted, exemptions cannot be applied if they do not comply with AAS. Added section 16.5 to black letter to clarify that entities must prepare information required for consolidation into the CFS. Impact: Entities are not able to apply exemptions where they result in non-compliance with AAS. 17 Approved Exemptions Removed exemption - for-profit entities are no longer exempt from making disclosures under Division 23. Impact: For-profit entities must make disclosures required under Division 23, including 2010-11 comparatives. 23 Director/ Executive Remuneration General: o Clarified that references to remuneration are taken to refer to Table A requirements only, whereas references to reportable remuneration refer to Table B and C disclosures (in relation to requirements for staff who were promoted to SES part-way through the reporting period, etc). o Added requirements for individuals on secondment. o Added guidance specifically encouraging entities to include extra footnote disclosure if any figures appear unusual or otherwise warrant additional explanation, only where it provides meaningful information for users. o Removed exemption for senior executives and other highly paid staff who worked wholly or mainly outside Australia (excluding those who are deployed). Impact: as described above, noting that from 2011-12 for-profit entities are within scope of Division 23 (see changes to Division 17 above). Added new requirements for Table B: o From 2011-12, this table is required to be prepared on a cash basis. With the exception of superannuation, all other items are to be based on the payment summary. Superannuation is based on payslips where available (otherwise entities need to work with their auditors). o The table now shows average annual reportable remuneration, which is comprised of reportable salary, contributed superannuation, reportable allowances and bonus paid (each element is disclosed as a separate column). o Each component of reportable remuneration is a defined term in Division 23 of the FMOs. o Bands are now based on the total column (i.e. total reportable remuneration). o Table B now applies to all substantive senior executives during the reporting period, rather than only those employed at 30 June. o Enhanced footnote disclosures have been added supporting the ■ Added or new section ■ Amended, clarified or moved ■ Removed Page 4 table. Impact: as described above, noting that these disclosures will also need to be prepared for 2010-11 comparatives. Added new requirements for Table C: o Disclosures for other highly paid staff (Table C) have been aligned with disclosures for senior executives in Table B. o As in 2010-11, the minimum threshold for other highly paid staff is $150,000 but it is now to be applied to reportable remuneration. Impact: as described above, noting that these disclosures will also need to be prepared for 2010-11 comparatives. 38 Assets Held in Trust Added section 38.2(c)(iv) to black letter to clarify that changes in fair value must be included in the disclosures to ensure the estimated value in the bottom line reconciles to the value on the balance sheet. Impact: As outlined above. 42 Provisions Removed division as it contained no black letter and sections merely paraphrased or referred to AAS and AGNs. No impact. 44 Measurement and Disclosure of Post Employment Plans Relocated guidance on PSS, CSS and military superannuation schemes from Division 90, which has been removed. No impact. Clarified the requirement to reference Australian Government bonds when determining a discount rate for employee benefits under AASB 119. No impact. 50 Statement of Changes in Equity 75 Schedule of Administered Items 81 Commitments Removed division, as it contained no black letter and the guidance was covered by Division 85. No impact. Removed division as the requirements were covered by Division 85. No impact. Amended Division 81 to ensure commitment requirements were unchanged following the removal of paragraph Aus 138.6 from AASB 101. No impact. 82 Asset Additions Removed division. Impact: Entities are no longer required to prepare the schedule of asset additions. ■ Added or new section ■ Amended, clarified or moved ■ Removed Page 5 85 Administered Reporting The treatment of administered transactions is unchanged from 201011, with the following amendments to disclosures: o Added the requirement to prepare a schedule of administered comprehensive income; o Net assets line added to the schedule of administered assets and liabilities; o Added requirement to prepare an administered cash flow reconciliation; and o Former administered reconciliation table has been given greater prominence and renamed as a schedule. Impact: As outlined above (also refer to administered reporting changes in PRIMA Forms detailed below). 86 Income and Expenses Administered on Behalf of Government 89 Impairment of Administered Assets 90 Liabilities Administered on Behalf of the Government 91 Transfer Payments 100 Recognition of Approps – General Clarified that quarantining in itself has no impact on recognition/disclosure of appropriations. Removed former section 100.51P as part of principles-based approach and focus on substance over form. If entities have appropriations then they must report them, regardless of their enabling legislation. Removed division, as it only referred to other divisions. No impact. Removed division and relocated guidance to Division 85. No impact. Removed division, black letter relocated to Division 44. No impact. Removed division and relocated guidance to Division 85. No impact. No impact. 103 Recognition of Appropriations – CAC Entities Removed division as guidance is inconsistent with principles-based approach and focus on substance over form. Policy is sufficiently covered by Division 102 and FinanceBrief 38. No impact. ■ Added or new section ■ Amended, clarified or moved ■ Removed Page 6 104 Disclosure of Approps Table A Annual appropriations – where applicable, a list of Finance Minister’s determinations supporting numbers in the table must be disclosed showing date of effect and amounts for administered as well as departmental appropriations. Added requirement to prepare new Table B Departmental and Administered Capital Budgets (refer to changes to Note 35 Appropriations below). Added new requirement to disclose unspent annual administered appropriations in Table C Unspent annual appropriations in addition to existing departmental disclosures. Removed former 104.67P, which previously gave entities the choice not to disclose Table F Reduction in administered items if no reduction was required (an additional change to Table F is detailed in the changes to Note 35 below). Impact: Entities must now: o disclose information on Finance Minister’s determinations supporting administered appropriations as well as departmental appropriations; o disclose total unspent administered appropriations as well as departmental, noting that 2010-11 comparatives must also be prepared; o disclose details of departmental and/or administered capital budgets (where relevant); and o publish Table F, regardless of whether an administered reduction is required. 120 Special Accounts Amended disclosures for Table A Special accounts and B Investments made under FMA Act section 39 (see detail in changes to Note 36 below). Impact: As outlined above. 123 Competitive Neutrality and Cost Recovery Receipts derived from cost recovery arrangements must be disclosed in accordance with PRIMA Forms (see detail in changes to Note 40 below). Impact: As outlined above. ■ Added or new section ■ Amended, clarified or moved ■ Removed Page 7 PRIMA Forms of Financial Statements Note 1 Summary of Significant Accounting Policies The summary of significant accounting policies will now be published as an attachment to PRIMA Forms. No impact. Consistent with changes in terminology throughout the FMOs, the PRIMA Forms no longer refer to FMA only and CAC only notes (refer to the general comments on the FMOs above for further details). Impact: Entities must prepare all disclosures that are relevant, regardless of whether they are a FMA Act agency, CAC Act body, etc. Administered reporting (various notes) Amended administered reporting requirements: o Subheadings added to the administered reconciliation schedule to clarify linkages to the schedule of administered comprehensive income; o Added administered disclosures to the following notes in PRIMA Forms – Note 2 Events after the reporting period, Note 40 Competitive neutrality and cost recovery, and added Note 23: Administered - Income Tax Expense (Competitive Neutrality). Impact: As outlined above (refer to changes to Division 85 above for additional details). Cash flow statement Guidance inserted clarifying that appropriations designated as contributions by owners are required to be disclosed as cash flows from financing activities. Impact: Entities must continue to disclose appropriations designated as contributions by owners as cash flows from financing activities. Schedule of Asset Additions Note 8 NonFinancial Assets Schedule of asset additions has been removed. Impact: Entities are no longer required to disclose the schedule of asset additions. As a consequence, some line items have been added back to Note 8 (see below). The requirement to disaggregate asset additions by type (purchase, finance lease, etc.) has been added back to due to the removal of the schedule of asset additions (see above). See Div 82 above Impact: As described above. Note 12 Restructuring The restructuring note has been reformatted into a table, and now requires disclosures to be prepared by entity and function for both the current and previous reporting period. Impact: As outlined above. Note 17 Substantial changes to Tables B and C disclosures (refer to Division 23 above for additional information). Impact: As outlined above. ■ Added or new section ■ Amended, clarified or moved ■ Removed Page 8 See Div 23 above Notes 19 and 33 Financial Instruments Amended disclosures in relation to the fair value hierarchy and accompanying reconciliation in accordance with the requirements of AASB 7. Impact: As described above. Notes 20 and 34 Financial Assets Reconciliation Added new departmental and administered financial assets reconciliation notes. These notes reconcile financial instruments (assets) back to the financial assets shown on the balance sheet or administered schedule of assets and liabilities for departmental and administered, respectively. Impact: As outlined above. Note 30 Administered cash flow reconciliation Note 35 Appropriations Removed the requirement to split between spent and retention amounts for the amount required in Table F Reduction of administered items. New requirement to prepare a cash flow reconciliation for administered cash flows. See Div 85 above Impact: As described above. See Div 104 above Impact: As outlined above (see changes to Division 104 above for additional changes to appropriation disclosures). Note 36 Special Accounts Disclosures for special accounts amended: o Disclosures split into Note 36A Special accounts (presented as a single table) and Note 36B Investments made under section 39 of the FMA Act. See Div 120 above o New requirement added that amounts debited from special accounts are required to be split into administered, departmental and special public money; and o New policy added to PRIMA Forms specifying that amounts transferred back to the OPA because they are no longer required, regardless of the dollar amount, must be disclosed as a major class named reduction transfer to the OPA. Impact: As outlined above. Note 40 Competitive Neutrality and Cost Recovery Competitive neutrality and cost recovery disclosures are no longer part of the outcomes note, they are to be disclosed in a separate note. Furthermore, income subject to Cost Recovery Policy is now required to be disaggregated by cost recovery arrangements. See Div 123 above Impact: As outlined above. Note 41 Net Cash Appropriation Arrangements The former Note 34 – Comprehensive Income/(Loss) attributable to the agency has been amended. Impact: Entities must prepare the disclosures in the format prescribed in PRIMA Forms and are not permitted to present the note elsewhere in their financial statements. ■ Added or new section ■ Amended, clarified or moved ■ Removed Page 9