IFRS workshop All India Chartered Accountants Society Session: AS convergence to IFRS Aseem Vohra July 10, 2010 © Grant Thornton International. All rights reserved. IFRS transition in India – Road Ahead Impact of convergence Process of transitioning financial reporting © Grant Thornton India. All rights reserved. IFRS transition in India … Road Ahead © Grant Thornton International. All rights reserved. IFRS transition in India – an introduction Need for Adoption in India • Global economy - need to speak in a language which is globally accepted. • International Financial Reporting Standards (‘IFRS’) has now evolved into being the most widely accepted and trusted financial reporting language • Considering the emerging role of India in the global economy, it was imperative for India to harmonize with global financial reporting standards • In August 2007, ICAI announced India’s intention to converge its reporting standards with IFRS - ICAI released a concept paper on convergence • MCA has set up a core group to develop a roadmap for India's transition to IFRS – roadmap released in January 2010 • MCA also released a separate roadmap for Banking and Insurance Companies in March 2010 • SEBI amended the listing agreement to permit voluntary early adoption of IFRS (as issued by IASB) by listed parent companies © Grant Thornton International. All rights reserved. IFRS transition in India – an introduction Progress to date Highlights of the MCA Roadmap MCA reiterates commitment to transition by 2011 MCA sets up core group to develop roadmap MCA's roadmap on transition released • Phased approach to convergence • Companies (except banking & insurance) - 2011 to 2014 • Banking & Insurance Companies – 2012 to 2014 Oct 2007 May 2008 Feb 2009 July 2009 Nov 2009 Jan 2010 Mar / Apr 2010 ICAI released concept paper on convergence with IFRS ICAI releases update on convergence process SEBI approves move to permit voluntary early adoption of IFRS BFSI Roadmap issued by MCA Amendment to listing agreement permits IFRS reporting • Two separate sets of accounting standards to be maintained under Section 211(3C) • Early adoption of IFRS converged standards permitted • Clarifications on implementation matters issued by MCA • Clarity still required on several practical aspects Government remains strongly committed to achieving the 2011 deadline © Grant Thornton International. All rights reserved. IFRS transition in India – an introduction Roadmap: Phased Approach Listed (only in India) Listed overseas (any Company in Nifty or Sensex Phase I Phase I NA Net worth > Rs 1,000 Cr Phase I Phase I Phase I Net worth > Rs 500 Cr upto Rs 1,000 Cr Phase II Phase I Phase II Net worth upto Rs 500 Cr Phase III Phase I Exempt Classes of Companies Unlisted securities) • Companies in Phase II and III can early adopt from years beginning April 1, 2011 onwards • Companies not covered in the 3 phases (including Small and Medium Companies can voluntarily adopt converged standards 6 © Grant Thornton India. All rights reserved. IFRS transition in India – an introduction Roadmap: Phased Approach MANDATORY REQUIREMENT Phases Opening balance sheet date First year end (without IFRS comparatives) OPTION FOR EARLY ADOPTION Opening balance sheet date First year end (with IFRS comparatives) Phase I 1 April 2011 31 March 2012 1 April 2010 31 March 2012 Phase II 1 April 2013 31 March 2014 1 April 2011 31 March 2013 Phase III 1 April 2014 31 March 2015 1 April 2011 31 March 2013 • March 31, 2011 information to be given in an additional column (in addition to existing Indian GAAP comparatives) • Phase II and III companies can early adopt from year starting April 1, 2011 onwards 7 © Grant Thornton India. All rights reserved. IFRS transition in India – an introduction MCA roadmap - BFSI: A phased approach Companies Insurance Companies Opening balance sheet First financial statements April 1, 2012 March 31, 2013 April 1, 2013 March 31, 2014 Urban co-operative banks with net worth > Rs 200 cr but not exceeding Rs 300 cr April 1, 2014 March 31, 2015 NSE- Nifty 50 or BSE- Sensex 30 Index Listed & unlisted with net worth > Rs 1,000 cr April 1, 2013 March 31, 2014 All other listed NBFCs Unlisted NBFCs with net worth > Rs 500 cr (other than above) April 1, 2014 March 31, 2015 Criteria for phased implementation All insurance companiesAll scheduled commercial banks Banking Companies Non Banking Financial Companies (NBFCs) 8 Urban co-operative banks net worth >Rs 300 cr Urban Co-operative Banks with net worth less than Rs 200 Crores, Unlisted NBFCs with net worth less than Rs 500 Crores and Regional Rural Banks are exempt, though they may voluntarily opt to do so © Grant Thornton India. All rights reserved. IFRS transition in India – an introduction MCA Roadmap: clarifications • Net worth: • reference date for companies (other than banking & insurance) is March 31, 2009 • Standalone net-worth to be considered • Net worth = share capital + reserves – revaluation reserves – miscellaneous expenditure – debit balance of P&L • Early adoption available for those in Phase II & Phase III • From April 1, 2011 onwards (opening balance sheet on 1 April 2010) • Once converged standards adopted, cannot revert to existing Indian GAAP 9 © Grant Thornton India. All rights reserved. • Group situations • each entity to apply its own criteria. However, early adoption permitted • Comparative information for first year • no IFRS comparatives required – but voluntary disclosures permitted • IFRS or Indian GAAP • Companies to follow converged standards and not IFRS • First public reporting • SEBI to clarify on quarterly reporting requirements (relevant for listed entities in the Group) IFRS transition in India – an introduction Roadmap: Developments to track Company law Potential impact • • • • • Several of these changes will impact IFRS transition strategies • Key areas to watch out for include: Draft Companies (Amendment) Bill NACAS to finalise amendments to Schedule VI Schedule XIV to also be amended shortly New Companies Bill under evaluation of Parliamentary Committees will also need revision before enactment Accounting Standards • ICAI to finalise – NACAS to recommend by mid year Taxation • ICAI and CBDT set up joint study group to recommend changes • MCA considering a tax neutral state for year 1 • Direct Tax Code under evaluation of Parliamentary Committees will also need revision before enactment 10 © Grant Thornton India. All rights reserved. • New standards, primarily IFRS 1 equivalent as it would spell out the exact transitional provisions • Tax laws – the Group would like to minimize the tax impact due to the transition to IFRS – key decisions and accounting choices would be impacted by these changes • Schedule VI being amended – may require additional disclosures and possibly functional classification IFRS transition in India – an introduction International scenario • IFRS continues to evolve • IFRS 9 to replace IAS 39 (AS 30) – in the process of development – Part issued – significant portions in progress. – Expected completion date – end 2010 • Several significant projects in pipeline – Apart from 3 exposure drafts (ED) relating to Financial Instruments, 10 other EDs expected in next 6 months – Revenue recognition, leases, financial statement presentation, income taxes, etc • India working to a moving target 11 © Grant Thornton India. All rights reserved. Potential impact • Several of these changes could impact you significantly • Key changes include revenue recognition, leases, financial instruments, etc • Very important for you to assess these likely changes when making the transition decisions and changes to systems, processes and business practices IFRS transition in India – an introduction Convergence • ICAI has already issued exposure drafts of all existing accounting standards that will be converged with IAS and IFRSs • ICAI has also issued exposure drafts on new standards, which are not existing as of now, key ones being: – Ind-AS 41: equivalent to IFRS 1, First time adoption – AS 40: equivalent to IFRS 9, Financial Instruments – AS 33: equivalent to IFRS 2, Share based payments – AS 37: equivalent to IAS 40, Investment properties • Once adopted, the converged accounting standards shall form the basis of generally accepted accounting principles in India (Indian GAAP) © Grant Thornton International. All rights reserved. Impact of convergence © Grant Thornton International. All rights reserved. Impact of convergence Potential Areas of Impact Systems and processes, both business and internal, would undergo change Key decision making metrics would undergo change Systems impact Organizational impact Financial impact Transactional accounting Transition to IFRS reporting Transition to IFRS is not an 'accounting' change; it impacts all aspects of the enterprise Accounting impact Non-routine accounting Business management Information systems Impact of IFRS conversion Internal controls Tax and regulatory Investor relations Knowledge transfer / sharing Industry issues Leadership Commitment © Grant Thornton International. All rights reserved. Project Management Impact of convergence Wider Impact Accounting and Reporting Systems & Processes • Information Systems Change • GAAP Differences • Policy Choices • Disclosure requirements Strategic • Dividend Policy • Profitability projections • Debt Covenant analysis • Borrowing capacities • Capital raising & Investment decisions © Grant Thornton International. All rights reserved. • Internal financial reporting processes & Controls change • Modification to Clause 49 documentation People • Training People on IFRS: All levels (Audit committee, Senior management, accountants) • Performance management & evaluation • Regular knowledge update Impact of convergence Challenges to a enterprise Generate the IFRS financial information • Getting employees IFRS literate • Gaining expertise to deal with complex accounting matters • Getting processes and systems in place to generate IFRS information • Making the whole IFRS reporting process, sustainable and cost effective so as to be able to generate information every quarter © Grant Thornton International. All rights reserved. Assess impact of IFRS information on key stakeholders • Employees and management – impact on performance linked compensation structures • Lenders – impact on key debt covenants • Investors and analysts – impact on key performance metrics • Stakeholders – communicating with and educating on a timely basis • Tax authorities – still unclear on how IFRS impacts taxation Impact of convergence Common issues and pitfalls • Lack of a convergence plan • Viewed as a technical accounting exercise resulting in under estimation of efforts involved • Lack of senior management commitment • Significant investment in IT Systems and training manpower • Lack of communication with stakeholders and users of financial reports • Difficulties in estimating fair values • Complexities in the presentation of financial statements • Non availability of skilled manpower © Grant Thornton International. All rights reserved. Process of transitioning financial reporting © Grant Thornton International. All rights reserved. Process of transitioning financial reporting • Cost and time shall be based on the size of an enterprise and complexity of operations • Process needs to be steered by the management • Should be based on a focused approach using project management principles • Changes shall be required at all functional processes, controls and data points © Grant Thornton International. All rights reserved. Process of transitioning financial reporting Key Activities • Constitute a project management structure: all functions • Draft a transition process • Determine key accounting impact areas • Determine areas of external assistance, valuation etc • Coordinate with IT vendor and review of changes in ERP functionalities • Draft a detailed training program for different functional and responsibility levels 20 © Grant Thornton India. All rights reserved. Process of transitioning financial reporting Focused approach Diagnostic review Implementation Diagnostic Study Project Set up Research Background Decide Way Forward Identify Problems Give Authority to Proceed Recommend Way Forward Establish Project Governance © Grant Thornton India. All rights reserved. Accounting Issue resolution Prepare Component Evaluations Resolve Issues Prepare Instructions Reporting Initial IFRS conversion Implement ation Prepare Subsidiaries IFRS Accounts Organisational & Operational Changes Consolidate & Analyse Group IFRS Accounts Implement new Systems & Procedures Sustainable IFRS reporting Parallel run reporting Change -over decision Sustainable and efficient reporting Process of transitioning financial reporting Aligning Operating processes & controls • Currently processes & controls are designed to capture, review & record financial information as per Indian GAAP • Converged AS shall bring in additional information requirements & accordingly new processes & related controls need to be defined • An enterprise should consider the following while drafting its transition: – Impact on CEO/CFO certification (Clause 49) – Aligning Risk management framework – Aligning Internal audit function & activity © Grant Thornton International. All rights reserved. Process of transitioning financial reporting Human resources needs • Transition to different set of accounting rules & principles encompass resources at all levels for all functions • Following functions need to be proficient in converged AS before April 01, 2011: – Accountants (data entry) – Finance managers (Review function) – Chief Financial Officer (Review function) – Audit committee members (Review function) – Senior Management (Decision Making) © Grant Thornton International. All rights reserved. Process of transitioning financial reporting Human resources needs – Training programs 24 Sessions Indicative area of coverage Induction workshops • • • Overview of IFRS and impacts Introduction of Project Team and roles & responsibilities Discussion on industry specific issues Workshop for senior management • • • • Introduction to IFRS and potential impact Areas of concern and questions they need to be asking to increase awareness Impact on management reporting and human resources Times lines, roles and responsibilities & risk management framework Focused workshop on areas of impact • • • • Topical sessions run by specialists on detailed impact and way forward Policy changes and disclosure required by an enterprise Statement of procedures and interdependencies Potential change management discussions Workshop for non accounting personnel • • Introduction to IFRS and potential impacts for their business process Discussions on specific areas of non accounting impact © Grant Thornton India. All rights reserved. Process of transitioning financial reporting Aligning Information Systems • Converged AS shall require following information systems to capture & generate GAAP compliant information – Internal MIS reporting – Financial accounting • Current Information system to be aligned depending upon application & modules currently implemented • Integration exercise will at the minimum include the following: – Establishing new data requirements – Changes to Chart of Accounts – Re-configuration of applications – Manage parallel systems © Grant Thornton International. All rights reserved. Illustrative timeline Week Phase Activity Detailed assessment of impact on consolidated financial statements I Detailed assessment of impact on HR, IT, Processes etc. Preparation of shell consolidated IFRS financial statements & reporting packs II Mapping of reporting packs back to Trial Balance of each entity Rolling out the reporting packs and instructions for completion III Assistance with completion of reporting packs and consolidation thereof © Grant Thornton International. All rights reserved. 1 2 3 4 5 6 7 8 9 10 11 12 Questions © Grant Thornton International. All rights reserved. Thank you About Grant Thornton International Ltd. (Grant Thornton International) Grant Thornton International is one of the world’s leading organisations of independently owned and managed accounting and consulting firms. These firms provide assurance, tax and specialist advisory services to privately held businesses and public interest entities. Clients of member and correspondent firms can access the knowledge and experience of more than 2400 partners in over 100 countries and consistently receive a distinctive, high quality and personalised service wherever they choose to do business. Grant Thornton International strives to speak out on issues that matter to business and which are in the wider public interest and to be a bold and positive leader in its chosen markets and within the global accounting profession. Grant Thornton India is a member firm within Grant Thornton International. Grant Thornton International and the member firms are not a worldwide partnership. Services are delivered independently by the member firms. © Grant Thornton International. All rights reserved.