Overview: This paper seeks to contribute to the literature on understanding and explaining the successful diffusion of IFRS standards globally in the era after Enron by analysing the role of discourse as means for legitimising. The paper is particularly interested in the
“theoretical significance” (Abstract) of “principles-based discourse” and tracing how this discourse has contributed significantly to the diffusion (and seeming triumph) of IFRs standards. It employs a combination of three theoretical traditions.
First, Foucaul dian ‘discourse analysis’, for the analysis of (accounting) discourse formations at different levels, where Foucault’s focus is particularly understood as seeing discourse as a
‘constructional element of social practices’ (8) so that “social reality is produced and made real through discourses” (Phillips & Hardy, cited p8). Second, critical discourse analysis
(CDA), (also understood as treating ‘discourses as elements of social practices’ (11) and so as especially focussing on (1 1) ‘institutional, political, gender and media discourses’), which is thus seen as taking up and perhaps extending Foucault in analysing the relation between language and power and so leading to a concern with ‘discourse and social change’ (12) and the possibility of a ‘discursive model of institutionalisation’ (12), thus enabling the production of a Table (13) naming a range of ‘discursive legitimation strategies’. Finally, the concept of translation is borrowed from Actor Network Theory (ANT) in order to seek to understand accounting change and dynamics, including how actors address problems, and enrol and mobilise other actors.
The discourse analysis then undertaken is based on material concerning the dissemination of a principlesbased discourse’, particularly following the collapse of Enron and the challenges thrown from the ‘principles-based’ side against the then-dominant ‘rules-based’ approach of US accounting standards-setting and regulation. The materials include documents issued by U.S. government and regulatory bodies national reports such as those from SEC, FASB, interested professional/academic groups (e.g. the AAA) and papers from within academic research traditions. The paper concludes (Abstract, p4) that there are two forms or aspects of Lat ourian ‘translation’ in the diffusion of IFRS: ‘problematization of rulesbased accounting standards and translational implementation of IFRS ’. It proposes that what ensued was a new supremacy for the principles-based approach and an enhanced legitimation of a principles-based accounting system, where a greater prominence or purchase is given to IASB/IFRS rhetoric and to the perceived value or importance of professional judgment.
The paper’s main contribution is seen as showing how actors react to changes in IFRS and how, despite continuing ambiguities in the principles-based approach, the approach has become increasingly accepted or taken-for-granted.
Discussant ’s comments:
This paper engages with an important ongoing debate on IFRS diffusion, and also on a wider and longstanding debate on principles versus rules based approaches to setting accounting standards and related forms of accounting regulation. As such the paper is relevant and makes a potential contribution. However, I see the paper as having two major areas where it needs further thought.

First I suggest that it is rather too focussed in the present as it frames the principles-vs-rules debate largely in terms of events post-Enron and so potentially overestimates the significance of the apparent triumph of the principles-based side in this longrunning debate. I suggest that a closer engagement with a wider literature, over a longer period, would be beneficial, not least for helping bring out more clearly the fundamental ambiguities or tensions in seeking to establish ‘principles’, thus perhaps leading to a more nuanced understanding or a more cautious evaluation of the apparent ‘success’ of the approach.
Second, I see some major theoretical tensions in the presentation of Foucault, and of Latour, as theorists concerned primarily with how discourse or translation operate at a ‘social’ or
‘institutional’ level of explanation. Latour (as the paper recognises, p14) dismissed a decade ago old forms of ‘sociology of the social’ in favour of a ‘sociology of associations’. Foucault equally, across his career, describes himself as undertaking forms of ‘bottom-up’ analysis
(e.g. seeking to analyse the state, for instance in Security, Territory, Population (2009: 358), as a ‘way of doing things and a way of acting’; or seeing how disciplinary power, in Discipline and Punish (1977: 30), operates in such a way that ‘the soul is prison of the body’). I understand the dilemma of the author(s): given that there is now so much work, both in and beyond critical accounting, which draws on institutional sociology and/or CDA to promote social and institutional forms of discourse analysis, and given also that such work often invokes Foucault or Latour as foundational theorists for the work undertaken, the author(s) find a necessity (institutional perhaps as well as intellectual) to draw on such work and to reecho such foundational claims. However I would suggest there would be a value in a return to F oucault’s and Latour’s own work on ‘discourse’ and ‘translation’ respectively, to establish how far, if at all, they themselves share these social or institutional frames of analysis. [I would point out to the author(s) in this regard that in summarising F oucault’s approach to understanding ‘discourse’ there is no direct quotation of, or even summary of, what Foucault himself actually says, particularly in The Archaeology of Knowledge (1971/2002), but reference to secondary authors: Foucault is only quoted (p8) on the interplay between knowledge as savoir , and power as pouvoir in constituting truth games (1977: 27), which is only peripherally relevant to his analysis of what discourse is and how it operates.]
Let me provide slightly more detail on each of these issues, as what I seek to provide as constructive criticism, and let me start with the second, and in particular the proposed combination of CDA, ANT and Foucault. The combination of ANT and Foucault can, I think, work well together so long as there is some thought-through and appropriately referenced analysis, drawing on their own works, to show how both are doing work that seeks to avoid developing explanations at the level of ‘cold monsters’ (as Foucault, quoting Nietzche, described the state). Both systematically avoid such global or second-level categories as
‘the social’, ‘the state’, ‘the institution’, or ‘the organisation’. These are outcomes of micropractices which work from the bottom up. [NB: Even ‘social practices’ as a primary category of analysis needs careful consideration, for Foucault at least. For him, the key practices are those that shape thinking, and from there acting, within the individual as well as across groups. He refers to these, in the piece co-authored by him and published under the name of
Maurice Florence, as: ‘regular or rule-based practices, reflexive or reflective practices, goaldirected or finalised practices’: not as ‘social practices’.]
Similarly, o ne of Latour’s key ambitions has been, and still, is to investigate ‘the social’ without taking it for granted (hence ANT, indeed). Again every cold or frozen monster should instead be the starting point of the investigation . ‘Re-assembling the social’ (2005) is all about how to perform such research. Two such key issue are called the flatland and performativity. The paper has a good quote from Latour which underlines the importance of these concepts and how far they are from traditional sociological or institutional levels of analysis:

“there is no society, no social realm, and no social ties, but there exist translations between mediators that may generate traceable associations ” (Latour, 2005, p. 108, italic original).
(p.15)
So the paper is on shaky ground when it begins its discussion of its Latourian framework
(p14) by defining ANT as having a ‘focus on social actors who act something with redefining themselves in social practices’: actors, yes, or ‘mediators’ or even actors-plus-actants. But
‘social actors’? No.
ANT is about how we organise things and people to become objects, facts, etc. It is an approach that investigates what the social ‘is’ and is made of. T ranslation – as ‘putting something in other place ’, and thereby become something else in relation to other things – is a key concept, although it is important to include objects and technology. It is about how things are organised to become facts and objects, which is hard work and requires resources. It is about investigating how organising is made up and sustained. So the issue of constructs such as micro to macro cannot be assumed: you must investigate how they are made and kept in place (e.g. as a ‘chain of translations’). Similarly an organisation, the social, or society cannot be taken for granted or seen as being grounded in a timeless nature or as the outcome of a process of frictionless ‘evolution’ or development: each is the product of constant negotiations and associations and it cannot be assumed that these are known in advance. The researcher does not begin with already-given facts, objects and actors (nor can these be assumed to speak with one voice or say one set of coherent and nonconflicting things). What they are and what they are made of cannot be decided prior to the research as they are always in the making, which is why a focus on ‘performativity’ is such a crucial aspect of the approach.
Symmetry is also part of this approach in the sense that the approach starts from an assumption of ‘symmetry’ (i.e. all relations found or followed in the research are assumed initially to be symmetrical, i.e. given the same importance and weight: the analysis of how translations take place and of performativity is what reveals how asymmetries (of weight, importance or power) are made up and how asymmetrical relations are. Both ‘power’ and
‘society’ are outcomes and effects of what ensues among actors and across networks and what takes effort to be kept in place (e.g. by technology).
A key difficulty in executing this type of research is that researchers often accept descriptions of how facts, objects and actors interplay too early, or jump to conclusions too soon, rather than following the object (e.g. the accounting inscription or statement) across the ‘chain of translations’ tracking what gets ‘performed’ along the way, and so what changes and what remains the same. It becomes too easy to relapse into assuming that the organisation, for instance, ‘exists’ instead of constantly having to be ‘performed’; or alternatively that accounting is just what takes place in a restricted discursive frame (e.g. just in a principles-based discourse) rather than operating across a wider range of related chains of translations. Insofar as this happens, you are likely to lose track of the negotiations and associations that you were interested in the first place. [Similarly, if the researcher assumes that accounting is in an organization, then the role of accounting in organising so that organisations are made up using accounting will be or is likely to be ignored.]
I would suggest therefore that, assuming that you see the relevance and value of adopting an ANT approach as part of your analysis, you should re-visit ANT, bearing in mind the above observations, to ensure that your analysis is following ANT principles and that you are considering the appropriate range of possible translations in which accounting is involved, even while keeping your focus on ‘principles-based discourse’. In suggesting that, I am not saying that you have to use everything that ANT offers. I am just saying that whatever you choose to use it has to be understood in terms of where it is coming from, and where and

how it might fit in with other approaches with similar ontological and epistemological grounds.
In that respect, you might consider whether you might be better off using Foucault’s approach to discourse analysis, insofar as his is also a bottom-up (micro before macro) approach. This might well apply both (firstly) in terms of making sense of what is going on discursively in terms of the range of statements getting said in the principles vs rules debate
(and in specifying the objects and concepts articulated, and the subject positions and strategic choices adopted in the debate since 2000): and then (secondly) in terms of analysing what gets said and what gets silenced institutionally, even though this is what the institutional theorists of discursive legitimation theories seek to define for you. So, one might say, why go elsewhere? Still, it is important to emphasise that Foucault was not a sociologist: and institutionally in the field of your research, making too much of that can itself currently be dangerous. In other words, being aware of what gets silenced can be a matter of constant vigilance.
I will say less on the first issue raised, but again I hope it will be constructive criticism. The principles vs rules based ‘battle’ is of longstanding: this is arguably just a latest skirmish, rather than a decisive victory, and you might wish to consider that. I would suggest this not least because both a rules or principles basis have long been argued to be equally flawed conceptually or logically. Each leads to its own conceptual or logical contradictions or cul-desacs. Perhaps this was best expressed (and this is in itself a sign of how long these debates have been ongoing) in Richard Macve’s 1983 report ‘The FASB’s conceptual framework: vision, tool or threat?’, published by Garland with other relevant papers under that title in
1997. These fundamental logical and conceptual issues or ambiguities within each position are not addressed as such, so far as I can see, in the literatures you currently cite: instead what are mainly addressed are the rhetorics through which, or the institutional frameworks within which, the principlesbased approach has been ‘winning’ post-Enron. I would suggest that your analysis would be deepened if you included in your analysis of what gets said discursively a consideration of the conceptual and logical ambiguities in the approach as well. A good starting point might be Macve (2014), which summarises many of the key issues first discussed in his 1983 paper and puts them in a wider historical and theoretical context, either or both of which may be helpful to you in considering some of the theoretical and analytical issues I have raised above.
Reference:
Macve, R. ‘Fair value versus conservatism: aspects of the history of accounting, auditing, business and finance from ancient Mesopotamia to modern China’, British Accounting
Review (on-line).