Our Ref.: C/FRSCSent electronically through the IASB Website (www.ifrs.org)
2 August 2018Mr Hans HoogervorstInternational Accounting Standards Board30 Cannon StreetLondon EC4M 6XHUnited KingdomDear Hans,IASB Exposure Draft ED/2018/1Accounting Policy ChangesThe Hong Kong Institute of Certified Public Accountants ("HKICPA") is the only bodyauthorised by law to set and promulgate standards relating to financial reporting,auditing and ethics for professional accountants, in Hong Kong. HKICPA is grateful forthe opportunity to provide you with our comments on this Exposure Draft.HKICPA appreciates the IASB's efforts in encouraging entities to adopt non-authoritative explanatory material included in agenda decisions published by the IFRSInterpretations Committee (IFRIC agenda decisions).HKICPA agrees that IFRIC agenda decisions might provide new information that lead acompany to change its previous accounting policy. Given the non-authoritative natureof IFRIC agenda decisions, HKICPA recommends that the IASB should requirecompanies that choose or plan to voluntarily change accounting policies resulting fromIFRIC agenda decisions to apply them on a prospective basis, and also provide anoption for companies to apply this kind of voluntary change in accounting policiesretrospectively if practicable.If the IASB decides to proceed with requiring a retrospective application, the IASBshould specify when companies should apply clarifications arising from IFRIC agendadecisions. HKICPA considers that a date no later than the next annual reporting periodis a possible solution, however, the IASB needs to be mindful of clarifications arisingfrom IFRIC agenda decisions that are issued closer to the date of the next annualreporting date. In addition, HKICPA recommends that the IASB explains in the Basisfor Conclusions why no transitional provisions are needed for voluntary change inaccounting policies resulting from IFRIC agenda decisions.In the spirit of encouraging more consistent application of IFRS Standards, HKICPAconsiders that issuing IFRIC agenda decisions as a method of clarifying Standardsmay not be as effective to promote consistent application. HKICPA therefore suggeststhe IASB to consider:
For IFRIC agenda decisions that lead to a prevalent and significant change inpractice, the IASB should consider reflecting those decisions via the AnnualImprovements Process or issue an Interpretation. Agenda decisions that havePage 2 of 2prevalent and significant effect in practice can be identified through the responsesthat IFRIC receives on its tentative agenda decisions consultation. Clarificationsmade this way are easier for stakeholders to follow.For IFRIC agenda decisions that are purely education in nature and do not lead toa prevalent/significant change in practice, the IASB could incorporate suchagenda decisions into its education materials. The IASB could also consider otherways to raise the awareness of these agenda decisions through its educationinitiative.In forming its views, HKICPA considered the views of its stakeholders who respondedto its Invitation to Comment on ED/2018/1. The major feedback from Hong Kongfinancial institution preparers are in the Appendix.If you have any questions regarding the matters raised in this letter, please contact meor Katherine Leung, Associate Director of the Standard Setting Department(katherineleung@hkicpa.org.hk).Sincerely,Christina NgDirector, Standard Setting DepartmentAppendix
Institute comments on IASB Exposure Drafts ED/2018/1 Accounting Policies Changes
下载原件Our Ref.: C/FRSCSent electronically through the IASB Website (www.ifrs.org)
2 August 2018Mr Hans HoogervorstInternational Accounting Standards Board30 Cannon StreetLondon EC4M 6XHUnited KingdomDear Hans,IASB Exposure Draft ED/2018/1Accounting Policy ChangesThe Hong Kong Institute of Certified Public Accountants ("HKICPA") is the only bodyauthorised by law to set and promulgate standards relating to financial reporting,auditing and ethics for professional accountants, in Hong Kong. HKICPA is grateful forthe opportunity to provide you with our comments on this Exposure Draft.HKICPA appreciates the IASB's efforts in encouraging entities to adopt non-authoritative explanatory material included in agenda decisions published by the IFRSInterpretations Committee (IFRIC agenda decisions).HKICPA agrees that IFRIC agenda decisions might provide new information that lead acompany to change its previous accounting policy. Given the non-authoritative natureof IFRIC agenda decisions, HKICPA recommends that the IASB should requirecompanies that choose or plan to voluntarily change accounting policies resulting fromIFRIC agenda decisions to apply them on a prospective basis, and also provide anoption for companies to apply this kind of voluntary change in accounting policiesretrospectively if practicable.If the IASB decides to proceed with requiring a retrospective application, the IASBshould specify when companies should apply clarifications arising from IFRIC agendadecisions. HKICPA considers that a date no later than the next annual reporting periodis a possible solution, however, the IASB needs to be mindful of clarifications arisingfrom IFRIC agenda decisions that are issued closer to the date of the next annualreporting date. In addition, HKICPA recommends that the IASB explains in the Basisfor Conclusions why no transitional provisions are needed for voluntary change inaccounting policies resulting from IFRIC agenda decisions.In the spirit of encouraging more consistent application of IFRS Standards, HKICPAconsiders that issuing IFRIC agenda decisions as a method of clarifying Standardsmay not be as effective to promote consistent application. HKICPA therefore suggeststhe IASB to consider:
For IFRIC agenda decisions that lead to a prevalent and significant change inpractice, the IASB should consider reflecting those decisions via the AnnualImprovements Process or issue an Interpretation. Agenda decisions that havePage 2 of 2prevalent and significant effect in practice can be identified through the responsesthat IFRIC receives on its tentative agenda decisions consultation. Clarificationsmade this way are easier for stakeholders to follow.For IFRIC agenda decisions that are purely education in nature and do not lead toa prevalent/significant change in practice, the IASB could incorporate suchagenda decisions into its education materials. The IASB could also consider otherways to raise the awareness of these agenda decisions through its educationinitiative.In forming its views, HKICPA considered the views of its stakeholders who respondedto its Invitation to Comment on ED/2018/1. The major feedback from Hong Kongfinancial institution preparers are in the Appendix.If you have any questions regarding the matters raised in this letter, please contact meor Katherine Leung, Associate Director of the Standard Setting Department(katherineleung@hkicpa.org.hk).Sincerely,Christina NgDirector, Standard Setting DepartmentAppendix