09/08/2015 - EFRAG's draft comment letter on the IASB's ED/2015/4 Updating References to the Conceptual Framework (Proposed amendments to IFRS 2, IFRS 3, IFRS 4, IFRS 6, IAS1, IAS 8, IAS 34, SIC-27 and SIC-32)

On 28 May 2015, the IASB issued the Exposure Draft ED/2015/4 Updating References to the Conceptual Framework (Proposed amendments to IFRS 2, IFRS 3, IFRS 4, IFRS 6, IAS 1, IAS 8, IAS 34, SIC-27 and SIC-32) (the 'ED') with a comment period ending on 26 October 2015.

The proposals in the ED intend to update the references to, and quotes from, the existing version of the Conceptual Framework or the version that was replaced in 2010. In addition, the IASB proposes to remove a number of footnotes that refer to the changes made to the Conceptual Framework.

EFRAG, in its draft comment letter on the ED, expresses its concerns about possible unintended effects resulting from the proposed amendments - other than amendments to IAS 8 - and considers that the amendments should remain editorial in nature and therefore not require any transition provision. It further questions the feasibility and the enforceability of the amendments to IAS 8 as many different factors may have influenced the design of accounting policies, i.e. analogy to existing IFRS or other GAAP, and the exclusive link to the conceptual framework may be difficult to establish. To form a final view, EFRAG seeks input from its constituents on the expected impact of these proposed changes, where they identify that the proposed changes would not be editorial only and the extent to which their accounting policies are affected and whether they agree with the proposed retrospective application.

EFRAG requests comments by 26 October 2015.