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«AASB 30-31 August 2016 ITC 34 Sub 1 Agenda paper A.1 (M153) ITC 34 Sub 2 Kris Peach Chair Australian Accounting Standards Board PO Box 204 Collins ...»

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AASB 30-31 August 2016

ITC 34 Sub 1

Agenda paper A.1 (M153)

ITC 34 Sub 2

Kris Peach

Chair

Australian Accounting Standards Board

PO Box 204

Collins Street West

VIC 8007

4 March 2016

Dear Kris,

Invitation to comment ITC 34 AASB Agenda Consultation 2017-2019

We are pleased to respond to your invitation to comment on the AASB’s priorities for its domestic

work program for the period 2017 to 2019.

Australian reporting framework

The review of the Australian reporting framework, particularly reporting by large proprietary companies, should be given high priority. It was disappointing to see financial reporting requirements being included in tax legislation last year, rather than amending the Corporations Act tiers of reporting and/or the accounting standards. The AASB is well placed to assist Treasury in ensuring the reporting framework is one which which meets the needs of users.

A second phase of the review should encompass the varying needs of smaller entities and public sector entities. We would support exploring the possibility of a third tier of financial reporting which could be used by very small entities such as small charities or small companies undertaking crowd-sourced funding activities. We would also support exploring the needs of users of financial reports in the public sector to see if they are being met by current requirements.

External reporting projects We support the AASB taking a broader role, in particular in relation to the disclosure of pro-forma and prospective information in IPO documents. Investors and preparers would benefit from some standardised requirements for information disclosed in IPO documents.

The current rules for remuneration reporting are complex and include redundant, overlapping requirements. There is significant room for improvement. We believe the AASB is well placed to assist Treasury consider what type of information stakeholders need and how this is measured. The AASB could also explore providing guidance on potential alternative measurement principles or disclosures which are commonly used to explain remuneration paid and payable in the future. PwC have conducted extensive outreach around the needs of the investor community and the future of remuneration reporting, and Margot le Bars would be available to assist in a project advisory panel.

Public sector priorities We are pleased to see the projects on service concession arrangements and income for not-for-profit entities are expected to be completed in the third quarter of this year. In terms of the longer-term agenda, we would suggest the AASB focus on providing guidance as to how the fair value measurement requirements are to be applied by not-for-profit entities. This would assist with a consistent application. The Board should also consider other issues being discussed,for example at the International Public Sector Accounting Standards Board to ensure our own standards keep pace with IPSASB developments.

PricewaterhouseCoopers, ABN 52 780 433 757 Freshwater Place, 2 Southbank Boulevard, SOUTHBANK VIC 3006, GPO Box 1331, MELBOURNE VIC 3001 T: 61 3 8603 1000, F: 61 3 8603 1999, www.pwc.com.au Liability limited by a scheme approved under Professional Standards Legislation.

Post-implementation review of adoption of IFRS The current work program includes a post-implementation review of the adoption of IFRS in Australia.

Given the international comparability and access to global markets IFRS provides for listed for-profit entities, we believe it would be highly unlikely Australia would revert back to local GAAP. Thus we believe additional research would not change the outcome and would be better directed elsewhere.

There is also no merit in comparing IFRS with the previous Australian GAAP, as it is not possible to know how the latter would have developed to address the challenges of the last decade.

Instead, we recommend that the post-implementation review should focus primarily on the impact on not-for-profit entities and small entities with reporting responsibilities. In particular, the project should address the question of whether the policy of transaction neutrality should be maintained, or whether it would be more cost effective to create a separate reporting framework for not-for-profit entities. Additionally whether a third tier of reporting is necessary for smaller entities.

If you have any questions or would like to discuss the comments made in this letter, please contact Regina Fikkers on 02 8266 8350 or me on 03 8603 3820.

Best regards John Dovaston Partner

–  –  –

11 March 2016 Ms Kris Peach Chair Australian Accounting Standards Board PO Box 204 Collins St West Victoria 8007 AUSTRALIA Dear Ms Peach Invitation to Comment (ITC 34) AASB Agenda Consultation 2017-2019 The Australasian Council of Auditors-General (ACAG) welcomes the opportunity to contribute to the future domestic work program of the AASB. Please find attached the ACAG response to the AASB Agenda Consultation 2017-2019 (ITC 34).

ACAG supports the AASB’s current work program of standards-level projects and research projects as they are critical areas of attention for public sector financial reporting.

ACAG’s suggestions for the 2017-2019 work program are based on our experiences as the auditor of public sector financial reports of not-for-profit and for-profit entities. We have suggested these projects on the basis that they either require clarification in terms of existing requirements and application guidance and/or to fill a void in existing pronouncements.





The views expressed in this submission represent those of all Australian members of ACAG.

The opportunity to comment is appreciated and I trust you will find the attached comments useful.

Yours sincerely A T Whitfield PSM Chairman ACAG Financial Reporting and Auditing Committee

–  –  –

1. What topics, including external reporting topics, do you think should be added to the AASB work program (research and standard-setting)? Please outline the reasons why you think the project(s) should be addressed by the AASB.

a) Projects for the AASB standard-setting work program

–  –  –

AASB 101 Presentation of Currently, the existing requirements of AASB 101, para 25 & 26, do not cater for the Financial Statements – public sector context where material uncertainties relating to the going concern Going Concern Assumption assumption are different from the private sector. There are unique public sector factors that can influence the existence of a material uncertainty, including the entity’s government funding model, changes in the enabling legislation, and machinery of government changes. The standard could prescribe the factors a public sector reporting entity should consider when assessing if there is a material uncertainty.

–  –  –

Post Implementation In light of the recent amendments to the System of National Accounts and the Review of AASB 1049 Government Finance Statistics manual, ACAG believes it is timely for a postWhole of Government and implementation review of AASB 1049 Whole of Government and General Government General Government Sector Sector Financial Reporting.

Financial Reporting In addition, ACAG suggests that the AASB reconsider the requirement to have all property, plant and equipment measured at fair value.

–  –  –

Post Implementation We recommend the AASB undertake a post-implementation review of AASB 1055.

Review of AASB 1055 Given other mechanisms such as final budget outcomes are the primary source of Budgetary Reporting information about how agencies have performed against budgets, the value of the information in financial reports needs to be analysed against the costs of preparing and auditing recast budgets and explanations of major variances.

–  –  –

Government departments & The AASB has carried forward differentiation in accounting treatment of government AASB 1050 Administered departments from AAS 29 Financial Reporting by Government Departments.

Items Government departments are defined with reference to being created pursuant to administrative arrangements or otherwise being designated as a government department.

It is not clear what the conceptual basis is for the differential treatment of government departments is. For example, is the basis of differentiation that departments are core appropriation process? Contemporary government structures may not reflect this.

–  –  –

2. What priority should be ascribed to the project(s)? Please outline the reasons why you think the project(s) should be prioritised in this manner by the AASB.

a) Projects for the AASB standard-setting work program

–  –  –

Post Implementation Review of Medium Recent amendments to the System of National Accounts and the AASB 1049 Whole of Government Finance Statistics manual warrant a post-implementation Government and General review of the AASB 1049.

Government Sector Financial Reporting

–  –  –

3. Are there any topics on the current AASB work program that you think should be removed from the work program? Please outline the reasons why you think the project(s) should be removed.

ACAG supports the AASB’s current work program of standards-level projects and research projects as they are critical areas of attention for public sector financial reporting.

ACAG does not recommend the removal of any projects from the current AASB work program as the current projects are adequate and cater for a range of constituents such as for-profits, not-forprofits and public sector agencies.

–  –  –

Dear Kris Invitation to Comment - AASB Agenda Consultation 2017-2019 CPA Australia welcomes the opportunity to respond to the above Consultation. CPA Australia represents the diverse interests of more than 155,000 members in 118 countries. Our vision is to make CPA Australia the global accountancy designation for strategic business leaders. We make this submission on behalf of our members and in the broader public interest.

CPA Australia supports the five strategic directions the AASB is currently focussed on, as part of its 2015-2019 strategy. In our view the AASB should undertake research to identify the information needs of users of financial reports, currently prepared applying Australian Accounting Standards (AAS). The progression of some current projects, including the Australian financial reporting framework project, and the addition of future projects to the AASB work agenda will be better informed by obtaining empirical evidence that identifies the range of information needs of Australian users across multiple sectors. With this in mind, we have provided our specific responses to questions below.

1. What topics, including external reporting topics, do you think should be added to the AASB work program (research and standard-setting)? Please outline the reasons why you think the project(s) should be addressed by the AASB.

As stated above, we believe the AASB should undertake research to gather empirical evidence that identifies the information needs of Australian users that will inform the future direction of current and new AASB projects. In this context, we support the AASB’s efforts in seeking to identify projects for external reporting that fall outside conventional financial reporting but we urge that they are based on the identification of users and their needs.

We also support the AASB liaising with other policy makers on other disclosures beyond the scope of AAS based financial reporting. This is critical to ensure that the objectives of different disclosure regimes are consistently developed to meet their intended objectives.

2. What priority should be ascribed to the project(s)? Please outline the reasons why you think the project(s) should be prioritised in this manner by the AASB.

Research projects Highest priority should be given to the Australian financial reporting framework project as it is likely to have an impact on a range of entities that includes large and small corporates, private and public sector not-for-profit entities. The project’s direction should be informed by empirical evidence on the identification of users and user information needs identified within the different sectors.

The role of tiers of reporting, including a possible third tier of reporting for smaller entities, particularly those in the not-for-profit sector, should be explored as part of this project. We also suggest the AASB explores the possibility of simplifying financial reporting recognition and measurement requirements for small to medium entities (SMEs) in the for-profit and not-for-profit sectors. We believe this consideration is necessary, particularly as complex new requirements for revenue recognition and leases come into effect in the near future.

ITC34 sub 5

Standard-setting projects

Highest priority should be given to the project on Income of not-for-profit entities. As AASB 15 Revenue from Contracts with Customers comes into effect for periods beginning on or after 1 January 2018, we consider the timely conclusion of this project and issuance of the final standard essential.

3. Are there any topics on the current AASB work program that you think should be removed from the work program? Please outline the reasons why you think the project(s) should be removed.

We do not think any of the topics should be removed from the current AASB work program.

If you require further information on any of our views expressed in this submission, please contact Ram Subramanian, CPA Australia by email at ram.subramanian@cpaaustralia.com.au.

Yours sincerely Dr Eva Tsahuridu Manager – Accounting Policy

–  –  –

20 June 2016 Ms K Peach The Chairperson Australian Accounting Standards Board PO Box 204 Collins Street West Victoria 8007 Dear Kris Re: ITC 34 AASB Agenda Consultation 2017-2019

1. Thank you for the opportunity to provide input on the AASB 2017-2019 agenda. I apologise for the lateness of this submission and trust that it will receive consideration by the AASB.

Time for fundamental change



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