Deloitte Submits Comment Letter Pertaining to IFRS for Small and Medium Enterprises to IASB

The IFRS Global office of Deloitte has written a comment letter to the IASB on its Request for Information 'Comprehensive Review of the IFRS for SMEs'.

In its comment letter, Deloitte stated that they agree with the fact that triennial revision of the International Financial Reporting Standards for small and medium enterprises must be comprehensive as far as its scope is concerned but also believes that few basic principles for incorporating changes in the standard would only be beneficial and will ensue that an approach that is consistent is followed. Deloitte also clarified that the International Financial Reporting Standards for small and medium enterprises should remain consistent in its relationship and approach to complete International Financial Reporting Standards.

According to Deloitte’s letter the principles listed below should be applied:

The International Financial Reporting Standards for small and medium enterprises shouldn’t be amended to depict changes in complete IFRSs as significant and complex as the reviewed needs on accounting for joint measurements and arrangements of fair value incorporated in International Financial Reporting Standard 10, 11 and 13 and consolidation before those very changes come into effect. Instead, how suitable a new accounting standard is, should be determined on the basis of how suitable it is in terms of being included into the International Financial Reporting Standards for small and medium enterprises, the moment a record of its implementation as per complete IFRSs is available. The post implementation related review of the new accounting standard could offer an opportunity for making this particular assessment.

Any inclusion of a complete IFRS related standard into the International Financial Reporting Standard for small and medium enterprises must retain the very integrity of the concept related model that is applied in that particular accounting standard.

At the time of assessing whether the complete IFRS related standard is suitable for inclusion into the International Financial Reporting Standard for small and medium enterprises or not, the board must take into consideration, the costs to small and medium enterprises and the efficiency of SMEs with regard to preparing finance related information even before it moves to any model that is complex.

In addition to this, reversal of the decision taken by International Accounting Standards Board to incorporate simple requirements in the International Financial Reporting Standards for small and medium enterprises should be considered only where clear evidence that is required exists.