FEE commented on objectives, boundaries of the financial statements, XBRL, division of responsibility, increased oversight role of the Trustees, and conceptual framework.

FEE agrees with EFRAG that the interest of the investors should remain the main focus when setting global financial reporting standards. However, FEE is not convinced that a distinction between short-term and long-term investors is either useful or operational. Rather, FEE believes that greater emphasis is required on the stewardship objective, which makes management accountable for the conduct of the business’ affairs and their ability to generate long-term economic value. A more explicit reference in the Constitution to the stewardship concept would address most of these concerns, because stewardship also implies management’s responsibility for the longer-term health and sustainability of the company. Therefore, it is desirable that the Constitution, as well as the mission of the Trustees, explicitly articulate this concept.

FEE believes that ‘economic decision’ should not be restricted only to forward-looking economic decision-making by capital providers when deciding whether to buy or sell instruments in the reporting entity. Economic decision-making also includes an assessment of how management have discharged their stewardship responsibilities.

FEE does not agree with EFRAG’s suggestion to narrow the responsibilities of the IFRSF from financial reporting to financial statements. FEE does believe that the IFRSF can play a role in setting direction for other elements of financial reporting.

FEE agrees with EFRAG that XBRL should not be part of the standard setting process. FEE very much supports XBRL as a powerful tool to transfer information. However, integrating XBRL into the standard-setting process has a risk of providing the wrong incentives with regard to the volume of disclosures in an era where a reduction of overall disclosure volume is being asked for. In addition, FEE does not believe that Board members necessarily are equipped to decide formally on rather IT technical questions concerning XBRL tagging as part of the formal standard-setting due process. Therefore, FEE believes its taxonomy should remain separate and be applied under its own separate due process.

FEE welcomes the increased role and public visibility of the Trustees’ Due Process Committee that is envisaged in the strategy paper. FEE agrees with EFRAG’s comment that a greater oversight should also be exercised over re-exposures to ensure that no standard will be issued without proper consultation.

FEE believes that it is imperative that the IASB completes its work on the Framework as a whole, since this will provide structure and direction to the development or amendment of individual standards. The Framework should have the formal status of principles upon which all standards are based and be a relevant source of reference when an individual standard does not cover a particular issue.

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