ESBG: Response to EFRAG consultation on IFRS 9

05 July 2019

ESBG has responded to EFRAG consultation on Equity Instruments - Research on Measurement: Alternative accounting treatments to IFRS 9 Financial Instruments requirements for equity and equity-type instruments held in a long-term investment business model.

In the ESBG opinion, the concept of a long-term investment business model could be related and interplay a role with "Sustainable Activities", since long-term investment decisions may require considering sustainability risks and opportunities. For some entities, when they invest in "Sustainable Activities", they are taking into account a long-term investment horizon most of the times. However, the ESBG acknowledges that not all the investments held in a long-term investment business model may meet the definition of "Sustainable Activities". Considering that there is no two-way relationship between both definitions of "Sustainable Activities" and "Long-term investment business model" answering some questions of this questionnaire is challenging.

It should be noted that a definition of sustainable activities has not been developed by the IASB nor the European Commission for the purpose of the EU endorsement of IFRS standards.

In the ESBG view, the definition of "Sustainable Activities" for any accounting purposes should be consequently determined by each company (entity-specific definition) according to its own criteria and consistently with its mission and strategic plan. In this regard, the definitions established in the Regulation on Taxonomy could act as a maximum to define its scope. That is, companies could have a more restrictive definition if their own criteria set narrower bounda-ries on the type of investments that could be considered "Sustainable Activities". The taxonomy would therefore be the basis that would determine the maximum scope of this accounting category of equity investments and provide discipline in the accounting arena.

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