Deloitte supports the objective of achieving a set of commonly shared guidelines on the presentation of, and information about, supplementary financial measures (SFMs), whose objective would be ensuring the quality, transparency and usefulness of the financial information provided to users, regardless of whether such supplementary financial measures are included within or outside of financial statements. Deloitte believes this objective is important given the widespread use of such measures and existing diversity in presentation and explanation of such measures around the world.
However, Deloitte notes that there are various initiatives in the area of supplementary financial measures in addition to the IFAC PAIB proposals, including:
Existing guidance in some jurisdictions, e.g. Australia, New Zealand and Canada
Separate proposals on this topic from the ESMA
Expected guidelines from the IOSCO
The IASB's indicated intention to research the presentation and disclosure of non-IFRS financial information as part of its disclosure initiative project.
In light of the above, Deloitte´s comment letter makes the following observations:
Therefore, due to the global nature of the subject and the varied placement of SFMs (i.e. inside/outside financial statements), care should be taken that actions or guidance targeted at a global audience do not conflict with global initiatives undertaken by global accounting standard-setters and regulators. Deloitte therefore strongly suggests that the IFAC PAIB liaises in particular with the IASB and IOSCO so as to coordinate its actions, as well as obtain input from them on any proposed IGPG on SFMs. In this way, Deloitte believes that the IFAC PAIB can most effectively contribute to the aim of high quality financial reporting applied without regional variation.
Full comment letter
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