for only regional and sub-national data in some cases. Data should also be disclosed on a standard country-specific basis Production revenues -- should be disclosed on a country-by-country basis to ensure the consistency of the new IFRS for extractive industries and prevent tax avoidance and evasion -- this type of reporting is currently rejected by the proposals Production and development costs -- the proposals make some recommendations here but also leave scope for only regional and sub-national data in some cases. Data should also be disclosed on a standard country-specific basis The names and locations of each key subsidiary and property in each country should be reported -- the proposal paper claims these are already available but does not offer proof 4. There should be no reporting exemptions, as these are unnecessary, would undermine comparability and would increase pressure on ethical companies seeking to be transparent The current proposal to give companies the option to exempt themselves from reporting payments to particular governments undermines the whole added value of an IFRS . It would remove the protection of a standard reporting requirement, leaving companies to explain to untransparent host governments why they were not using the exemption. Resulting non-reporting would reduce the comparability of company reports. Such exemptions are not needed since regulations like IFRS s would override restrictions of confidentiality clauses if applied in a uniform manner. The IASB should remove the currently proposed exemptions. To protect companies, the standard should require disclosure of payments to all governments without