Comments on the Invitation toComment “IASB and IFRSInterpretations Committee DueProcess Handbook”（原文）IFRS Foundation
30 Cannon StreetLondon EC4M 6XH
United Kingdom
Dear Sir or Madame,

Comments on the Invitation to Comment“IASB and IFRS Interpretations Committee Due Process Handbook”

We welcome the opportunity to express our comments on “IASB and IFRS Interpretations
Committee Due Process Handbook”（hereinafter referred to as “the Handbook”）.
We really appreciate the efforts of the IFRS Foundation staff involved and engaged in theHandbook, which has a critical role in further improving the due process for developing
IFRSs. We believe that transparency of the due process is essential for enabling the global
use of IFRSs.
We agree with the proposals in the Handbook in general. However, we believe that improvements in the following matters, in particular, would be necessary. We consider thesematters to be important although not included in the questions specified in the Handbook.
・Operation of IASB Board meeting（including when to distribute staff papers and how
to discuss the draft IFRS in the Board meeting）
・Ensuring a 60-day publication period as a minimum for exposure documents
・Clarification of the process for suspension and cancelation of the projectIn addition, we also acknowledge the introduction of research programmes as one of especially important proposals in the Handbook, because it would facilitate, through clarifying

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key issues, smoother deliberations after the addition to the standards-level projects. We
would like to actively contribute to the standards-level projects in IASB by participating inthe IASBʼs research programme, as a national standard setter.

Question 1
The Trusteesʼ have included an introductory section dealing with ʻoversightʼ, and the re15）.
sponsibilities of the DPOC（see paragraphs 2．
1─2．
Do you support the inclusion and content of this section? Why or why not?
We agree to deal with ʻoversightʼ, and the roles and responsibilities of the DPOC in conjunction with the due process of IASB and IFRS Interpretations Committee, because the improvement of internal monitoring function would be essential for further improving the due
process of IASB and IFRS Interpretations Committee.

Question 2
The DPOC have created a Due Process Protocol in the form of a table that shows thesteps that the IASB must, or could, take, as well as reporting metrics to demonstrate thesteps that they have taken, in meeting their due process obligations（see Appendix 4）.
Do you agree with the idea that such a table should be maintained on the public website
for each project? Why or why not?
We agree with this proposal, because it would further improve the transparency of standard
development by providing the means for the IASB and IFRS Interpretations Committee tofulfil their accountability to the DPOC and clearly revealing the steps from the start to theend of their standard development.
Please note some inconsistencies in descriptions in the Due Process Protocol in Appendix 4,
which we detailed in the appendix of this comment letter.

Question 3
A research programme is described, which we expect will become the development basefrom which potential standards-level projects will be identified（see paragraphs 4．
9─4．
22）. In addition, a new section on maintenance has been added, which formalises thepractice that the IASB and the Interpretations Committee have been following for addressing matters that are narrow in scope. It clarifies that the more formal project proposal processes were always intended to apply to new IFRSs and major amendments.
The IASB has the discretion to initiate changes that are narrow in scope to IFRSs as partof the general maintenance of IFRSs. The new section also explains how the activities of2012.12 vol.39 季刊 会計基準71

the IASB and the Interpretations Committee are closely related（see paragraphs 5．
11─5．20）.
Do you agree with the distinction between narrow-scope projects, which come under theheading of maintenance and comprehensive projects, which come under the heading ofdevelopment of IFRSs? Why or why not?
Do you agree with the introduction of a separate research programme that will likely be
the development base from which potential standards-level projects will be identified?
Why or why not?
⑴

Research programme

We basically agree with this proposal to introduce research programmes, because it wouldfacilitate, through clarifying key issues, smoother deliberations after the addition to the standards-level projects.
However, there may be cases where research programmes would not be necessary（for example, when there is a global consensus or resources in the past are available）. We have aconcern that requiring a research programme for every case might cause a delay in thestandard development. Therefore, we suggest that the Handbook should clarify the cases
where the research programme is not required.
Although paragraph 4．12 of the Handbook mentions the participation in research programmes by national standard setters and others, it does not describe the IASBʼs process
after receiving the results of their researches. We suggest that the Handbook should provide feedback to national standard setters and others about how the IASB has made use of
their researches in determining whether to add the subjects to standards-level projects.
⑵

Distinction between narrow-scope projects and comprehensive projects

We suppose “narrow-scope projects” and “comprehensive projects” in this question as corresponding to “implementation and maintenance” and “new IFRSs or major amendments”, respectively. We basically agree with this proposal to distinguish them. Which of the two category a project belongs to need be clarified when the IASB will initiate each project in thefuture because the applicable due process would depend on that distinction, although there
might be a case where it would be difficult to distinct them.

Question 4
Two changes to comment periods are proposed. The first would increase the minimum
comment period for exposing the draft of a rejection notice of a request for an Interpretation request from 30 days to 60 days（see paragraph 5．
16）. The other change relates tothe re-exposure of a document. The DPOC is proposing to allow the IASB to have a re-72

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duced comment period of a minimum of 60 days for documents it plans to re-expose, if
the re-exposure is narrow in focus（see paragraph 6．
26）.
Do you agree with the changes in the comment period lengths for rejection notices andre-exposure drafts? Why or why not?
We support the proposal for the comment period for the rejection notice. However, we disagree with the proposal for comment period regarding the re-exposure due to the following
reasons.
We disagree with the proposal to shorten the comment period from 120 days to 60 days, because we need to review the re-exposure draft in its entirety, even when it is narrow in focus, and translation would also take some time for the jurisdictions in which English is not
an official language.
For similar reasons, we also disagree with the provision in paragraph 6．7 that IASB may
consider the comment period of no less than 30 days for an exposure draft if the matter isnarrow in scope and urgent. We believe a comment period of less than 60 days should not
be allowed.
According to paragraph 6．8, in exceptional circumstances, the IASB may reduce the period
for public comment below 30 days after formally requesting and receiving prior approval
from 75 per cent of the Trustees. We suppose this provision has been included so as not torepeat the mistake of amending IAS 39 without complying with due process during theglobal financial crisis in 2008. Although we acknowledge an urgent treatment as above
might become necessary in extremely exceptional circumstances, a minimum reasonable
comment period should be specified in the Handbook.

Question 5
Are there any other matters in the proposed handbook that you wish to comment on, including matters that are not covered by the handbook that you think should be?
1 ．Section 3 “Principles”
aTiming of distribution of staff papers for the IASB Board meeting（3．
8）

Staff papers for the IASB Board meeting are normally distributed 10 to 14 days before thediscussion and published on the IASB web page at the same time. We consider that it
would be effective to sound beforehand the stakeholdersʼ reactions to the staff papers fortentative decision making sessions in order to facilitate the discussions at the Board. Ouridea is that, for example, the IASB would distribute and publish staff papers 30 to 40 days
before the meeting so that board members and staff would be able to receive feedback fromthe stakeholders in a timely fashion depending upon circumstances appropriately on the papers before discussing at the Board meeting. Such practice would reduce the possibility of

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frequent changes of the Boardʼs tentative decisions.
bDeliberation on the draft IFRS in the Board meeting（3．
21─3．
28）

Ballot drafts are not discussed in the IASB Board meeting but distributed to IASB mem28）. Currently, the Board makes tentabers without being open to the public（from 3．21─3．
tive decisions at its meeting only for key issues. However, because basis for conclusions andillustrative examples included in the draft may have a significant influence in practice,drafts should be discussed at the public Board meeting to avoid the surprise when the draft
is published.
⒞

Review draft（3．29─3．35）

Although our understanding is that the purpose of review drafts is to seek input on thedraft from particular people outside the IASB, paragraph 3．
29 states that it may also bemade available on the web page. We believe that the purpose of review drafts should belimited to seeking input from particular stakeholders, because the publication on the web
page would be difficult to distinguish from exposure drafts and identify the purpose.
The IASB has sometimes issued Requests for Views, Supplementary Documentations, Review Drafts and Staff Drafts, which appears to be alternatives to exposure drafts. We consider those documents to be similar to exposure drafts in that they seek input and it is likely that respondents have the same views. Some of these have shorter comment periods thatexposure draft and therefore may give rise to a due process issue. Therefore, it should beclarified that the means for seeking public comments on draft standards should be exposure
drafts only.
dNational and regional network（3．49）

Paragraph 3．
49 names the International Forum of Accounting Standard Setters（IFASS）,, the Group of Latin American Stanthe Asian-Oceanian Standard-Setters Group（AOSSG）
dard-setters（GLASS）,the Pan-African Federation of Accountants（PAFA）and the European Financial Reporting Advisory Group（EFRAG）and jurisdictional（national）standard-setters as groups with which the IASB shares information and consults. However, they havedifferent characteristics and therefore descriptions about relationships with them should be
separated according to those characteristics.
⒠Clarification of the role of the liaison office

The IFRS Foundation will open the Asia-Oceanian Office in Tokyo in November 2012 as thefirst liaison office outside London. We expect it will play the roles as described below andhope that these roles will be specified in the Handbook.
・Implementation of the outreach activities to stakeholders

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・Road show of new standards
・Support for Post-Implementation Review
・Performing on Effect Analysis
・Support for consultation between the AOSSG and the IASB・Information gathering and meeting with regulators and accounting standard setters
・Educational activities of IFRS・Support for trustees and advisory council members and so on⒡70）
Ensuring transparency of fieldwork（3．67─3．

Fieldwork is an activity undertaken to help IASB assess the likely effects of proposed IFRS
to the interested parties and IASB can plan it voluntarily. However, the IASB should makepublic the information about the fieldworks it has undertaken（at least, in which countries
and to which bodies）, because fieldworks should be undertaken as widely as possible fromthe global perspective, without being limited to specific regional bodies.
2 ．Section 4 “Technical work programme”
aProcess for suspension and cancelation of the project

Although paragraph 5．2 to 5．5 of the Handbook specifies the process for adding standardslevel projects to the technical work programme, the Handbook included no specifies procedures for suspension and cancelation of projects when the standard development has notbeen proceeding well for a long time.
When a project is suspended during the standard development, whether tentative decisions
on the project are still valid is sometimes unclear, due to lack of adequate announcement
about its treatments. When a project for which a certain time period has passed is not proceeding smoothly, it may be useful to discuss whether to cancel the project on a timely basefrom the viewpoint of appropriate resource allocation and announce the result of the discussion.
3 ．Section 6 “New or amended IFRSs”
aRe-exposure（6．25）

A re-exposure draft usually asks questions only for the changes from the original exposure
draft. However, for significant issues with which many respondents expressed disagreement
and nevertheless no change is proposed in the re-exposure draft, questions should be added
to ask whether respondents support the Boardʼs decisions not to change, with the reasonsfor those decision being included in the basis for conclusions.
b

Status of the basis for conclusions（6．29）

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practice as well as requirements and provides indispensable grounds for adequate interpretation of requirements.
cEarlier application（6．32）

The Handbook should specify that an IFRS needs to state whether its earlier application ispermitted not, as well as its mandatory effective date and transitional provisions.
dClarification of the process of application for Post-implementation review（6．
50）

The Handbook states that a PIR may be conducted in response to changes in the financial
reporting environment and regulatory requirements, or in response to concerns about thequality of an IFRS that have been expressed by the Advisory Council, the Interpretations
Committee, standard-setters or interested parties. However, it does not prescribe specificprocesses about to whom stakeholders should express concerns and how the IASB should
address such concerns. These processes should be clarified in order to ensure fairness andtransparency.
eExposure draft（6．7 and 6．8）⑴

Comments period

As we mentioned in Question 4, paragraph 6．
7 states that the IASB may consider the comments period to be no less than 30 days if the matter is narrow in scope and urgent, although it normally allows a minimum period of 120 days. We believe the comment period
should be no less than 60 days in any case so that sufficient time for discussion of the exposure draft would be ensured in jurisdictions where English is not an official language.
In addition, paragraph 6．8 states that, in exceptional circumstances, the IASB may reduce
the period for public comment below 30 days after formally requesting and receiving priorapproval from 75 per cent of the Trustees. We acknowledge an urgent treatment as above
might become necessary in extremely exceptional circumstances, but a minimum reasonable comment period should be specified in the Handbook.
⑵

Effective date in the exposure draft

The effective date is not often specified in exposure drafts. However, the effective date is avery important factor for implementation of an IFRS and therefore it need to be predictable.
We acknowledge that the IASB has difficulty in specifying the mandatory effective date in
the exposure draft, considering length of a deliberation period after the issuance of an exposure draft. However, an exposure draft should indicate at least the planned length of timebetween the publication date of the standard and its mandatory effective date.

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4 ．Section 7 “Interpretations”
aIssuance of jurisdiction specific guidance

We acknowledge that local guidance should be avoided as much as possible in order to apply IFRS consistently all over the world and it is ideal to resolve all issues within IFRSs andIFRIC interpretations. However, in exceptional cases, there may be necessity for nationalstandards setters to issue jurisdiction-specific guidance when the IFRS Interpretations Committee rejects issuing the interpretation because it is considered to be specific to the jurisdiction. The Handbook should specify the concept of such jurisdiction-specific guidance andprocedures for issuing them, admitting the necessity of such guidance in exceptional cases.
b

Clarification of the proposed revised agenda criteria of IFRS Interpretations Committee

In Report on the Trusteesʼ Review of Efficiency and Effectiveness of the IFRS Interpretations
Committee, IASB and IFRS Interpretations Committee propose to amend the agenda criteria to address the diversity in practice and wider range issues. However, the Handbook
does not specify the revised agenda criteria. Because the agenda criteria is very important
for the IFRS Interpretations Committee to determine which issues should be taken onto its
agenda, the criteria should be clearly stated in the Handbook.
cIASB members’ voting requirements for draft interpretation and interpretation（7．
10）

Paragraph 7．
10 provides that, if four or more IASB members object to the release of thedraft Interpretation during the balloting process, the draft Interpretation is not released. On
the other hand, paragraph 7．23 provides that ratification of an Interpretation takes place ina public meeting of the IASB and requires a supermajority. The Handbook should clarify
the reason for the difference in treatments between a draft interpretation and a final interpretation.
★

★

★

We hope our comments will contribute to the forthcoming deliberations of the IFRS Foundation.
Yours sincerely,

Ikuo Nishikawa
Chairman of the Accounting Standards Board of Japan

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Appendix
We noted the following possible inconsistencies in the description of the Due Process Protocol in the Appendix 4.
Descriptions that appears to bemistakenDescriptions we suppose to becorrect

8th line from the top on page 56“Development and publication ofan exposure draft for an IFRS,
practice guidance or Conceptual
Framework chapter”～ normally allows a period of
120 days for comments on discussion and research papers.

～ normally allows a period of
120 days for comments on exposure draft.

7th line from the top on page 63“Development and publication ofAnnual Improvements Exposure”～ publishing a draft Interpretation and in responding to comments received.

～ publishing a proposed annual
improvements and in responding to comments received.

3rd column from the bottom inthe table on page 64 “Development and publication of Annual
Improvements Exposure”

DPOC receives summary reporton due process steps followed
before a draft Interpretation isissued

DPOC receives summary reporton due process steps followed
before a proposed annual improvements is issued

2rd column from the bottom inthe table on page 64 “Development and publication of Annual
Improvements Exposure”

DPOC informed of the release of
the draft Interpretation

DPOC informed of the release of
the proposed annual improvements

3rd column from the bottom inthe table on page 65 “Development and publication of draft rejection notice”

Draft Interpretation has appropriate comment period.

Draft rejection notice has appropriate comment period.

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