Survey on the revised exposure draft Leases
August 2013
Japan Leasing Association○ Japan Leasing Association (JLA) conducted a survey on the revised exposure draft leases (the re-ED)
issued by the International Accounting Standards Board (IASB) and the Financial AccountingStandards Board (FASB) in May 2013. The purpose of the survey is to understand views on the re-ED
from public companies and large companies in Japan from the standpoint of lessee accounting (thenumber of the companies which were surveyed is 9,226.).
○ More than 90% of the respondents disagree to the proposals by the Boards in the re-ED. Morethan 80%* of the respondents view that the current standard should be retained.
* The reasons to disagree to the proposals are as follows.
“It is more reasonable to improve the disclosures considering costs and practicability into account if
the information provided under the current standard is not sufficient.”“The current standard is appropriate.”○ For the on-balance sheet treatment of leases, about 80% of the respondents agree to that treatment
only if a lessee were allowed to recognize an asset and a liability at the undiscounted lease payments(undiscounted lease payments approach). For the proposal associated with measuring a lease term in
the re-ED, about 90% of the respondents disagree to that proposal. For the proposed short term leaseaccounting, about 80% of the respondents disagree to that proposal. For a lease of a non-core asset,
about 90% of the respondents disagree to the proposal that there is no any distinction in accounting on
the basis of whether the underlying asset is core to an entity’s operations. According to the result of
the survey, it has become clear that the majority of the respondents (companies) in Japan haveconcerns to the proposals in the re-ED.
Ⅰ Summary
1. Aim

JLA conducted the survey on the re-ED issued by the IASB and the FASB in May 2013 for the purpose of
 understanding the views from preparers of financial statements (Japanese lessees) broadly,
 including the views in JLA’s comment letter, and having the IASB and other standards setters understand the views.
2. Items
a. The proposed lessee accounting
b. Recognition of lease expenses on a straight line basis
c. Measurement of a lease termd. Accounting for a short term leasee. Accounting for a lease of a non-core asset

3. Method to conduct the survey

Questionnaires were sent to companies.

14. Scope of surveyed companies and respondents

The survey was conducted to all the public companies (3,538 companies) and large companies (5,688
companies). A large company is defined as a company whose capital is 500 million yen or more, or a company whose
liability is 20 billion yen or more. The number of companies within the scope is 9,226. The respondents account for
13.6% of all the companies surveyed.
Table; The number of companies surveyed and that of respondents
Companies surveyed

Respondents

Respondents/Companies surveyed

Public companies

3,538

514

14.5%

Non-public companies(Large companies)

5,688

737

13.0%

Total

9,226

1,251

13.6%

JLA’s member companies are not included. The companies surveyed cover almost all the public companies and large companies inJapan.
5. Period

From June 14, 2013 to July 16, 2013
6. Aggregation method

The number of the respondents is not same with that of valid respondents in each question because all the
respondents did not answer each of the questions.
Ⅱ Result of the survey
1. Lessee Accounting
Do you agree to the proposal for lessee accounting?

For the proposed lessee accounting in the revised exposure draft (the re-ED), the majority (90.8%) of the
respondents disagree to the proposal, while only 9.2% of the respondents agree (refer to Table 1-1).
Table1-1 Whether you agree to the proposed lessee accounting in the re-ED (the number of thevalid respondents 1,232)

Disagree
90.8%

0%

10%

20%

30%

40%

50%

2

Agree
9.2%

60%

70%

80%

90%

100%

<The reasons for disagreeing to the proposal>

43.9% of the respondents who disagree to the proposal view that it is more reasonable to improve the disclosuresconsidering costs and practicability into account if the information provided under the current standard is not sufficient.
36.4% of those respondents view that the current standard is appropriate.” Consequently, more than 80% of those
respondents view that the current standard should be retained.
14.2% of those respondents view that the off-balance sheet treatment is appropriate for a lease of property as
required in the current standard. 3.0% of those respondents view that a straight-line lease expense recognition patternis appropriate, regardless of whether the underlying asset is property or not (Refer to table 1-2).
Many of the respondents who answered “others (2.5%)” view that it is impossible to apply the proposal inpractice. In addition, some respondents have a concern associated with costs and benefits, and other respondents viewthat comparability would be reduced because of arbitrariness associated with measuring a lease term.
Table1-2 The reasons for disagreeing to the proposal by the boards (The number of valid respondents; 1,100)
It is more reasonable to improve the disclosuresconsidering costs & practicability into account if theinformation provided under the current standard is not
sufficient.

43.9%
36.4%

The current lease standard is appropriate.
The off‐balance sheet treatment is appropriate for alease of property as required in the current standard.

14.2%

If operating leases are recognized on a lessee's B/S, astraight‐line lease expense recognition is appropriate
regardless of the nature of the underlying asset.

3.0%
2.5%

Others
0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

<The reasons for agreeing to the proposal>

The respondents who agree to the proposed lessee accounting account for only 9.2% (113 companies) of all the
respondents. Some (50.4%) of those respondents view that it is appropriate to recognize all the leases in a lessee’sbalance sheet. However, it is agreeable to the proposed classification of leases for the purpose of lease expense
recognition patterns unless there are any forms of appropriate approaches to classify leases. In addition, some (41.6%)of those respondents view that recognizing all the leases on a lessee’s balance sheet is appropriate and the proposedclassification of leases for the purpose of lease expense recognition patterns is also appropriate (Refer to Table 1-3.).
The respondents who answered “others (8.0%)” include respondents who are reluctantly supportive of the
proposal. In addition, some required the boards to pay more attentions to practicability.

3

Table1-3 Reasons for agreeing to the proposal (the number of valid respondents; 113)
Recognizing all the leases on a lessee’s BS isappropriate. However, it is agreeable to the
proposed classification of leases unless anotherexpense recognition is more appropriate.

50.4%

Recognizing all the leases on a lessee’s BS isappropriate and the proposed lease expense
recognition patterns are also appropriate.

41.6%

8.0%

Others
0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

2. Straight-line lease expense recognition<Which approach do you agree to, either the proposed lease expense recognition pattern in which thelessee recognizes lease expense on a straight-line basis or “undiscounted lease payments approach”?>

If the lessee’s ROU model were adopted, the majority (78.6%) of the respondents are supportive of the“undiscounted lease payments approach*2”, while the minority (10.9%) of the respondents are supportive of the
proposal in the re-ED and the others (10.5%) are supportive of other approaches to recognize lease expense (Refer toTable2-1.).
*2 Under the undiscounted lease payments approach, the lessee recognizes a ROU asset and lease liability at the undiscounted lease
payments. The lessee recognizes depreciation evenly over the lease term and amortizes lease liability at the amount of lease

payments in each period.
Table2-1 Straight-line lease expense recognition pattern (the number of valid respondents; 1,217)

supportive of theundiscounted lease
payments approach
78.6%

0%

10%

20%

30%

40%

supportive of supportive
the proposal of others
10.9%
10.5%

50%

60%

70%

80%

90%

100%

<The reasons for being supportive of the undiscounted lease payments approach>

The majority (83.7%) of the respondents who are supportive of the “undiscounted lease payments approach”
view that that approach is more appropriate than the proposed lease expense recognition patterns to realize a lessee’s
straight-line expense recognition. 12.6% of those respondents view that the proposed accounting in the re-ED would
not faithfully reflect the pattern in which the lessee expects to consume the right-of-use asset’s future economic
benefits (Refer to Table2-2.).
Many of the respondents who answered “others (3.7%)” indicate that the proposed lessee accounting is moreburdensome because it requires lessees to discount lease payments.

4

Table2-2 The reasons for being supportive of the undiscounted lease payments approach (the number ofvalid respondents; 951)

The undiscounted lease payments approach ismore appropriate to realize a lessee’s straight‐line
expense recognition.

83.7%

The proposed lessee accounting in the re‐ED would
not faithfully reflect the pattern in which the lessee
expects to consume the right‐of‐use asset’s future
economic benefits.

12.6%

3.7%

Others
0.0%

20.0%

40.0%

60.0%

80.0%

100.0%<The reasons for being supportive of the proposal in the re-ED>

The respondents who are supportive of the proposal in the re-ED account for only 10.3% (133 companies).
60.6% of the supportive view that the proposed lessee accounting is more appropriate than the undiscounted lease
payments approach to realize a lessee’s straight-line expense recognition. Some (34.8%)of the supportive view thatthe proposed lessee accounting is more preferable because a lessee overstates ROU asset and lease liability under theundiscounted lease payments approach even though that approach might be more appropriate to realize a lessee’s
straight-line lease expense recognition.
Table2-3 The reasons for being supportive of the proposal in the re-ED (the number of the valid respondents; 132)
The proposed accounting is more appropriate
than the undiscounted lease payments approachto realize a straight‐line expense recognition.

60.6%

The proposed accounting is more preferable
because a lessee overstates ROU asset and liability
under the undiscounted lease payments approacheven though that approach is more appropriate torealize a straight‐line lease expense recognition.

34.8%

4.5%

Others

0.0%

20.0%

40.0%

60.0%

80.0%

100.0%<The reasons for being supportive of other approaches>

The respondents who are supportive of other approaches account for only 10.5% (128 companies). 42.3% of the
respondents who are supportive of others prefer to be able to choose either the approach proposed in the re-ED or theundiscounted lease payments approach. Some (39.8%) of those respondents prefer that a lessee apportions interest
component of lease payments over the lease term on a straight line basis (refer to Table2-4.).
The respondents who answered “others” (17.9%) view that the current standard is more preferable.

5Table2-4 The reasons for being supportive of others (the number of the valid respondents; 123)
Prefer to be able to choose either the approach
proposed in the re‐ED or the undiscounted lease
payments approach.

42.3%

Prefer to apportion interest component of lease
payments over the lease term on a straight line
basis.

39.8%

17.9%

Others
0.0%

20.0%

40.0%

60.0%

3. Measurement of a lease term
<Do you agree to the proposed measurement of a lease term in the re-ED?>

The majority (89.3%)of the respondents disagree to the proposed measurement of a lease term*3 inthe re-ED, while the minority (10.7%) of the respondents agree to the proposal (refer to Table3-1.).
*3

The re-ED proposes that a lease term be determined as the non-cancellable period together with theperiods covered by an option to extend or terminate the lease if the lessee has a significant
economic incentive.

Table3-1The proposed measurement of a lease term (the number of the valid respondents; 1,229)

Disagree
89.3%

0%

10%

20%

30%

40%

50%

Agree
10.7%

60%

70%

80%

90%

100%

<The reasons for disagreeing to the proposal>

At first, 54.9% of the respondents who disagree to the proposal view that it is difficult to determine whether thelessee has a significant economic incentive or not. At second, 22.9% of those respondents view that comparability offinancial statements would be reduced because some uncertain options could be included in the lease term (Refer toTable3-2.).
Some (1.0%) of the respondents who answered “others” view that the proposed measurement of a lease term iscomplex and others view that a lease term might be arbitrarily determined.

6

Table3-2 The reasons for disagreeing to the proposal (the number of the valid respondents; 1,094)
It is difficult to determine whether the lessee has asignificant economic incentive or not.

54.9%

Comparability of financial statements would be
reduced because some uncertain options could be
included in the lease term.

22.9%

There is no any defect to the current standard.

21.2%

Others

1.0%
0.0%

20.0%

40.0%

60.0%

<The reasons for agreeing to the proposal>

The respondents who agree to the proposal in the re-ED account for only 10.7% (131 companies) of all the
respondents. 62.3% of those respondents view that the proposed measurement of a lease term would reflect the natureof the lease term although it is difficult to determine whether the lessee has a significant economic incentive. 32.3% of
those respondents view that the proposed measurement would reflect the nature of the lease term and it is easy todetermine whether the lessee has a significant economic incentive (Refer to Table3-3.).
Table3-3 The reasons for agreeing to the proposal (the number of the valid respondents 130)
The proposal for lease term reflects the nature oflease term although it is difficult to determine
whether the lessee has a significant economic
incentive.

62.3%

The proposal for lease term would reflect thenature of lease term and it is easy to determine
whether the lessee has a significant economic
incentive.

32.3%

5.4%

Others
0.0%

20.0%

40.0%

60.0%

80.0%

100.0%

4. Accounting for a short term lease<Do you agree to the proposed accounting for a short term lease?>

The majority (78.5%) of the respondents disagree to the proposed accounting for a short term lease*4, while theminority (21.5%) of the respondents agree to the proposal (refer to Table4-1.).
*4 The re-ED proposes that an entity can choose to account for a short term lease under the off-balance sheet
treatment. A short term lease is defined as “a lease that, at the commencement date, has a maximum possible
term under the contract, including any options to extend, of 12 months or less.”

7

Table4-1 Accounting for a short term lease (the number of the valid respondents; 1,220)

Disagree
78.5%
0%

10%

20%

30%

40%

Agree
21.5%
50%

60%

70%

80%

90%

100%

<The reasons for disagree to the proposal>

The majority (60.5%) of the respondents who disagree to the proposal view that if options to extend the leases
are included, there are few leases to which the proposed accounting for a short term lease could be applied, which
would be burdensome. 37.3% of those respondents view that the proposed accounting for a short term lease could not
be applied to many leases, because there are many leases where the non-cancelable lease term is more than one year,
which would be burdensome. (Refer to Table4-2.).
Some (2.2%) of the respondents who answered “others” view that it is difficult to determine options to extend
the lease and others view that the definition of short term lease should be one year or less excluding options to extend
the lease.
Table4-2 The reasons for disagreeing to the proposal (the number of the valid respondents; 954)
If options to extend the leases are included,
there are few leases to which the proposed
accounting for a short term lease could beapplied, which would be burdensome.

60.5%

The proposed accounting for a short termlease could not be applied to many leases,
because there are many leases where thenon‐cancelable lease term is more than one
year, which would be burdensome.

37.3%

2.2%

Others

0.0%

20.0%

40.0%

60.0%

80.0%

100.0%<The reasons for agreeing to the proposal>

The respondents who agree to the proposal account for only 21.5% (262 companies) of the all the respondents.
At first, the majority (72.7%) of those respondents view that the proposal for a short term lease is appropriate from thestandpoint of costs and benefits. At second, 15.8% of those respondents view that the proposal is appropriate in orderto prevent an entity from intentionally structuring short term leases. 9.2% of those respondents view that the proposal
would be agreeable if the definition of a short term lease is consistent with that of a lease term (i.e. options are included
if the lessee has a significant economic incentive.) (Refer to Table4-3.).

8

Table4-3 The reasons for agreeing to the proposal (the number of the valid respondents; 260)

The proposal for a short term lease is appropriate
from the standpoint of costs and benefits.

72.7%

The proposal is appropriate in order to prevent anentity from intentionally structuring short termleases.

15.8%

The proposal would be agreeable if the definitionof a short term lease is consistent with that of alease term.

9.2%

2.3%

Others
0.0%

20.0%

40.0%

60.0%

80.0%

5. Accounting for a lease of a non-core asset<Do you agree to the proposal that there is no any distinction in accounting on the basis of whether theunderlying asset is core to an entity’s operations?>

The majority (87.2%) of the respondents disagree to the proposal that there is no any distinction in accounting on
the basis of whether the underlying asset is core to an entity’s operations, while the respondents who agree account for
only 12.8% of all the respondents (Refer to Table5-1.).
Table5-1 Accounting for a lease of a non-core asset (the number of the valid respondents; 1,061）

Disagree
87.2%
0%

10%

20%

30%

40%

Agree
12.8%

50%

60%

70%

80%

90%

100%

<The reasons for disagreeing to the proposal>

At first, 58.2% of the respondents who disagree to the proposal view that it is appropriate to apply the current
operating lease accounting to a lease of a non-core asset. At second, 40.9% of those respondents view that there would
be practical difficulties unless there is any practical relief in which an entity is able to determine whether the proposals
in the re-ED should be applied to its leases based on the materiality threshold set by the entity in the lease accounting
standard itself(Refer to Table 5-2.).
The respondents who answered “others” (0.8%) view that it is likely to be extremely costly and burdensome torecognize all the immaterial leases on a lessee’s balance sheet.

9

Table5-2 The reasons for disagreeing to the proposal (the number of the valid respondents; 1,061)
It is appropriate to apply the current
operating lease accounting to a lease of anon‐core asset.

58.2%

There would be practical difficulties without
any practical relief in which an entity candetermine whether the proposals should beapplied to its leases based on the materiality
threshold set by the entity in the standard.

40.9%

0.8%

Others

0.0%

20.0%

40.0%

60.0%

80.0%

<The reasons for agreeing to the proposal>

The respondents who agree to the proposal (i.e. there is no any distinction in accounting on the basis of whether
the underlying asset is core to an entity’s operations.) account for only 12.8% (156 companies) of all the respondents.
43.7% of those respondents view that there should be no exception for a lease of non-core asset. 35.1% of those
respondents view that there is no need to provide a specified accounting because the IFRS allows an entity todetermine whether the proposals in the re-ED should be applied to its leases by itself based on the materiality
threshold set by the entity. 17.2% of those respondents view that there is no need to provide any exception because
any numerical threshold would be complex to apply.
Table5-3 The reasons for agreeing to the proposal (the number of the valid respondents; 151)

There should be no exception for a lease ofnon‐core asset.

43.7%

There is no need to provide a specified
accounting because the IFRS allows an entity todetermine whether the proposals in the re‐EDshould be applied to its leases by itself basedon the materiality threshold set by the entity.

35.1%

There is no need to provide any exception
because any numerical threshold would becomplex to apply.

17.2%

4.0%

Others

0.0%

20.0%

10

40.0%

60.0%

80.0%

<Appendix 1> Attribution of respondents, Respondents who use leases and those who do not.
(1) Area (The number of the valid respondents; 1,233)

Area

Publiccompanies

Hokkaido
Tohoku area
(Aomori, Iwate, Miyagi, Akita, Yamagata, Fukushima)
Kanto‐Koshinetsu(Ibaraki, Tochigi, Gunma, Saitama, Chiba, Tokyo, Kanagawa, Niigata,
Yamanashi, Nagano, Shizuoka)
Tokyo only
Chubu area
(Toyama, Ishikawa, Gifu, Aichi, Mie)
Kinki area
(Fukui, Shiga, Kyoto, Osaka, Hyogo, Nara, Wakayama)
Chugoku area
(Tottori, Shimane, Okayama, Hiroshima, Yamaguchi)
Shikoku area
(Tokushima, Kagawa, Ehime, Kochi)
Kyushu area
(Fukuoka, Saga, Nagasaki, Kumamoto, Oita, Miyazaki, Kagoshima, Okinawa)
Total

297

Non‐publiccompanies
23(3.2%)
38(5.2%)
415(58.7%)(57.1%)(57.7%)

221(43.7%)
55(10.9%)
92(18.2%)
17(3.4%)
7(1.4%)
22(4.3%)
506(100.0%)290(39.9%)
62(8.5%)
102(14.0%)
24(3.3%)
18(2.5%)
45(6.2%)
727(100.0%)511(41.4%)
117(9.5%)
194(15.7%)
41(3.3%)
25(2.0%)
67(5.4%)
1,233(100.0%)Publiccompanies
136(26.7%)
177(34.7%)
65(12.7%)
87(17.1%)
18(3.5%)
27(5.3%)
510(100.0%)Non‐publiccompanies
301(41.0%)
330(45.0%)
45(6.1%)
42(5.7%)
9(1.2%)
7(1.0%)
734(100.0%)6( 1.2% )10(2.0%)

Total
29(2.4%)
48(3.9%)
712(2) Capital stock (the number of the valid respondents; 1,244)

Capital stock
Less than 1,000 million yen
1,000 million yen – less 5,000 million yen
5,000 million yen – less 10,000 million yen
10,000 million yen – less 50,000 million yen
50,000 million yen –less 100,000 million yen
100,000 million yen ‐
Total

11

Total
437
(35.1%)
507(40.8%)
110(8.8%)
129(10.4%)
27(2.2%)
34(2.7%)
1,244(100.0%)(3) Type of business (The number of the valid respondents; 1,241)

Type of business

Publiccompanies
34(6.7%)
212(41.5%)
34(6.7%)
20(3.9%)
101(19.8%)
19(3.7%)
18(3.5%)
73(14.3%)
511(100.0%)Construction
Manufacturing
Information and Communication
Transport
Wholesale and retail trade
Finance and Insurance
Real estate
OthersTotal

Non‐publiccompanies
39(5.3%)
211(28.9%)
55(7.5%)
34(4.7%)
112(15.3%)
74(10.1%)
56(7.7%)
149(20.4%)
730(100.0%)Total
73(5.9%)
423(34.1%)
89(7.2%)
54(4.4%)
213(17.2%)
93(7.5%)
74(6.0%)
222(17.9%)
1,241(100.0%)(4) Type of underlying assets (The number of the valid respondents; 1,218)

Type of underlying asset under leases

PublicNon‐public
Total
companies
companies
Respondents who have lease contracts
481
657
1,138
(96.0%)(91.6%)(93.4%)
Property
291
371
662
(58.1%)(51.7%)(54.4%)
596
Equipment(assets other than property
446
1,042
(89.0%)(83.1%)(85.6%)
Respondents who have no lease contracts (owned assets only)
20
60
80(4.0%)(8.4%)(6.6%)
Total
501
717
1,218
(100.0%)(100.0%)(100.0%)* The respondents multiply answer to “Property” and “Equipment (assets other than property)”. If a respondent
answers either “Property” or “Equipment”, the respondent is included in “Respondents who have lease
contracts”.
(5) Type of property leases (the number of the valid respondents; 653)

Type of property leases

Publiccompanies
38(13.2%)
275(95.5%)
288(100.0%)Finance lease
Operating lease
Total

12

Non‐publiccompanies
33(9.0%)
350(95.9%)
365(100.0%)Total
71(10.9%)
625(95.7%)
653(100.0%)(6) Type of equipment leases (leases of assets other than property)

Type of equipment
Finance lease
Operating lease
No leases
Information & communication equipment (the valid698(75.5%)371(40.1%)
26 (2.8%)
respondents; 925)
Manufacturing equipment & construction equipment346(45.8%)
158(20.9%)329(43.6%)(the valid respondents; 755)
Commercial & service equipment (the valid261(39.0%)
127(19.0%)332(49.6%)
respondents; 670)
Cars (the valid respondents; 846)
382(45.2%)448(53.0%)
118(13.9%)
Others (the valid respondents; 357)
64(17.9%)34(9.5%)273(76.5%)*1 The respondents multiply answer to “finance lease” and “operating lease”.
*2 “Others” includes software, office equipment, transport equipment other than cars, and medical equipment.
<Public companies>

Type of equipment
Information & communication equipment(the valid respondents; 400)
Manufacturing equipment & construction
equipment (the valid respondents; 357)
Commercial & service equipment(the valid respondents; 322)
Cars (the valid respondents; 382)
Others (the valid respondents; 157)

Finance lease304(76.0%)

Operating lease161(40.3%)

No leases12(3.0%)191(53.5%)76(21.3%)

134(37.5%)

141(43.8%)64(19.9%)147(45.7%)

177(46.3%)
33(21.0%)214(56.0%)11(7.0%)44(11.5%)
121(77.1%)

Finance lease394(75.0%)

Operating lease210(40.0%)

No leases
14(2.7%)

155(38.9%)82(20.6%)

195(49.0%)120(34.5%)63(18.1%)

185(53.2%)

205(44.2%)
31(15.5%)234(50.4%)
23(11.5%)

74(15.9%)
152(76.0%)<Non-public companies>

Type of equipment
Information & communication equipment(the valid respondents; 525)
Manufacturing equipment & construction
equipment (the valid respondents; 398)
Commercial & service equipment(the valid respondents; 348)
Cars (the valid respondents; 464)
Others (the valid respondents; 200)

(7) Share of property leases in operating leases (the valid respondents; 623)

Share

Publiccompanies
44(16.4%)
53(19.8%)
25(9.3%)
146(54.5%)
268(100.0%)Less than 10%
10%‐ 50%More than 50‐70%More than 70%
Total

13

Non‐publiccompanies
71(20.0%)
65(18.3%)
28(7.9%)
191(53.8%)
355(100.0%)Total
115(18.5%)
118(18.9%)
53(8.5%)
337(54.1%)
623(100.0%)<Appendix 2> Details of the results from the survey
1. The proposed lessee accounting in the re-ED(1) The proposed lessee accounting in the re-ED (the valid respondents; 1,232)

Respondents
1,119

Share
90.8%

Agree to the proposal.

113

9.2%

Total

1,232

100.0%Disagree to the proposal.

a. Public/Non-public ones (the valid respondents; 1,232)

Public companies
453(89.7%)52(10.3%)505(100.0%)

Disagree to the proposal.
Agree to the proposal.
Total

Non‐public companies
666(91.6%)61(9.2%)727(100.0%)

b. Respondents who use leases/respondents who do not. (the valid respondents; 1,200)

Companies using leases
1,024(91.1%)100(8.9%)
1,124(100.0%)

Disagree to the proposal.
Agree to the proposal.
Total

Companies using no leases
64(84.2%)
12(15.8%)
76(100.0%)

c. Type of underlying assets used by respondents who use leases (the valid respondents; 1,124)

both property & others942(91.5%)
88(8.5%)1,030(100.0%)

Disagree to the proposal.
Agree to the proposal.
Total

only property
82(87.2%)
12(12.8%)
94(100.0%)(2)The reasons for disagreeing to the proposal (the valid respondents; 1,100)

Respondents

Share

It is reasonable to improve the disclosures considering costs & practicability into
account if the information provided under the current standard is not sufficient.

483

43.9%

The current lease standard is appropriate.

400

36.4%

156

14.2%

33

3.0%

Others

28

2.5%

Total

1,100

100.0%The off‐balance sheet treatment is appropriate for a lease of property as required in
the current standard.
If operating leases are recognized on a lessee's B/S, a straight‐line lease expense
recognition is appropriate regardless of the nature of the underlying asset.

a. Public/Non-public companies (the valid respondents; 1,100)

Public companies

Non‐public companies

It is reasonable to improve the disclosures considering costs & practicability into
account if the information provided under the current standard is not sufficient.

188(42.4%)295(44.9%)

The current lease standard is appropriate.

153(34.5%)247(37.6%)

The off‐balance sheet treatment is appropriate for a lease of property as requiredin the current standard.

69(15.6%)

87(13.2%)

If operating leases are recognized on a lessee's B/S, a straight‐line lease expense
recognition is appropriate regardless of the nature of the underlying asset.

14(3.2%)19(2.9%)Others19(4.3%)9(1.4%)

Total

443(100.0%)657(100.0%)

14

b. Companies using leases/companies using no leases(the valid respondents; 1,070)

Using leases

Using no leases

It is reasonable to improve the disclosures considering costs & practicability into
account if the information provided under the current standard is not sufficient.

449(44.6%)27(42.9%)

The current lease standard is appropriate.

359(35.7%)28(44.4%)

The off‐balance sheet treatment is appropriate for a lease of property as requiredin the current standard.

142(14.1%)5(7.9%)

If operating leases are recognized on a lessee's B/S, a straight‐line lease expense
recognition is appropriate regardless of the nature of the underlying asset.

31(3.1%)2(3.2%)

Others26(2.6%)1(1.6%)

1,007(100.0%)63(100.0%)

Total

c. Type of underlying assets used by respondents who use leases (the valid respondents; 1,007)

Both property & others

Only property

It is reasonable to improve the disclosures considering costs & practicability into
account if the information provided under the current standard is not sufficient.

421(45.5%)28(34.6%)

The current lease standard is appropriate.

331(35.7%)

28(34.6%)

The off‐balance sheet treatment is appropriate for a lease of property as requiredin the current standard.

120(13.0%)22(27.2%)

If operating leases are recognized on a lessee's B/S, a straight‐line lease expense
recognition is appropriate regardless of the nature of the underlying asset.

30(3.2%)1(1.2%)

Others24(2.6%)2(2.5%)

Total

926(100.0%)81(100.0%)(3) The reasons for agreeing to the proposal (the valid respondents; 113)

Respondents
Recognizing all the leases on a lessee’s BS is appropriate. However, it is agreeable to the
proposed classification of leases unless another expense recognition is more appropriate.
Recognizing all the leases on a lessee’s BS is appropriate and the proposed lease
expense recognition patterns are also appropriate.

Share

57

50.4%

47

41.6%

Others

9

8.0%

Total

113

100.0％

a. Public/Non-public companies (the valid respondents; 113)

Public companies

Non‐public companies

25 (48.1%)

22(36.1%)

23(44.2%)

34(55.7%)

Others4(7.7%)

5(8.2%)

Total

52(100.0%)61(100.0%)

Recognizing all the leases on a lessee’s BS is appropriate. However, it is agreeable to the
proposed classification of leases unless another expense recognition is more appropriate.
Recognizing all the leases on a lessee’s BS is appropriate and the
proposed lease expense recognition patterns are also appropriate.

15b. Companies using leases/companies using no leases (the valid respondents; 112)

Using leases
Recognizing all the leases on a lessee’s BS is appropriate. However, it is agreeable to the
proposed classification of leases unless another expense recognition is more appropriate.
Recognizing all the leases on a lessee’s BS is appropriate and the
proposed lease expense recognition patterns are also appropriate.
Others
Total

Using no leases

51(51.0%)6(50.0%)43(43.0%)4(33.3%)6(6.0%)

2(16.7%)100(100.0%)12(100.0%)

c. Type of underlying assets used by respondents who use leases (the valid respondents; 100)

Both property & others

Only property

44(50.0%)7(58.3%)39(44.3%)

4(33.3%)

Others5(5.7%)

1(8.3%)

Total

88(100.0%)12(100.0%)

Recognizing all the leases on a lessee’s BS is appropriate. However, it is agreeable to the
proposed classification of leases unless another expense recognition is more appropriate.
Recognizing all the leases on a lessee’s BS is appropriate and the
proposed lease expense recognition patterns are also appropriate.

2. Straight-line lease expense recognition(1) Straight-line lease expense recognition (the valid respondents; 1,217)

Respondents
956

Share
78.6%

Supportive of the proposal in the re‐ED.

133

10.9%

Supportive of other approaches.

128

10.5%

Total

1,217

100.0%

Supportive of the “undiscounted lease payments approach”.

a. Public/Non-public companies (the valid respondents; 1,217)

Supportive of the “undiscounted lease payments approach”.
Supportive of the proposal in the re‐ED.
Supportive of other approaches.
Total

Public companies
385(77.2%)63(12.6%)
51(10.2%)
499(100.0%)

Non‐public companies
571(79.5%)70(9.7%)77(10.7%)718(100.0%)

b. Companies using leases/companies using no leases (the valid respondents; 1,187)

Supportive of the “undiscounted lease payments approach”.
Supportive of the proposal in the re‐ED.
Supportive of other approaches.
Total

Using leases
877(78.8%)120(10.8%)116(10.4%)
1,113(100.0%)

Using no leases
58(78.4%)9(12.2%)7(9.5%)
74(100.0%)

c. Type of underlying assets used by respondents who use leases (the valid respondents; 1,113)

Supportive of the “undiscounted lease payments approach”.
Supportive of the proposal in the re‐ED.
Supportive of other approaches.
Total

16

Both property & others809(79.3%)
105(10.3%)
106(10.4%)
1,020(100.0%)

Only property
68(73.1%)
15(16.1%)
10(10.8%)
93(100.0%)

(2) The reasons for being supportive of the undiscounted lease payments approach (the valid respondents;
951)

Respondents
The undiscounted lease payments approach is more appropriate to realize a lessee’s
straight‐line expense recognition.
The proposed lessee accounting in the re‐ED would not faithfully reflect the pattern inwhich the lessee expects to consume the right‐of‐use asset’s future economic benefits.

Share

796

83.7%

120

12.6%

Others

35

3.7%

Total

951

100.0％

a. Public/Non-public companies (the valid respondents; 951)

Public companies

Non‐public companies

308(80.2%)488(86.1%)

58(15.1%)

62(10.9%)

Others18(4.7%)17(3.0%)Total

384(100.0%)567(100.0%)

The undiscounted lease payments approach is more appropriate torealize a lessee’s straight‐line expense recognition.
The proposed lessee accounting in the re‐ED would not faithfully reflect the pattern inwhich the lessee expects to consume the right‐of‐use asset’s future economic benefits.

b. Companies using leases/companies using no leases (the valid respondents; 930)

Using leases
The undiscounted lease payments approach is more appropriate torealize a lessee’s straight‐line expense recognition.
The proposed lessee accounting in the re‐ED would not faithfully reflect the pattern inwhich the lessee expects to consume the right‐of‐use asset’s future economic benefits.

Using no leases

735(84.1%)

46(82.1%)

107(12.2%)9(16.1%)Others32(3.7%)1(1.8%)

Total

874(100.0%)56(100.0%)

c. Type of underlying assets used by respondents who use leases (the valid respondents; 874)

Both property & others
The undiscounted lease payments approach is more appropriate torealize a lessee’s straight‐line expense recognition.
The proposed lessee accounting in the re‐ED would not faithfully reflect the pattern inwhich the lessee expects to consume the right‐of‐use asset’s future economic benefits.

Only property

676(83.9%)59(86.8%)

98(12.2%)9(13.2%)Others32(4.0%)0(0.0%)

Total

806(100.0%)68(100.0%)(3) The reasons for being supportive of the proposal in the re-ED (the number of the valid respondents; 132)

Respondents
The proposed accounting is more appropriate than the undiscounted lease
payments approach to realize a straight‐line expense recognition.
The proposed accounting is more preferable because a lessee overstates ROU andliability under the undiscounted lease payments approach even though thatapproach is more appropriate to realize a straight‐line lease expense recognition.

Share

80

60.6%

46

34.8%

Others

6

4.5%

Total

132

100.0%

17

a. Public/Non-public companies (the valid respondents; 132)

Public companies

Non‐public companies

34(54.8%)46(65.7%)

24(38.7%)22(31.4%)

Others4(6.5%)

17 2.9%)Total

62(100.0%)70(100.0%)

The proposed accounting is more appropriate than the undiscounted lease payments
approach to realize a straight‐line expense recognition.
The proposed accounting is more preferable because a lessee overstates ROU and liability
under the undiscounted lease payments approach even though that approach is more
appropriate to realize a straight‐line lease expense recognition.

b. Companies using leases/companies using no leases (the valid respondents; 128)

Using leases
The proposed accounting is more appropriate than the undiscounted lease payments
approach to realize a straight‐line expense recognition.
The proposed accounting is more preferable because a lessee overstates ROU and liability
under the undiscounted lease payments approach even though that approach is more
appropriate to realize a straight‐line lease expense recognition.

Using no leases

71(59.7%)

6(66.7%)43(36.1%)

2(22.2%)Others5(4.2%)

1(11.1%)

Total

119(100.0%)9(100.0%)

c. Type of underlying assets used by respondents who use leases (the valid respondents; 119)

Both property & others
The proposed accounting is more appropriate than the undiscounted lease payments
approach to realize a straight‐line expense recognition.
The proposed accounting is more preferable because a lessee overstates ROU and liability
under the undiscounted lease payments approach even though that approach is more
appropriate to realize a straight‐line lease expense recognition.

Only property

62(59.6%)9(60.0%)37(35.6%)

6(40.0%)

Others5(4.8%)

0(0.0%)

Total

104(100.0%)15(100.0%)(4) The reasons for being supportive of others (the number of the valid respondents; 123)

Respondents
Prefer to be able to choose either the approach proposed in the re‐ED or theundiscounted lease payments approach.
Prefer to apportion interest component of lease payments over the lease term on astraight line basis.

Share

52

42.3%

49

39.8%

Others

22

17.9%

total

123

100.0%

a. Public/Non-public companies (the valid respondents; 123)

Public companies

Non‐public companies

17(35.4%)35(46.7%)21(43.8%)

28(37.3%)

Others10(20.8%)

12(16.0%)

total

48(100.0%)75(100.0%)

Prefer to be able to choose either the approach proposed in the
re‐ED or the undiscounted lease payments approach.
Prefer to apportion interest component of lease payments over thelease term on a straight line basis.

18

b. Companies using leases/companies using no leases (the valid respondents; 118)

Using leases
Prefer to be able to choose either the approach proposed in the
re‐ED or the undiscounted lease payments approach.
Prefer to apportion interest component of lease payments over thelease term on a straight line basis.

Using no leases

49(44.1%)

1(14.3%)44(39.6%)3(42.9%)Others18(16.2%)

3(42.9%)total

111(100.0%)7(100.0%)

c. Type of underlying assets used by respondents who use leases (the valid respondents; 111)

Both property & others
Prefer to be able to choose either the approach proposed in the
re‐ED or the undiscounted lease payments approach.
Prefer to apportion interest component of lease payments over thelease term on a straight line basis.

Only property

44(43.6%)

5(50.0%)42(41.6%)2(20.0%)

Others15(14.3%)

3(30.0%)total

101(100.0%)10(100.0%)

3. Measurement of a lease term
(1) Measurement of a lease term (the valid respondents; 1,229)

Respondents
1,098
131
1,229

Disagree to the proposal in the re‐ED.
Agree to the proposal in the re‐ED.
Total

Share
89.3%
10.7%
100.0%

a. Public/Non-public companies (the valid respondents; 1,229)

Public companies
444(88.1%)60(11.9%)504(100.0%)

Disagree to the proposal in the re‐ED.
Agree to the proposal in the re‐ED.
Total

Non‐public companies
654(90.2%)71(9.8%)725(100.0%)

b. Companies using leases/companies using no leases (the valid respondents; 1,200)

Using leases
1,009(89.8%)
115(10.2%)
1,124(100.0%)

Disagree to the proposal in the re‐ED.
Agree to the proposal in the re‐ED.
Total

Using no leases
62(81.6%)
14(18.4%)
76(100.0%)

c. Type of underlying assets used by respondents who use leases (the valid respondents; 1,124)

Both property & others936(90.9%)94(9.1%)
1,030(100.0%)

Disagree to the proposal in the re‐ED.
Agree to the proposal in the re‐ED.
Total

19

Only property
73(77.7%)21(22.3%)
94(100.0%)

(2) The reasons for disagreeing to the proposal (the number of the valid respondents; 1,094)

Respondents
It is difficult to determine whether the lessee has a significant economic incentive ornot.
Comparability of financial statements would be reduced because some uncertain
options could be included in the lease term.

Share

601

54.9%

250

22.9%

There is no any defect to the current standard.

232

21.2%

Others

11

1.0%

Total

1,094

100.0%

a. Public/Non-public companies (the valid respondents; 1,094)

It is difficult to determine whether the lessee has a significant
economic incentive or not.
Comparability of financial statements would be reduced becausesome uncertain options could be included in the lease term.
There is no any defect to the current standard.
Others
Total

Public companies

Non‐public companies

242(54.9%)359(55.0%)111(25.2%)

139(21.3%)

83(18.8%)

149(22.8%)5(1.1%)

6(0.9%)

441(100.0%)653(100.0%)

b. Companies using leases/companies using no leases (the valid respondents; 1,067)

Using leases
It is difficult to determine whether the lessee has a significant
economic incentive or not.
Comparability of financial statements would be reduced becausesome uncertain options could be included in the lease term.
There is no any defect to the current standard.
Others
Total

Using no leases

557(55.4%)29(46.8%)231(23.0%)15(24.2%)

209(20.8%)

16(25.8%)8(0.8%)

2(3.2%)

1,005(100.0%)62(100.0%)

c. Type of underlying assets used by respondents who use leases (the valid respondents; 1,005)

Both property & others
It is difficult to determine whether the lessee has a significant
economic incentive or not.
Comparability of financial statements would be reduced becausesome uncertain options could be included in the lease term.
There is no any defect to the current standard.
OthersTotal

20

Only property

521(55.8%)36(50.0%)215(23.0%)16(22.2%)

189(20.3%)

20(27.8%)8(0.9%)

0(0.0%)

933(100.0%)72(100.0%)

(3) The reasons for agreeing to the proposal (the number of the valid respondents 130)

Respondents
The proposal for lease term reflects the nature of lease term although it is difficult todetermine whether the lessee has a significant economic incentive.
The proposal for lease term would reflect the nature of lease term and it is easy todetermine whether the lessee has a significant economic incentive.

Share

81

62.3%

42

32.3%

Others

7

5.4%

Total

130

100.0%

a. Public/Non-public companies (the valid respondents; 130)

Public companies

Non‐public companies

39(65.0%)42(60.0%)17(28.3%)25(35.7%)

Others4(6.7%)

3(4.3%)

Total

60(100.0%)70(100.0%)

The proposal for lease term reflects the nature of lease term
although it is difficult to determine whether the lessee has asignificant economic incentive.
The proposal for lease term would reflect the nature of lease term
and it is easy to determine whether the lessee has a significant
economic incentive.

b. Companies using leases/companies using no leases (the valid respondents; 128)

Using leases
The proposal for lease term reflects the nature of lease term
although it is difficult to determine whether the lessee has asignificant economic incentive.
The proposal for lease term would reflect the nature of lease term
and it is easy to determine whether the lessee has a significant
economic incentive.
Others
Total

Using no leases

75(65.2%)

5(38.5%)35(30.4%)

6(46.2%)5(4.3%)

2(15.4%)115(100.0%)13(100.0%)

c. Type of underlying assets used by respondents who use leases (the valid respondents; 115)

Both property & others
The proposal for lease term reflects the nature of lease term
although it is difficult to determine whether the lessee has asignificant economic incentive.
The proposal for lease term would reflect the nature of lease term
and it is easy to determine whether the lessee has a significant
economic incentive.

Only property

57(60.6%)

18(85.7%)

32(34.0%)3(14.3%)

Others5(5.3%)

0(0.0%)

Total

94(100.0%)21(100.0%)

21

4. Accounting for a short term lease(1) Accounting for a short term lease (the valid respondents; 1,220)

Respondents

Share

Disagree to the proposal in the re‐ED.

958

78.5%

Agree to the proposal in the re‐ED.

262

21.5%

Total

1,220

100.0%

a. Public/Non-public companies (the valid respondents; 1,220)

Public companies
372(74.3%)
129(25.7%)
501(100.0%)

Disagree to the proposal in the re‐ED.
Agree to the proposal in the re‐ED.
Total

Non‐public companies
586(81.5%)133(18.5%)719(100.0%)

b. Companies using leases/companies using no leases (the valid respondents; 1,192)

Using leases
880(78.9%)236(21.1%)
1,116(100.0%)

Disagree to the proposal in the re‐ED.
Agree to the proposal in the re‐ED.
Total

Using no leases
57(75.0%)19(25.0%)76(100.0%)

c. Type of underlying assets used by respondents who use leases (the valid respondents; 1,116)

Both property & others811(79.4%)
211(20.6%)
1,022(100.0%)

Disagree to the proposal in the re‐ED.
Agree to the proposal in the re‐ED.
Total

Only property
69(73.4%)25(26.6%)
94(100.0%)(2) The reasons for disagree to the proposal (the number of the valid respondents; 954)

Respondents
If options to extend the leases are included, there are few leases to which the proposed
accounting for a short term lease could be applied, which would be burdensome.
The proposed accounting for a short term lease could not be applied to many leases, because there aremany leases where the non‐cancelable lease term is more than one year, which would be burdensome.

Share

577

60.5%

356

37.3%

Others

21

2.2%

total

954

100.0%

a. Public/Non-public companies (the valid respondents; 954)

Public companies

Non‐public companies

235(63.5%)342(58.6%)

125(33.8%)231(39.6%)

Others10(2.7%)11(1.9%)total

370(100.0%)584(100.0%)

If options to extend the leases are included, there are few leases to which the proposed
accounting for a short term lease could be applied, which would be burdensome.
The proposed accounting for a short term lease could not be applied to many leases, because there aremany leases where the non‐cancelable lease term is more than one year, which would be burdensome.

b. Companies using leases/companies using no leases (the valid respondents; 933)

Using leases
If options to extend the leases are included, there are few leases to which the proposed
accounting for a short term lease could be applied, which would be burdensome.
The proposed accounting for a short term lease could not be applied to many leases, because there aremany leases where the non‐cancelable lease term is more than one year, which would be burdensome.

Using no leases534(61.0%)29(50.9%)326(37.2%)

26(45.6%)

Others16(1.8%)2(3.5%)

total

876(100.0%)57(100.0%)22

c. Type of underlying assets used by respondents who use leases (the valid respondents; 865)

Both property & others
If options to extend the leases are included, there are few leases to which the proposed
accounting for a short term lease could be applied, which would be burdensome.
The proposed accounting for a short term lease could not be applied to many leases, because there aremany leases where the non‐cancelable lease term is more than one year, which would be burdensome.

492(61.7%)42(61.8%)

302(37.9%)24(35.3%)

3(0.4%)

2(2.9%)

797(100.0%)68(100.0%)

Otherstotal

Only property(3) The reasons for agreeing to the proposal (the number of the valid respondents; 260)

Respondents
The proposal for a short term lease is appropriate from the standpoint of costs andbenefits.
The proposal is appropriate in order to prevent an entity from intentionallystructuring short term leases.
The proposal would be agreeable if the definition of a short term lease is consistent with thatof a lease term (i.e. options are included if the lessee has a significant economic incentive.).
Others

Share

189

72.7%

41

15.8%

24

9.2%

6

2.3%

260

100.0%

a. Public/Non-public companies (the valid respondents; 260)

The proposal for a short term lease is appropriate from thestandpoint of costs and benefits.
The proposal is appropriate in order to prevent an entity from
intentionally structuring short term leases.
The proposal would be agreeable if the definition of a short term lease is consistent with thatof a lease term (i.e. options are included if the lessee has a significant economic incentive.).
Others
Total

Public companies

Non‐public companies

88(68.2%)

101(77.1%)

26(20.2%)

15(11.5%)12(9.3%)12(9.2%)3(2.3%)

3(2.3%)

129(100.0%)131(100.0%)

b. Companies using leases/companies using no leases (the valid respondents; 253)

Using leases
The proposal for a short term lease is appropriate from thestandpoint of costs and benefits.
The proposal is appropriate in order to prevent an entity from
intentionally structuring short term leases.
The proposal would be agreeable if the definition of a short term lease is consistent with thatof a lease term (i.e. options are included if the lessee has a significant economic incentive.).
OthersTotal

23

Using no leases

172(73.2%)

15(83.3%)

37(15.7%)1(5.6%)

22(9.4%)0(0.0%)

4(1.7%)

2(11.1%)235(100.0%)18(100.0%)

c. Type of underlying assets used by respondents who use leases (the valid respondents; 235)

Both property & others
The proposal for a short term lease is appropriate from thestandpoint of costs and benefits.
The proposal is appropriate in order to prevent an entity from
intentionally structuring short term leases.
The proposal would be agreeable if the definition of a short term lease is consistent with thatof a lease term (i.e. options are included if the lessee has a significant economic incentive.).

152(72.4%)20(80.0%)33(15.7%)4(16.0%)21(10.0%)1(4.0%)

4(1.9%)

0(0.0%)

210(100.0%)25(100.0%)

Others
Total

Only property

5. Accounting for a lease of a non-core asset(1) Accounting for a lease of a non-core asset (the valid respondents; 1,223)

Respondents

Share

Disagree to the proposal in the re‐ED.

1,067

87.2%

Agree to the proposal in the re‐ED.

156

12.8%

Total

1,223

100.0%

a. Public/Non-public companies (the valid respondents; 1,223)

Public companies
430(84.8%)77(15.2%)
507(100.0%)

Disagree to the proposal in the re‐ED.
Agree to the proposal in the re‐ED.
Total

Non‐public companies
637(89.0%)79(11.0%)716(100.0%)

b. Companies using leases/companies using no leases (the valid respondents; 1,194)

Using leases979(87.6%)
139(12.4%)
1,118(100.0%)

Disagree to the proposal in the re‐ED.
Agree to the proposal in the re‐ED.
Total

Using no leases
64(84.2%)
12(15.8%)
76(100.0%)

c. Type of underlying assets used by respondents who use leases (the valid respondents; 1,118)

Both property & others
900(87.9%)124(12.1%)
1,024(100.0%)

Disagree to the proposal in the re‐ED.
Agree to the proposal in the re‐ED.
Total

Only property
79(84.0%)15(16.0%)94(100.0%)(2) The reasons for disagreeing to the proposal (the number of the valid respondents; 1,061)

Respondents
It is appropriate to apply the current operating lease accounting to a lease of anon‐core asset.
There would be practical difficulties without any practical relief in which an entity isable to determine whether the proposals should be applied to its leases based on
the materiality threshold set by the entity.
Others
Total

24

Share

618

58.2%

434

40.9%

9

0.8%

1,061

100.0%

a. Public/Non-public companies (the valid respondents; 1,061)

It is appropriate to apply the current operating lease accounting to alease of a non‐core asset.
There would be practical difficulties without any practical relief in which anentity is able to determine whether the proposals should be applied to its
leases based on the materiality threshold set by the entity.

Public companies

Non‐public companies

223(52.2%)395(62.3%)200(46.8%)234(36.9%)4(0.9%)

5(0.8%)

427(100.0%)634(100.0%)

OthersTotal

b. Companies using leases/companies using no leases (the valid respondents; 1,037)

Using leases
It is appropriate to apply the current operating lease accounting to alease of a non‐core asset.
There would be practical difficulties without any practical relief in which anentity is able to determine whether the proposals should be applied to its
leases based on the materiality threshold set by the entity.

563(57.9%)

37(57.8%)404(41.5%)25(39.1%)6(0.6%)

2(3.1%)

973(100.0%)64(100.0%)

Others
Total

Using no leases

c. Type of underlying assets used by respondents who use leases (the valid respondents; 969)

Both property & others
It is appropriate to apply the current operating lease accounting to alease of a non‐core asset.
There would be practical difficulties without any practical relief in which anentity is able to determine whether the proposals should be applied to its
leases based on the materiality threshold set by the entity.

522(58.6%)41(52.6%)

367(41.2%)

37(47.4%)2(0.2%)

0(0.0%)

891(100.0%)78(100.0%)

Others
Total

Only property(3) The reasons for agreeing to the proposal (the number of the valid respondents; 151)

Respondents
There should be no exception for a lease of non‐core asset.

Share

66

43.7%

53

35.1%

26

17.2%

Others

6

4.0%

Total

151

100.0%

There is no need to provide a specified accounting because the IFRS allows an entity to determine whether
the proposals in the re‐ED should be applied to its leases by itself based on the materiality threshold set by
the entity.
There is no need to provide any exception because any numerical threshold would
be complex to apply.

25

a. Public/Non-public companies (the valid respondents; 151)

There should be no exception for a lease of non‐core asset.
There is no need to provide a specified accounting because the IFRS allows anentity to determine whether the proposals in the re‐ED should be applied toits leases by itself based on the materiality threshold set by the entity.
There is no need to provide any exception because any numericalthreshold would be complex to apply.
Others
Total

Public companies

Non‐public companies

34(45.3%)

32(42.1%)

32(42.7%)21(27.6%)5(6.7%)

21(27.6%)4(5.3%)

2(2.6%)

75(100.0%)76(100.0%)

b. Companies using leases/companies using no leases (the valid respondents; 146)

Using leases
There should be no exception for a lease of non‐core asset.

Using no leases

59(43.4%)

5(50.0%)51(37.5%)2(20.0%21(15.4%)

3(30.0%)

Others5(3.7%)

0(0.0%)

Total

136

10

There is no need to provide a specified accounting because the IFRS allows anentity to determine whether the proposals in the re‐ED should be applied toits leases by itself based on the materiality threshold set by the entity.
There is no need to provide any exception because any numericalthreshold would be complex to apply.

c. Type of underlying assets used by respondents who use leases (the valid respondents; 136)

Both property & others
There should be no exception for a lease of non‐core asset.
There is no need to provide a specified accounting because the IFRS allows anentity to determine whether the proposals in the re‐ED should be applied toits leases by itself based on the materiality threshold set by the entity.
There is no need to provide any exception because any numericalthreshold would be complex to apply.
OthersTotal

26

Only property

53(43.8%)6(40.0%)44(36.4%)7(46.7%)19(15.7%)2(13.3%)5(4.1%)

0(0.0%)

121(100.0%)25(100.0%)