Document ID: chunk:federal_register_of_legislation:F2023C00381:reg:25:p38
Version: federal_register_of_legislation:F2023C00381
Segment Type: reg
Provision Reference: reg 25 (pt 38/47)
Character Range: 129402–132719

number of entities moving from SPFS indicated that the costs of RDR were seen to outweigh the benefits for these entities. However, in comparison to Tier 1 GPFS there was some benefit as 13% had voluntarily moved to RDR. Respondents felt that something in between the RDR and SDR framework would better satisfy user needs and suggested a more balanced approach to disclosures was needed;

          (e)                    there is widespread uncertainty on whether AASB 1 provides enough transitional relief to facilitate the transition from SPFS to Tier 2 GPFS (in whatever form that may take);

          (f)                    only one Tier 2 GPFS framework is necessary for for-profit private sector entities, given the entities required to prepare and in some cases publicly lodge financial statements is such a small proportion of actively trading entities, however some respondents were concerned that the proposals were not also considering who should be publicly lodging financial statements, noting in particular that the thresholds used from determining what constitutes a large proprietary company had not been reviewed for a number of years;

          (g)                   there were no clear views on what additional transitional relief, is needed;

          (h)                   respondents were concerned about the effect of the proposals on entities with a non-legislative requirement to prepare financial statements that comply with AAS (ie entities with trust deeds and other constituting documents inadvertently requiring compliance with AAS). Respondents were also concerned about the complexities and the potential costs involved in changing such documents;

          (i)                     a small number of respondents wanted the AASB to further consider the International Financial Reporting Standard for Small and Medium-sized Entities (IFRS for SMEs Standard) as an optional Tier 2 GPFS framework alternative or as the Tier 2 GPFS framework;

          (j)                     a small number of respondents asked for a financial reporting framework for those entities not required by legislation to prepare or lodge financial statements; and

          (k)                   some respondents thought more evidence of user needs was required.

     BC59            Subsequent to receiving comments on ITC 39, all formal comment letters were made available to the public via the AASB website.[32] Summaries of feedback obtained from various outreach events, results from user and preparer surveys, and agenda papers for AASB Board meetings were also made available via the AASB website.

     BC60            The Board decided to proceed with Phase 2 and resolve the issues with SPFS after considering:

          (a)                    the responses from financial statement users, preparers and other stakeholders during the public consultation period, including over 200 targeted discussions;

          (b)                   the findings in AASB Research Reports and commissioned academic research;

          (c)                    the level of voluntary compliance with ASIC RG 85;

          (d)                   the low number of entities moving from SPFS to RDR;

          (e)                    the results of user and preparer surveys;

          (f)                    the