Document ID: chunk:federal_register_of_legislation:F2025C00209:reg:221:p18
Version: federal_register_of_legislation:F2025C00209
Segment Type: reg
Provision Reference: reg 221 (pt 18/73)
Character Range: 212542–215511

AASB 124 Related Party Disclosures and AASB 136 Impairment of Assets.

      3.             After issuing ITC 39, the Board held targeted outreach with key stakeholders, including State, Territory and National regulators, audit offices, accounting firms, the Australian Securities Exchange (ASX), the Australian Taxation Office (ATO), the Australian Securities and Investments Commission (ASIC), credit rating agencies and professional bodies. The ITC 39 proposals were also presented at various forums, workshops, roundtables and discussion groups.

      4.             The Board received feedback on its proposals in ITC 39 through 33 formal comment letters from professional service firms, regulators, professional bodies, academics, preparers, users of financial statements and other respondents. Furthermore, feedback was sought via targeted user and preparer surveys in quarter 3 of 2018, which received a total of 37 user and 49 preparer responses[48]. The surveys were focussed on the specific matters for comment in ITC 39, and were used to get a better understanding of which of the Tier 2 GPFS frameworks proposed in ITC 39 users preferred (and why), as well as what transitional relief would be helpful to preparers.

      5.             The feedback on the proposed SDR framework was that the SDR had too many disclosures in some ways but fell short in many other ways. For example, the feedback received from roundtables, surveys and submissions on ITC 39 was that whilst the disclosures in SDR are important, requiring full disclosure of those nine Standards (as explained in paragraph BC13) was too much. Most participants further suggested that SDR might not be appropriate for all industry sectors and is missing some critical disclosures to help predict the viability of an entity such as liquidity, contingent liabilities, subsequent events and commitment disclosures.

      6.             At the same time, respondents noted that refining the principles used in determining the level of disclosures required for Tier 2 entities to achieve an appropriate balance between the benefits of financial information to users and the costs to preparers of providing that information is crucial. The feedback from the roundtables, surveys and submissions on ITC 39 indicated that RDR has too many disclosure requirements.

Revisiting the proposals in ED 277

      1.             The RDR disclosure requirements in Australia and New Zealand are essentially the same and are based on an approach developed by the Board in 2010. That approach draws on the disclosure requirements in the IFRS for SMEs Standard when Tier 2 R&M requirements are the same as those under the IFRS for SMEs Standard; and applies the 'user needs' and 'cost-benefit' principles applied by the IASB in developing its IFRS for SMEs Standard when full R&M requirements are not the same as those available under the IFRS for SMEs Standard. A top-down approach is used which starts with