ASCG comment letter on the proposed amendments to the Due Process Handbook

Today, the ASCG has submitted to the IFRS Foundation a comment letter in response to the Exposure Draft for proposed amendments to the Due Process Handbook (DPH).

We generally support the idea of reflecting the ISSB and its work on IFRS sustainability standards in the DPH. In particular, we agree with making the due process for the IASB, which has been successfully established and has been carefully improved whenever experience suggested to do so, equally applicable for the ISSB. In this regard, we generally support the proposals. We also agree with the proposals in respect of the interaction of the two boards, reflecting connectivity. We fully agree with the idea that both boards operate basically independent, however liaising when helpful, while following identical rules and procedures.

Further, we support the proposals for clarifying or amending other specific aspects of the DPH, eg. as regards post-implemention reviews, minor amendments and supporting material. Notwithstanding this general consent, we have some reservations to the DPH requirements in respect of deciding whether, and why, application questions could or should lead to standard-setting. In particular, we feel there is some ambiguity as to when and why findings from post-implemention reviews or from IFRS IC discussions do (or do not) warrant, or require, standard-setting activities.

Our comment letter has also been submitted to the EFRAG.