ASCG comments on proposed amendments to IFRS 17

The ASCG today sent its final comment letter on the IASB draft ED/2019/4 (Proposed Amendments to IFRS 17) to the IASB and to EFRAG with the same wording.

In this letter, we welcome the extraordinary efforts of the IASB and therefore strongly support the proposed amendments. We also agree with the IASB’s premise that any amendments to IFRS 17 should not disrupt current implementation. Although any delays would entail considerable additional costs for stakeholders, we consider it appropriate to defer the effective date by one year. A postponement beyond that would, however, be questionable from the point of view of our stakeholders.

With regard to the proposed changes, we consider the following to warrant further consideration:

• the proposals concerning reinsurance contracts, which, while going in the right direction, overly and unnecessarily narrow the range of types of contracts benefiting from the change (see our reply to Q4, Annex A to the opinion);
• eligibility for applying the retrospective transitional method, whereby the wording could be tightened up (see reply to Q8); and
• the proposals for minor changes where we identify some need for clarification or improvement (see Q9 reply).

With regard to the issues for which the IASB does not propose amendments, we fundamentally agree with the IASB’s decisions and motives. However, with regard to the topics “annual cohorts” (BC164 et seq.), business combinations (BC204 et seq.), interim reports (BC214 et seq.) and comparative figures  (BC117 et seq.), we acknowledge the IASB’s reasoning, but in our opinion it does not adequately consider cost-benefit concerns. We therefore encourage a reconsideration of these issues (see our comments in Appendix B of the comment letter).