ASCG comments on IASB ED/2022/1 

Today the ASCG submitted its comment letter on IASB ED/2022/1 Third edition of the IFRS for SMEs Accounting Standard.

Due to the limited relevance of the standard and thus also of the draft amendment from a German perspective, the FR Technical Committee decided to refrain from comprehensively commenting on the ED. Instead, the focus is on issues that are linked to other standard-setting activities, in particular with regard to ED/2021/7 Subsidiaries without Public Accountability: Disclosures.

The proposed clarification of the scope of application for entities without public accountability is viewed positively in relation to the IFRS for SMEs.

However, the scope linkage with the standard arising from ED/2021/7 Subsidiaries without Public Accountability: Disclosures is seen as problematic; in that standard, the scope should instead be defined independently. When defining this scope, the criterion of ‘fiduciary capacity’ should be softened or, if possible, completely eliminated. Furthermore, we suggest developing further simplification criteria by combining the criterion of public accountability with size-related thresholds.