ASCG comments on IASB DP/2017/1 Disclosure Initiative – Principles of Disclosure

Today, the ASCG submitted its comment letter on the discussion paper DP/2017/1 Disclosure Initiative – Principles of Disclosure to the IASB. Additionally, the ASCG submitted a comment letter to EFRAG on additional questions raised by EFRAG in context of the discussion paper.

The ASCG generally agrees with the description of the disclosure problem in the discussion paper and disagrees with EFRAGs tentative view that the description of the disclosure problem in the discussion paper does not give sufficient emphasis to the problem of disclosure overload. Nonetheless, the ASCG shares the tentative view from EFRAG, that the IASB should undertake a comprehensive standards-level review in a holistic manner to remove the issues in current IFRS guidance that have contributed to the disclosure problem.

Beside its response to the detailed questions in the discussion paper, the ASCG raises the concern that some relevant issues were not addressed in the discussion paper in light of effective and efficient communication. Particularly, the discussion about the granularity of disclosure requirements in IFRSs and the discussion about the impact of electronic reporting on IFRS disclosure guidance are missing in the IASB paper