ASCG’s response on the EU Fitness check on the EU framework for public reporting by companies

The ASCG participated in the EU Public consultation Fitness check on the EU framework for public reporting by companies.

Our final answers to the questions asked in the consultation document, including an accompanying letter summarizing the main messages of our answers, can be found here.

Although we are in favour of the fitness check in principle, we are critical regarding some elements of this consultation. We do not see any convincing arguments for undertaking a further review of the IAS Regulation a few years after the last evaluation and strongly oppose the idea to allow for modifications of IFRSs as issued by the IASB in the course of or even after the endorsement process.

Furthermore, we suggest that the EU enlarge the scope of the review to include supervisory disclosure requirements in order to eliminate existing overlaps and duplication of those requirements with accounting legislation. Equally, we suggest including the Level 2 and Level 3 requirements in the fitness check, because contradictions and inconsistencies do exist here in particular.

The ASCG also advises the European Commission not to undertake any short-term activities concerning the Bank Accounts Directive, the Insurance Accounts Directive, and non-financial reporting but to monitor the developments and carefully consider the available evidence instead.