Submission to the IASB - Disclosures - "Less is more"

4 November 2009

Sir David Tweedie
Chairman
International Accounting Standards Board
30 Cannon Street
London EC 4M 6XH
UNITED KINGDOM
commentletters@iasb.org.uk

Dear Sir David

Disclosures - "Less is More"

The Group of 100 (G100) is an organization of chief financial officers from Australia’s largest business enterprises with a purpose of advancing Australia’s financial competitiveness.

The G100 is pleased to present a paper “Less is More” which outlines principles that we believe should be applied by standard-setters when developing disclosure requirements in accounting standards.

The paper has been prepared, with the assistance of PricewaterhouseCoopers, in response to your invitation at the G100/FRC Workshop ‘The IFRS Experience in Australia’ in August 2008. At that Workshop concerns were expressed about the detail, complexity and volume of disclosures required in financial reports and their perceived usefulness to users.

The principles are currently being ‘roadtested’ by a number of member organizations. We will inform you of these results when the testing is completed.

As indicated in the paper, the G100 believes that now is an appropriate time to consider a principles-based framework to be used by standard-setters for assessing current disclosures when standards are being reviewed/revised and in developing new disclosure requirements.

In advancing these views the G100 is encouraged by recent developments such as the initiation of a disclosure framework project by the FASB and the paper developed by the FRC in the United Kingdom “Louder than Words” and believes that a similar project should have a high priority on the IASB’s active work program. A copy of this paper will also be sent to the FASB for consideration in the development of its project.

Please do not hesitate to contact me if you need any further information about, or assistance with, this project.

While we appreciate the current pressures and workload of the IASB your feedback on the principles would be greatly appreciated.

Yours sincerely

Tony Reeves
National President