The G100 agrees that the issue of a non-mandatory guidance document is preferable because the requirement for management commentary style reports is often a separate requirement of national legislation and stock exchange listing requirements. This is the case in Australia where providing a review of operations and financial condition is a listing requirement and a legislative requirement (Corporations Act 2001 Section 299) for listed companies. {In December 2009 the Government released draft amendments to the Corporations Law to require all listed entities to provide a review of operating results, financial position and business strategies and prospects}. The frequency of reporting and the level of assurance required should also be determined at the national level.

A guidance document can establish high level principles to inform preparers of what constitutes the basis of good practice and the interaction with the financial statements.
 

Yes. The items are broadly consistent with the guidance provided in the G100 publication ‘Guide to Review of Operations and Financial Condition’ (www.group100.com.au) and provide high-level principles-based guidance. However, the G100 suggests that the guidance should also highlight the usefulness of discussion of matters such as shareholder returns, liquidity and funding, the impacts of legislation and investments for future performance.
 

Yes. The G100 agrees with the reasons advanced for not including application guidance and illustrative examples. We believe that, if needed, national bodies and industry associations can develop more detailed guidance on the application of high-level principles to entities operating in their industry or jurisdiction.