i for-profit private sector entities that are do not have public accountability;
ii not-for-profit private sector entities; and
iii public sector entities, other than those required by the AASB to apply Tier 1

The G100 believes that the approach adopted to identify entities to which Tier 2 would apply is reasonable. However, it is suggested that government business enterprises should be included in those public sector entities required to apply Tier 1.

It is not clear from the proposals whether private equity entities would be Tier 1 or Tier 2 entities. The G100 believes that a competitive advantage may be conferred on such entities in the event that they are Tier 2 entities. The G100 feels strongly that private equity entities should be included in Tier 1. The concept of an ‘equal playing field’ should apply to ensure adequate disclosure by entities (whether listed or privately owned) is provided for all interested parties in addition to shareholders.
 

Yes. The G100 believes that relief from the disclosure load based on the disclosures required by the IFRS for SMEs standard is appropriate in the Australian environment rather than directly adopting the IASB standard.

The G100 strongly believes that all general purpose financial reports should be prepared in accordance with a common set of recognition and measurement requirements in order to maintain the integrity of financial reporting. We consider that it is important that measures of profit or loss, assets and liabilities and ratio measures based on them are made on a consistent basis. It is unacceptable for the profit or loss of an entity to be determined on a different basis depending on whether the entity is subject to Tier 1 or Tier 2.
 

The G100 considers that the definition of public accountability developed by the AASB, while consistent with the principles on which the definition in ‘IFRS for SMEs’ is based, better captures entities in the Australian environment.
 

Yes. The G100 believes that government business enterprises should be Tier 1 entities because of their commercial significance and their participation in markets in competition with private sector entities.
 

The G100 believes that the meaning of GPFSs is clarified and agrees that a GPFS should only be described as such where it is prepared in accordance with the applicable accounting standards. The G100 also agrees with the modification of the reporting entity concept.
 

The G100 believes that the disclosures removed for Tier 2 entities are unlikely to impair the ability of users of the financial statements of these entities to make informed assessments about the entity.

We believe that many of the disclosures such as those relating to financial instruments, risk and liquidity and reconciliations such as those required for intangible assets and property, plant and equipment and share-based payment disclosures could also be removed for Tier 1 entities without adversely affecting the information content for users.

However, we suggest that the requirements of para 37 be discussed and given prominence in the Preface to the proposed Standard and the Basis for Conclusions.
 

(i) have been retained in the RDR that you consider should be excluded from the RDR, and your reasons for exclusion;

(ii) have been excluded from the RDR that you consider should be retained, and your reasons for retention

We note that the proposed RDR regime provides for a greater level of disclosure than that required by IFRS for SMEs and do not understand why disclosure relief for Australian entities is not as extensive as that in jurisdictions that have adopted IFRS for SMEs.
 

The G100 supports the transitional requirements. However, in respect of those entities not currently preparing GPFSs simplification of the disclosure requirements of AASB 1 may be necessary.
 

We are not aware of any impediments to adopting the proposals.
 

Yes. The G100 believes that the application of proposals would reduce the costs for TIER 2 entities and would not adversely affect the users of these financial statements.
 

Yes.