a.

Do you agree with the two categories we identified and the five strategic areas within them? If you disagree, how do you think the IASB should develop its agenda, and why?

While the categories and strategic areas provide a convenient segmentation of the potential agenda items, of themselves they do not guide agenda decisions. The Agenda Consultation and the process would be enhanced if it provided some guidance or clarity around the IASB's views on the relative importance of each strategic area.

The G100 considers that the IASB should, as part of its response to the Agenda Consultation, develop a framework that discusses the relative importance of each of the five strategic areas.

In the view of the G100, the main focus of the IASB should be on standards-level projects, the conceptual and disclosure frameworks, and post- implementation reviews. The latter is an important part of understanding how to better develop new standards and avoid unintended consequences, and whether the effects analysis appropriately captured relevant effects.

The G100 believes that the current emphasis on implementation needs would be minimized by the use of more comprehensive effects analysis and field testing.

The G100 does not consider that the two categories need to be considered independently of each other. The important aspect of agenda setting is to select projects and allocate priorities and resources which best meet the objective of improving the quality of financial reporting. As such, the categorisations may be useful but should not be conclusive.

b.

How would you balance the two categories and five strategic areas? If you have identified other areas for the IASB's agenda, please include these in your answer.

Refer 1a.

In addition, as indicated in our response to the Trustee's Strategy Review, integration of XBRL should not influence the content of IFRSs on the grounds that XBRL is merely a service activity to facilitate the use of IFRS information.

a.

Considering the various constraints, to which projects should the IASB give priority, and why? Where possible, please explain whether you think that a comprehensive project is needed or whether a narrow, targeted improvement would suffice?

The G100 believes that the IASB should complete its existing major projects before embarking on new projects.

The G100 suggests that the following project be given priority:

Development of a conceptual framework, including a disclosure framework. We believe that agreement on a conceptual framework will help resolve many of the issues, particularly those raised in respect of cross cutting issues and gaps and deficiencies in present IFRSs and would be expected to result in fewer demands on the IASB to provide guidance and fewer instances of re-exposures etc of consultation documents. However, we acknowledge that it is impractical to expect that work on other projects will cease until the conceptual framework is agreed and, as such, the IASB should also be addressing other significant needs.

The existence of a conceptual framework also provides a significant discipline for the standard-setter. For example, where the standard-setter departs from the framework it needs to explain why such a departure is necessary to resolve an issue and whether the framework itself needs to be amended in some way.

Initially, the disclosure aspect of such a project could be based on the work undertaken by the NZICA and ICAS, in particular, and that being undertaken by the FASB and EFRAG. In addition, the developing practice of companies reporting underlying earnings and other measures, principally in response to meeting the needs of shareholder and other users, raises questions about the nature and volume of the current disclosure and presentation requirements and whether information is prepared on the basis of IFRSs enables directors to communicate the performance of their companies to shareholders and other users. The continuation of these practices serves to erode the benefits of adopting IFRSs.

OTHER PROJECTS

The G100 has selected the following projects based on the principle that the IASB should concentrate on projects that have the most impact on financial reporting:

Other Comprehensive Income: The G100 classifies this project as a 'standards level project'. Although 'Other comprehensive income' is a significant component of most financial statements there is little clarity around its use, and little understanding of its importance, in the user community. The G100 believes that further work is needed to make the use of 'other comprehensive income' more robust and better understood.

Financial Statement Presentation: This topic, which has been on the IASB agenda for some time, is closely aligned to 'other comprehensive income', and is a standards level project. The project has the potential to improve considerably the understanding of the current mixed measurement model.

The G100 also believes that the IASB should:

• further develop its work on accounting for emissions trading schemes as several countries have emissions trading schemes in operation or, as in Australia, have foreshadowed their introduction. Because of the nature of some schemes it is suggested that accounting for government grants could be considered as part of this project;
  
• maintain its involvement in the evolution of integrated reporting in view of the guidance issued in relation to management discussion and analysis; and
  
• maintain the capacity to respond promptly to evolving issues and the need for clarifying and interpreting IFRSs as a result of post-implementation reviews and experiences of the preparers, users and regulators.
  
  

b.

Adding new projects to the IASB's agenda will require the balancing of agenda priorities with the resources available. Which of the projects previously added to the IASB's agenda but deferred do you think should be reactivated and why? Please link your answer to your answer to Q2a.

See response to Q2a.

The G100 supports the move by the IASB towards undertaking post-implementation reviews of its standards. However, we believe that the scope of such reviews should not be limited to those major IFRSs developed by the IASB. Rather, there is extensive experience with, say, IFRS 2 "Share-based Payment' and a number of "old" IASs, for example, the treatment of bearer biological assets under IAS 41 'Agriculture' which would support a review to determine the nature and extent of any issues which need to be addressed and whether the standards need to be updated to ensure consistency with the conceptual framework.