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ISCA comments on IASB’s ED on Subsidiaries Without Public Accountability: Disclosures

Although we appreciate IASB’s efforts to develop a new IFRS Standard with reduced disclosure requirements for eligible subsidiaries without public accountability to help them save costs while maintaining the relevance and usefulness of the financial statements to users, we have received mixed views regarding the practicability of the proposed Standard.

We highlighted the following potential benefits we envisage (in addition to those set out in the ED) and concerns on the proposed Standard:

Potential benefits

  • Aid parent in having better control over subsidiaries in terms of information retention and record keeping
  • Benefit subsidiaries which are not required to submit group reporting packages but are required to prepare statutory financial statements


  • Potential low adoption rate
  • Narrow eligibility scope
  • Additional information disclosed may not be useful or relevant to users of financial statements belonging to subsidiaries that cease to be eligible at the end of the reporting period
  • Result in two different approaches to disclosures within IFRSs

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