IASB EDs & ISCA Comments Letters

ISCA actively undertakes public consultation with its members and stakeholders to gather feedback on matters such as proposals in Exposure Drafts/Discussion Papers/Requests for Information issued by the International Accounting Standards Board (IASB).

All responses should be sent to professionalstandards@isca.org.sg by the respective due dates as indicated below.


TitleComment due byISCA’s Comment Letters to IASB
Exposure Draft IASB/ED/2024/7 Equity Method of Accounting—IAS 28 Investments in Associates and Joint Ventures (revised 202x)20 November 2024 
Exposure Draft IASB/ED/2024/6 Climate-related and Other Uncertainties in the Financial Statements (Proposed illustrative examples)10 October 2024 
Exposure Draft IASB/ED/2024/5 Amendments to IFRS 19 Subsidiaries without Public Accountability: Disclosures9 October 2024 
Exposure Draft IASB/ED/2024/4 Translation to a Hyperinflationary Presentation Currency (Proposed amendments to IAS 21)4 October 2024 
Exposure Draft IASB/ED/2024/3 Contracts for Renewable Electricity (Proposed amendments to IFRS 9 and IFRS 7)21 June 2024
(Closed)		Comment letter on Contracts for Renewable Electricity (Proposed amendments to IFRS 9 and IFRS 7)
Exposure Draft IASB/ED/2024/1 Business Combinations—Disclosures, Goodwill and Impairment (Proposed amendments to IFRS 3 and IAS 36)7 June 2024
(Closed)
Comment letter on Business Combinations—Disclosures, Goodwill and Impairment (Proposed amendments to IFRS 3 and IAS 36)

Past Comment Letters to IASB

TitleISCA’s Comment Letters to IASB
Exposure Draft IASB/ED/2023/5 Financial Instruments with Characteristics of Equity—Proposed amendments to IAS 32, IFRS 7 and IAS 1 Comment letter on Financial Instruments with Characteristics of Equity—Proposed amendments to IAS 32, IFRS 7 and IAS 1
IASB’s Exposure Draft Annual Improvements to IFRS Accounting Standards — Volume 11 Comment letter on Annual Improvements to IFRS Accounting Standards — Volume 11
IASB’s Post-implementation Review of IFRS 15 Revenue from Contracts with Customers Comment letter on Post-implementation Review of IFRS 15 Revenue from Contracts with Customers
Exposure Draft IASB/ED/2023/3 International Tax Reform—Pillar Two Model Rules Proposed amendments to the IFRS for SMEs Standard -
IASB’s Post-implementation Review IFRS 9 Financial Instruments Impairment  Comment letter on Post-implementation Review IFRS 9 Financial Instruments Impairment
Exposure Draft ED/2023/2 Amendments to the Classification and Measurement of Financial Instruments (Proposed amendments to IFRS 9 and IFRS 7) Comment letter on Amendments to the Classification and Measurement of Financial Instruments (Proposed amendments to IFRS 9 and IFRS 7)
Exposure Draft ED/2023/1 International Tax Reform—Pillar Two Model Rules (Proposed amendments to IAS 12)
 Comment letter on International Tax Reform—Pillar Two Model Rules (Proposed amendments to IAS 12)

TitleISCA’s Comment Letters to IASB
Exposure Draft ED/2021/10 Supplier Finance Arrangements (Proposed amendments to IAS 7 and IFRS 7)Comment letter on Supplier Finance Arrangements (Proposed amendments to IAS 7 and IFRS 7)
Exposure Draft ED/2021/9 Non-current Liabilities with Covenants Proposed amendments to IAS 1Comment letter on Non-current Liabilities with Covenants Proposed amendments to IAS 1
IASB Post-implementation Review IFRS 9 Financial Instruments Classification and MeasurementComment letter on IASB Post-implementation Review IFRS 9 Financial Instruments Classification and Measurement
Exposure Draft ED/2021/8 Initial Application of IFRS 17 and IFRS 9—Comparative Information (Proposed amendment to IFRS 17)Comment letter on Initial Application of IFRS 17 and IFRS 9—Comparative Information (Proposed amendment to IFRS 17)
Exposure Draft ED/2021/7 Subsidiaries without Public Accountability: DisclosuresComment letter on Subsidiaries without Public Accountability: Disclosures
Exposure Draft ED/2021/6

Management Commentary

Basis for Conclusions: Management Commentary

 		-
Exposure Draft ED/2021/4 Lack of Exchangeability (Proposed amendments to IAS 21)Comment letter on Lack of Exchangeability (Proposed amendments to IAS 21) 
Exposure Draft ED/2021/3

Disclosure Requirements in IFRS Standards—A Pilot Approach (Proposed amendments to IFRS 13 and IAS 19)

Snapshot: Disclosure Requirements in IFRS Standards—A Pilot Approach

Basis for Conclusions: Disclosure Requirements in IFRS Standards—A Pilot Approach (Proposed amendments to IFRS 13 and IAS 19)

Comment letter on Disclosure Requirements in IFRS Standards—A Pilot Approach (Proposed amendments to IFRS 13 and IAS 19)
Request for Information: Third Agenda ConsultationComment letter on Request for Information: Third Agenda Consultation
Exposure Draft ED/2021/1

Regulatory Assets and Regulatory Liabilities

Illustrative Examples: Regulatory Assets and Regulatory Liabilities

Basis of Conclusions: Regulatory Assets and Regulatory Liabilities

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IASB Post-implementation Review - IFRS 10 Consolidated Financial Statements, IFRS 11 Joint Arrangements & IFRS 12 Disclosure of Interests in Other Entities Comment letter on IASB Post-implementation Review - IFRS 10 Consolidated Financial Statements, IFRS 11 Joint Arrangements & IFRS 12 Disclosure of Interests in Other Entities
Exposure Draft ED/2021/2 Covid-19-Related Rent Concessions beyond 30 June 2021 (Proposed amendment to IFRS 16)Comment letter on Covid-19-Related Rent Concessions beyond 30 June 2021 (Proposed amendment to IFRS 16)
TitleISCA’s Comment Letters to IASB
Discussion Paper DP/2020/2 Business Combinations under Common Control Comment letter on Business Combinations under Common Control
Exposure Draft ED/2020/4 Lease Liability in a Sale and Leaseback (Proposed amendments to IFRS 16) Comment letter on Lease Liability in a Sale and Leaseback (Proposed amendments to IFRS 16)
Exposure Draft ED/2020/3 Classification of Liabilities as Current or Non-current (Deferral of Effective Date) (Proposed amendment to IAS 1) Comment letter on Classification of Liabilities as Current or Non-current (Deferral of Effective Date) (Proposed amendment to IAS 1)
Exposure Draft ED/2020/2 Covid-19-Related Rent Concessions
(Proposed amendment to IFRS 16)		 Comment letter on Covid-19-Related Rent Concessions (Proposed amendment to IFRS 16)
Exposure Draft ED/2020/1 Interest Rate Benchmark Reform - Phase 2
(Proposed amendments to IFRS 9, IAS 39, IFRS 7, IFRS  4 and IFRS 16)		 Comment letter on Interest Rate Benchmark Reform - Phase 2  (Proposed amendments to IFRS 9, IAS 39, IFRS 7, IFRS  4 and IFRS 16)
Discussion Paper DP/2020/1  Business Combinations – Disclosures, Goodwill and Impairment Comment Letter on Business Combinations – Disclosures, Goodwill and Impairment
TitleISCA’s Comment Letters to IASB
Exposure Draft ED/2019/7 

General Presentation and Disclosures

Illustrative Examples: General Presentation and Disclosures

 Comment Letter on General Presentation and Disclosures
Exposure Draft ED/2019/6 Disclosure of Accounting Policies (Proposed amendments to IAS 1 and IFRS Practice Statement 2) Comment Letter on Disclosure of Accounting Policies (Proposed amendments to IAS 1 and IFRS Practice Statement 2)
Exposure Draft ED/2019/5 Deferred Tax related to Assets and Liabilities arising from a Single Transaction (Proposed amendments to IAS 12) Comment Letter on Deferred Tax related to Assets and Liabilities arising from a Single Transaction (Proposed amendments to IAS 12)
Exposure Draft ED/2019/4 Amendments to IFRS 17 Comment Letter on Amendments to IFRS 17
Exposure Draft ED/2019/3 Reference to the Conceptual Framework (Proposed amendments to IFRS 3) Comment Letter on Reference to the Conceptual Framework (Proposed amendments to IFRS 3)
Exposure Draft ED/2019/2 Annual Improvements to IFRS® Standards 2018–2020 Comment Letter on Annual Improvements to IFRS 2018-2020
Exposure Draft ED/2019/1 Interest Rate Benchmark Reform (Proposed amendments to IFRS 9 and IAS 39) Comment Letter on Interest Rate Benchmark Reform (Proposed amendments to IFRS 9 and IAS 39)
Draft IFRIC Interpretation Tentative agenda decision—Over time transfer of constructed good Comment Letter on Tentative agenda decision—Over time transfer of constructed good
TitleISCA’s Comment Letters to IASB
Exposure Draft ED/2017/6 Definition of Material (Proposed amendments to IAS 1 and IAS 8)Comment Letter on Definition of Material (Proposed amendments to IAS 1 and IAS 8)
Exposure Draft ED/2017/5 Accounting Policies and Accounting Estimates (Proposed amendments to IAS 8)Comment Letter on Accounting Policies and Accounting Estimates (Proposed amendments to IAS 8)
Exposure Draft ED/2017/4 Property, Plant and Equipment–Proceeds before Intended Use (Proposed amendments to IAS 16)Comment Letter on Property, Plant and Equipment–Proceeds before Intended Use (Proposed amendments to IAS 16)
Post-implementation Review—IFRS 13 Fair Value Measurement -
Discussion Paper DP/2017/1 Disclosure Initiative—Principles of Disclosure  -
Exposure Draft ED/2017/2 Improvements to IFRS 8 Operating Segments (Proposed amendments to IFRS 8 and IAS 34)Comment Letter on Improvements to IFRS 8 Operating Segments (Proposed amendments to IFRS 8 and IAS 34)
Exposure Draft ED/2017/3 Prepayment Features with Negative Compensation (Proposed amendments to IFRS 9)  -
Exposure Draft ED/2017/1 Annual Improvements to IFRS® Standards 2015–2017 Cycle Comment Letter on Annual Improvements to IFRS® Standards 2015–2017 Cycle
TitleISCA’s Comment Letters to IASB
Exposure Draft ED/2015/11 Applying IFRS 9 Financial Instruments with IFRS 4 Insurance Contracts (Proposed amendments to IFRS 4)Comment Letter on Applying IFRS 9 with IFRS 4 Insurance Contracts (Proposed Amendments to IFRS 4)
Exposure Draft ED/2015/10 Annual Improvements to IFRSs 2014-2016 CycleComment Letter on Annual Improvements to IFRSs 2014-2016 Cycle
Exposure Draft ED/2015/9 Transfers of Investment Property (Proposed amendment to IAS 40) Comment Letter on Transfers of Investment Property (Proposed amendment to IAS 40)
Exposure Draft ED/2015/8 IFRS Practice Statement: Application of Materiality to Financial StatementsComment Letter on IFRS Practice Statement: Application of Materiality to Financial Statements
Draft IFRIC Interpretation DI/2015/2 Foreign Currency Transactions and Advance ConsiderationComment Letter on DI/2015/2 Foreign Currency Transactions and Advance Consideration 
Draft IFRIC Interpretation DI/2015/1 Uncertainty over Income Tax TreatmentsComment Letter on DI/2015/1 Uncertainty over Income Tax Treatments
Request for Views on IASB 2015 Agenda ConsultationComment Letter on Views on 2015 Agenda Consultation
Exposure Draft ED/2015/7  Effective Date of Amendments to IFRS 10 and IAS 28Comment letter on Effective Date of Amendments to IFRS 10 and IAS 28
Exposure Draft ED/2015/6  Clarifications to IFRS 15Comment letter on Clarifications to IFRS 15
Exposure Draft ED/2015/4 Updating References to the Conceptual Framework -
Exposure Draft ED/2015/4 Updating References to the Conceptual Framework -
Exposure Draft ED/2015/3 Conceptual Framework for Financial ReportingComment letter on Conceptual Framework for Financial Reporting
Exposure Draft ED/2015/2 Effective Date of IFRS 15 (Proposed amendments to IFRS 15)Comment letter on Effective Date of IFRS 15 (Proposed amendments to IFRS 15)
Exposure Draft ED/2015/1 Classification of Liabilities (Proposed amendments to IAS 1)
Comment letter on Classification of Liabilities (Proposed amendments to IAS 1)
TitleISCA’s Comment Letters to IASB
Exposure Draft ED/2014/6 Disclosure Initiative (Proposed amendments to IAS 7)Comment letter on Disclosure Initiative (Proposed Amendments to IAS 7)
Exposure Draft ED/2014/5 Classification and Measurement of Share-based Payment Transactions (Proposed amendments to IFRS 2)Comment letter on Classification and Measurement of Share-based Payment Transactions (Proposed amendments to IFRS 2)
Exposure Draft ED/2014/4 Measuring Quoted Investments in Subsidiaries, Joint Ventures and Associates at Fair ValueComment letter on Measuring Quoted Investments In Subsidiaries, Joint Ventures And Associates At Fair Value
Exposure Draft ED/2014/3 Recognition of Deferred Tax Assets for Unrealised Losses (Proposed amendments to IAS 12)
Comment letter on Recognition of Deferred Tax Assets for Unrealised Losses
Discussion Paper on Accounting for Dynamic Risk Management: A Portfolio Revaluation Approach to Macro Hedging
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Exposure Draft ED/2014/2 Investment Entities–Applying the Consolidation Exception (Proposed amendments to IFRS 10 and IAS 28)
Comment letter on Investment Entities: Applying the Consolidation Exemption (Proposed Amendments to IFRS 10 and IAS 28)
Exposure Draft ED/2014/1 Disclosure Initiative proposed amendments to IAS 1
Comment letter on Disclosure Initiative proposed amendments to IAS 1
Request for Information (RFI) Post-implementation on Review: IFRS 3 Business Combinations
Comment letter on Request for Information – Post-implementation Review: IFRS 3 Business Combinations
TitleISCA’s Comment Letters to IASB
Exposure Draft ED/2013/11 Annual Improvements to IFRSs 2012-2014 CycleComment letter on ED Annual Improvements to IFRSs 2012-2014 Cycle
Exposure Draft ED/2013/10 Equity Method in Separate Financial StatementsComment letter on ED Equity Method in Separate Financial Statements
Discussion Paper on A Review of the Conceptual Framework for Financial ReportingComment letter on Discussion Paper – A Review of the Conceptual Framework for Financial Reporting
Exposure Draft ED/2013/8 Agriculture: Bearer Plants Proposed amendments to IAS 16 and IAS 41Comment letter on Exposure Draft on Agriculture Bearer Plants
Exposure Draft ED/2013/7 Insurance Contracts, Illustrative Examples & Basis for ConclusionsJoint ASC ISCA Comment Letter Insurance Contracts
Exposure Draft ED/2013/6 Leases, Illustrative Examples & Basis for ConclusionsComment Letter Leases
Exposure Draft ED/2013/5 Regulatory Deferral Accounts-
Exposure Draft ED/2013/4 Defined Benefit Plans: Employee Contributions (Proposed Amendments to IAS 19)Comment Letter Defined Beneift Plans: Employee Contributions
Exposure Draft ED/2013/3 Financial Instruments: Expected Credit Losses-
Exposure Draft ED/2013/2 Novation of Dervatives and Continuation of Hedge Accounting (Proposed amendments to IAS 39 and IFRS 9)Comment Letter Novation Of Derivatives And Continuation Of Hedge Accounting
Exposure Draft ED/2013/1 Recoverable Amount Disclosures for Non-Financial Assets – Proposed Amendments to IAS 36Comment Letter Recoverable Amount Disclosure For Non-Financial Assets.Appendix 1 to Comment Letter – Recoverable Amount Disclosures for Non financial assets
 
TitleISCA’s Comment Letters to IASB
Exposure Draft ED/2012/7 Acquisition of an Interest in a Joint Operation (Proposed amendment to IFRS 11)Comment letter Acquisition Of An Interest In A Joint Operation
Exposure Draft ED/2012/6 Sale or Contribution of Assets between an Investor and its Associate or Joint Venture (Proposed amendments to IFRS 10 and IAS 28)Comment letter Sales Or Contribution Of Assets Between An Investor & Its Associate Or Joint Venture
Exposure Draft ED/2012/5 Clarification of Acceptable Methods of Depreciation and Amortisation (Proposed amendments to IAS 16 and IAS 38)Comment letter Clarification of Acceptable Methods of Depreciation and Amortisation
Exposure Draft ED/2012/4 Classification and Measurement : Limited Amendments to IFRS 9 (Proposed amendments to IFRS9 (2010)Comment letter Classification and Measurement: Limited Amendments to IFRS 9
Exposure Draft ED/2012/3 Equity Method: Share of Other Net Asset Changes (Proposed amendments to IAS 28)Comment Letter Equity Method Share of Other Net Asset Changes
Exposure Draft ED/2012/2 Annual Improvements to IFRSs 2011-2013 CycleComment Letter Annual Improvements to IFRSs 2011-2013 Cycle
Draft IFRIC Interpretation DI/2012/2 Put Options Written on Non-controlling InterestsComment Letter Put Options Written on Non-Controlling Interests
Draft IFRIC Interpretation DI/2012/1 Levies Charged by Public Authorities on Entities that Operate in a Specific MarketComment Letter Levies Charged by Public Authorities on Entities that Operate in a Specific Market
Exposure Draft ED/2012/1 Annual Improvements to IFRSs 2010-2012 CycleComment Letter Annual Improvements to IFRSs 2010-2012 Cycle
Invitation to Comment: IASB and IFRS Interpretations Committee Due Process HandbookComment Letter IASB & IFRS Interpretations Committee Due Process Handbook
TitleISCA’s Comment Letters to IASB
Exposure Draft ED/2011/7 Transition Guidance Proposed amendments to IFRS 10Comment Letter Transition Guidance Proposed Amendments to IFRS 10
Exposure Draft ED/2011/6 Revenue from Contracts with CustomersComment Letter Revenue from Contract with Customers
Exposure Draft ED/2011/5 Government Loans Proposed amendments to IFRS 1Comment Letter Government Loans (Proposed Amendments to IFRS 1)
Exposure Draft ED/2011/4 Investment EntitiesComment Letter Investment Entities
Request for Views: Agenda Consultation 2011Comment Letter Agenda Consultation 2011
Exposure Draft ED/2011/3 Mandatory Effective Date of IFRS 9Comment Letter ED Mandatory Effective Date of IFRS 9
Exposure Draft ED/2011/2 Improvements to IFRSsComment Letter ED Improvements to IFRSs
Report of the Trustees’ Strategy Review IFRSs as the Global Standard: Setting a Strategy for the Foundation’s Second DecadeComment Letter ED Report of the Trustees Strategy Review
Exposure Draft ED/2011/1 Offsetting Financial Assets and Financial LiabilitiesComment Letter ED Offsetting Financial Assets and Financial Liabilities
IFRS Foundation Monitoring Board Consultative Report on the Review of the IFRS Foundation’s GovernanceComment Letter ED Review of the IFRS Foundations Governance

TitleISCA’s Comment Letters to IASBComment Letters from other parties to IASB
Exposure Draft ED/2010/13 Hedge Accounting-Comment letter Financial Instruments – Hedge Accounting
Exposure Draft ED/2010/11 Deferred Tax: Recovery of Underlying Assets Proposed amendments to IAS 12 <link no longer available>ED Deferred Tax: Recovery of Underlying Assets (Proposed Amendments to IAS 12)Comment letter Deferred Tax: Recovery of Underlying Assets (Proposed Amendments to IAS 12)
Exposure Draft ED/2010/9 LeasesComment Letter ED Leases-
Exposure Draft ED/2010/8 Insurance Contracts <link no longer available>Comment Letter ED Insurance Contracts 
Exposure Draft ED/2010/6 Revenue from Contracts with Customers <link no longer available>ED Revenue from Contracts with Customers-
Exposure Draft ED/2010/7 Measurement Uncertainty Analysis Disclosure for Fair Value Measurements Limited re-exposure of proposed disclosure <link no longer available>ED Measurement Uncertainty Analysis Disclosure for Fair Value Measurements-
Exposure Draft ED/2010/5 Presentation of Items of Other Comprehensive Income (Proposed Amendments to IAS 1) <link no longer available>ED Presentation of Items of Other Comprehensive Income (Proposed Amendments to IAS 1)-
Exposure Draft ED/2010/4 Fair Value Option for Financial Liabilities <link no longer available>Comment Letter ED Fair Value Option for Financial LiabilitiesComment letter Financial Instruments – Fair Value Option for Financial Liabilities
Exposure Draft ED/2010/2 Conceptual Framework for Financial Reporting, the Reporting Entity <link no longer available>ED Conceptual Framework for Financial Reporting, the Reporting Entity-
Exposure Draft ED/2010/1 Measurement of Liabilities in IAS 37 proposed amendments to IAS 37 <link no longer available>ED Measurement of Liabilities in IAS 37 (Proposed Amendments to IAS 37)Comment letter Measurement of Liabilities in IAS 37
Exposure Draft ED/2009/12 Financial Instruments: Amortised Cost and Impairment <link no longer available>ED Financial Instruments: Amortised Cost and ImpairmentComment letter Financial Instruments – Amortized Cost and Impairment