When: 27 June 2013
Where: IFRS Conference, Amsterdam, the Netherlands
In a speech to the IFRS Conference in Amsterdam, Hans Hoogervorst, Chairman of the IASB set out a 10-point plan to tackle the use of boilerplate text in financial reporting disclosures.
Today, we have a great deal of ground to cover in a relatively short period of time. Later in the programme, my fellow members of the IASB and our senior staff will provide you with a comprehensive update on our current work programme as well as on our plans for the future.
This morning, I intend to focus my remarks on three topics. First, I will talk about progress towards the G20-endorsed goal of global accounting standards. Second, I will talk briefly about three important parts of our current work programme, namely loan-loss provisioning, insurance and the Conceptual Framework. Finally, the main topic of my speech will be disclosures. I will share with you a ten-point plan to make disclosures more effective.
1. Global standards
First of all, global standards. How much progress are we making towards the goal of one single set of global accounting standards?
To answer this question, we are undertaking a major piece of research. As you may know, earlier this month, we published the first results on the IFRS website.
The survey offers a very encouraging insight into IFRS adoption. First of all, there is almost universal support for IFRS as the single set of global accounting standards. 95 per cent of the jurisdictions have made a public commitment to the concept of a single set of high quality global accounting standards. Furthermore, almost every jurisdiction confirmed that this single set should be IFRS. This includes those jurisdictions that have yet to make a decision on adopting IFRS, such as the United States.
Second, more than 80 per cent of the jurisdictions report IFRS-adoption for all (or in five cases almost all) public companies. Most of the remaining 11 non-adopters have made significant progress towards IFRS adoption. This is a remarkable achievement when you consider that this shift has occurred in little more than 10 years.
Third, those jurisdictions that have adopted IFRSs have made very few modifications to IFRSs. Indeed, more than 40 per cent of the IFRS adopters do so automatically, without an endorsement process. Moreover, where modifications have occurred, they are regarded as temporary arrangements to assist in the migration from national GAAP to IFRSs. We expect that most of these transitional adjustments will ultimately disappear.
Of course we know that a few large and important economies have not yet (fully) adopted IFRS. But even in such countries, more progress is being made than many people are aware of.
Japan already permits the use of full IFRS and has recently widened the scope of companies that are allowed to adopt.
The Japanese Keidanren expects that in the near future about 60 big Japanese companies will be using IFRS, representing about 20% of the total market capitalisation of the Tokyo Stock Exchange. Furthermore, the governing LDP party has asked the Japanese FSA to develop a roadmap that will result in around 300 companies using IFRS by 2016.
Contrary to what many think, the dynamics for IFRS in Japan are still very strong.
In the United States, the SEC’s 2007 decision to permit non-US companies to use IFRS for their American listings was a major game-changer. Today, more than 450 Foreign Private Issuers are reporting using IFRSs, which represents trillions of dollars in market capitalisation. So the use of IFRS in the United States is far from marginal, which explains why the American SEC remains very interested in progress being made by the IASB.
So, all in all, we can conclude that amazing progress has been made around the world in terms of the use of IFRS, although there is clearly more to do.
2. Current work programme
Let us now turn to the second topic of my speech, namely our current work programme.
First of all, impairment. As you know, both the IASB and the FASB have developed proposals to replace the incurred loss model by an expected loss model.
During the financial crisis it has become clear that the incurred loss model has some serious drawbacks. It simply gave too much room for banks not recognise losses, even when it became increasingly clear that those losses were close to becoming inevitable. Moreover, although the objective of the incurred loss model was to limit the room for earnings management, there are strong indications of wide divergence in practice.
Earlier this year, we published for public comment a simplified version of our expected loss model that we had jointly developed with the FASB. We believe that this model will lead to more timely recognition of credit losses than the existing, incurred loss model. We think our model will faithfully reflect the economics of the underlying transaction. At the same time, the FASB has now developed another variant of an expected loss approach—one that recognises full lifetime expected losses on initial recognition of the related assets.
While this divergence in views between the IASB and the FASB is undesirable, all is not lost. Our respective proposals have overlapping comment periods and both boards are keen to hear views on each approach.
Both boards are well aware of the need to do all that we can to achieve convergence or at least more convergence in this very important area. I am sure that Central Bank Governor Klaas Knot will remind us of the importance of this work later today.
The second area I want to discuss is insurance contract accounting. The insurance industry is a hugely complex and important one, with a collective investment measured in the trillions. There can be no doubt about the systemic importance of the insurance industry.
Given this, it is unacceptable that we do not yet have a proper standard to account for insurance contracts. As a result, there is huge diversity and complexity in how insurance companies report their numbers around the world. Investors talk about insurance accounting being a ‘black box’.
Many insurance companies rely on out-dated assumptions when measuring their liabilities. Indeed, some use interest rates from many years ago, while we know that the current lowinterest environment makes life very difficult for the industry.
In Japan, low interest rates caused some insurance companies to go bankrupt, while others had to lower the returns they had promised to their customers.
Many insurance companies also link the accounting for their liabilities to the assets that they hold, or intend to hold. This means that the measurement of their liabilities is affected by their assets, even when they are in fact completely disconnected. This is another source of deficient comparability and transparency in the insurance industry.
Fortunately, the end to this unacceptable situation is in sight. Last week we released our second and final exposure draft for a new insurance standard. In our proposals, we require measurement of liability using current interest rates relevant to the liability. This will allow investors to gain a much more realistic view on the true performance of the industry. Markets will gain much more insight into how effective insurers are in matching their liabilities with assets.
Where our proposals lead to more volatility, it is probably a reflection of real economic risks. At the same time, we have worked very hard to ensure that the new Standard minimises, to the extent possible, non-economic, accounting-related volatility. Our revised proposals go a long way to addressing concerns in this respect about our first exposure draft. We do acknowledge, however, that there has been a trade-off of increased complexity. We think that we have got the balance about right, but we are keen to hear views before moving to finalise the standard during 2014.
Last and not least, a major project for us is the further development of our Conceptual Framework. We will shortly publish for public comment a Discussion Paper. It sets out our preliminary views on some fundamental accounting topics, such as measurement and the use of Other Comprehensive Income. We do not pretend that this Discussion Paper will give a definitive answer to all accounting problems. Even if we took ten years and a thousand pages this could not be done.
We decided to discipline ourselves both in terms of time and scope. Thus far, we have been able to meet our deadlines even though they were very ambitious. Despite these tight deadlines, I think we were able to produce a Discussion Paper that is both readable and thought-provoking. I trust it will serve as a solid basis for a profound public debate.
Hopefully we will be able to shed more light on some of the most difficult issues that have confounded standard-setters for many years. Our Board is looking forward to engaging with our constituents and we are confident we can make progress.
3. Breaking the boilerplate
Behavioural change in financial disclosures The third and final topic I would like to discuss is the need to improve financial reporting disclosures. For many companies, the size of their annual report is ballooning. The amount of useful information contained within those disclosures has not necessarily been increasing at the same rate. The risk is that annual reports become simply compliance documents, rather than instruments of communication.
In January this year we got regulators, preparers, auditors, users and standard-setters in the same room and refused to let them out until we had all understood the various perspectives of this problem. A common conclusion was that many aspects of the disclosure problem have to do with behavioural factors.
For example, many preparers will err on the side of caution and throw everything into the disclosures. They do not want to risk being asked by the regulator to restate their financials. After all, no CFO has ever been sacked for producing voluminous disclosures, while restatements may be career-limiting. Moreover, excessive disclosures can even be very handy for burying unpleasant, yet very relevant information! And sometimes it’s just easier to follow a checklist, rather than put in the effort to make the information more helpful and understandable.
In summary, understandable risk-aversion on the part of preparers, auditors and regulators leads to a ticking-the-box mentality. The communicative value of financial statements suffers as a result. So what can we do to change this culture? What can we do to break the boilerplate?
Well, first of all, we decided to give a good example ourselves. We managed to reduce the size of our 2012 Annual Report and the accompanying disclosures by 25 per cent compared to the previous year. At the same time, we actually increased the amount of useful information in the report and made it easier to read.
It took some intensive discussions internally and with our auditors; but I assure you, it can be done!
More importantly, we recently published a feedback statement that set out the key messages everything that we had heard during the disclosure event I just mentioned. On the basis of this document, today I would like to set out a ten-point plan to deliver tangible improvements to disclosures in financial reporting.
Let me start with eight possible measures that could lead to tangible results in the short run. None of these points is particularly revolutionary. Most are even very simple. However, in my experience in government, the simplest solutions are usually the most effective at tackling seemingly intractable problems.
- We should clarify in IAS 1 that the materiality principle does not only mean that material items should be included, but also that it can be better to exclude nonmaterial disclosures. Too much detail can make the material information more difficult to understand— so companies should proactively reduce the clutter! In other words, less is often more.
- We should clarify that a materiality assessment applies to the whole of the financial statements, including the notes. Many think that items that do not make it onto the face of primary financial statements as a line item need to be disclosed in the notes, just to be sure. We will have to make clear that this is not the case. If an item is not material, it does not need to be disclosed anywhere at all in the financial statements.
- We should clarify that if a Standard is relevant to the financial statements of an entity, it does not automatically follow that every disclosure requirement in that Standard will provide material information. Instead, each disclosure will have to be judged individually for materiality.
- We will remove language from IAS 1 that has been interpreted as prescribing the order of the notes to the financial statements. This should make it easier for entities to communicate their information in a more logical and holistic fashion.
- We could make sure IAS1 gives companies flexibility about where they disclose accounting policies in the financial statements. Important accounting policies should be given greater prominence in financial statements. Less important accounting policies could be relegated to the back of the financial statements.
- At the request of many users around the world, we will consider adding a net-debt reconciliation requirement. Not only would this provide users with clarity around what the company is calling ‘net debt’ but it also consolidates and links the clutter of scattered debt disclosures through the financial statements.
- We will look into the creation of either general application guidance or educational material on materiality. Doing so should provide auditors, preparers and regulators with a much clearer, more uniform view of what constitutes material information. We want to work with the IAASB and IOSCO on this important matter.
- When developing new Standards, we will also seek to use less prescriptive wordings for disclosure requirements. Instead, we will focus on disclosure objectives and examples of disclosures that meet that objective. In recent Standards we have already started doing this, creating more explicit room for judgement on materiality.
Finally, we will begin work on two pieces of work to deliver improvements in the medium term.
- During the second half of 2013, we will begin a research project to undertake a more fundamental review of IAS 1, IAS 7 and IAS 8. This project will revisit some of the 6 work we already did in the Financial Statement Presentation project. The goal will be to replace those Standards, in essence creating a new disclosure framework.
- Finally, once the review of these Standards has been completed, we will then undertake a general review of disclosure requirements in existing Standards.
I am convinced these measures have great potential. Even the eight quick wins I just mentioned can have a big impact. Taken together, they remove most excuses for boilerplate disclosures. They will certainly help to ignite the much-needed change in mind set of preparers, auditors and regulators that is so sorely needed. The IASB will continue to engage with these constituents and also, very importantly, with users, for the joint effort that is needed to make disclosures less indiscriminate and more meaningful.
Ladies and gentlemen, I am grateful for your attention. We have covered a great deal of ground during my opening remarks. I have talked about how the IFRS profiles provide strong evidence of the success of IFRSs. I have talked about the major projects we are working on, and I have set out a ten-point plan to improve financial disclosures.
We have a wonderful programme for the rest of this event, and I look forward to what will no doubt be a thought-provoking day.